CaptionMate Privacy Policy

Your privacy is important to us. Therefore, we have developed this Privacy Policy that describes the ways CaptionMate collects, uses, stores, manages, and shares information, including personal information.

By visiting the CaptionMate public website (“Site”) and using the CaptionMate Application (“Application”), operated by CaptionMate LLC, you are expressing your agreement to this Policy and the processing of your information and data, including your personal information, in the manner provided in this Policy.

IF YOU DO NOT AGREE TO THESE TERMS, PLEASE DO NOT VISIT THE CAPTIONMATE WEBSITE OR USE THE CAPTIONMATE APPLICATION.

If you have any questions or concerns, please contact us with the information provided in the Contact Information section at the bottom of this Policy.

TABLE OF CONTENTS

• INFORMATION AND DATA WE COLLECT
• HOW WE COLLECT PERSONAL INFORMATION
• HOW WE USE THE DATA WE COLLECT
• HOW WE MAY DISCLOSE THE DATA WE COLLECT TO THIRD PARTIES
• INFORMATION SHARED WITH THE TELECOMMUNICATION RELAY SERVICE (TRS) USER REGISTRATION DATABASE
• COOKIE POLICY
• PRIVACY CHOICES AND OPTING-OUT
• SECURITY SAFEGUARDS
• DATA RETENTION
• CHANGES TO THIS POLICY
• CONTACT INFORMATION OF DATA CONTROLLER

INFORMATION AND DATA WE COLLECT

• CaptionMate may collect personal information that you voluntarily provide to us through the Site or Application for registration purposes, including your name, email address, mailing address, registered location, phone number, birthday, and the last four digits of your social security number.

· When you use the Site and Application, we may collect other information, such as your Internet protocol (“IP”) address, device identifiers and other unique identifiers, browser type, phone type, browser language, operating system name and version, device name and model, version, referring and exit pages, dates and times of service access, links clicked, pages visited, forms submitted, features used, crash reports and session identification information.

• We collect information on personal preferences, such as your areas of interest, and demographic information.
• When you use the Application, you generate Customer Proprietary Network Information (“CPNI”), including the time, date, duration and destination number of each call and the type of network you subscribe to.
• When you use the Application, we collect information about the phone calls that you make and receive, in order to process the calls and in order to collect reimbursement for these calls as appropriate.
• At the end of each call, we may collect satisfaction ratings and complaint codes, including free-form text, that you may choose to provide.
• When you make or receive calls using the Application, we temporarily collect the audio speech of the phone call, for the purposes of transcribing that speech and displaying that speech on your screen. This information is immediately discarded from our equipment upon the end of a telephone call. We do not permanently store your speech or that of other parties on your phone calls, or the transcription of such speech. We temporarily store information on servers located in the United States via third parties as well as on our own servers. We collect this information only to transcribe the speech into text, and then it is discarded by us and the third party server providers. Likewise, the speech engine that we use to create the transcriptions also does not permanently store your speech or that of other parties on your phone calls, or the transcription of such speech. CaptionMate has a premium subscription to the speech engine in order to ensure the privacy of your speech.

HOW WE COLLECT PERSONAL INFORMATION

We collect personal information from a variety of sources depending on how you use our Site or Application including:

· Directly from you when you share personal information through our Site, Application, or in person;

· From your use of the Site;

· From your use of the Application; and

· From third party partners, including analytics and data providers.

HOW WE USE THE DATA WE COLLECT

We use the information we collect for a variety of purposes relating to our business. For example, we may use your personal information:

· To fulfill or meet the purpose for which you provided the information, or pursuant to your consent;

· To provide our call transcription and other services (“Services”);

· To make our Site, Application, and Services available to you;

· To analyze and/or improve the quality of the Site, Application, and Services;

· To conduct research;

· For testing, research, analysis, and product development, including to develop and improve our Site, Application, and Services;

· To administer your accounts with us;

· To administer and deliver our newsletter;

· To send you information, updates, and/or promotional materials about our Site, Application, and/or Services, programs, partnerships, offerings, and/or events that may interest you;

· To respond to your requests, assist with customer support, provide technical support, or to process and/or resolve other issues regarding our Site, Application, or Services;

· To communicate with you, including to respond to your requests, to investigate and address your concerns, to respond to any other inquiry or correspondence you send to us, and to monitor and improve our responses;

· For marketing to you and/or other potential users about our Site, Application, and Services;

· To notify you about changes to our Site, Application, or Services;

· To ensure compliance with applicable law, or manage our everyday business needs, such as auditing or administering of our Services;

· To provide emergency services;

· For analytics, monitoring and security, and the enforcement of reporting obligations or other policies;

· To help maintain the safety, security, and integrity of our Site, Application, Services, databases and other technology assets, as well as our physical offices and business generally;

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all CaptionMate’s assets, in which personal information held by CaptionMate about our consumers is among the assets transferred.

· To report usage and submit costs to the FCC for reimbursement as appropriate;

· For complying with a legal obligation; or

· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

HOW WE MAY DISCLOSE THE DATA WE COLLECT TO THIRD PARTIES

We may disclose information we collect in the following situations:

• With our service providers, vendors, or third parties to assist us in providing, supporting, analyzing, administering, developing, improving and/or personalizing our Site, Application, and/or Services. 
• With service providers to provide a variety of services including, but not limited to providing a telephony SIP trunk, providing emergency services, ensuring that your calls are routed to the correct location, and provisioning caller ID services. CaptionMate may also disclose or permit access to CPNI derived from its provision of TRS without customer approval, for (1) the provision of CPE or iTRS access technology, and call answering, voice or video mail or messaging, voice or video storage, and retrieval services; (2) the provision of inside wiring installation, maintenance, and repair services; and (3) to market services formerly known as adjunct-to-basic services, such as, but not limited to, speed dialing, call waiting, caller ID, and call forwarding, only to those customers that are currently registered with that TRS provider as their default provider.
• With the FCC or other necessary third parties for the purposes of claiming compensation or reimbursement, in accordance with FCC policies and reporting requirements.
• With advertising, data, and/or analytics partners to assist us in monitoring, analyzing, and/or advertising our Site, Application, and Services to improve your experience and reach additional potential end users.

· In the event of a merger, sale of change of control, we may transfer or assign this Privacy Policy and any personal information to a third-party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control (such as the result of a bankruptcy proceeding).

· If we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of CaptionMate, our users, or the public.

· We may also disclose personal information or other information pursuant to your consent or direction.

• Use, disclose, or permit access to CPNI to the extent necessary to:
• Accept and handle 911/E911 calls;
• Access, either directly or via a third party, a commercially available database that will allow the TRS provider to determine an appropriate Public Safety Answering Point, designated statewide default answering point, or appropriate local emergency authority that corresponds to the caller’s location;
• Relay the 911/E911 call to that entity; and
• Facilitate the dispatch and response of emergency service or law enforcement personnel to the caller’s location, in the event that the 911/E911 call is disconnected or the caller becomes incapacitated.

INFORMATION SHARED WITH THE Telecommunication Relay Service (TRS) User Registration Database

Following the regulations set out by the FCC ( FCC regulation 64.611), we collect the following information: Full name; address; ten-digit telephone number assigned in the TRS numbering directory; last four digits of the social security number or Tribal Identification number, if the registered internet-based TRS user is a member of a Tribal nation and does not have a social security number; date of birth; Registered Location; TRS provider name and dates of service initiation and termination; a digital copy of the user's self-certification of eligibility for TRS and the date obtained by the provider; the date on which the user's identification was verified; and (for existing users only) the date on which the registered internet-based TRS user last placed a point-to-point or relay call.  We may ask to collect proof of your eligibility for IP CTS use in the form of further documentation such as a driver license, passport, etc.

The information listed above will be transmitted to the TRS User Registration Database to ensure proper administration of the TRS program, and failure to provide consent will result in the registered internet-based TRS user being denied service.

COOKIE POLICY

We use cookies to improve your experience on our Site. There are two kinds of cookies, a session cookie and a persistent cookie. A session cookie is text that is stored temporarily in your computer’s memory but never written to a drive. It is destroyed as soon as you close your browser. CaptionMate may also use persistent cookies, which are saved to a file on your hard drive.

CaptionMate may use Google Analytics to perform analytics and better understand and improve our Site. As part of this service, we may make available certain personal information (such as an IP address) to Google Analytics.    

PRIVACY CHOICES AND OPTING-OUT

Access:  We offer you the right to know what types of information we hold about you and, in some cases, to have the information communicated to you. If you wish to exercise this right, please contact us at privacy@captionmate.com. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why.

Cookies: You can control and/or delete or disable certain cookies by adjusting your browser settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. If you turn off cookies, you may not be able to take full advantage of all of the features of our Site or Application. You may also manage your preferences for individual third parties by contacting them directly, including Google Analytics .

Newsletter: You may opt-out of receiving our newsletter by (1) opting out during the registration process, (2) changing your settings in your profile menu in the Application, or (3) by following the instructions in the newsletter emails. If you opt-out, we may still send you non-promotional emails, such as emails that we deem necessary to communicate important product announcements.

SECURITY SAFEGUARDS

CaptionMate takes the protection of your information seriously and takes reasonable physical, administrative, and technical measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

DATA RETENTION

We retain your information for as long as needed to provide you the Services and in accordance with FCC regulations. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We do not permanently store your speech or that of other parties on your phone calls, or the transcription of such speech. We temporarily store information on servers located in the United States via third parties as well as on our own servers. We collect this information only to transcribe the speech into text, and then it is discarded by us and the third party server providers. The speech engine that we use to create the transcriptions also does not permanently store your speech or that of other parties on your phone calls, or the transcription of such speech.

CHANGES TO THIS POLICY

We may update this Policy to reflect changes to our data and information privacy practices. If we make any material changes, we will notify you on this Site. We encourage you to periodically review this page for the latest information on our privacy practices.

CONTACT INFORMATION OF DATA CONTROLLER

CaptionMate LLC
PO Box 1206
Hixson, TN 37343

If you have any questions or concerns about our data privacy practices, or if you have any requests for resolving issues with your personal information, please contact us at: privacy@captionmate.com.