“CONNECTCINCINNATI”
MOBILE APPLICATION
PRIVACY POLICY
(Eff. 5.1.2015)


Welcome to ConnectCincinnati, the app that allows you experience a more-connected Cincinnati.  The ConnectCincinnati app (“the App” or “Application”) is offered by Cincinnati Bell Telephone Company LLC (“Cincinnati Bell”, “we”, “us” or “our”).

This privacy policy explains how we collect, use, and disclose information about you when you use the App, or when you access free Wi-Fi at a ConnectCincinnati venue on a tablet, laptop computer, Blackberry mobile device, or other device similarly “unsupported” by the App (collectively, the “Service”). 

By using the Service or the App, you acknowledge that you understand and agree to our collection, use, and disclosure of your personal information as described in this privacy policy.

The Service gives users access to free Wi-Fi Internet connectivity at ConnectCincinnati venues throughout the Cincinnati area. In addition, the App provides users with relevant in-app content, and sends users notifications about nearby deals and attractions.

We may change this privacy policy from time to time.  If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we will provide you with additional notice (for example, adding a statement to the ConnectCincinnati homepage at www.cincinnatibell.com/connectcincinnati/ or sending you an email notification).  We encourage you to review the privacy policy periodically to stay informed about our practices and the ways you can help protect your privacy.


What information does the Application obtain and how is it used?

Information You Provide to Us  – We collect information you directly give us.  For example, we collect information about you when you sign up for our Service, download and register the App, fill out a form, give feedback, ideas, or submissions about the Service or App, communicate with us via third party social media sites, request customer support, or otherwise communicate with us. Registration with us is mandatory in order to be able to use the basic features of the App.

When you register with us and use the Service or the Application, you generally provide:  (a) registration information such as your name, email address, user name, Cincinnati Bell telephone number, or other similar registration information; (b) transaction-related information, such as when you respond to offers or download or use applications from us; (c) information you provide us when you contact us for help; (d) information you voluntarily provide to complete your ConnectCincinnati profile, such as contact information, your age, and info about your individual preferences; and (e) information provided by accounts to which you give the App access, such as information you have made publicly viewable on your Facebook account. We may use the information you provide us to contact you from time to time to provide you with important information, required notices, and marketing promotions.

Automatically Collected Information – When you access or use our Service or our App, we automatically collect certain information about you.  This information includes:
Information We Collect from Other Sources – We may also obtain information from other sources and combine that with information we collect through the Service or the App.  For example, if you create or log in to your account through a social media site like Facebook we will have access to certain information from that site (including but not limited to your name, account information, and friends lists), in accordance with the authorization procedures determined by those social media sites.


Does the Application collect precise real-time location information of the device?
This application does collect precise information about the location of your device.  The Application uses this location information to provide requested location services, and to deliver (and improve the relevance of) content about nearby deals and attractions.  Collecting this precise information also allows the Application to retrieve and render the correct content instantaneously, improving users’ experience with the Application.  To do this, the Application monitors precise location information even when the Application is only running in the mobile operating system’s background.

You may at any time opt-out from further allowing us to have access to your location data by turning off location sharing in your device settings.  You may also uninstall the Application from your device.  For more information, please see the section below entitled “opt-out rights.”


How will you use information about me? 
We may disclose Information You Provide to Us, Automatically Collected Information, and Information We Collect from Other Sources to:
Cincinnati Bell is based in Cincinnati, Ohio, in the United States of America, and the information we collect is governed by U.S. law.  By accessing or using the Service or the App or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.


Do third parties see and/or have access to information obtained by the Application?
Yes. We will share your information with third parties only in the ways that are described as follows or otherwise described in this privacy statement.

Automatic Data Collection and Advertising
This Application is supported via advertising, and it collects data to help the Application serve ads. Cincinnati Bell will function as an advertising network, aggregating supply of advertising space and matching it with demand by its local Cincinnati advertisers.  We may allow analytics companies to help us understand how the Application is being used, such as the frequency and duration of usage. We may also work with advertisers, analytics companies, and third party advertising networks that would need to know how you interact with advertising provided in the Application, to help us keep the cost of the Application free.  Advertisers, analytics companies, and advertising networks may use some of the information collected by the App, including the unique identification ID of your mobile device and your mobile telephone number.  These third parties may also use cookies, web beacons, or other technologies to collect information about your use of the App or Service,  information about other applications you’ve downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., your zip code), and data such as your email address, age (but not date of birth), gender, your User-Provided App profile information, zip code, and other non-precise location information.  We and others may use this information to, among other things, analyze and track data, determine the popularity and relevance of certain content, personalize the user experience, and better understand your activity.  

If you’d like to opt-out from our or third party use of this type of information, please visit the section entitled “What are my opt-out rights?” below.


What are my opt-out rights?
There are multiple opt-out options for users of this Application:

Opt-out of all information collection by uninstalling the Application – You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Use by the App of Location Information – During initial installation of the App, you were asked to consent to Cincinnati Bell’s collection of location information – including collection while the App runs only in the background.  We require this location information in order for the App to function as designed. 

If you consent to our collection of location information, you may subsequently stop the collection of this location at any time by changing the location preferences in your device settings.  However, if you stop the collection of this location information the App can no longer function fully as intended.  

If you consent to our collection of location information and you do not subsequently stop the collection of this location information, the App will continue to collect this location information.

If you consent to our collection of location information, subsequently stop the collection of this location information, and later consent to the collection of this location information, the App will resume collection of location information.

You may also stop our collection of location information by following the standard uninstall process to remove the App from your device.

Account Information – If you wish to delete your account, contact us as privacy@cinbell.com.  Note that we may retain certain information as required by law or for legitimate business purposes as may be necessary to fulfill the purposes identified by this privacy policy.  We may also retain cached or archived copies of information (including but not limited to location information) about you for a certain period of time.

Push notifications or Alerts – During the initial installation of the App on your device, you may have consented to receive “push notifications” or “alerts” from the App.  You can deactivate these messages at any time by changing the notification settings on your mobile device in your device settings.

Cookies – Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Service.

Promotional Communications – You may opt out of receiving promotional communications from Cincinnati Bell by following the instructions in those communications or at https://www.cincinnatibell.com/customer_support/policies/do_not_call_policy/.  If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.


Data Retention Policy, Managing Your Information
We will retain data obtained by the App for as long as you use the Application and for a reasonable time thereafter. If you’d like us to delete User Provided Data that you have provided via the Application, please contact us at privacy@cinbell.com and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly, and we may be required to retain certain information by law.


Children
We do not use the Application to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@cinbell.com.  We will delete such information from our files within a reasonable time.


Security
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop, or improve our Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.


Changes
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here http://www.cincinnatibell.com/connectcincinnati/mobileapplicationprivacy/ and by informing you via email, push notification, in-Application message, or text message. You are advised to consult this Privacy Policy regularly for any changes.  Use of the Application after a change to the Privacy Policy shall constitute your consent.


Your Consent
By using the Services, you are consenting to our processing of User Provided and Automatically Collection information as set forth in this Privacy Policy now and as amended by us. "Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. If you reside outside the U.S. your information will be transferred to the U.S., and processed and stored there under U.S. privacy standards. By using the Application and providing information to us, you consent to such transfer to, and processing in, the US.


Contact us
If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at privacy@cinbell.com.