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California Consumer Privacy

Effective Date: January 1, 2020

This California Consumer Privacy Notice (“Notice”) applies to CoxCom, LLC and its affiliates, (“Cox,” “us,” “we, “our”) and “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) and should be read along with our other privacy policies or notices found on www.cox.com.  In the event of a conflict between any other Cox policy, statement or notice and this Notice, this Notice will prevail as to California Consumers’ rights under the CCPA.

This Notice covers the Collection, use, disclosure, and Sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA.  This Notice describes the rights California Consumers have and includes notices to Californians required by other laws.  The description of our data practices in this Notice will be updated at least annually or more frequently if our practices materially change and we believe a Consumer would expect notice.

Job applicants, current and former employees and contractors of Cox, and persons with whom we interact in their capacity of representing another business, are not Consumers under CCPA.

To make this easier to read, we have abbreviated or summarized CCPA terms, but a full copy of the CCPA is available at Title 1.81.5. of the California Civil Code, California Consumer Privacy Act of 2018 section 1798.100 - 1798.199.  We have also included references to specific CCPA sections.  Capitalized terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.

This Privacy Notice contains a longer explanation of the CCPA and your rights.  If you prefer, you can view a shorter explanation of CCPA on the separate Cox CCPA page here.

You can click on the following links to navigate to the different sections in this Notice.

1.     PI We Collect

2.     Sharing of PI

3.     Your California Privacy Rights

a.     Information Rights

b.    Obtaining Copies of PI

c.     Do Not Sell

d.    Delete

e.     Non-Discrimination

f.     Exercising Your CCPA Rights

g.     Limitations on Your Rights

4.     Additional California Notices

a.     Third Party Marketing

b.    Online Privacy Practices

c.    Tracking and Targeting

d.    California Minors

5.    Contact Us

 

  1. PI We Collect

The table below provides the categories of PI we collect about California Consumers, examples of PI, sources and business purposes of PI, and the types of companies with whom we share the PI in connection with our business.

 

Category of PI Examples of PI Sources of PI Business or Commercial Purposes for PI Collection Categories of Recipients with whom PI is Shared
1. Identifiers (as defined in CCPA §1798.140(o)(1)(A)) This may include but is not limited to: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.

Consumer, Cox and Service Providers

To securely deliver, troubleshoot and improve services

Ad platform providers, Business analytics providers, Credit reporting agencies, E-signature services, Marketing Services companies, Product Service providers, Data Brokers, Media Measurement companies and TV Programmers

2. Personal Records (as defined in CCPA §1798.140(o)(1)(B)) This may include information such as: physical characteristics or description, signature, telephone number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.

Consumer, Data Brokers and Third Parties

To facilitate the delivery of service as well as to enable billing and collection

Business analytics providers, Credit reporting agencies, E-signature services, Marketing Services companies and Product Service providers

3. Customer Characteristics (as defined in CCPA §1798.140(o)(1)(C)) This may include but is not limited to: age, marital status, religion, veteran status, familial status, disability, gender and interests.

Consumer, Data Brokers and Third Parties

To understand consumers, improve services and marketing along with enhancing our customers’ experience

Advertising Service Provider

4. Customer Account Details / Commercial Information (as defined in CCPA §1798.140(o)(1)(D)) This may include but is not limited to: products or services purchased, obtained, or considered, other purchasing or consuming histories or tendencies.

Cox and Service Providers

To support billing and collection, improve services

Business analytics providers, Marketing Services companies and Product Service providers

5. Services Activity Information (as defined in CCPA §1798.140(o)(1)(F)) This may include but is not limited to: information regarding your interaction with an Internet Web site, application, or advertisement. It may also include service-related data such as the amount of Internet data used by your household, cable and telephone service activity, TV viewership activity, home security and automation activity.

Cox, Service Providers and Third Parties

To support billing and collection, maintain and improve services, research and resolve issues

Ad platform providers, Business analytics providers, Marketing Services companies, Product Service providers, Media Measurement companies and TV programmers

6. Geolocation Data (as defined in CCPA §1798.140(o)(1)(G)) This may include but is not limited to: market location or movements.

Cox and Service Providers

To deliver and offer services

Business analytics providers

7. Sensory Data (as defined in CCPA §1798.140(o)(1)(H)) This may include but is not limited to: audio recordings of customer care and sales calls, electronic, visual, or similar information.

Cox

To research and resolve issues and improve our customers’ experience

Business analytics providers

8. Professional or Employment Information (as defined in CCPA §1798.140(o)(1)(I)) This may include but is not limited to: professional, education, or employment-related information.

Data Brokers

To deliver services, support billing and collection, and improve our customers’ experience

Business analytics providers and Marketing Services companies

9. Inferences from PI Collected (as defined in CCPA §1798.140(o)(1)(K)) This may include but is not limited to: creating a profile about a Consumer reflecting the Consumer’s characteristics, interests, and preferences.

Cox and Data Brokers

To deliver services, understand consumers and improve our customers’ experience

Business analytics providers and Marketing Services companies

In addition, in our operations we may share your PI for the following additional Business Purposes: (i) we have business relationships with other parties that collectively use information from us and other businesses to help all of us prevent fraud and maintain security; and (ii) our Service Providers may themselves engage their own Services Providers or subcontractors to enable them to perform services for us.  We typically restrict our Service Providers’ use of your PI shared for CCPA-qualified Business Purposes, or we treat the disclosure as a Sale as defined by the CCPA.  In addition, if you direct us to share PI with another party that is not a Sale.  Finally, we have the right under the CCPA to transfer your PI as part of a merger, acquisition, restructure or asset sale and such activity is also not a Sale.     

We collect information needed to serve you and improve our services.  This “Services Activity Information” includes your interactions with our services, such as the amount of Internet usage, video viewership records, telephone call detail records, etc.  Cox treats Services Activity Information as PI that you can access through your account.  However, “Telemetry/Network Data” is network and application data Cox has in connection with, for example, measuring service and network quality, capacity, and device health. Telemetry/Network Data is necessary to operate our networks, but so voluminous or irrelevant to an individual that Cox does not treat this as PI.

We may deidentify or aggregate your PI, and as permitted by applicable law, we do not treat Deidentified or Aggregate Consumer Information as PI.  Similarly, as permitted by the CCPA, we do not treat publicly available data as PI.

We have no obligation to keep PI longer than we need it, or reidentify it, to respond to Consumer requests.  This helps us practice data minimization, which we consider to be a privacy best practice consistent with our mission to respect our customers.  If, however, you make a CCPA request we will retain your PI used to make your CCPA request for our record keeping purposes.

 

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2. Sharing and Sales of PI

We may share your PI for commercial purposes, such as for interest-based advertising and TV viewership for advertisers. This sharing of PI may be considered a sale under the CCPA, even though we never sell your personal information with your name, address, e-mail or other contact information.

The CCPA has an odd definition of “Sale.”  As such, sharing PI even without your name and address could be considered a Sale under CCPA.  The term “Sold” as defined by the CCPA means that even transfers of digital ad serving data, which is typically only pseudonymized data, could potentially also be considered a Sale.

Accordingly, we may have Sold your PI as the term Sold is defined by the CCPA for Commercial Purposes such as online digital advertising in connection with our and third party websites and mobile apps (“Online Advertising”) and the commercialization of TV viewing data tied to a unique identifier but not to your name or physical address (“Pseudonymous Data Transfers”).  Until Jan 1, 2020, we have not treated these as a Sale, but under CCPA we will.

In addition, if you are a Cox customer, we provide you with choices regarding our Pseudonymous Data Transfers in our Preference Center.  Although there is not a consensus if cookies that facilitate Online Advertising or other purposes are a Sale, you can learn how to exercise choice regarding those third party technologies here and Online Advertising here.  In addition, we provide you with additional information in the Do Not Sell section below.

We also share PI with the following:  Service Providers, other qualified vendors, Businesses, and Third Parties (including those that facilitate interest-based and other advertising and marketing).

 

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3. Your California Privacy Rights

Your California privacy rights are described in this section.  You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations.  Under the CCPA, requests you submit to us are subject to an identification and residency verification process (“Verifiable Consumer Request”).  We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.  Please follow the instructions at our CCPA page here and respond to any follow up inquires we may make.

We will make commercially reasonable efforts to identify Consumer PI that we Collect, use, and store in response to your California Consumer privacy rights requests.  Some of the PI we Collect is voluminous, difficult to present to you, or generally not helpful, so we may provide a list of that PI and give you the opportunity to elect whether you want the rest or not.  If you are a Cox customer or former customer, much of your PI is accessible to you through our self-service tools located in My Account.  For instance:

  • Account number, services subscribed to, plan details, discounts and purchases are available on your Cox bill
  • Household Internet data usage and telephone call details records are available in My Account
  • Payment methods are found in the billing information on My Account
  • Cox email is available in your email account
  • Notification preferences and privacy preferences are located in your My Account

While we will not charge a fee for routine requests, we may charge a reasonable fee, or refuse to act upon a request, if your request is unfounded (e.g., unwarranted, unsupported, seeks irrelevant data, etc.) or unreasonably repetitive or burdensome.  If we determine that your request warrants a fee, or we refuse it, we will give you notice explaining why we made that decision.  You will be provided a cost estimate and the opportunity to accept the incurring of fees before we will charge you for responding to your request.

If we cannot comply with a request, we will explain the reasons in our response.  If you have any questions or concerns about Cox’s California privacy policies and practices, you can submit questions or comments to californiaprivacy@cox.com.  

Your California CCPA Consumer privacy rights are as follows:

a. Right to Know

You have the right to send us a request, no more than twice in a twelve-month period, for the following information for the period that is 12 months prior to the request date:

  • The categories of PI we have Collected about you.
  • The categories of sources from which we Collected your PI.
  • The Business or Commercial Purposes for Collecting or Selling your PI.
  • The categories of Third Parties to whom we have shared your PI.
  • The specific pieces of PI we have Collected about you.
  • A list of the categories of PI disclosed for a Business Purpose in the prior 12 months, or that no disclosure occurred.
  • A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred. If we Sold your PI, we will explain:
    • The categories of your PI we have Sold.
    • The categories of Third Parties to which we Sold PI, by categories of PI Sold for each Third Party.

To make a request, please go here for an online request or call us at 1-800-699-0885 (service hours are Monday-Friday, 8-5 Pacific Time, except holidays).  Please note that PI is retained for various time periods, so we may not have PI in all categories going back 12 months prior to your request.   

b. Obtaining Copies of PI:

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.  If you have an account with us, you can utilize your My Account to obtain a copy of your PI that we make available for you to access on a self-serve basis.  If you do not have an account and would like to make a request, please go here or call us at 1-800-699-0885 (service hours are Monday-Friday, 8-5 Pacific Time, except holidays).

c. Do Not Sell:

You have the right to direct us to not sell your PI.  

While there is not yet a consensus, data practices of third party cookies and tracking devices associated with our websites and mobile apps may potentially constitute a “sale” of your PI as defined by the CCPA.  You can exercise control over browser-based cookies by adjusting the settings on your browser.  In addition, third party tools enable you to search for and opt-out of some of these devices, such as the Ghostery browser plug-in available at https://www.ghostery.com/.  We provide helpful information about cookies and, if available, opt-out programs, on our Cookie Information page found here. Further, you can learn more about your choices regarding certain kinds of Online Advertising here. We do not represent that these third party tools, programs or statements are complete or accurate.

Cox customers may exercise more limited control of your PI by visiting the Preference Center located in My Account here including opting out of the Sale of TV viewing data.

We do not have actual knowledge of the age of Consumers under 16 and do not knowingly link PI with the age of Consumers under age 16.  Consumers who opt-in to PI “sales” may opt-out at any time.

d. Delete:

You may request that we delete PI collected directly from you unless we need it for Business Purposes, such as to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, to protect against fraud, for legitimate internal Business Purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement.  We will not delete your PI that we are permitted to retain under applicable law.  In some situations, we may obfuscate or render PI unusable or unviewable in lieu of deletion.  To make a request, go here or call us at 1-800-699-0885 (service hours are Monday-Friday, 8-5 Pacific Time, except holidays).  However, you may choose to limit use of your PI by making selections in your My Account by visiting the Preference Center here, or going to the Consumer Rights Request page here. Currently, the only way to exercise choice regarding cookie preferences is by following the instructions here.

e. Non-Discrimination:

We will not discriminate against you in a manner prohibited by the CCPA because you exercised your CCPA rights.  

f. Exercising Your CCPA Rights

Customers with Cox accounts will be expected to make requests at www.cox.com/ccpa, be verified and receive responses via their account.  

Other Consumers and authorized agents of Consumers may make a request by visiting here or calling 1-800-699-0885 (service hours are Monday-Friday, 8-5 Pacific Time, except holidays), in which case the Consumer will be required to be verified using a third-party identity verification service, and, if verified, credentials will be provided to use a guest request portal to make and facilitate a request and response.

If you are not a Cox customer, you do not have to create a service account with Cox to make a request, but you will have to set up identity verification credentials to exercise your rights.  We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses unless you also gave it to us for another purpose

g.  Limitation on Your Rights:

Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law.  In addition, we will not honor any of your requests to the extent doing so would infringe upon our rights or any other person or party’s rights or conflict with applicable law.

 

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4. Additional California Notices:

In addition to CCPA rights, Californians are entitled to certain other notices, including:

a. Third Party Marketing:

We may share personal information as defined by California Civil Code § 1798.83 (“Shine the Light” law) with third parties for their direct marketing purposes.  Separate from your CCPA rights, California's "Shine the Light" law permits California customers to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes.

You can make a request to exercise your rights under “Shine the Light” by sending an email to privacy@cox.com and indicate “Shine the Light” in the subject line or body of your email request.  If applicable, we will provide you with a list of personal information that we may have shared with some or all of these third parties.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

b. Online Privacy Practices:

For more information on our online practices and your California rights specific to our online services see our Online Privacy Policy.  Without limitation, Californians that visit our online services and seek or acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:

c. Online Tracking and Targeting:

When you visit our online services, we and third parties may use tracking technologies to collect usage information based on your device for a variety of purposes, including serving you advertising, based on you having visited our services or your activities across time and third-party locations.  Some browsers may enable you to turn on or off a so-called “Do Not Track” signal.  Because there is no industry consensus on what these signals should mean and how they should operate, we do not look for or respond to “Do Not Track” signals.  For more information on tracking and targeting and your choices regarding these practices, see our Online Privacy Policy.  Consumers can also exercise preferences regarding cookies by following the instructions here.

d. California Minors:

Although our online service(s) are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the online service, can request removal by contacting us at privacy@cox.com, detailing where the content or information is posted and attesting that you posted it.  We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law.  This removal process cannot ensure complete or comprehensive removal.  For instance, third parties may have republished or archived content by search engines and others that we do not control.

 

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5. Contact Us

For more information on your California privacy rights contact us at 1-800-699-0885 (service hours are Monday-Friday, 8-5 Pacific Time, except holidays) or email us at californiaprivacy@cox.com. You may also visit our Preference Center or our Consumer Rights Request page or write to us at:

Cox Communications

6205-B Peachtree Dunwoody Road

Atlanta, GA 30328

Attn:  Privacy Operations – 15th Floor

 

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