SAN BRUNO MUNICIPAL CABLE TV
SUBSCRIBER PRIVACY NOTICE

The City of San Bruno, d/b/a San Bruno Municipal Cable TV (“SBMCTV,” “we,” “our,” “us”) is strongly committed to protecting the privacy of our subscribers.  47 U.S.C. § 551 requires us to inform you of the nature of personally identifiable information that we collect, the nature, frequency, and purpose of any disclosure of the information, the period of retention of the information, how you may access your personally identifiable information, and the limitations on our use and disclosure of this information. 

Below is our policy related to the personally identifiable information of our subscribers (“Privacy Policy”).

Privacy Policy

1.         Collection of Personally Identifiable Information
We keep regular business records so that we may continue to provide reliable, high-quality services to our subscribers.  These records may contain your name, address, telephone number, and social security number; information to allow us to honor your payment preferences, such as your bank account or credit card number; and other similar personally identifiable information that we use to establish and maintain your account.  Our records include billing, payment, deposit, complaint and service records, information about the service options that you have chosen; and information about your use of our services, including the type, technical arrangement, quantity, destination and amount of use of certain services (“Personally Identifiable Information”).

2.         Use of Personally Identifiable Information
We use Personally Identifiable Information for legitimate business activities related to our services, including: 

  • Selling, maintaining, disconnecting and reconnecting services;
  • Confirming that you are receiving the services that you requested;
  • Confirming that you are properly billed for the services you receive;
  • Maintaining financial, accounting, tax service and property records;
  • Identifying you when changes are made to your account;
  • Offering you other services or products that we think may be of interest to you (subject to your right to limit or restrict us from making these offers as described in this Privacy Policy);
  • Determining whether applicable policies and terms of service are being violated;
  • Assisting us in detecting and protecting against fraudulent, abusive, or unlawful use of our services;
  • Configuring our services, equipment, and software; and
  • Complying with the law.

In addition, we use Personally Identifiable Information for marketing and marketing research (subject to your rights to limit or restrict us from using your Personally Identifiable Information as described in this Privacy Policy).

3.         Disclosure of Personally Identifiable Information
SBMCTV considers the Personally Identifiable Information contained in our business records to be confidential.  We may only disclose Personally Identifiable Information to third parties if:

  • We receive your consent in writing or electronically;
  • Disclosure is required pursuant to a court order and you are notified of the order;
  • Requested by a government entity authorized under Title 18, Chapters 119, 121 or 206 of the U.S. Code (except that any such disclosure shall not include records revealing your selection of video programming);
  • Disclosure is necessary to render or conduct a legitimate business activity related to our services. 

We may also disclose your name and address for mailing lists as described in Section 5 below.

4.         Nature, Frequency and Purpose of Disclosure 
We may disclose your Personally Identifiable Information to employees, agents and contractors for legitimate business activity related to our services, including:

  • Providing administrative and other services;
  • Preparing, printing and delivering monthly invoices for our services, or for other marketing or informational materials;
  • Preparing and conducting subscriber surveys to assess and enhance the services that we provide to you;
  • Collecting outstanding fees and charges, including supplying information on delinquent accounts to collection agencies and credit bureaus;
  • Marketing our products and services (subject to your right to limit or restrict us from making these offers as described in this Privacy Policy); and
  • Assisting us in detecting and protecting against fraudulent, abusive, or unlawful use of our services.

As noted above, we may also disclose your Personally Identifiable Information if requested by a government entity authorized under Title 18, Chapters 119, 121 or 206 of the U.S. Code.
Disclosure for these purposes is routine, and does not occur with any specific frequency. 

5.         Disclosure of Name and Address
We may disclose your name and address for mailing lists or other purposes unless you object. We do not presently sell our subscriber list or otherwise disclose it to commercial users, and do not anticipate making any such disclosure in the future.  Should we make any such disclosure in the future, we will not disclose the extent of your use of our video services, or of any transaction you may make over our cable system, but we may disclose that you are among those who subscriber to a particular service. If you do not wish to have your name and address included on a subscriber list disclosed to commercial or charitable users, please contact us in writing at our customer service department at the address in Section 12 below.

6.         Disclosure during Use of SBMCTV’s Services
Your Personally Identifiable Information may be disclosed during your use of our services.  For example:

  • SBMCTV transmits Personally Identifiable Information and other information about you over its Internet services when you send or receive e-mail, video mail or instant messages, transfer or share files, make files accessible, visit websites, or otherwise use the Internet service and its features. Our transmission of this information is necessary to render the Internet service.
  • We may use third parties to deliver some features and functions of the Internet service, such as support, e-mail, video mail, instant messaging or web hosting, and those third parties may collect or transmit Personally Identifiable Information and other information about you. These third parties are not permitted to use your Personally Identifiable Information except for the purpose of providing their services.
  • We (or our third party providers) may store e-mail messages and video mail messages on computer systems for a period of time. We could be required to disclose these messages and communications along with other Personally Identifiable Information about you to comply with law or to protect our Internet service.
  • Any Personally Identifiable Information you provide in forums, chat areas, or bulletin boards may be read and used by others who access those services. We are not responsible for any such disclosures by you.
  • Your name and telephone number may be transmitted and displayed on a Caller ID device unless you have elected to block such information. Please note that Caller ID blocking may not prevent the display of your name and telephone number when you dial certain business numbers, 911, 900 numbers, or toll-free 800, 888, 877, or 866 numbers (where available).
  • Your Personally Identifiable Information may be disclosed to the telephone companies serving persons to whom you make calls so that your calls can be completed.

We reserve the right to collect and disclose information in collective or aggregate formats, such as ratings surveys and other statistical reports, which do not personally identify you.
Personally Identifiable Information may be part of the assets transferred in the event that the SBMCTV engages in a business transition, such as an acquisition or a sale of our assets.  If, as a result of the business transition, this Privacy Policy is changed, you should refer to the section of this Privacy Policy entitled “Notices and Changes to Privacy Policy.”  

7.         Security
We take the security of your Personally Identifiable Information seriously. We follow industry-standard practices to take such actions as are necessary to prevent unauthorized access to Personally Identifiable Information. However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose Personally Identifiable Information.


8.         Retention of Personally Identifiable Information
SBMCTV maintains Personally Identifiable Information about you in our regular business records while you are a subscriber to our services.  We also maintain this information for a period of time after you are no longer a subscriber if the information is necessary for the purposes for which it was collected or to satisfy legal requirements, including business, legal, or tax purposes.  If these purposes no long apply, we will destroy the information according to our internal document retention and destructions procedures.
 
9.         Your Right to Access and Correct Information
You may examine your Personally Identifiable Information that we collect and maintain in our regular business records. In most cases, the Personally Identifiable Information contained in these records consists solely of billing and account information. You may examine these records at the SBMCTV offices upon reasonable prior notice to us and during our regular business hours. If you wish to examine these records, please contact us by mail or telephone at our customer service department, giving us a reasonable period of time to locate and, if necessary, prepare the information for review. You will only be permitted to examine records that contain Personally Identifiable Information about you and no one else. You will be provided a reasonable opportunity to correct any errors in your Personally Identifiable Information. SBMCTV reserves the right to charge you for the cost of photocopying any documents that you request.

10.         Enforcement
You may enforce the limitations imposed on us by federal law with respect to the collection and disclosure of Personally Identifiable Information about you, through a civil action under federal law, in addition to other rights and remedies that may be available to you under federal or other applicable laws.

11.         Notices and Changes to Privacy Policy
We reserve the right to modify this Privacy Policy at any time.  We will notify you of any material changes via written, electronic or other means permitted by law.  If you continue to use our services following notice, we will consider that as acceptance of the change.

12.       Contact Information
SBMCTV is happy to answer any questions you may have.  Please contact us at the following number or email address:

(650) 616-3100
info@sanbrunocable.com

Alternatively, you may write to:
San Bruno Municipal Cable TV
398 El Camino Real
San Bruno, CA 94066

For general information, please visit our website at www.sanbrunocable.com.