Privacy Policy

Effective October 20, 2023

This privacy notice for Pay Tel Communications, Inc. (“Pay Tel”, “Company”, “we”, “us” or “our”), describes our privacy practices, including how and why we might collect, store, use, disclose and/or share (“process”) your personal information. This Privacy Policy (“Policy”) applies to personal information collected by Pay Tel through our websites (https://www.paytel.com and https://www.paytelconnect.com ), mobile application (Pay Tel Connect™), and the products and services we offer (collectively, the “Services”). This Policy applies to personal information, which does not include publicly available information or anonymized/de-identified information.

This Policy is applicable as of the Effective Date posted above. This Policy is part of, and is governed by, the Terms of Use set forth in the Site.

Reading this Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@paytel.com.

The section titled “Additional Privacy Information for Certain Jurisdictions” below provides information about our compliance with applicable U.S. state privacy laws.

Table of Contents

The Information We Collect:

Personal Information you disclose to us. We may collect personal information that you provide to us when you express an interest in obtaining information about us or our Services, participate in any activity related to or associated with the Services, or otherwise contact us regardless of the means used to do so. The personal information that we collect depends on the context of your interactions with us and the Services and the choices you make and the products and features you use. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

The personal information we collect may include the following:

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we may process the following categories of sensitive information:

Depending on your jurisdiction you may also have a right to limit our use and disclosure of sensitive information. See the sections below on “Additional Information for California Residents” and “Additional Information for Residents of States with Applicable Privacy Laws” for more information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. When you make a payment using your credit or debit card, we use methods designed to keep your payment card information secure. All payment data is stored by CyberSource. You may find their privacy policy link here: Visa Privacy Center | Visa

Application Data. If you use our Pay Tel Connect™ mobile application, we also may collect the following information if you choose to provide us with access or permission.

This information is primarily needed to allow us to administer our Services and/or certain features of the Services, maintain the security and operation of our application, for troubleshooting, and for our internal analytics and reporting purposes.

In addition, we may request to send you push notifications regarding your account or certain features of the application. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

Information Automatically Collected. We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location information about how and when you use our services and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

Cookies and Other Tracking Technology

Cookies, Web Beacons, Similar Tracking Technology. Like many businesses, we use cookies and similar technologies, such as web beacons, to recognize you when you visit our website. Web beacons are web page elements that can recognize certain types of information on your computer or mobile device such as cookies and the time and date of a page viewed. Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, improve the quality of service, as well as to provide reporting information. Cookies help websites remember information about your visit, which can make it easier to use the services, and improve your online experience, such as storing user preferences for future use of services.

Information that we may collect by cookies and web beacons includes, without limitation:

Your browser may allow you to review and delete cookies stored on your device, and/or to disable or otherwise prevent cookies from being placed on your device or notify you when you are sent a cookie. If you disable cookies, your experience while using the Services may not be optimal. For example, you may not be able to use certain features on our websites, and disabling cookies may invalidate opt outs that rely on cookies to function. Some cookies are “essential” or “strictly necessary”, meaning they are required for technical reasons in order for the website to operate. You have the right to decide to accept or reject cookies, however, essential cookies cannot be rejected as they are strictly necessary to provide you with Services.

Web Analytic Services. We may also use certain web analytics services, such as Google Analytics, to help us understand and analyze how visitors use our Services, such as for user segment analysis and impression reporting.

Do Not Track Features. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.

How We Process Your Information

We process your information to provide, improve, and administer our services, to communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To further assist with understanding the types of personal information we may collect and how it may be used, we have provided examples in the “Additional Privacy Information for Certain Jurisdictions” section below.

How We Share Your Information

We may share your data with third party vendors, service providers, contractors, or agents (third parties) who perform services for us on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with for this purpose are as follows:

We may disclose or share the information we collect in connection with our Services with the following recipients and/or under the following circumstances:

Service Providers. To support the Services we offer to you, we may disclose personal information with service providers that help us with our business activities.

Government and Legal Authorities. To respond to lawful requests, we may disclose personal information in response to lawful requests by government and other legal authorities, including requests from national security agencies, courts, and law enforcement.

Law Enforcement. To support law enforcement activities, under appropriate circumstances, we may disclose personal information to law enforcement personnel and/or Correctional Facilities and certain third parties for use in connection with and in support of law enforcement activities. All calls, video visits, and communications using our Services will be recorded and may be monitored in accordance with applicable law, with the exception of calls to numbers and visits with third parties exempted from recording by Correctional Facilities as outlined in the Terms of Use that govern this Policy. All of this data may be stored, monitored, searched, analyzed and transferred amongst law enforcement agencies for law enforcement purposes.

Correctional Facilities. To fulfill our contractual service obligations with Correctional Facilities, we may disclose personal information to allow them to offer you our products and Services. When you use our Services to communicate with or process a transaction on behalf of an incarcerated individual housed within a Correctional Facility, we process personal information for the Facility, and the facility staff are able to access your personal information in order to operate these facilities, conduct investigations, and/or to verify transactions. All communications data and recordings are the property of the Correctional Facility and do not belong to Pay Tel.

Business Transfers/ Transactions. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from users of the Service to third parties. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

Safety, Fraud and Government Requests. To the extent permitted by law, we may disclose your personal information to government authorities or third parties if: (a) required to do so by law, or in response to a subpoena or court order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect our property or other rights or those of other users of the Services, third parties or the public at large; or (c) we believe that you have abused the Services by using them to attack other systems or to gain unauthorized access to any other system, to engage in spamming, or otherwise to violate applicable laws or in violation of our Terms of Use. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

Pay Tel does not sell or share personal information about the users of our Services to third parties for monetary or other valuable consideration.

How Long We Keep Your Information

We will only keep your information for as long as necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law. When personal information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

How We Protect Your Information

For privacy and security of personal information, Pay Tel requires each customer to create their own six-digit Personal Identification Number (PIN). For a customer to access their account to make a payment, check the account balance, review account information, or request a refund, the customer must provide the correct PIN.

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have implemented appropriate and reasonable physical, electronic, technical and organizational security measures designed to protect the security of any personal information we process.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Children’s Privacy

Our Services are not directed at children and are not intended for use by individuals under 18 years of age. By using our Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. We do not knowingly collect personal information from children under the age of 18. If we become aware that we have inadvertently obtained personal information from a person under the age of 18, we will delete it in accordance with applicable law.

How You Can Access or Correct Your Information

You can access your personally identifiable information that we collect online and maintain in connection with your user account by logging in on our website, entering your ten-digit phone number and six-digit Personal Identification Number (PIN). On the “Account” page, click on “Account Information” to review or edit your information. You may also contact our Customer Service team using the contact information provided on the website.

You can correct factual errors in your personally identifiable information by contacting us by telephone or by sending us a written request for such correction with supporting information that credibly shows error. To protect your privacy and security, we will require you to provide your six-digit PIN to verify your identity before granting access or making corrections.

Based on the applicable laws of your jurisdiction, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete personal information, please send an email to privacy@paytel.com.

Information for Users Outside of the United States

If you are located outside of the United States, please be aware that information we collect through our Services will be processed in the United States. By using the Services, you fully understand and acknowledge that your personal information may be transferred to and processed in jurisdictions outside your own, including the United States, where the privacy laws may not be as comprehensive as those in the country where you reside. Your consent to this Policy followed by your submission of information through the Services represents your agreement to the transfer of your information to the United States.

Additional Privacy Information for Certain Jurisdictions

Residents of certain states have additional rights under applicable privacy laws, as described in this section.

If you are a resident of California, please review our California Notice at Collection provided in Subsection 1 below, as well as Subsection 2 below, which includes additional information about your privacy rights under applicable California privacy laws.

If you are a resident of another state that has enacted an applicable privacy law, please review Subsection 3 below for additional information about your privacy rights under applicable state privacy laws.

  1. California Notice at Collection

This section provides California residents with information about our collection, use, and disclosure of their personal information. Please reference the other sections of the Privacy policy for more information about our privacy practices.

Collection, Use and Disclosure of Personal Information

The chart below describes how and why we collect, use, and disclose personal information, and also describes how and why we have collected, used, and disclosed personal information within the past 12 months.

Collection Source

Categories of Personal Information Collected

Purpose and Use of Personal Information

When you set up an account to use our Services and when you contact our Customer Service team

Personal Identifiers, such as your name, email address, postal address, phone number, and PIN Number

Customer records information, such as your phone number, credit card information, and other financial information

Biometric information, such as your voice derived from call recordings captured during calls with our service representatives

You provide this information to us when you register for our Services on our website or with a live agent over the phone. We use this information to:

Establish your account with Pay Tel;

Send you communications about the services you requested, and promotional materials on our products and Services;

Fulfill customer service requests, such as troubleshooting applications;

Process your payments for the Services you requested;

Monitor and improve our customer service; and to

Conduct statistical and research analysis to understand customer and market needs, improve our solutions and inform partnership and business development decisions.

When an individual becomes incarcerated at a Correctional Facility and uses our Services and when they contact our Customer Service team

Personal Identifiers, such as name and incarcerated individual ID

Customer records information, such as phone number, projected release date, and court appearance dates

We process data on behalf of Correctional Facilities to:

Provide our Services to Correctional Facilities so that they may provide incarcerated individuals the ability to use our Services.

When Friends and Families use our Services to communicate with incarcerated individuals

Personal Identifiers, such as your name, email address, postal address, phone number, PIN Number, and driver’s license or government ID

Customer Proprietary Network Information, such as time stamp, call length and phone numbers

Biometric information, such as image, voice and voice patterns

Commercial records, such as the content of their communications, products and Services purchased, financial information, for example bank account or credit card information

Internet or other electronic network activity information, such as IP address, time and length of call

We process data on behalf of Correctional Facilities as part of our services to:

Allow friends and family to communicate with incarcerated individuals;

Abide by Correctional Facility rules and support law enforcement activities; and to

Conduct statistical and research analysis to understand customer and market needs, improve our solutions and inform partnership and business development decisions.

When Pay Tel payment products/ options

Personal Identifiers, such as your name, email address, postal address, phone number, PIN Number, and driver’s license or government ID

Customer record information, such as your phone number, financial information, for example bank account or credit card information, type of payment and purpose of payment

You provide this information while using our services to allow us to:

Process payments to fund family and friend accounts in order to use the services to communicate with incarcerated individuals;

Conduct credit checks for use of certain products;

Abide by Correctional Facility rules and support law enforcement activities, as required; and to

Conduct statistical and research analysis to understand customer and market needs, improve our solutions and inform partnership and business development decisions.

When you access our Services or use our mobile application

Internet or other electronic network activity information, such as IP address, cookies, and server log files

This information is automatically collected through our website and mobile applications to allow us to:

Improve your user experience on our websites;

and to enable the basic features of our websites to function, such as allowing images to load.

When responding to a consumer opinion survey

Personal Identifiers such as your name, job title and phone number

Commercial records such as your survey responses and your organization name

You provide this information when responding to our surveys to allow us to:

Understand our customer base and improve our products and Services.

When applying for our job opportunities

Personal Identifiers such as your name, email address, postal address and phone number

Professional or employment-related information such as your job history and other information provided on your resume or through our application form

You provide this information through our Careers site to allow us to:

Manage the application process;

Assess your suitability for the position.

Selling and Sharing of Personal Information

Pay Tel does not sell personal information or share personal information for cross-contextual behavioral advertising. For purposes of this Notice, “sell” means the disclosure of personal information for monetary or other valuable consideration. We disclose personal information for business purposes as noted in the “How We Share Your Information” section of this Policy.

Retention of Personal Information

We maintain the categories of personal information described above for as long as is necessary for the purposes described in this CA Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

When personal information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

2. Additional Information for California Residents

This section is provided pursuant to the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (the “CCPA”) supplements and should be read in conjunction with this Policy. The information in this section applies solely to consumers who reside in the State of California.

The California Code of Regulations defines a “resident” as:

All other individuals are defined as “non-residents”.

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year.

We may collect, use, and disclose your personal information as described above in this Policy, including the following categories that are considered “sensitive” personal information under the CCPA:

The categories of personal information we collect and the sources from which we collect personal information varies based on our relationship or interaction with a specific California resident and the business purpose for which the personal information is collected.

California Consumer Rights

Subject to certain exceptions, as a California resident, you may have the following rights to your personal information:

Right to Know and Access: Request access to your personal information that we have collected, used, disclosed, or sold about you, including:

Right to Deletion: Request deletion of your personal information that we collected from you and retained, subject to certain limitations. If you ask to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as but not limited to:

Right to Correction: You have the right to request that we correct personal information we maintain about you that you believe is inaccurate.

Right to Opt-out of Sales and Sharing: We do not sell or share the personal information of California consumers, as defined by the CCPA, so this right is not applicable.

Right to Limit Use and Disclosure of Sensitive Personal information: We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.

Right to Non-Discrimination for the Exercise of Rights: You have the right to be free from unlawful discrimination for exercising your rights under the CCPA. We will not discriminate against you based upon your exercising your rights with respect to your personal information.

Exercising Your Rights

If you are a California resident and wish to exercise any of these rights, you can contact us by email at privacy@paytel.com or write to Pay Tel Communications, Inc., PO Box 8179, Greensboro, NC 27419, Attn: Privacy.

When submitting your request, you must provide sufficient information that allows us to verify you are the person about whom we collected personal information or an authorized agent. This information includes your first and last name, email address, and billing address. When submitting your request, please provide sufficient detail that allows us to properly understand, evaluate and respond to it. You may be asked to provide additional proof of identification so that we can verify your identity, and we may require that you validate your request. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud prevention purposes. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We will delete such additionally provided information as soon as we finish verifying you.

Authorized Agents

You have the right to designate an authorized agent to act on your behalf to exercise your rights under the CCPA. In order to do so, Pay Tel must verify your identity, and your authorized agent must have written permission from you. We reserve the right to deny a request from an agent that does not submit proof that they are authorized to act on your behalf.

Response Timing

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

3. Additional Information for Residents of States with Applicable Privacy Laws

Residents of certain U.S. states have the right to receive disclosures regarding a business’s processing of “personal data”, as defined under Applicable Privacy Law. Residents of these states may have unique rights with respect to our processing of such personal data. To the extent you are a resident of a state with such a privacy law, and we collect, use or disclose personal data subject to your state’s privacy law, this section of our Policy applies. For more information about the personal data we collect, use and disclose, please see “The Information We Collect,” “How We Process Your Information,” and “How We Share Your Information” sections in this Policy.

Consumer Rights

Under Applicable Privacy Law, you have the following rights:

Exercising Your Rights

If you are a resident of a state that has enacted an applicable privacy law and wish to exercise any of these rights, you can contact us by email at privacy@paytel.com or write to Pay Tel Communications, Inc, PO Box 8179, Greensboro, NC 27419, Attn: Privacy.

Verification Process

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Response Timing

Upon receiving your request, we will respond without undue delay, but in all cases, within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to Appeal

If we decline to take action regarding your request, we will inform you of our decision and the reasoning behind it. If you wish to appeal our decision, please e-mail us at privacy@paytel.com. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason(s) for the decision. If your appeal is denied, you may contact your state’s Attorney General to submit a complaint related to the denial.

Changes to This Privacy Policy

We reserve the right to modify this Policy at any time. We encourage you to review this Policy frequently to be informed of how we are protecting your information. The updated version will be indicated by an updated date and the updated version will be effective as soon as it is accessible. Your use of the Services following changes to the Policy means that you accept the revised Policy.

Release

By accessing and using our website, equipment, and services, you hereby release and forever discharge Pay Tel, its Affiliates, employees, contractors, and agents, from any and all liability, expense, cost or remedy which may arise as a result of your use of our Services as well as the use of the personal information in the manner described herein.

How To Contact Us

Should you have other questions or concerns about this Policy, write us at Pay Tel Privacy Policy, PO Box 8179, Greensboro, NC 27419, or send us an email at privacy@paytel.com.

If you have any questions regarding the Services or your account, please contact our Customer Service team using the information supplied through the “Contact Us” link on the Site, which provides contact phone number.