Privacy Policy and Your California Privacy Rights

Last modified: June 15, 2023

1. Introduction

One Ring Networks, Inc. (“One Ring” or “we” or “us”) respects your privacy and are committed to protecting it through our compliance with this privacy notice.

This Privacy Notice (our “Privacy Notice”) describes the types of information we may collect, use, maintain, protect, disclose, or otherwise process about you when you visit our website oneringnetworks.com and our online business interface located at https://onering.alphastack.com/login and use our communication services, including our fixed wireless, hosted PBX, fiber internet, temporary broadband, managed services, and other similar services (collectively along with the Websites, our “Services”), and our practices for collecting, using, maintaining, protecting, disclosing, or otherwise processing that information.

This policy applies to information we collect:

• when you use our Services;
• when you are listed as an employee, owner, director, officer, or independent contractor of another company, partnership, sole proprietorship, non-profit or government agency (a “Business Entity”), even if you don’t use our Services;
• in email, text, and other electronic messages between you and us, including on or through our Services; and
• through desktop applications you download from our Websites (including Communicator, our virtual phone and communications application), which provide dedicated non-browser-based interaction between you and parts of our Services; and
• when you otherwise interact with or use our Services.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by One Ring or any third-party, including our affiliates and subsidiaries;
• us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us;
• your employer, if you access and use our Services through your employer; or
• any third party including our affiliates and subsidiaries, including through any application or content (including advertising) that may link to or be accessible from our Services.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using these Services, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of these Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.

2. Children Under the Age of 18

While our Services may be used by children under the age of 18 as part of the services obtained by their parent or other legal guardian, children under the age of 18 are not allowed to register for our Services and our Services are not intended to be used by such children without the consent of their parent or guardian. One Ring does not know if a child under the age of 18 is using the Services, and all expected use of the Services by a child under the age of 18 is for the internal operations of the Services, including to perform network communications. Accordingly, no one under age 18 may register to obtain the Services without appropriate consent from their parents or guardian. We do not knowingly collect Personal Data directly from children under 18 not otherwise necessary for the internal operations of the Services. If you are under 18, do not register to use or directly provide any information on our Services or on or through any of its features without consent of your parent or guardian, including providing us with your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received such Personal Data directly from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us at privacy@oneringnetworks.com.

3. Information We Collect About You and How We Collect It

Throughout this Privacy Notice, the term “Personal Data” means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Data does not include any deidentified or aggregated information.

Generally

We collect Personal Data from various sources, including:

• directly from you when you provide it to us;
• automatically as you navigate through our Services;
• information that we create about you as you use our Services;
• from third parties, for example, our payment processor.

Information You Provide to Us

We collect the following types of Personal Data directly from you when you access or use our Services: real name, home or work postal address, unique personal identifier, email address, home or work telephone number, tokenized credit or debit card number (for recurring payments). In addition, we also collect other types of information that you may provide when you fill out a form or through your correspondence with us.

The Personal Data we collect on or through our Services through:

• information that you provide by filling in forms on our Websites. This includes information provided at the time of subscribing to our Services. We may also ask you for information when you report a problem with our Services;
• if you contact us, records and copies of your correspondence (including email addresses).

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain Personal Data about your interaction with our Services, including information about your equipment, browsing actions, and patterns. This includes:

• details of your visits to our Websites and use of our Services. This includes browsing history, search history, traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites or use of the Services, error information, clickstream data, and other communication data and the resources that you access, use, or otherwise interact with our Services;
• Information about your computer and internet connection, i.e., your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data and we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences;
• manage our network, including the Services;
• secure our network and Services; and
• recognize you when you return to our Websites or use our Services again.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Our Websites may use both session cookies (which expire once you close your browser) as further described below and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Websites. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies you may be unable to access certain parts of our Websites. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.
• Session Cookies. Our use of browser cookies also includes “session cookies.” Each time you access the Websites, a session cookie containing an encrypted, unique identifier is placed on your browser. These session cookies allow us to uniquely identify you when you use the Websites (such as to maintain your login state) and track which pages of the Websites you access. Session cookies are required to use the Websites.
• Web Beacons. Pages of our Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit One Ring, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Websites Interaction and Performance Monitoring Tools.Our Websites may also use interaction and/or performance monitoring tools (sometimes call tracking scripts, analytics tools, session replay tools, or heatmap tools). These tools execute code in your web browser to help us collect data about your use of and interactions with the pages and content on our Websites. This may include recording your mouse movements, keystrokes, navigation pathways, other actions that you take our Websites, and information automatically transmitted from your web browser to our Websites such as information about your operating system, computer hardware, and browser preferences.

Third-Party Use of Cookies and Other Similar Technologies

Some content or applications on the Services (including our Websites) are served by third-parties, including advertisers, ad networks and servers, content providers, analytics providers, social media companies, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services (including our Websites). The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Information We Create About You

We may also create certain information about you. When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: unique identifiers (account numbers), network traffic logs, IP addresses, and other similar information used by us to operate our Services and bill you (or your employer) for your use of our Services.

Information We Collect from Third Parties

We may collect Personal Data from third parties, such as service providers who help us maintain and operate our Services, our affiliates, and your employer (if you use our Services through your employer or if your Personal Data is provided to us by your employer to help us manage our relationship with your employer). When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: real name, alias, current or prior home/work postal address, unique personal identifier, email address, home/work telephone number, account name, title, employer name, and financial information.

4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

• to provide and personalize our Services (including our Websites) and its content to you;
• to provide you with information, products, or services that you request from us, including the access and use of our Services;
• to support, develop, troubleshoot, and debug our Services;
• to create, maintain, customize, and secure your account with us;
• to process your requests, purchases, transactions, and payments and prevent transactional fraud;
• to provide you with notices about your account, including expiration and renewal notices;
• to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
• to help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business;
• for internal testing, research, analysis, and product development, including to develop and improve our Services, and to develop, improve, or demonstrate new or other products and services;
• auditing relating to your interaction with our Services, including, but not limited to, monitoring your bandwidth usage for billing purposes;
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• debugging to identify and repair errors that impair existing intended functionality;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Services and any other products or services we offer or provide though them;
• in any other way we may describe when you provide the information;
• to fulfill any other purpose for which you provide it; and
• for any other purpose with your consent.

5. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Notice:

• to our subsidiaries and affiliates;
• to contractors, service providers, and other third parties we use to support our business. These entities provide IT and infrastructure support services, and payment processing services. Their privacy policies may be found at https://paysimple.com/privacy, https://alphastack.com/privacy-policy, and https://www.zendesk.com/trust-center/;
• to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of One Ring’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by One Ring about our Services’ users is among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our terms of use https://oneringnetworks.com/terms-and-conditions/  and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of One Ring, our customers, or others.

6. Choices About How We Use and Disclose Your Information

We do not control the collection and use of your information collected by third parties as part of our providing you with our Services as further described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

We also do not control the collection and use of your Personal Data and other information by third parties who may operate products and services generally accessible through our Services, but who are otherwise not involved in our performance of the Services, such as third-party website providers. If you have any questions about their collection and use of your Personal Data or other information, please contact the responsible third parties directly.

We do not control third parties’ collection or use of your Personal Data and other information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).

7. Accessing, Correcting, and Deleting Your Personal Data

You can review and change some of your Personal Data by logging into the Websites and visiting your account profile page.

You may also send us an email at privacy@oneringnetworks.com to request that we correct, delete, or otherwise provide you access to any Personal Data that we have collected about you. We cannot delete your Personal Data except by also closing and deleting your account (which we cannot do unless and until you or your employer terminates our provision of Services and closes the account). We may not accommodate a request to change or delete your Personal Data if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.

The jurisdiction in which you are a resident or are located may provide you with additional rights and choices regarding your Personal Data. Please see Jurisdiction-Specific Privacy Rights for more Information.

8. Jurisdiction-Specific Privacy Rights

The law in some jurisdictions may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your state that is attached to this Privacy Notice.

Your California Privacy Rights

If you are a resident of California, you have the additional rights described in the California Privacy Addendum.

9. Do Not Track Signals

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

10. Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All payment transactions are processed by our third-party payment processor and any payment transactions and customer service communications will be encrypted using TLS/SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to or through our Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on our Services or any other website or service available on or through our Services.

11. Consent to Processing of Personal Data in the United States

In order to provide our Services to you, we may send and store your Personal Data outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your Personal Data may be processed and stored in the United States and federal, state, and local governments, courts, or law enforcement or regulatory agencies in the United States may be able to obtain disclosure of your information through the laws of the United States. By using our Services, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States.

Your Personal Data is transferred by One Ring to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with this Privacy Notice when we transfer it to a third party, One Ring uses Data Protection Agreements between One Ring and all other recipients of your Personal Data.

12. Changes to Our Privacy Notice

We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the primary email address specified in your account and/or through a notice on the Websites’ home page. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this Privacy Notice to check for any changes.

Your continued use of our SERVICES following the posting of changes constitutes your acceptance to such changes.

13. Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Websites.

One Ring Networks

1799 Enterprise St,

Athens, Texas 75751

USA

404-303-9900

privacy@oneringnetworks.com

One Ring Networks Privacy Notice Addendum for California Residents

Effective Date: June 15 2023

Last Reviewed on: June 5, 2023

1. Introduction

This Privacy Notice Addendum for California Residents (the “California Privacy Addendum”) supplements the information contained in One Ring Networks, Inc.’s Privacy Notice and describes our collection and use of Personal Information (as defined below). This California Privacy Addendum applies solely to all visitors, users, and others who reside in the State of California (“Consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CPRA”) and any terms defined in the CPRA have the same meaning when used in this notice.

2. Scope of this California Privacy Addendum

This California Privacy Addendum applies to information that we collect when you use our Services that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). It also applies to Personal Information that we collect reflecting written or verbal communications or a transaction between us and you as an employee, owner, director, officer, or independent contractor of another company, partnership, sole proprietorship, non-profit or government agency (a “Business Entity”) in the context of us providing a product or service to or receiving a product or service from your Business Entity (a “Business Relationship”). However, publicly available information that we collect from government records and deidentified or aggregated information (when deidentified or aggregated as described in the CPRA) are not considered Personal Information and this California Privacy Addendum does not apply to such information.

This California Privacy Addendum does not apply to employment-related Personal Information collected from our California-based employees, job applicants, contractors, or similar individuals (“Personnel”). Please contact your local human resources department if you are part of our California Personnel and would like additional information about how we process your Personal Information.

This California Privacy Addendum also does not apply to certain Personal Information that is excluded from the scope of the CPRA, like: (a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and (b) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

3. Information We Collect About You and How We Collect It

One Ring collects, and over the prior twelve (12) months have collected, the following categories of Personal Information about Consumers:

Personal Information Category	Applicable Pieces of Personal Information Collected
Identifiers.	A real name; alias; postal address; unique personal identifier; online identifier; Internet Protocol address; email address; account name; and other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name; signature; address; employment; employment history; telephone number; bank account number; credit card number, debit card number, or any other financial information. Some Personal Information included in this category may overlap with other categories.
Commercial information.	Records of personal property, products, or services purchased (including the level of service purchased from One Ring Networks), obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity.	Browsing history; search history; information on a Consumer’s interaction with a website, application, or advertisement.
Sensory data.	Audio; electronic; or similar information.
Sensitive Personal Information (“Sensitive Personal Information”)	Complete account access credentials (user names, combined with required access/security code or password)

One Ring will not collect additional categories of Personal Information without providing you notice. As further described in To Whom Do We Sell or Share Your Personal Information, solely through our use of cookies on our Website we do not “sell” your Personal Information for monetary consideration, however under the definitions of “sell” and “share” in the CPRA, we may “sell” any categories of Personal Information for non-monetary valuable consideration and we may “share” any categories of Personal Information for cross-context behavioral advertising.

4. Sources of Personal Information

We collect Personal Information about you from the sources described in our Privacy Notice.

5. Purposes for Our Collection of Your Personal Information

We may use, “sell” for non-monetary valuable consideration, “share” for the purposes of cross-context behavioral advertising, or disclose the Personal Information we collect and, over the prior twelve (12) months, have used, “sold” for non-monetary valuable consideration, “shared” for the purpose of cross-context behavioral advertising, or disclosed the Personal Information we have collected, for the purposes described in our Privacy Notice as well as the following additional purposes:

• Short-term, transient use, provided the Personal Information that is not disclosed to another third-party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, managing your connection to the Internet and your other use of our Services.
• Performing services on behalf of another business or service provider (each as defined in the CPRA), such as your employer, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, shipping, advertising, marketing, or analytics services, or providing similar services on behalf of that other business or service provider.

One Ring will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

6. Third Parties to Whom Do We Disclose Your Personal Information for Business Purposes

One Ring may disclose your Personal Information to third-parties for one or more business purposes. When we disclose Personal Information to non-affiliated third-parties for a business purpose, we enter a contract that describes the purpose, requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the specific business purposes for which the Personal Information was disclosed, and requires the recipient to otherwise comply with the requirements of the CPRA.

In the preceding twelve (12) months, One Ring has disclosed the following categories of Personal Information for one or more of the business purposes described below to the following categories of third-parties:

Personal Information Category	Categories of Non-Service Provider and Non-Contractor Third Party Recipients
Identifiers.	Service Providers; advertisers and advertising networks; affiliates, parents, and subsidiary organizations of One Ring; Internet cookie information recipients, such as analytics and behavioral advertising services; collection agencies; and other Internet network providers that we may connect to in order to provide you with our Services.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Service Providers; collection agencies; and affiliates, parents, and subsidiary organizations of One Ring.
Commercial information.	Service Providers; collection agencies; and affiliates, parents, and subsidiary organizations of One Ring.
Internet or other similar network activity.	Service Providers; advertisers and advertising networks; affiliates, parents, and subsidiary organizations of One Ring; and Internet cookie information recipients, such as analytics and behavioral advertising services; and other Internet network providers that we may connect to in order to provide you with our Services.
Sensory Data	Service Providers and affiliates, parents, and subsidiary organizations of One Ring.

 

Sensitive Personal Information Category	Categories of Third Party Recipients
Complete account access credentials (user names combined with required access/security code or password)	Service Providers and affiliates, parents, and subsidiary organizations of One Ring.

We disclose your Personal Information to the categories of third-parties listed above for one or more of the following business purposes:

• helping to ensure security and integrity of our products, services, and IT infrastructure to the extent the use of the Personal Information is reasonably necessary and proportionate for these purposes;
• debugging to identify and repair errors that impair existing intended functionality;
• short–term, transient use, including, but not limited to, managing your connection to the Internet and your use of our Services. Our agreements with third-parties prohibit your Personal Information from disclosure to another third-party and from using your Personal Information to build a profile about the you or otherwise alter your experience outside your current interaction with us;
• performing services on behalf of us, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of us;
• undertaking internal research for technological development and demonstration; and
• undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

In addition to the above, we may disclose any or all categories of Personal Information to any third-party (including government entities and/or law enforcement entities) as necessary to:

• comply with federal, state, or local laws, or to comply with a court order or subpoena to provide information;
• comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
• cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers’) believe may violate federal, state, or local law;
• comply with certain government agency requests for emergency access to your Personal Information if you are at risk or danger of death or serious physical injury; or
• exercise or defend legal claims.

7. To Whom Do We Sell or Share Your Personal Information

“Sale” of Your Personal Information for Monetary or Other Valuable Consideration

As noted in our Privacy Notice, we do not sell Personal Information as the term “sell” is commonly understood to require an exchange for money. However, the use of advertising and analytics cookies on our Website is considered a “sale” of Personal Information as the term “sale” is broadly defined in the CPRA to include both monetary and other valuable consideration. Using this broad definition, our “sale” is limited to our use of certain third-party advertising and analytics cookies and their use in providing behavioral advertising and their use in understanding how people use and interact with our Website. However, the CPRA does not consider it a “sale” when you merely use our Services to intentionally interact with another third-party (such as third-party’s website or online service). Our “sales” of your Personal Information in this matter is subject to your right to opt-out of those sales (see Your Choices Regarding our “Sale” or “Sharing” of your Personal Information). The CPRA prohibits third-parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

“Sharing” of Your Personal Information for Cross-Context Behavioral Advertising

One Ring may “share” your Personal Information for the purpose of cross-context behavioral advertising, subject to your right to opt-out of that sharing (see Your Choices Regarding our “Sale” or “Sharing” of your Personal Information). Our “sharing” for the purpose of cross-context behavioral advertising would be limited to our use of certain third-party advertising cookies and their use in providing you cross-context behavioral advertising (i.e., advertising on other websites or in other mediums). When the recipients of your Personal Information disclosed for the purpose of cross-context behavioral advertising are also permitted to use your Personal Information to provide advertising to others, we also consider this disclosure as a “sale” for monetary or other valuable consideration under the CPRA.

In the preceding twelve (12) months, One Ring has “sold” for non-monetary valuable consideration, or “shared” for the purpose of cross-context behavioral advertising, the following categories of Personal Information to the following categories of third-parties:

Personal Information Category	Sold or Shared	Business or Commercial Purpose for Sale or Sharing (as appropriate)	Categories of Third Parties to Whom Your Personal Information is Sold or Shared
Identifiers.	Sold and Shared	Website and Services analytics and cross-context behavioral advertising regarding the Services.	Business partners; advertisers and advertising networks; Internet cookie information recipients, such as analytics and behavioral advertising services.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	No	N/A	N/A
Commercial information.	No	N/A	N/A
Internet or other similar network activity.	Sold and Shared	Website and Services analytics and cross-context behavioral advertising regarding the Services.	Internet cookie information recipients, such as analytics and behavioral advertising services.
Sensory data.	No	N/A	N/A

 

Sensitive Personal Information Category	Sold or Shared	Business Purpose for Sale or Sharing (as appropriate)	Categories of Third Parties to Whom Your Personal Information is Sold or Shared
Complete account access credentials (user names combined with required access/security code or password)]	No	N/A	N/A

Reselling Personal Information

The CPRA prohibits a third-party from reselling Personal Information unless you have received explicit notice and an opportunity to opt-out of further sales. You may request a current list of the third-party providers of analytics and advertising cookies at any time by emailing us at privacy@oneringnetworks.com. For more information about your right to opt-out of our “sale” of Personal Information through cookies and other similar technologies, please see Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information.

Sale or Sharing of Personal Information of Minors Under the Age of 16

We do not have any actual knowledge that we “sell” the Personal Information of minors under the age of 16 for monetary or other valuable consideration and we do not have any actual knowledge that we “share” such Personal Information for cross-context behavioral advertising without affirmative consent as required by the CPRA. More information on how minors under the age of 16 may change their choice regarding the “sale” or “sharing” of their Personal Information can be found in Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information.

8. Consumer Data Requests

The CPRA provides California residents with specific rights regarding their Personal Information. This section describes your CPRA rights and explains how to exercise those rights. You may exercise these rights yourself or through your Authorized Agent. For more information on how you or your Authorized Agent can exercise your rights, please see Exercising Your CPRA Privacy Rights.

• Right to Know. You have the right to request that One Ring disclose certain information to you about our collection and use of your Personal Information over the past 12 months (a “Right to Know” Consumer Request). This includes: (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which that Personal Information came from; (c) our purposes for collecting this Personal Information; (d) the categories of third-parties with whom we have shared your Personal Information; and (e) if we have “sold” or “shared” or disclosed your Personal Information, a list of categories of third-parties to whom we “sold” or “shared” your Personal Information, and a separate list of the categories of third-parties to whom we disclosed your Personal Information to. You must specifically describe if you are making a Right to Know request or a Data Portability Request. If you would like to make both a Right to Know Consumer Request and a Data Portability Consumer Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. You may make a Right to Know or a Data Portability Consumer Request a total of two (2) times within a 12-month period at no charge.
• Access to Specific Pieces of Information (Data Portability). You also have the right to request that One Ring provide you with a copy of the specific pieces of Personal Information that we have collected about you, including any Personal Information that we have created or otherwise received from a third-party about you (a “Data Portability” Consumer Request). If you make a Data Portability Consumer Request electronically, we will provide you with a copy of your Personal Information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the Personal Information to another third-party. You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like to make both a Right to Know Consumer Request and a Data Portability Consumer Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. In response to a Data Portability Consumer Request, we will not disclose your financial account number, or your account password or security question or answers. We will also not provide this information if the disclosure would create a substantial, articulable, and unreasonable risk to your Personal Information, your account with One Ring, or the security of our systems or networks. We will also not disclose any Personal Information that may be subject to another exception under the CPRA. If we are unable to disclose certain pieces of your Personal Information, we will describe generally the types of personal information that we were unable to disclose and provide you a description of the reason we are unable to disclose it. You may make a Right to Know or a Data Portability Consumer Request a total of two (2) times within a 12-month period at no charge.
• You have the right to request that we correct any incorrect Personal Information about you to ensure that it is complete, accurate, and as current as possible. You may also request that we correct the Personal Information we have about you as described below under Exercising Your CPRA Privacy Rights. In some cases, we may require you to provide reasonable documentation to show that the Personal Information we have about you is incorrect and what the correct Personal Information may be. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect or if the Personal Information is subject to another exception under the CPRA.
• You have the right to request that One Ring delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your Consumer Request (see Exercising Your CPRA Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies pursuant to the CPRA. Some exceptions to your right to delete include, but are not limited to, if we are required to retain your Personal Information to complete the transaction or provide you the goods and services for which we collected the Personal Information or otherwise perform under our contract with you (in other words, we may not be able to delete your Personal Information unless you close your account and terminate Services), to detect security incidents or protect against other malicious activities, and to comply with legal obligations. We may also retain your Personal Information for other internal and lawful uses that are compatible with the context in which we collected it.
• Non-Discrimination. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not do any of the following as a result of you exercising your CPRA rights: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CPRA Privacy Rights

To exercise the rights described above, please submit a request (a “Consumer Request”) to us by either:

• Calling us at (855) ONE-RING.
• Emailing us at privacy@oneringnetworks.com.
• Contacting us at https://oneringnetworks.com/contact-us-2/.

If you (or your Authorized Agent) submit a Consumer Request to delete your information online, we will use a two-step process in order to confirm that you want your Personal Information deleted. This process may include verifying your request through your email address on record, calling you on your phone number on record (which may include an automated dialer), sending you a text message and requesting that you text us a confirmation, and/or sending you a confirmation through US mail. By making a Consumer Request, you consent to us contacting you in one or more of these ways.

If you fail to make your Consumer Request in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above or provide you with information on how to submit the request or remedy any deficiencies with your request.

Only you, or your Authorized Agent that you authorize to act on your behalf, may make a Consumer Request related to your Personal Information. To designate an Authorized Agent, see Authorized Agents below.

All Consumer Requests must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Agent of such a person. This may include:
  • Providing an account number or other similar private information about your account that we can compare against our records.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 which Personal Information relates to you or the individual for whom you are making the request as their Authorized Agent.

Making a Consumer Request does not require you to create an account with us.

We will only use Personal Information provided in a Consumer Request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information.

Authorized Agents

You may authorize your agent to exercise your rights under the CPRA on your behalf by providing them with written authorization or with power of attorney to exercise your rights in accordance with applicable laws (an “Authorized Agent”). We may request that your Authorized Agent submit proof of identity and that they have been authorized exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.

Response Timing and Format

We will confirm our receipt of your Consumer Request within ten (10) business days of its receipt. We will generally process these requests within forty-five (45) calendar days of its receipt. If we require more time (up to an additional 45 calendar days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

In response to a Right to Know or Data Portability Consumer Request, we will provide you with all relevant information we have collected or maintained about you on or after January 1, 2022, unless an exception applies. The response we provide will also explain the reasons we cannot comply with a Consumer Request, if applicable. For Data Portability Consumer Request, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your Consumer Request unless it is excessive, repetitive, or manifestly unfounded. We reserve the right to consider more than two (2) total Right to Know or Data Portability Consumer Requests (or combination of the two) in a twelve (12) month period to be repetitive and/or excessive and require a fee. If we determine that your Consumer Request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

9. Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information

“Sale” of Your Personal Information

You have the right to direct us to not sell (as defined in the CPRA) your Personal Information for monetary or other valuable consideration at any time (the “right to opt-out”). Because of the nature of our Services, we are unable to determine if you or any other user of our Services is under the age of 16. We do not sell the Personal Information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

“Sharing” of Your Personal Information

You have the right to direct us to not share your Personal Information for the purposes of cross-context behavioral advertising, which is showing advertising on other websites or other media based on your browsing history with our Website (the “right to opt-out”). Because of the nature of our Services, we are unable to determine if you or any other user of our Services is under the age of 16. We do not share the Personal Information of Consumers we actually know are less than 16 years of age for this purpose, unless we receive affirmative authorization from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to our sharing of Personal Information for these purposes may opt-out of future such sharing at any time.

How You May Opt-Out of Our Sale or Sharing of Your Personal Information

To exercise the right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration and of “sharing” your Personal Information for the purposes of cross-context behavioral advertising, you (or your Authorized Agent) may adjust your cookie preferences by visiting the “Do Not Sell or Share My Personal Information” link available on the footer of each page of our Website and disabling “Sales and Sharing of Personal Information” or otherwise setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or by configuring your browser to refuse all or some of our cookies, you may be unable to access certain parts of our Website or other websites. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize our “sale” and “sharing” of your Personal Information. However, you may change your mind and opt back into the “sale” and “sharing” of Personal Information at any time by changing your browser cookies to accept the relevant browser cookies again or by once again visiting our cookie consent manager through the “Do Not Sell or Share My Personal Information” link and turning on the “Sales and Sharing of Personal Information” control.

You do not need to create an account with us to exercise your opt-out rights. Your opt-out of sale or sharing will only apply to the device and particular browser from which you opt-out. You will need to repeat the process on each device and in each browser that you use to access our Website.

If you (or your Authorized Agent) submit a request to opt-in to our “sale” or “sharing” of your Personal Information, we will use a two-step process in order to confirm that you want to opt-in for such “sale” or “sharing” of your Personal Information. This process may include verifying your request through your email address on record, calling you on your phone number on record (which may be through the use of an automated dialer), sending you a text message and requesting that you text us a confirmation (which may be through the use of an automated dialer), providing you with a pop-up to confirm or requiring that you click an additional button to confirm your opt-in choice, and/or sending you a confirmation through US mail. By making a Consumer Request, you consent to us contacting you in one or more of these ways.

Browser Privacy Control Signals

You may also exercise your right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration and “sharing” your Personal Information for the purposes of cross-context behavioral advertising by setting the privacy control signal on your browser, if your browser supports it. We currently recognize and support the following privacy signals sent by browsers:

• Global privacy control (for more information on how to configure your browser to send this signal, please see https://globalprivacycontrol.org/).

When we receive one of these privacy control signals, we will opt you out of any further “sale” or “sharing” of your Personal Information when you interact with our Website through that browser and on that device.

10. Your Choices Regarding our Use and Disclosure of Your Sensitive Personal Information

We do not use or disclose your Sensitive Personal Information for any purpose other than the following:

• to perform the services or provide the goods reasonably expected by an average Consumer who requests such goods or services;
• to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted Personal Information, provided that our use of your Personal Information is reasonably necessary and proportionate for such purposes;
• to resist malicious, deceptive, fraudulent, or illegal actions directed at One Ring and to prosecute those responsible for those actions, provided that our use of your Personal Information is reasonably necessary and proportionate for this purpose;
• to ensure the safety of natural persons, provided that our use of your Personal Information is reasonably necessary and proportionate for this purpose;
• for short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that the Personal Information is not disclosed to another third-party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;
• to perform services on behalf of us, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of us; and
• to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by us.

Because we only use your Sensitive Personal Information for the purposes outlined above, we do not provide a method for you to limit your use and disclosure of Sensitive Personal Information to the above uses.

11. Personal Information Retention Periods

One Ring will retain your Personal Data for the entire time that you keep your account open plus a period of up to ninety (90) days (if you do not have an account, we will retain your Personal Information for a period of one (1) year). However, we may retain any or all categories of Personal Information in excess of this time when your information is subject to one of the following exceptions:

• when stored in our backup and disaster recovery systems. Your Personal Information will be deleted when the backup media your Personal Information is stored on expires or when our disaster recovery systems are updated;
• when necessary for us to exercise or defend legal claims;
• when necessary to comply with a legal obligation; or
• when necessary to help ensure the security and integrity of our Website and IT systems.

12. Changes to This CPRA Privacy Addendum

One Ring reserves the right to amend this California Privacy Addendum at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Website and update the addendum’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

13. Contact Information

If you have any questions or comments about this California Privacy Addendum, the ways in which One Ring collects and uses your information described above and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (855) ONE-RING

Website: https://oneringnetworks.com/contact-us-2/

Email: privacy@oneringnetworks.com

Postal Address:         One Ring Networks

Attn: California Privacy Request

1799 Enterprise Street
Athens, Texas 75751