Privacy Policy

Updated as of: January, 2021

Introduction and Overview

This Privacy Policy is maintained by China Telecom do Brasil Ltda (“we” or the “Company”), the U.S. affiliate of China Telecommunications Corporation.  Headquartered in Herndon, Virginia, we provide telecommunications and related services to U.S. and foreign customers.  Our services are provided predominately to enterprise customers, including other carriers, but we also provide certain mobile services to individual retail customers.

We take privacy concerns very seriously and are committed to ensuring that our handling of personally identifiable information complies with applicable data protection and privacy laws and related regulations.  This Privacy Policy sets out our policies and practices regarding the collection, processing, use, storage and disposal of information that we collect from and about any of our customers that may be “personally identifiable.”  This includes any information (other than publicly listed information) by which you can be individually identified, including but not limited to name, mailing and/or billing address, email address, phone and fax number, and any other such information.  This Privacy Policy also outlines the steps that you can take to further protect any personally identifiable information that you may provide to us and how you may contact us about privacy issues.  All information submitted through our websites is subject to the terms and conditions of this Privacy Policy, as it may be amended from time to time.

Your Consent to Our Collection and Use of Your Personally Identifiable Information

Your submission of personally identifiable information to us constitutes your acknowledgement that you have read and understood this Privacy Policy and that you consent to our collection, processing, use, storage and disposal of your personally identifiable information, whether electronically or manually, for the expressed purpose in accordance with this Policy.  Any personally identifiable information which you submit to us will be treated and processed by us only in accordance with this Privacy Policy.

Because the Company is part of a world-wide group of affiliated companies that often combine resources, your consent to our collection and use of your personally identifiable information also includes your consent to the transfer, storage and processing of such information between our offices in the United States and our affiliates abroad as may be necessary in connection with our provision of international services.

Our Collection of Your Personally Identifiable Information and CPNI

Personally Identifiable Information.  The primary way that we may collect information about you is by asking you to provide it to us, in connection with registering to use our website, requesting information from us or ordering services from us.  In that context, we will collect your name, billing address, telephone number and email address.  We may also collect debit or credit card information and/or banking details and other relevant payment information necessary for us to process your order or manage our provision of service to you.  Also, if you contact us by phone, email or otherwise, we may retain a record of that communication.  We will also maintain records of your visits to our websites, including but not limited to traffic data, location data and other communications data as well as the details of transactions you carry out through our websites and the fulfillment of your orders for our services.

Customer Proprietary Network Information (“CPNI”).  In the course of providing to you services that you have ordered from us, we may also collect information that is referred to by the Federal Communications Commission (“FCC”) as “Customer Proprietary Network Information” or “CPNI.”  This includes information about the type, quantity, configuration, destination, location and amount of use of the telecommunications services you purchase, how you purchase and use those services and related billing and end user information.

Online Activity Tracking.

Cookies.  “Cookies” are text files, which may be encrypted, containing small amounts of information that a server may download to your computer or mobile device when you visit a website, use an application, or access an advertisement or widget on a website.  Personally identifiable information is not generated by the cookies, but by your input into website order forms, registration pages, payment pages, other online forms, and your use of the website.  When you return to a website, your browser retrieves and sends the information in the cookie to the website’s server.  Cookies facilitate efficient navigation on websites, identify and remember individual user personal preferences gleaned from use of a website, authenticate log-in information, and gather aggregated website user information.  Some cookies, knowns as “Session Cookies,” store a session ID that is not personally identifiable, but only for a particular browsing session.  Such cookies store information about pages you view and allow you to easily navigate from one page to another during the browsing session, but are deleted from your computer when the session is over.  Other cookies, known as “Persistent or Tracking Cookies,” retain user preferences for future browsing sessions on a website by the same user.  Such cookies assign a unique ID to the user’s browser and are not deleted when the browser is closed.

All of the cookies we may use on our website are deployed to help our websites function.  They are essential to ensure that you can effectively navigate our website and access your desired content when you visit our websites.  We do not utilize cookies that gather information for ad tracking or monetization purposes.  Any cookies that we use to gather information about the content you have viewed collects such information on an aggregated and anonymous basis.  The information collected by these cookies cannot track browsing activities on other websites.

By using our website, you consent to our use of these cookies and agree that we can place them on your device.  If you do not want our websites to place cookies on your device, you should not use our websites or you should delete any cookies that have been placed on your device by our website.  You may also be able to adjust your browser settings to notify you when new cookies are placed on your device, limit acceptance of certain cookies, make them expire, or disable them entirely.  However, because cookies allow you to take advantage of many of the essential features on our websites, disabling them may impair your use of our websites.  It is always a good practice to secure your device against possible problems caused by cookies on the internet.  As a general matter, you should be sure to keep your browser updated, and install and keep updated a good antispyware application on your device.  For more information about cookies, please see https://www.allaboutcookies.org.

Analytics. We also may use certain forms of display advertising and other advanced features through Google Analytics. For more information on the use of Google Analytics, please visit Google’s privacy policy here.  You can also view available Google opt-out options in the How to Opt Out of Google Data Collection section below.

Online Ads. We also permit third-party online advertising networks, social media companies and other third-party services to collect information about your use of our online services over time so that they may play or display personalized or interest-based ads on our online services, on other websites, apps or services you may use, and on other devices you may use. The information used for interest-based advertising may be collected through cookies or tracking technologies. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Certain tracking technologies we use are related to advertising networks, and through those technologies we may share certain information such as IP addresses.  Please note that the information we share with those advertising networks might be combined with other information about you that those networks may have collected from other sources. Please refer to the Your Choices About Online Ads section below for more information about the choices and opt-out options you may have in relation to those practices.

Hypertext Links.  Our websites may include hypertext links to other websites.  We have no control over websites that we do not own or maintain.  These other websites may be subject to different privacy policies than ours.  You should review the specific privacy policies of such websites to be sure that you understand how they collect, use and share your information and so that you can adjust your usage accordingly.  We expressly disclaim any and all responsibility or liability for the privacy policies or practices of other websites that may be accessed via hypertext links from our websites.

Our Use of Your Personal Information

Use by the Company.  We are committed to protecting your privacy.  Consequently, your personally identifiable information is collected, processed, stored and disposed of in accordance with applicable data protection and privacy laws.  Specifically, we process your personally identifiable information solely to:

• provide access to our websites;
• process service order(s);
• provide services, including to process billing and payment information;
• administer services;
• analyze the use of our websites and services on a personalized or aggregated basis to gather broad demographic information, interests, and behavior so that we may better tailor our websites and services in accordance with customer preferences;
• process IP addresses to help diagnose problems with our servers and administer our websites;
• inform customers of any new promotions and services offered, improve our level of service and provide notifications regarding service changes or outages or in order to carry out market research; and
• investigate any complaints or other inquiries customers may submit to us.

We would like to keep you up to date with details of our services using the information that you have supplied.  We will do this in accordance with applicable privacy laws and FCC policies, and in accordance with any direct marketing permissions which were given by you when we collected information from you.

Sharing with Others

Unless we have your permission to do otherwise or are required by law, we will share your personally identifiable information only with our affiliated group companies and to our selected business partners who act on our behalf in providing the services.  In connection with our provision of service to you, your personally identifiable information may be accessible by third-party service providers with whom we subcontract, including those who assist us in the provision of our services or who host and maintain our websites or our other services, or who provide billing and other out-sourced services to us.  All such service providers commit to complying with our instructions and to keeping all personally identifiable information secure.  We make every reasonable effort to ensure that our affiliates and business partners, including those in the U.S. and/or any other countries in which we operate, process your personally identifiable information in accordance with the terms of this Privacy Policy.

Other than as mentioned above, we may disclose personally identifiable information and account information in special cases when legal interests are at stake.  For example, we may disclose such information as is necessary to identify, contact, or bring legal action against someone who may be violating a user agreement or may be causing injury to or interference with us, you, or anyone else that could be harmed by such activities.  We may disclose personally identifiable information as necessary to collect payment for the services we provide.  We also may disclose such information as is required by government or law enforcement officials.  We can, and you hereby authorize us to, disclose any information to law enforcement or other parties that we, in our sole discretion, believe is required or appropriate to comply with the law.

We may share non-personal, non-individual information in aggregate form with selected third parties.  Other than as set forth herein, we do not sell or disseminate personally identifiable information to third parties without your consent.

Your Choices About Online Ads

How to Opt Out of Online Advertising in Internet Browser

We support the Self-Regulatory Principles for online behavioral advertising (“Principles”) published by the Digital Advertising Alliance (“DAA”). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please following the instructions at: www.aboutads.info/choices, or https://www.networkadvertising.org/choices/.

When you elect to opt-out through these sites, they will place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements.  Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.  And some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again. Disabling cookies may limit your ability to use the services.

By visiting www.privacyrights.info or www.optout.privacyrights.info/?c=1, you can opt out from sales of this type of personal information by businesses that participate in the DAA’s CCPA App-based Opt-Out Tool.

How to Opt Out of Online Advertising in Mobile Applications

If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at https://www.aboutads.info/appchoices.

To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at https://www.privacyrights.info/appchoices.

How to Opt Out of Google Data Collection

We also may use certain forms of display advertising and other advanced features through Google, such as Google Analytics. These features enable us to use data collection technologies to inform, optimize, and display ads based on your past visits to the online services.

• You may opt-out of certain Google advertising products by visiting https://google.com/ads/preferences.
• You can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

Effect of Opting Out

Please note that when you opt-out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services.  It means that the online ads that you do see from DAA program participants should not be based on your interests.  We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Our Retention of Your Personal Information

The length of time we keep your information for can vary depending upon the way in which we use the information.  Unless there is a specific legal requirement to keep your information, we will not keep it for longer than we believe is reasonably necessary for the purposes for which the data was collected.

Online Privacy Policy for Children

Our websites do not target and are not intended for use by children under the age of 13, and we abide by the United States’ Children’s Online Privacy Protection Act (CORPA) and other applicable laws relating to the use of children’s data.  We do not knowingly collect or maintain personally identifiable information from children under the age of 13.

Data Protection and Security

We have implemented reasonable technical and organizational measures to secure your personally identifiable information from accidental loss and from unauthorized access, use, alteration or disclosure.  Our websites have security measures in place to protect against the loss, misuse and alteration of information under our control.  However, the internet is an open system, and we cannot guarantee that unauthorized third parties will not be able to defeat the security measures we have in place, or that they will not use your personally identifiable information for improper purposes.

Certain information may be transmitted to you by electronic mail.  Although it may be illegal to intercept or disclose such messages, the transmissions are not secured.

Customer Choice, Controls and Changes

You may request a copy of the personally identifiable information we hold about you, such as contact information, banking details and marketing preferences, and you may review, correct, update, change or delete this information at any time by submitting a request to [email protected].  Please note that in certain circumstances we may withhold access to your information where we are required to do so by applicable law or order, or have the right to do so under current data protection legislation.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states.  Please refer below for disclosures that may be applicable to you:

• If you are a resident of the State of California in the United States, please see below for additional California-specific privacy disclosures.
• If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at [email protected].

California Residents

This section applies to you if you are a resident of the state of California.  California law requires us to disclose certain information regarding the categories of personal information we collect.  For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with us, or that is excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, such as the HIPAA, the FCRA, GLBA or the Driver’s Privacy Protection Act of 1994.  This section does not apply to information relating to our employees, contractors, applicants and other personnel.  This section also does not apply to personal information we collect when we are acting as a “service provider” to process information in accordance with a contract with our business customers.

Collection and use of personal information.  We collect personal information from and about you for a variety of purposes.  For example, we use personal information to fulfill your requests, process your transactions and provide our services to you; to communicate with you; for marketing and advertising purposes; to monitor, improve, and develop our products and services; and to protect the security and integrity of our business, comply with legal requirements and obligations; for our business and operational purposes; and as otherwise permitted or required by law.

To learn more about the types of personal information we collect and the purposes for which we collect this information, please refer to the Our Collection of Your Personally Identifiable Information and CPNI and Our Use of Your Personal Information sections above.

In the last 12 months, we have collected the following categories of personal information:

Disclosure of personal information.  We share personal information with third parties for business purposes.  We do not “sell” personal information about our users as most people would typically understand that term (see below).  The categories of third parties to whom we disclose your personal information for a business purpose include:  (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) marketing and strategic partners; (iv) promotional partners; (v) ad networks and advertising partners; (vi) analytics providers; (vii) social networks.  To learn more about how we disclose data to third parties, please refer to the Sharing with Others section above.

In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose:

• All of the categories of personal information we collect, explained in the table above.

We do not “sell” personal information about our users as most people would typically understand that term.  However, as is common practice among companies that operate online, we have permitted third party advertising networks, social media companies and other third party businesses to collect and disclose your personal information (including Internet / Network Information, Commercial Information, and Inferences) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us, for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting.  To learn more about online advertising and how you may be able to control some of this activity, please see the Online Activity Tracking and Your Choices About Online Ads sections above.

Your Rights and Choices.  As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

• The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
• The specific pieces of personal information we have collected about you;
• The categories of personal information we have collected about you;
• The categories of sources of the personal information;
• The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
• The business or commercial purposes for collecting or, if applicable, selling personal information.
• The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
• The Right to Opt Out of Personal Information Sales to third parties now or in the future.

You also have the right to be free of discrimination for exercising these rights.  However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

To submit your California Consumer Rights Requests.  You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below.  We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one.  In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To exercise your right to know and/or right to deletion, please submit a request by:

• Emailing [email protected] with the subject line “California Rights Request,”
• Filling out our California Consumer Rights Request Form, or
• Calling 703-787-0088.

Before processing your request, we may need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your name, mobile number, email address, mailing address, customer ID, and/or date of last interaction with customer service.

In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.

To exercise your right to opt out: As described in the Disclosure of personal information section above, we utilize third-party providers to engage in online analytics and advertising involving the collection of personal information, including Identifiers, Internet/Network Information, and Geolocation Data, directly from your browser or device through cookies or related technologies when you visit or interact with our online services or otherwise engage with us online. We use these third-party providers to analyze and optimize our online services, provide more relevant content and ads to users of our online services and other third parties, and perform other services related to analytics or advertising consistent with this section and our Privacy Policy. These third-party businesses may use the information they collect directly from you for their own purposes in accordance with their own privacy notices, which may include using this information for services provided to other third parties, including other parties operating in advertising networks. To the extent that these practices qualify as “sales” under the CCPA, you may have the right to opt out as described above. Please see the Online Activity Tracking and Your Choices About Online Ads sections above for more information about the choices and opt-out options you may have in relation to those practices.

Authorized Agents. In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this section where we can verify the authorized agent’s authority to act on your behalf by:

i. For requests to know or delete personal information:

• Receiving a power of attorney valid under the laws of California from you or your authorized agent; or
• Receiving sufficient evidence to show that you have:
  • provided the authorized agent signed permission to act on your behalf;
  • verified your own identity directly with us pursuant to the instructions set forth in this section; and
  • directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

ii. For requests to opt-out of personal information “sales”: receiving a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Minors.  We do not sell the personal information of consumers we know to be less than 16 years of age without affirmative authorization from the minor or the minor’s parent or guardian.  Please contact us at [email protected] to inform us if you, or your minor child, are under the age of 16.

California’s “Shine the Light” Law.  California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes.  To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please email us at [email protected] and provide your contact information to be added to our suppression list.

Contact Information

If you have any questions or complaints about this Privacy Policy, the information we collect, or how we use that information please contact us at [email protected] or by writing to us at the following address:

China Telecom do Brasil Ltda
607 Herndon Parkway, Suite 201
Herndon, VA 20170

Changes to the Policy

We reserve the right to modify this Privacy Policy as we update our websites and/or our services, or as required by changing legal requirements.  We will post any changes to our Privacy Policy on our website.