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Privacy Policy of Level 3 Communications, Inc. and its group companies, including Level 3 Communications, LLC, Global Crossing Telecommunications, Inc., Global Crossing North America Inc., Level 3 Communications Limited, Level 3 Communications UK Limited and other affiliated Level 3 and Global Crossing entities (referred to throughout as ‘Level 3’, ‘we’ or ‘us’).

We are committed to protecting the privacy of individuals. This Privacy Policy sets out our practices regarding personally identifiable information we collect from you, or that you provide to us, via our websites or our audio, conferencing and on-line services, as described herein.


Introduction

This Privacy Policy explains:

•  How we collect information about you when you use our services
•  What information we collect about you
•  How we may use and share that information
•  How you can update or access any personal information we hold about you

Please read this Privacy Policy in conjunction with the applicable general terms & conditions and any other service specific terms and conditions (however styled) applicable to the services provided to you.


What do we mean by the term Personal Identifiable Information?

When we refer to the term ‘personally identifiable information’, we mean information that can identify you as an individual or is capable of doing so with other information that we may hold about you now or in the future.  The term does not include any statistical, aggregated or anonymized information.


What information do we collect about you?

We may collect and process the following personally identifiable information about you:

•  Information which you may submit to us including your name, address, telephone number and email address. This includes information provided at the time of registering to use our website and/or any of our services, subscribing to our services (including services not provided solely via our websites), posting material or requesting further services. Such information includes verification details that you provide to us in order to access and use specific features of our services, such as verification details provided to us in order to access our conferencing, audio or online services. This will include any verification details which you provide in order to access, download or play taped records.
•  Debit/credit card information, banking details and any other relevant payment information necessary for us to process your order or to manage your service.
•  Where you are an existing customer, additional information which your company has provided – such as your company's name and address, your employee ID, or your email short name/address.
•  If you contact us by phone, email or otherwise, a record of that communication.
•  Any surveys you complete that are used for research purposes.
•  Details of transactions you carry out through the websites and the fulfillment of your orders for our services.
•  Details of your visits to our websites including, but not limited to, traffic data, location data, weblogs and other communication data.
•  Information about the type, quantity, configuration, destination, location and amount of use of telecommunications services you currently purchase, how you use those services, and related billing information and end user information for those services. This information is collected in the normal course of providing telecommunications services to our customers, and is commonly referred to as customer proprietary network information, or "CPNI". CPNI is discussed in detail below.

The submission of your personally identifiable information constitutes your acknowledgment that you have read and understood this Privacy Policy and agree to its terms. You also acknowledge and consent to our collection, storage, and processing of such personally identifiable information.


How do we use your personally identifiable information?

We take the privacy of our customers and suppliers seriously and respect your right to privacy.  Because of our commitment to protecting your privacy, personally identifiable information will be collected, processed, stored, and disposed of in accordance with this Privacy Policy.

We process your personally identifiable information for a number of purposes in order to:

•  provide you with access to our websites
•  process your order(s)
•  supply you with our products and services (including processing any payment information for such products and services)
•  process such information for billing and administration purposes
•  analyze how you use our websites, products and services on a personalized or aggregated basis to gather broad demographic information, interests, and behavior so that we may better understand you and can tailor our products and services in accordance with your preferences
•  process your IP address to help diagnose problems with our servers and administer our websites
•  inform you of any new promotions, products and services offered, improve the level of service and provide notifications regarding service changes or outages or in order to carry out market research
•  process any competitions or surveys that you have participated in
•  investigate any complaints or other enquiries you may submit for our attention
•  process any  job applications you may have made via our websites
•  disclose your information to selected third parties (see the section entitled ‘Who do we share your information with?’ below for further information)
•  obtain references from previous employers, credit or debt agencies or for the purposes of fraud or money laundering or crime detection and prevention

We may occasionally match or combine your personally identifiable information with personally identifiable information you have provided to other affiliate companies within our group in order to understand and improve the services we provide to you and to determine what other products, services or promotions may be of interest to you.

Where we process personally identifiable information in the course of our conferencing, audio or on-line services, this is done to allow us to provide the services which your company has asked us to provide, for example, by allowing us to create an authorized user ID for you, to allow you to use our services and by allowing us to provide billing and service usage information to your company.


Who do we share your information with?

We do not sell or disseminate personally identifiable information to third parties without your consent.

Unless we have your permission or are required by law, we only share your personally identifiable information with our affiliated group companies and to our selected business partners who act on our behalf in order to provide the services. We make every reasonable effort to ensure that such 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.

We may share non-personal, non-individual information in aggregate form with other companies within our group or to carefully selected third parties. Your personally identifiable information may also be accessible by third-party service providers to 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 must commit to complying with out instructions and to keep all personally identifiable information secure.  Notwithstanding other provisions of this Privacy Policy, we may disclose personally identifiable information and account information in special cases when it is necessary to identify, contact, or bring legal action against someone who may be violating any 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 also disclose personally identifiable information as necessary to collect for the charges related to the services we provide.

We reserve the right to disclose your personally identifiable information as explicitly set forth in this Privacy Policy or any user agreement agreed to by you, or as otherwise 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 disclose, assign, sell, license, or otherwise transfer to a third party, your name, address, e-mail address, member name and any other personally identifiable information in connection with an assignment, sale, joint venture, or other transfer or disposition of a portion or all of our assets or stock.


How long do we keep your information?

The length of time we keep your information for can vary according to how we use that 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.


Direct Marketing

We would like to keep you up to date with details of our products and services using the information that you have supplied. We will do this in accordance with applicable privacy laws and in accordance with any direct marketing permissions which were given when we collected information from you. If you would like to change these preferences, please contact the privacy@level3.com or speak to your Account Manager.


Transfers of your Information Outside of the European Economic Area (EEA)

We are a multinational group of companies and the information that we collect from you may be shared with Level 3 affiliate companies in locations around the world. All Level 3 entities comply with this Privacy Policy when they use personally identifiable information.

Users from the EEA should note that we may transfer personally identifiable information to countries outside of the EEA where we, or our subcontractors, may store and process it.  Some countries to which personally identifiable information may be transferred may not have data protection legislation equivalent to EEA legislation, however, we will take all steps reasonably necessary to ensure that all personally identifiable information is treated securely and in accordance with this Privacy Policy.



How to Review and Update your Information

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 the privacy@level3.com. Please note that in certain circumstances we may withhold access to your information where we have the right to do so under current data protection legislation.


Children's Privacy Protection

Our websites do not target and are not intended for 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.


Cookies

A cookie, also known as a browser cookie, is a text file containing small amounts of information which a server may download to your computer, mobile or tablet when you visit a website or use an app.

There are different types of cookies which are used to do different things, such as letting you navigate between different pages on a website efficiently, remembering preferences you have given and helping us to identify ways to improve your overall site experience.  Others are used to provide you with advertising which is more tailored to your interests or to measure the number of site visits and the most popular pages users visit.

Due to their core role of enhancing and enabling usability or site processes, disabling certain cookies may prevent you from using certain aspects of our website.

Broadly speaking, there are two different types of browser cookie:

1.  Session cookies – these types of cookies are stored in the computer’s memory during a user’s browsing session and are automatically deleted from the user’s computer when the browser is closed or the session is deemed to have ended.  These cookies usually store a session ID that is not personally identifiable to users, allowing the user to move from page to page without having to log-in repeatedly.  They are widely used by commercial websites; for example, to keep track of items that a user has added to a shopping basket.
2.  Persistent cookies – these types of cookies are stored on a user’s computer and are not deleted when the browser is closed.  Persistent cookies can be used to retain user preferences for a particular website, allowing those preferences to be used in future browsing sessions.  Persistent cookies usually assign a unique ID to the user’s browser and they are usually configured to identify a user for a prolonged period of time.

How does Level 3 use cookies?

We only use browser cookies to measure non-personal information, for example to learn about the behavior of visitors to our website, to remember your preferences and to ensure we serve the correct content to you whilst on our website.


What cookies does Level 3 use on this website?

The following classification of cookies used on our website is based on the International Chamber of Commerce guide for cookie categories:

Strictly necessary cookies
'Strictly necessary' cookies let you move around the website and use essential features such as ensuring that you connect to the right service on our website when we make any change to the way our website works. These cookies don't gather any information about you that could be used for marketing or remembering where you've been on the internet. Accepting these cookies is a condition of using this website as they are required for the proper operation of the website. If you prevent them, we cannot guarantee how our website will perform during your visit.

Performance cookies
We use these cookies to collect information about how visitors use our website, which parts of the website you like and what types of content you view. By using our website, you agree that we can place these types of cookies on your device. We use the information to improve our website and enhance our user experience.  All information these cookies collect is aggregated and therefore anonymous.

Functionality cookies
These cookies remember choices you make to improve your experience. By using the website, you agree that we can place these types of cookies on your device.

These cookies allow the website to remember choices you make (such as content preferences, language or the region you are in) and provide enhanced, more personalized features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.


How can you control the use of cookies?

Your use of this website constitutes your consent to this website setting cookies on your device.

If you do not want this website to set cookies on your device then you should not use this site and you should delete any cookies which have been placed on your device.  Alternatively, the ‘Help’ menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookies and how to disable cookies altogether.  However, because cookies allow you to take advantage of some of our website’s essential features, we recommend that you leave them turned on. 

Useful information about cookies can be found at:  http://www.allaboutcookies.org


Linked Internet Websites

Our websites may provide hyper-text links to other websites over which we have no control and which may contain privacy provisions that are difference from those provided herein. We are not responsible for and expressly disclaim any and all liability for the privacy policies or practices of other websites to which you choose to link from our websites. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your information.


Security

We have implemented reasonable technical and organizational measures designed to secure your personal 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 never be able to defeat those measures or use your personal information for improper purposes. Certain information may be transmitted to you by electronic mail. Although it may be illegal to intercept or disclose these messages, these transmissions are not secured.


Customer Proprietary Network Information (CPNI)

CPNI is information that we obtain when we provide telecommunications services to you, including services provided through your local telephone company. It includes the types of telecommunications services you purchase from us, how you use them, and the related billing information for those services. CPNI does not include your telephone number, name and address. CPNI also typically includes the type of information found on your bill, such as call details and the types of local, long distance and other telecommunications services that you have purchased. We have internal policies and safeguards designed to safeguard the privacy of CPNI and protect it from unauthorized access or improper use. In the normal course of providing telecommunications services, we collect and maintain CPNI to enable us to make more meaningful suggestions to you when discussing products and services, packages and promotions that best suit your communications needs. In the US, we are obliged to protect the confidentiality of your CPNI in accordance with federal and certain state laws. We do not sell, trade or share your CPNI, including your calling records with anyone outside of our group of companies or to third parties who perform functions on our behalf (such as billing functions) except as may be required by law or authorized by you. Generally, we are also permitted to use or disclose CPNI to offer telecommunications services of the same type that you already purchase from us. We may also use or disclose your CPNI for legal or regulatory reasons such as a court order, to investigate fraud or to protect against the unlawful use of our telecommunications network and services and to protect other users of our services and to collect bills.


Changes to this Privacy Policy

As we grow and new features are added to our website or to our products and services, or legal requirements change, this Privacy Policy may be modified. Any changes to the Privacy Policy will be posted on all our applicable websites. All information submitted through our websites is subject to the terms and conditions of this Privacy Policy, as amended.


Submission of personal details to us

Any personally identifiable information which you submit to us will be treated and processed by us only in accordance with this Privacy Policy. By submitting any such information, you consent to our holding and processing the information, both electronically and manually, for the expressed purpose. You also consent to the transfer, storage and processing of such information between our offices worldwide.


How to contact us

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 privacy@level3.com or by writing to us at either of the following addresses:

For UK, Europe, Middle East and Africa please contact: Data Protection Officer, Legal Department, Level 3 Communications, 7th Floor, 10 Fleet Place, London EC4M 7RB, United Kingdom.

For all other worldwide locations, please contact: Privacy Officer, Legal Department, Level 3 Communications, 1025 Eldorado Blvd, Broomfield, Colorado 80021, USA.

Policy Updated January 2014