General Privacy Statement
Policy Revised Fall 1999
•• Items of interest have been highlighted ••
WebTV Network Statement of Privacy Your privacy is important to us. At WebTV Networks, Inc. (WNI), we are committed to maintaining the privacy and accuracy of your personal information and to protecting such information from loss, misuse and unauthorized access and disclosure.
This Statement of Privacy describes how WNI treats information received about you when you become a subscriber to the WebTV Network service, when you provide information to us, and when you use the WebTV Network service. This statement addresses the following:
Collection and use of Personal Information
With whom Personal Information is shared
How to access and modify Personal Information
How we safeguard children's privacy
Collection and use of Operating Information
With whom Operating Information is shared
How Personal and Operating Information is protected
Other Situations in which Personal and/or Operating Information May Be Disclosed
Please read this Statement of Privacy carefully. Questions regarding this statement should be directed to us as indicated at the end of this statement.
Collection and Use of Personal Information
When you register as a primary user of the WebTV Network service, WNI will request information that personally identifies you or allows us to contact you. On the WebTV Network service, this information is your name, home address, phone number, e-mail address, and credit card number ("Personal Information"). Any such information collected from Secondary Users is treated as the Personal Information only of the Primary User (Primary and Secondary Users are discussed in the WebTV Networks Terms of Service). Personal Information is also collected at other times by specifically requesting it from you, such as when you order premium services, when you request other promotional material, when we ask you to complete customer surveys, and in other circumstances when you interact with the WebTV Network service or our employees, agents and contractors working to provide the WebTV Network service to you.
WNI collects, stores and processes Personal Information for the following purposes:
To service accounts, process or collect payments, and otherwise operate and deliver the WebTV Network service.
To assist with questions about membership, billing, or use of the WebTV Network service or the Internet.
To conduct both business and individual surveys to be used for the purposes set forth in the survey.
To alert you to new products, product upgrades, special offers and other information related to the WebTV Network service.
With Whom Personal Information Is Shared
WNI may share your Personal Information with third parties for their use to provide services to WNI in the operation and delivery of the WebTV Network service, such as to process or collect payments, service WebTV Network accounts, or provide the products and services associated with the WebTV Network service. All such third parties are prohibited from use of such Personal Information except to provide such services to WebTV, and they are also required to maintain the confidentiality of such Personal Information.
Occasionally WNI may select third parties to send you information or special offerings about products or services that we believe may be of interest to you. WNI also may forward some Personal Information (name, home and e-mail addresses, and phone number) to the equipment supplier that manufactured your WebTV Network unit. WNI will share Personal Information for these purposes only with those third parties whose policies regarding Personal Information are consistent with our privacy policies or who agree to abide by our policies with respect to Personal Information. If you do not want WNI to send your Personal Information to third parties for these purposes, you may elect not to have this done ("opt out") by selecting Setup Sharing Personal Information
Except under the circumstances described above, or as described below under "Other Situations in which Personal and/or Operating Information May Be Disclosed," WNI does not disclose Personal Information to third parties.
How To Access and Modify Personal Information
You may access your WebTV Network account to review and, if necessary, modify your Personal Information. You may do so by selecting "Account" from the WebTV Network Web Home Page, and then selecting "Subscriber info," or by clicking here: Edit personal information.
How We Safeguard Children's Privacy
WNI currently does not knowingly collect or use Personal Information from children under 13, and WNI will not do so in the future without first obtaining verifiable consent from their parents. Should a child whom WNI knows to be under 13 send Personal Information to WNI, WNI will only use that information to respond directly to that child or seek parental consent. Parents are ultimately responsible for the use of the WebTV Network service by their children. WNI encourages parents to use a password to prevent inadvertent identification of your child to others or access to inappropriate materials by your child. WNI also encourages parents to talk to their children about safe and responsible use of their Personal Information while using the Internet.
Collection and Use of Operating Information
WNI collects and stores Operating Information, which consists of the electronic instructions and data communicated from your set-top device to the WebTV Network service. Operating Information includes the websites you have chosen to access and the television channels you have selected to view through the WebTV Network service.
WNI uses Operating Information to effectively operate the WebTV Network service and enhance your experience on the Internet. For example, WNI stores the websites that you have selected to be part of your list of favorite sites, so that you can access them quickly, and stores the most recent websites that you have visited to make browsing more efficient. Operating Information may also be used to customize the advertising, content, information and services that are delivered to your set top device.
WNI also uses Operating Information to understand how our system is being used and navigated. For example, WNI processes aggregated Operating Information concerning the amount of hits on certain websites, the use of certain features, such as "Mail," "Search," and "Explore," the number of set-top devices that are exposed to certain advertisements placed by advertisers on our system, and the number of set-top devices that are tuned in to certain television programming.
Understanding the use and navigation of the WebTV Network helps WNI in a number of ways. For example, collection and analysis of Operating Information helps us track traffic volume for revenue reporting purposes, evaluate the popularity of certain television programs for advertising purposes, and measure the costs of providing certain features and programs to ensure our pricing and business models are appropriately aligned with usage patterns. In addition, WNI uses Operating Information to improve connections to popular websites, enhance the selection of interactive television programming, and ensure the technical success of interactive television features. In general, the collection and use of Operating Information allows WNI to analyze the use of the WebTV Network to continue to develop and provide improved advertising, content, features and services that are of the most interest to our subscribers.
With Whom Operating Information Is Shared
WNI may provide Operating Information to third parties for their use to provide services to WNI in the operation and delivery of the WebTV Network service. All such third parties are prohibited from use of such Operating Information except to provide such services to WNI, and they are also required to maintain the confidentiality of such Operating Information. Operating Information that includes the websites you have chosen to access or the television channels you have selected to view through the WebTV Network service is not provided to any such third party.
WNI may also provide Operating Information in aggregate form to third parties. This aggregate information contains no Personal Information about any of our individual subscribers. It simply describes on an aggregate level how our subscribers are using the WebTV Network service. Except under the circumstances described above, or as described below under "Other Situations in which Personal and/or Operating Information May Be Disclosed," WNI will only share Operating Information with third parties if the Operating Information is in aggregate form and is disclosed in a manner that does not otherwise identify individual subscribers to the third parties.
WNI is sensitive to the concerns some of our subscribers may have with respect to the use of Operating Information containing the television channels selected for viewing through the WebTV Network service, even when such use is in aggregate form. If you do not want WNI to collect or store the television channels you have selected to view through the WebTV Network service, you may elect not to have this done ("opt out") by selecting TV data collection opt-out.
How Personal and Operating Information Is Protected
WNI takes reasonable steps to protect Personal and Operating Information. WNI uses technologies and processes such as encryption, access control procedures, network firewalls and physical security. These technologies and methods increase the security and privacy of information traveling to, from and within the WebTV Network.
WNI also safeguards Personal and Operating Information from unauthorized access. Most Operating Information is maintained in databases that are separate from those containing Personal Information, and only authorized WNI employees or agents carrying out permitted business functions are permitted to access Personal or Operating Information. Employees who violate WNI's privacy access policies are subject to disciplinary actions, including termination when appropriate.
WNI urges you to use a password to protect your account from unauthorized access by others. If you do allow others, including family or household members, to access the WebTV Network service through your account, including Secondary Users or other members of your household, please understand that you are responsible for the actions of those individuals.
Other Situations in which Personal and/or Operating Information May Be Disclosed
WNI may disclose Personal Information and/or Operating Information if required to do so by law or in the good-faith belief that such action is necessary or appropriate to (a) conform to the edicts of the law or comply with legal process served on WNI, (b) protect and defend the rights or property of WNI, the WebTV Network or the users of the WebTV Network service, whether or not required to do so by law, or (c) protect the personal safety of users of the WebTV Network service or the public. WNI reserves the right to contact and disclose Personal Information to appropriate authorities at its discretion when it appears that activities which are illegal or violate the WebTV Network Terms of Service are taking place within the context of a user account.
Changes To The WebTV Network Service Statement of Privacy
WNI may make changes to this statement from time to time. We will post changes to our privacy statement here, so be sure to check back periodically. We may also notify you of significant changes by e-mail or in other ways.
Questions, Comments, Concerns
If you have any questions or comments about our use of Personal Information or about this Statement of Privacy, please contact us at firstname.lastname@example.org. WNI will use reasonable efforts to promptly investigate any complaint you may have regarding our use of Personal Information and to comply fully with the legal and regulatory supervisory authorities responsible for enforcing our adherence to the privacy principles stated above.