Updated November 29, 2022
Hamilton Relay, Inc. (“we” or “us”) is committed to protecting the privacy of our customers. This privacy policy is designed to inform you about how we treat the information of customers of the various Telecommunications Relay Services we offer, as well as how we treat information obtained through the Hamilton Relay website and mobile apps.
What Information We Collect and How We Collect It
We may collect information about you and your use of our products and services as well as visits to our websites and mobile apps.
Information You Provide to Us
We collect information about you that you provide to us, such as your name and contact information, including when you provide it to us through our website or mobile apps. In order to register for relay services for which the Federal Communications Commission (“FCC”) requires registration, we will ask you to provide certain information to us, including your name, your date of birth, the last four digits of your social security number (or equivalent, if applicable), your street address, your telephone number, and your registered location information for emergency calling purposes. We may also maintain information provided by you, including your address and telephone number, in connection with call handling preferences as contained in your profile. FCC rules require that in certain cases we collect and maintain records about your eligibility to use certain relay services that may include self-certification from you, or third party certifications from approved professionals.
Information About Your Use of Our Services
We also collect information about how you use our relay services. This information includes customer proprietary network information (“CPNI”), such as information about who you call. As noted below, FCC rules provide you certain rights with respect to access, use, and disclosure of your CPNI.
Confidentiality of Calls Made Using Relay Services
In compliance with federal law, all calls made using the services are treated by Hamilton as confidential. Communication Assistants are required to abide by applicable TRS laws and regulations. By using the Service, you consent to the collection, storage, disclosure, and use of your personal information in accordance with applicable law, and you agree to the transmission of the incoming audio portion of your telephone call audio to Hamilton or our Communications Assistants and ASR platform, and you waive any rights you may have under applicable law restricting the same. The content of a call is collected only to transcribe speech into text, either by a Communication Assistant or by speech-to-text recognition software, and is not retained after termination of the call. When calling 911, your phone number, location, and other information may be transmitted to local emergency service providers. Such information may also be provided to law enforcement and other public safety officials in order to assist them with respect to your call for emergency services.
Information As You Visit Our Website and Mobile Apps
We may collect certain information about your computer or device when you visit our website or use our mobile apps, such as the domain name, IP address, browser, type of computer operating system, information about the web page that brought you to our site or app, time spent on different pages within the site or app, and/or location. We may use cookies and other tracking mechanisms to collect information about how you use our website and apps. A cookie is a small data string that our server requests that your browser store and that contains a unique user ID. Cookies are used to deliver web content specific to your interests. The cookie permits the server to recall information from your previous visit. With most web browsers, you can choose to change your settings to disable cookies. You may also decline Internet cookies by using the appropriate feature of your web client software. Please be aware, however, that cookies may be required to complete certain functions on the Hamilton Relay website and other Internet sites.
Our website also uses web analytics services that collect information about how visitors use our website. As an example of one such service we use, Google Analytics, provided by Google Inc., places a cookie on your web browser to identify you as a unique user and only Google can use the cookie. Google Analytics collects information only regarding the domain/IP address, or device identifier, of visitors to the sites. Our analytics services do not collect names or other identifying information and we do not combine the information collected through analytics with any personally identifiable information. Analytics services’ terms of use and privacy policies—such as the Google Analytics Terms of Use and the Google Privacy Policy—restrict the service providers' ability to use and share information collected by the analytics about visitors to the sites. You can prevent an analytics service from recognizing your return visits to the sites by disabling cookies on your browser or, in the case of Google, by installing the Google Analytics browser add-on.
Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to those signals. For more information regarding Do Not Track mechanisms, see http://allaboutdnt.com.
Information Provided to Us by Third Parties
At times, we may receive information about customers and prospective customers from third parties. For example, we may acquire mailing lists or lists of participants of conferences we attend or sponsor. We also may collect certain information about you through social media platforms, including when you engage with us through social media.
How We Use and Share the Information We Collect
We use the information that we collect to provide our services, to improve our services, and to promote the most helpful and targeted products and services to you in order to meet your needs as permitted by applicable law.
We may disclose information about you and how you use our services (1) with your permission; (2) as required by FCC regulations, including (i) your registered location information and other information to an emergency service provider when you make a 911 call, (ii) your registration information to the TRS User Registration Database or other FCC-mandated databases, and (iii) information about you and your service usage to the Administrator of the TRS Fund and/or the FCC for billing purposes or to respond to a customer complaint; (3) as otherwise required by law, including pursuant to a duly-served subpoena or other government request for information; (4) to investigate or defend against third-party claims or allegations; (5) to protect our rights, property, and personal safety, or that of our customers or others, (6) with an affiliated company when Hamilton is your default provider or with your permission; or (7) as part of any merger, acquisition, sale of company assets or transition of service to another provider.
In addition, we may share your information with partners and certain service providers that help us provide our services. When we share information in this manner, we contractually limit the use and disclosure of the information we share for the specific purpose for which we shared it.
We do not otherwise share our customers' personal information. We may, however, share anonymous or aggregate information with third parties for purposes that include improving how we provide service to existing and potential customers.
How We Protect Your Information
We use technical, administrative, and physical safeguards to protect the personal information we collect. Notwithstanding these efforts, we cannot guarantee that we can prevent every unauthorized attempt to access, use, or disclose customer information. We also cannot guarantee the confidentiality of any communication or information you provide.
We retain the personal information we collect only as long as we deem reasonably necessary for business, accounting, tax, legal or regulatory purposes.
Your Privacy Choices
We offer several choices regarding how we use and share your information.
You may limit our use and sharing of your individually identifiable CPNI to market relay-related services to you by updating your Communication Permissions within your profile, either via the web/mobile application or by calling or emailing us.
Telephone and Mail Solicitation
You can also opt out of receiving telephone or mail solicitation from us by updating your Communication Permissions within your profile, either via the web/mobile application or by calling or emailing us.
Updating Your Information
We encourage you to modify, correct, or update your profile information, either via the web/mobile application or by calling or emailing us.Children's Privacy
We do not knowingly collect personal information from individuals under the age of 18 without their parent's or guardian's verifiable consent. If registration is required for any services on our website or mobile apps, the child’s parent or guardian must complete such registration on behalf of the child and consent to use of the service by such child. Hamilton Relay does not provide any personally identifying information collected about children, regardless of its source, to any third party for any purpose whatsoever, except with a parent's or guardian's verifiable consent and as required by the FCC to provide relay, or otherwise required by law. In addition, Hamilton Relay does not use information collected through the website or mobile apps from users self-identified as children for any marketing or promotional purposes whatsoever, either inside or outside Hamilton Relay.
Links to Third-Party Websites and Content
We are not responsible for content or privacy policies of other third-party websites. We encourage you to review the privacy policies of such websites.
Updates to this Privacy Policy
We continually strive to improve the services we offer and may consequently update this privacy statement from time to time. We reserve the right to expand our capabilities for information collection and use and may change policies along with this privacy statement at any time. We also reserve the right to contact site visitors regarding account status and changes to the subscriber agreement, privacy policy, or any other policies or agreements relevant to site visitors.
Social Media Policy
We may post photos taken during community and corporate events to a Hamilton Facebook page or other internet page. As a general rule, we will not tag or otherwise identify individuals in photos unless those individuals have agreed to be identified. However, if you would like a photo removed from a social media post that we control, please send an email with the following detailed information to info@hamiltonrelay.com a link to where the photo is posted, your name, contact information, and the title of the image you wish to have removed.
Contacting Us
To learn more information about our information practices or exercise your rights under this privacy policy, please contact us:
By Phone: 800-618-4781
By Email: info@hamiltonrelay.com
Your California Privacy Rights
California law permits California residents to make the following requests of us regarding the personal information Hamilton Relay, Inc. (“we” or “us”) collects, uses, discloses and sells through the various Telecommunications Relay Services we offer, as well as through our website and mobile apps.
Direct Marketing
California residents may request certain information regarding our disclosure of personal information to third parties for such parties’ direct marketing purposes. We, however, do not share personal information with third parties for their direct marketing purposes.
Access
California residents may request the categories of personal information we have collected about them, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information, and the specific pieces of personal information we have collected about them. The types of personal information we have collected about consumers in the past 12 months include:
We share this information with business partners and service providers that help us deliver and market our services to our users. We also share certain of this information with the FCC, the TRS User Registration Database or other FCC-mandated databases, and the TRS Fund Administrator, as required by law.
Correction
California residents may request that we correct inaccurate personal information we have collected about the consumer. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Deletion
California residents may request that a business delete personal information the business has collected from the consumer.
Sharing of Information
California residents have the right to request the categories of personal information that we have collected about them, the categories of personal information that we have sold about them and the categories of third parties to whom that information was sold, and the categories of personal information that we disclosed about them for a business purpose. We, however, do not sell personal information, and therefore have not sold personal information in the last 12 months.
The types of personal information about consumers we have disclosed for a business purpose (e.g., to provide and market services) in the last 12 months include:
We share your location information with Public Safety Answering Points when you call 911.
Please note that by using our CapTel services, you also engage and intentionally interact with CapTel, Inc., without whose services your service and your CapTel device would not properly function. Thus, you direct us to disclose your personal information to CapTel, Inc. in connection with its provision of services to you. CapTel, Inc. uses your personal information according to its privacy policy, and you understand that we do not control and are not responsible for its policies.
Opt-Out of Sale of Personal Information
California residents have the right to opt out of the sale of their personal information. We, however, do not sell personal information.
Notice of Non-Discrimination
Exercising any of these rights will not result in us engaging in prohibited discrimination against California residents, including, for example, denying services to them.
How to Make a Request
To make a request pursuant to one or more of the rights described above, please email us at info@hamiltonrelay.com or call us at 800-618-4781. Please note that we may need to reasonably verify any request before we can fulfill it, including those submitted by your authorized agent. To do so, we may need certain information from you, including, for example, username, address, telephone number, email address, or your device's electronic serial number (ESN). In addition, please note that certain exceptions and limitations apply, including how frequently we need to honor requests.