John R. Guzzo LLC dba Hudson Valley Wireless (“HVW,” “we,” “our,” or “us”) understands that residential and business subscribers, visitors and users (collectively, “Subscribers,” “you,” or “your”) care about your personally identifiable information (“Personal Information”). (We may use the term users separately from Subscribers, where appropriate.) HVW takes Subscribers’ privacy seriously. Our Privacy Policy explains how we collect, use, disclose, and dispose of your Personal Information through the HVW website (the “Site”) and any of our services, including broadband Internet access services, voice over IP services, and other related services purchased by you (collectively, the “Services”). This Privacy Policy together with HVW’s Master Services Agreement, NITRO Services Confirmation of Sale, Dedicated Internet Service Level Agreement, Transport Service Level Agreement, Carrier / Wholesale Agreement, Code of Conduct (also known as an “Acceptable Use Policy”), Supported Applications Statement, Antivirus Policy, DMCA Copyright Infringement Notification Policy, and Open Internet Compliance Statement (collectively, “Service Agreements”) govern your use of the Site and Services and our collection, use, disclosure, and disposal of your information.

By using or accessing our Site and Services in any manner, Subscriber acknowledges that Subscriber accepts the practices and policies outlined in this Privacy Policy. If you disagree with the way we collect, use, disclose, and dispose of Personal Information, do not use the Site or any of the Services.

Any capitalized terms not defined in this Privacy Policy will have the same meaning as defined in our Service Agreements.

Your California Privacy Rights

Generally, California residents are entitled by law to ask HVW for a notice identifying the categories of Personal Information that HVW shared with its Affiliates and/or other third parties for their marketing purposes the preceding year and provide contact information for such Affiliates and/or third parties unless HVW meets certain exceptions in the law. This Privacy Policy and Site meet those exceptions. Therefore, if Subscriber resides in California and Subscriber has an established business relationship with HVW, Subscriber may request information about HVW’s opt-out and out-in policies of sharing Subscriber Personal Information with other companies (including our Affiliates) for their marketing purposes. Please send Subscriber’s written request via email or postal mail following the instructions below. HVW will not accept requests via the telephone or facsimile or respond to requests that are not labeled or sent properly, or do not have complete information.

• For all requests, include Subscriber’s full name, street address, city, state and zip code.

• In an email request, Subscriber must state “Re: Your California Privacy Rights” in the subject line and send Subscriber email to privacy@hvwisp.com .

• In a postal request, Subscriber must send a letter or post card to:

Hudson Valley Wireless
11 Cannon Street GReen Island, NY 12183

Attention: Your California Privacy Rights

General Information

HVW’s Site and Services are designed and targeted to United States audiences and are governed by and operated in accordance with the laws of the U.S. If Subscriber is not a U.S. citizen or does not reside in the U.S., Subscriber voluntarily consents to the collection, transfer, use, disclosure and retention of Subscriber Personal Information in the U.S. Subscriber also agrees to waive any claims that may arise under Subscriber’s own national laws.

When Subscriber uses the Site and Services, the Personal Information Subscriber sends and receives is transmitted over wired and wireless networks and may be subject to interception by unauthorized third parties who seek to do you harm. While it is HVW’s objective to take reasonable measures to reduce the risk that unauthorized third parties will be able to intercept the information Subscriber sends and receives through the Site and Services, HVW cannot and does not make any guarantee that transmissions over the Internet are 100% secure or error-free.

HVW does not knowingly collect, solicit or use Personal Information from anyone under the age of 13. If Subscriber is under age 13, please do not attempt to register for the Services or send any Personal Information about yourself to HVW. If HVW learns that we have collected Personal Information from a child under the age of 13, we will delete that information as quickly as possible to the extent technically feasible. If you believe that your child under age 13 may have provided HVW Personal Information, please contact HVW at privacy@hvwisp.com.

What Information does HVW collect and how does HVW use this Information?

Generally, HVW collects and uses Personal Information internally in connection with providing the Site and Services to Subscriber, including to personalize, evaluate and improve the Site and Services, to contact Subscriber, to respond to and fulfill Subscriber requests, and to analyze how Subscriber uses the Site and Services.

HVW collects and uses various types of information about Subscribers and Subscribers’ use of the Site and Services via various features and registration pages, Help Desk and call centers, postal mail, remote kiosks, the HVW Facebook Page or other social network platforms, or by other means. Such information is generally classified as Personal Information or Non-Personal Information.

Personal Information

Personal Information is the information Subscriber provides to HVW voluntarily or passively through Subscriber use of the Site and/or Services, and information which is directly associated with or reasonably linked to a specific person, computer or device. For example, we collect and use Personal Information through the registration process, when the equipment to provide the Service is installed, maintained or upgraded at Subscriber’s premises, and when Subscriber contacts HVW regarding the Site or Services. Through Subscriber account settings, HVW collects and uses Personal Information such as Subscriber name, email address, landline and/or wireless telephone number, postal address, billing address (if different) and billing information (such as credit/debit card account number or other financial account information), service address, and the nature of any of Subscriber devices or other property making use of the Services. Personal Information also includes Subscriber [customer] proprietary network information (“CPNI”) which is collected and used to provide VoIP services to you. CPNI includes any information that relates to the quantity, technical configuration, type, destination, location, and amount of use of our VoIP service, such as call detail, logs, and specifics regarding your VoIP account. Subscriber may be required to provide certain Personal Information to assist HVW in improving Subscriber’s Service or troubleshooting problems Subscriber is experiencing with the Site or Service, Subscriber computer or device, or otherwise to improve the quality of the Services.

HVW will communicate with Subscriber if Subscriber has provided HVW the means to do so such as submission of a Subscriber’s postal address, email address or phone number. HVW will mail, email, call or text Subscriber about Subscriber’s use of the Services or product improvements or upgrades, and other transactional information about Subscriber’s service.

HVW may also combine Personal Information with additional data obtained from HVW’s Facebook Pages or other social network platforms, its Affiliates, and its agents, representatives and contractors (third party owned companies that provide or perform services on HVW’s behalf, to help serve Subscribers better and to perform functions in order to support HVW’s businesses and operations), or other companies, such as credit bureaus, background check firms, and marketing research companies.

Some forms of Non-Personal Information as described below will be classified as Personal Information if required by applicable law or when such information is directly associated with or reasonably linked to a specific person, computer or device, or is combined with other forms of Personal Information.

Non-Personal Information
Website Information, Use of Cookies and other Similar Tracking Technology

When you visit HVW’s Site, HVW will collect various types of Non-Personal Information, such as information on HVW server logs from Subscriber’s browser or device, which may include Subscriber IP Address, unique device identifier, “cookie” information, the type of browser and/or device you are using to access the Services, and the page or feature Subscriber requested. (IP Address and device identifiers are traditionally classified as Non-Personal Information, unless HVW is required to do so otherwise under applicable law.) “Cookies,” “web beacons” are text file identifiers HVW transfers to Subscriber’s browser or device that allow HVW to recognize Subscriber’s browser or device and tell HVW how and when pages and features on the HVW Site are visited, by how many people, and other activity on the Site. HVW also uses cookies and web beacons to serve advertising to its Subscribers on its Site and on third party websites. Subscribers can delete cookies used for advertising.

Subscribers can change the preferences on Subscriber’s browser or device to prevent or limit Subscriber’s device’s acceptance of cookies, web beacons or other similar technology, but this may prevent Subscribers from taking advantage of some of the features on the HVW Site, or accessing certain functions and conveniences. This Privacy Policy does not cover the use of cookies or other such tracking technology by any third parties, and HVW is not responsible for their privacy policies and practices.

HVW also uses Personal Information and Non-Personal Information to enhance the HVW Site and Services: such as how often visitors use a particular feature or activity; which products and services are most interesting to current and potential Subscribers; ways to make the Site useful and interesting to as many Subscribers as possible; and to enhance and refine HVW’s Services. HVW will continue to conduct analytics on HVW Site and Services performance. Subscribers may not opt-out of this use of cookies, Personal Information and Non-Personal Information.

Technology is improving every day and to improve HVW’s operations and functions HVW may introduce new technologies and monitoring techniques without advance notice or consent from Subscriber.

HVW may also use third party providers to conduct such internal functions and analyses.(518) 963-4287 x4

Network Information
HVW also collects and uses HVW Network Information, information about Subscriber access to, and use of, the HVW Network, which may or may not be directly associated with or reasonably linked to a specific person, computer or device. For example, HVW may collect use information about the performance of the our equipment installed on Subscriber property or at Subscriber premises, when Subscriber is using the Services, the various devices Subscriber is using to access the Services, the amount of data Subscriber is transmitting and receiving, the content of the data Subscriber are transmitting and receiving, the websites Subscriber is visiting, and any other information that is transmitted over the HVW Network. HVW may also aggregate HVW Network Information from multiple Subscribers and share such aggregated Non-Personal information about the overall performance of the HVW Services and HVW Network with our Affiliates and other third parties. Aggregated information does not identify a specific individual, computer or device.