Wireless Zone^® Data Protection and Privacy Policy

INTRODUCTION
Automotive Technologies, Inc. (“ATI”) does business under the name Wireless Zone® and other trade names and trademarks, operating through independently owned, franchised and licensed retail locations. ATI, as well as its independent franchisees, licensees and affiliates, are called the “ATI Group,” and are sometimes referred to using the words “we,” “us,” or “our.” Verizon Wireless, and such other carriers as may offer or sell services through the ATI Group in certain locations and from time to time, are called “carriers.”

ATI takes data protection and privacy concerns very seriously. ATI recognizes the importance of protecting the privacy of the Personal Information of employees of the ATI Group, including employees of franchisees and licensees within the ATI Group, and of retail customers. Our Data Protection and Privacy Policy (the “Policy”), and the principles set forth herein, reflect ATI’s commitment to data protection and maintaining the privacy of Personal Information.

ATI does not directly control the data protection and privacy policies of its franchisees and licensees, or the collection and use of Personal Information by franchisees and licensees, but does require that each franchisee and licensee establish a privacy policy and procedures that meet the standards established by this Policy and the Data Protection Procedures promulgated by ATI, and the requirements of law, as in effect from time to time.

WEBSITE PRIVACY POLICY, LEGAL NOTICE, AND DISCLAIMERS
ATI has adopted a Website Privacy Policy that governs the types of information the ATI Group obtains about visitors to its website at www.wirelesszone.com and linked sites, how the information is obtained, how it is used, how long it is retained and how its use or disclosure can be restricted. This policy can be found at: http://www.wirelesszone.com/privacy.php. Additionally, ATI provides a Legal Notice and Disclaimers relating to the use of its website, located at: http://www.wirelesszone.com/disclaimer.php. You should read the Website Privacy Policy and Legal Notice and Disclaimers carefully before using ATI’s website.

DEFINITIONS
When used in this Policy, the following words and phrases have the meanings described below:

Personal Information means an individual’s first name and last name, or first initial and last name, in combination with any one or more of the following identifiers or data elements that relate to such individual:

• social security number
• driver’s license number
• state-issued identification card number
• financial account number
• credit or debit card number (with or without security code, access code, or PIN)
• alien registration number
• health insurance identification number

Personal Information also means information containing one or more of the above identifiers if it is capable of being associated with a particular individual.  Information that is lawfully obtained from publicly available information, or from federal, state, or local government records, is not Personal Information. 

Consumer Proprietary Network Information is information created by virtue of your relationship with Verizon Wireless or another carrier, and may include such information as the services purchased, related local and toll billing information, and the type, destination, technical configuration, location, and amount of use of purchased services (“CPNI”).  CPNI may include Personal Information and, to the extent that it does, is covered by this Policy.  CPNI that does not constitute Personal Information will be treated in accordance with the requirements of Verizon Wireless or other applicable carrier. 

PRIVACY PRINCIPLES
The following Principles apply to our use of Personal Information.  Included is an explanation of each Principle, together with some examples of how it is applied.  These examples are for illustration purposes only, and are not comprehensive.

The Principles may change over time.  We will revise and update them from time to time as necessary to reflect changes to our practices, or to meet the changing requirements of law.

How we obtain your Personal Information.

We may obtain Personal Information in a number of ways.  For example, we may obtain Personal Information in connection with your application for employment, or employment with ATI or a member of the ATI Group.  We may obtain Personal Information in connection with your purchase of goods or services online, or through a member of the ATI Group, including information required to be collected by our carriers in their application, customer agreement or otherwise in connection with your purchase of goods or services through the carriers.  We may ask you questions to better serve your special needs and interests.  For example, we may ask whether you work at home, and for information about members of your household in order to determine whether you may be interested in certain services.  We may obtain Personal Information in connection with your visiting our website (see our Website Privacy Policy, Legal Notices and Disclaimers, above).  We comply with laws relating to consumer information gathering and contact, such as the Federal Telephone Consumer Protection Act, and the Controlling the Assault of Non-Solicited Pornography and Marketing (“CAN-SPAM”) Act.

We Collect Personal Information with Appropriate Notice and Consent.

ATI will collect Personal Information with the knowledge and consent of the individual.  The type of notice or consent required will depend upon the context and the circumstances, and sensitivity of the Personal Information, the individual’s reasonable expectations, and the requirements of law.  Generally, by voluntarily providing us with Personal Information, you are communicating your consent to our collection, use, and disclosure of such Personal Information in accordance with this Policy and the terms of any carrier contract, or other agreement you have signed.  Where required by law, we will notify you of disclosures of your Personal Information to third parties.

How we use your Personal Information.

We will use your Personal Information lawfully, and for specific, limited, and legitimate purposes.  For example, information concerning employees of ATI or members of the ATI Group will be used in connection with the employment application process, for purposes of compensation, and other employment-related matters.  Information about customers will be used lawfully and in accordance with the requirements of the carriers.  The carrier customer agreements contain disclosures about Personal Information that is required to be protected under federal law, how and when such information is used, when it may be disclosed, and the ways you can restrict how it is used or disclosed.  We will observe all of the requirements described in the carrier customer agreements.  The carriers may also include information about the privacy implications of individual products and services in the terms and conditions for those products and services.  These terms and conditions typically are found in the printed brochures for particular products or services, or sometimes you may view them on their websites, or electronically the first time you use the products or services.

We may use Personal Information to protect customers, employees, and property against fraud, theft, or abuse, to conduct industry or consumer surveys, for internal management purposes within the ATI Group, and to maintain good customer relations.

We Limit Disclosure of Personal Information to Third Parties.

We will share your Personal Information with persons or entities outside the ATI Group only when you have consented, except when we share such information as required by law or to protect the safety of persons or property, and except when we share such information with our carriers, vendors, suppliers, or other companies that also provide service to you, and who will use it to provide, support and market products and services to you.  As an example, we will share Personal Information we collect from you when you apply for carrier service with the carrier and its authorized persons.  You should consult the data privacy policy of the carrier for further information about how they treat Personal Information.  As another example, we may share Personal Information in response to a subpoena or other legal request, or with law enforcement agencies, as required by law.

We are Committed to Data Security and Protection of Personal Information.

We have appropriate physical, electronic, and procedural safeguards to protect and secure your Personal Information, and will implement reasonable administrative, physical, and technological security measures to protect Personal Information from loss, misuse, unauthorized access or disclosure.  We will provide a level of security appropriate to the risks and the sensitivity of the Personal Information.  We will provide reasonable procedures for secure destruction of Personal Information that is no longer required.  For more specific information about ATI’s data security in connection with its website, please go to: http://www.wirelesszone.com/privacy.php.  When handling credit card information, we comply with the requirements of law, and the Payment Card Industry Data Security Standards.

You can Control your Personal Information.

You may control how we use your personally identifiable information to introduce you to new products and services.  To learn more, please send an email to:  privacy@wirelesszone.com, or contact us at the address and phone number listed at the end of this Policy.

We Strive to Ensure the Accuracy of Your Personal Information.

We are committed to ensuring that the Personal Information about you that we have in our possession is accurate.  To that end, we strive to verify that our customer records are correct.  If you find an error in your Personal Information, please notify us so we can correct it, by sending an email to: privacy@wirelesszone.com, or contacting us at the address and phone number listed at the end of this Policy.

How we Implement our Policy.

ATI has developed Data Protection Procedures, which are incorporated into its Employee Handbook, which is provided to all employees of ATI, and into its Operations Manual, which is provided to all franchisees.  The Procedures contain details of ATI’s requirements for protection of Personal Information and other data privacy matters.  Our employee and franchisee training programs include information about the responsibilities of our employees, franchisees, and their employees with respect to Personal Information and data privacy and protection.  We encourage our employees, franchisees, licensees and their employees to be proactive in implementing and enforcing these Principles, and we require our franchisees and licensees and their employees to comply with all applicable laws and regulations relating to the protection of Personal Information.  If employees become aware of practices that raise privacy concerns, they are encouraged to report them to their supervisors. Data security breaches and certain related circumstances must be reported immediately.  We expect ATI’s employees, and its franchisees and licensees and their employees, as well as vendors, consultants, agents, affiliates, suppliers, and contractors, to observe these Principles and the Data Protection Procedures with respect to Personal Information.  They will be held accountable for their actions.  

What Happens in the Event of Breach of Security. 

The question of whether a breach of security relating to Personal Information has occurred is determined with reference to applicable federal and state law.  If ATI determines that a breach requiring notice to any party has occurred, it will promptly provide such notice in accordance with law.

Questions about this Policy

If you have questions or comments about this policy, please send an email to privacy@wirelesszone.com.  You may also contact our corporate headquarters at:

Automotive Technologies, Inc.
Attention: Legal Department
34 Industrial Park Place
Middletown, Connecticut 06457

Phone: 860-632-9494, extension 8271
Fax: 860-613-0041

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