PURPOSE
Telecomunicaciones de Puerto Rico, Inc., and its subsidiaries Puerto Rico Telephone Company, Inc. d/b/a “Claro” and/or “Claro Puerto Rico” and Coqui.Net, (hereinafter collectively referred to as “TELPRI”) are committed to maintaining the highest standards of ethical and legal conduct in the collection, use and disclosure of information about its customers and anyone visiting the Websites owned or operated by TELPRI or the social media accounts managed by TELPRI. The purpose of this Privacy Policy (“Policy”) is to inform our customers and users (as such terms are defined below) regarding the practices followed by TELPRI in relation to the type of information it collects, how and when said information is collected, used and disclosed and for how long it will be kept in the company’s records or systems and how customers and/or users can restrict the use or disclosure of the information that has been collected about them. This Policy applies only to information that is collected from customers and/or users in their capacity as customers and/or users.

SCOPE
This Policy constitutes the agreement on the collection, storage, management and disclosure of information between TELPRI and its customers and/or users. By accessing or using the Websites owned or operated by TELPRI, the social media accounts managed by TELPRI (as such terms are defined below), the customers and/or users agree, and consent to, the TELPRI practices described in this Policy and to the Term of Use adopted by TELPRI for them.

DEFINITIONS:
The following terms shall have the following definitions for purposes of this Policy.

• “App”: means any software app available on websites, Internet pages, or through the app markets of the various mobile operating systems (e.g. “App Store,” “Google Play” and Microsoft) and/or on mobile devices that is run or downloaded for a fee or free on smartphones, computers, tablets or any other equipment that allows users to access a variety of services, games and information.
  
• “Customer”: means any person who buys or uses TELPRI products or services or maintains an active account with TELPRI.
  
• “Social Media Account”: means the accounts or presence in social media managed by or on behalf of TELPRI in social media (including but not limited to: Claro Puerto Rico and Claro PR (Claro todo) on Facebook; Claro Instagram (Claro Todo); Claro Asistencia and @clarotodo on Twitter; and Claro Puerto Rico on You Tube) and any other accounts of this or a similar type.
  
• “Public Forums”: means those areas or services that may be offered by TELPRI to allow customers and/or users to publish or share information or another type of content that may be accessed or shared by or with other customers and/or users or third parties (including, but not limited to, discussion forums, comments, open sections and any other media known now and/or designed or known in the future that allows customers and/or users to provide information or other content so that it can be reviewed by other customers and/or users or by third parties).
  
• “Information”: means any kind of information and includes Personal Information and Non-Personal Information.
  
• “Personal Information”: means information that TELPRI associates directly with a customer or user, such as for example, name, address, telephone numbers, email address, social security number, service details, security codes, payment information, call logs and other similar information. Personal information does not include any other information that is not associated with a customer or a user, information posted on a commercial telephone directory or on the TELPRI social network websites.
  
• “Non-Personal Information”: means information that TELPRI obtains through cookies and other similar technologies on how customers and/or users use TELPRI products or services but which does not personally or individually identify the Customer or the user. Non-Personal Information does not include “Personal Information”.
  
• “Customer Proprietary Network Information” or “CPNI”: Means the customer information that is generated in TELPRI’s or a Voice over Internet Protocol or “VoIP” provider’s telecommunications network, regarding the services contracted with said companies. CPNI includes the call or text messaging detail record for all types of messages and in any format including but not limited to text messages (such as, among other information, for example, date, time, duration of the calls or text message and the recipient phone number for each call or each text message, information about the contracted service plans, the features the customer keeps active in their account for their contracted products or services. The ’CPNI does not include their name, address or their telephone number. The use and management of the CPNI is regulated by the Federal Communications Commission (“FCC”).
  
• “Websites”: means the websites or Internet pages owned or operated by TELPRI (including, but not limited to, www.claropr.com; www.coqui.net) Facebook, Claro.
  
• “User”: shall mean anyone who visits our Websites or social media accounts (as defined in this Policy) and/or uses our apps via smartphones, computers, tablets or any other equipment that allows access to a variety of services and information.
  

POLICY

• Information we collect:
  TELPRI collects a variety of information from its customers and its users. To this end, TELPRI may collect the following information on or about its customers and/or users (as applicable):
  • Personal Information
  • Non-Personal Information
  • Customer Proprietary Network Information or CPNI.
  • Equipment and Log Information - Information that TELPRI obtains from the fixed or mobile equipment, including, when the people who visit our Websites, as defined in this Policy, are in roaming or Wi-Fi mode, that somehow identifies the equipment (telephone number, serial number, model, OS version) and that they provide voluntarily and that is recorded in our servers.
  • Network Diagnostic and Performance Information: TELPRI may collect information about your equipment for diagnostic and performance analysis purposes and to determine the use you make of our network, including, when you access our network through roaming, via a Wi-Fi connection service or using a mobile device.
  • Location Information: TELPRI may collect information about the location of the equipment you use to access our Websites or when it is on, subject to coverage limitations. Some products installed on mobile telephone equipment, such as, but not limited to, signals from the Global Positioning System or “GPS,” the sensors in mobile devices and/or equipment, Wi-Fi connection access points and cell tower IDs may be used to infer or estimate a precise location. You may choose to switch off the location services of your equipment. Certain equipment and/or apps may also offer additional location control configurations.
  • Video Information: When you use a video app we may collect information about the apps you access or download to determine consumer habits and to adapt the video selections to our customers’ taste.
• How We Collect Information
  TELPRI collects information about you in several ways.

• Information provided by the customers and/or users: TELPRI may collect information that is voluntarily provided by the customer or user to request, use or purchase TELPRI products or services, or that they voluntarily provide when otherwise communicating with TELPRI. For example, TELPRI may collect information when a customer or user requests information about any TELPRI product or service, creates an account with TELPRI, buys music or downloads an app or when they submit a claim contesting any charges from their invoice.
  
• Information that is gathered automatically. The TELPRI Web network servers automatically recognize the domain name of the person who visits our Websites, such as for example, .com, .edu, .pr, etc., from which they access our Website, which pages they visit on our site and how long they spend on each page. The TELPRI systems also collect details about the type and location of the wireless devices that the customer or the user uses to access our Websites as well as other data and services that are generated by the use of said wireless device. For example, calls and text messages originated and received from the device.
  
• Cookies: The TELPRI Websites use cookies. Cookies are small files placed on the computer or device of the person visiting a Website either through the link itself or an app. Cookies are used to identify the computer or device of the visiting person and record their preferences and other data so that the visited sites may customize the view. Also, they let the TELPRI server recognize the computer or device and any parameter you have created on our Website. The cookie restores those settings so that you don’t have to retype the same information each time you visit our Websites. For example, if you wrote your zip code on a visit to our Website, when you return to the same site this information will appear without you having to re-enter the data. TELPRI would like to clarify the fact that just because its systems or servers recognize its customers’ and/or users’ computers or devices when it retrieves the cookies this does not mean TELPRI is actually acquiring information about such persons. You may configure your browser to delete the cookies or to warn you before accepting them.
  
• Do Not Track Signals. Do Not Track Signals is a mechanism which allows the consumer to choose not to have their Internet browsing tracked by third parties. You may configure your computer browser setting to activate the Do Not Track Signals preference to alert TELPRI that you don’t want your online activities to be tracked by third parties while visiting TELPRI’s Websites. While the Do Not Track preference is active, TELPRI will not track your on line activities.
  
• Monitoring tools, Web beacons or other similar types of technology. TELPRI can also use monitoring tools for Web pages (such as Web beacons or similar technology) to monitor the use of its Websites and to know where visitors come from and where they go after leaving our site. Web beacons are electronic files, also known as web bugs, pixel tags or gif, which are used to monitor user behavior on the Website and are commonly used in conjunction with cookies. For example, when a user accesses a browser it loads the image and certain non-personal user information is stored, such as for example, how long they stay on the page, the browser type, the Internet protocol address, among other information. TELPRI may use web beacons to count the number of people accessing its Websites. Although you can configure your browser to not accept or delete cookies, web beacons and other similar technology could detect the visits to our Websites but without collecting non-personal information collected through cookies. TELPRI does not monitor the customer’s and/or user’s activity on websites not belonging to TELPRI. TELPRI collects this information and uses it to evaluate, optimize and improve our Websites and to evaluate and improve the performance of our wireless devices.
  
• Voice Controlled Apps: To the extent that TELPRI has voice controlled apps available, and you use them TELPRI, it is possible that said app may collect and record your requirements and other information about you and your phone.
  
• Other sources: TELPRI may collect information from customers or users from other sources, either with their consent or through the acquisition of information collected by third parties. For example, receiving credit information about a customer regarding the hiring of a service with TELPRI, email lists or demographic or marketing data containing information about customers or users, among others.
  
• How We Use the Information We Collect
  TELPRI uses the information it collects from its customers or users for different purposes. The following is a description of the way TELPRI uses information collected from its customers or users for the following purposes:
  • Routing calls or sending text messages.
  • Provide or offer any TELPRI service or product.
  • Confirm the delivery of products and services purchased from TELPRI.
  • Send invoices and collect payments for services contracted with TELPRI.
  • Validate a customer’s identity when providing any service or technical support for a service contracted with TELPRI.
  • Create or modify our products and services.
  • Provide technical support and upgrade services for our network, products or services.
  • Provide you information regarding the user experience and inform you of interesting product and service offers.
  • Protect our rights, interests, security and property and those of our customers, users, service providers and other third parties.
  • Protect the integrity and security of our network, ensuring its quality control and optimization capability.
  • Prevent any misuse, illegal activity, suspected fraud or potential threats to our network.
  • Comply with the laws, regulations and any other applicable legal provision.
• Grouping of information: TELPRI may group non-personal information in anonymous categories used by TELPRI for statistical and operational control purposes. For example, in order to compare the behavior related to the use of mobile phones from customers and/or users in a specific geographic area (San Juan, Puerto Rico) with another (Mayagüez, Puerto Rico), TELPRI may transform non-personal information into information that can identify the customer or user and combine their data that meets certain criteria, such as the zip code, to understand the differences or similarities between both groups.
  
• Specific Purposes. When the users or customers who visit our Websites and/or social networks provide information about themselves for a specific purpose, TELPRI uses it for that purpose (for example, to provide information requested by the user). When the users or customers that visit our sites use them to request services or products or information about them, we may use the information the same way we would outside the Website. This, in order to evaluate your service needs and contact you about other services that may be of interest. However, the customer or user will always have the right to choose not to receive this information via an unsubscribe mechanism.

If you provide us with Personal Information in the context of an event sponsored by another company jointly with TELPRI, such as for example a competition, or if you register in a Website, social networks or feature with more than one sponsor you may also be providing such information to that sponsor. In such circumstances, the other sponsor’s privacy policy shall prevail so you should review it carefully. TELPRI regularly uses other contractors to provide services such as the management, design and hosting of its Websites and special promotions, but it does not use the user information except to provide the specific services on the TELPRI Websites.

• No Publication of Mobile Phone Numbers. TELPRI does not publish or provide the mobile phone numbers of its customers to third parties, without the customer’s consent, except as required by law or a court order.*
  
• Marketing. TELPRI may use the information it collects to communicate with the customers or users by telephone (calls or text messages) regarding TELPRI products, services and offers that we consider may be of interest. A customer or user may contact TELPRI at any time to opt out of receiving our marketing communications. TELPRI does not send unsolicited email or “SPAM”. For more information, access the FCC Regulations on the National Do-Not-Call Registry and the Controlling the Assault of Non-Solicited Pornography and Marketing Act (“CAN-SPAM-Act “)by accessing the www.fcc.gov/consumers link.

TELPRI offers a TELPRI opt-out or STOP feature in its email and text message campaigns, so that the TELPRI customers or users that receive them can opt-out of receiving further communications from TELPRI via email. If a customer or a user receives an unsolicited email message from TELPRI, they can simply opt-out of receiving future mailings.

• Advertisements:

It is possible for a user to see advertisements from TELPRI, from TELPRI advertisers or third parties, on their mobile device or when they visit our Websites, as defined in this Policy. Any third-party advertisement may place cookies or web beacons or any other similar technology in your equipment and collect anonymous information about your visit. TELPRI has no control over the information that third party advertisers may place on your equipment when.

Claro Puerto Rico can help its advertisers better communicate with its customers and may provide some of its advertisers certain non-personal information about customers or users to better target TELPRI’s advertising.

TELPRI also advertises on third party Websites or Websites belonging to other companies, so when publishing those advertisements, the privacy policy established by said companies and not this Privacy Policy shall apply.

• Prevention of Network Fraud and Abuse:
  TELPRI may use personal or proprietary information of the network, proprietary information of the customer or user or information about the network or equipment in order to prevent or investigate network and service fraud or abuse.

• Compliance with the Law:
  TELPRI does its utmost to protect the privacy of customer and user information. However, TELPRI may have to disclose personal information in those cases in which it is required by law, when there is a good faith certainty that such an action is necessary in order to comply with a governmental or judicial proceeding or when there is a governmental and/or judicial resolution and/or order.

• Links to other Websites:
  The TELPRI Websites and its Social Media Accounts contain links to other Websites and Social Media. TELPRI is not responsible for the content or the privacy practices employed in other Websites and other social media accounts that are not owned by or operated, managed by or on behalf of TELPRI, as applicable.
  
  TELPRI is not responsible for any information that customers or users publicly disclose or share in or through Public Forums or the Social Media Accounts managed by or on behalf of TELPRI, as such terms have been defined in this Policy. Information publicly disclosed or shared by customers and/or users in the Public Forums or in the Social Media Accounts managed by or on behalf of TELPRI, may be accessed, stored and used by third parties.

• Updating the Contact Information
  Customers and users can access the information they have provided to TELPRI, correct it and update it by visiting our Website and using our Customer Assistance request or by accessing their account through the Log-in to My TELPRI link. The ChatBot window on the Website has links to help that the users can use to send information updates.

• When TELPRI Shares Information Collected about a Customer and/or a User
  TELPRI does not sell or rent or provide personal information to unaffiliated third parties to market their products or services without your consent.
  Except where this policy states otherwise, TELPRI may disclose or share customer or user information with third parties when:
  • It is given with the customer’s or user’s consent.
  • It is given to another holder of the account (in the case of customers).
  • It is given to a TELPRI service provider to complete transactions or perform some technical support service on behalf of TELPRI.
  • In connection with events outside of its ordinary business practices, including but not limited to a sale, merger, consolidation, change in control, transfer or sale of assets, reorganization, liquidation, or in cases of bankruptcy or receivership.
  • It is a legal procedure and to protect TELPRI’s rights. See, VII. Compliance with the Law.
  • It is an emergency in which the life and/or property of the people concerned is in danger, subject to the legal provisions that so authorize.

TELPRI is not responsible for third-party apps that a customer or user selects or downloads on their equipment (e.g., telephone, mobile phone, or computer, among others), as by accessing them the customer or user may grant their consent to said third parties accessing information stored on their equipment and on the TELPRI network for such apps to run. Therefore, the manner and way in which such third parties manage and use the customer’s or user’s information shall be governed by the terms and conditions of their Privacy Policy and not by the TELPRI Policy.

• How we store your information
  TELPRI uses encrypted Secure Socket Layer technology to transmit information or exchange data (information on social security cards, social security number, etc.) between a customer or user (via the Internet) and a server. The SSL protocol is used to ensure that the information is sent directly to TELPRI and that only TELPRI can decrypt it.
  TELPRI retains the information and/or data it collects from its customers and from its users solely while there is some type of relationship or business need, for the term permitted by the applicable state or federal laws or regulations. TELPRI maintains effective internal procedures for the protection, retention and destruction of documents and information stored physically and electronically.

• Other Information You Should Know
  
• Regulations applicable to the CPNI

The federal CPNI regulation adopted by the FCC, as explained below, sets the rules that telecommunications and VoIP service companies must meet regarding the use and disclosure of their customer’s CPNI. The federal CPNI regulations establish that telecommunications and VoIP service companies, such as TELPRI, may only disclose the customer’s CPNI, via telephone or online access, when the customer provides their password. Furthermore, such regulations require that its customers specifically authorize (opt-in) the disclosure of their CPNI to third parties, affiliated or not, and to independent contractors for purposes related to marketing communications related to the services contracted by the customers.

TELPRI maintains effective internal procedures to ensure compliance with the laws and regulations, both state and federal, aimed at protecting CPNI. TELPRI does not disclose its customers’ CPNI to third parties without each customer’s consent, except as permitted by the rules adopted by the FCC. Should TELPRI be interested in using its customers’ CPNI they must obtain their prior consent, which may be obtained by any of the following two methods adopted by the FCC. The first one is (i) an “opt-out” or voluntary exclusion clause and the second one is an “opt-in” or explicit participation clause.

• When using the “opt-out” method - TELPRI sends the customer a notice informing them that they will consider that the customer has given their approval for the use of their CPNI for commercial purposes unless the customer tells them not to do so within a period of thirty (30) days.
  
• When using the “opt-in” method – TELPRI sends the customer a notice whereby they request the customer’s specific authorization to use their CPNI for commercial purposes.
  TELPRI may obtain said consent in writing; online, through agreements that require their acceptance by clicking on the “Accept” or “Authorize” button or that term that is available at the time the customer gives their consent.
  
  Should there be any changes of the CPNI information in their account, TELPRI will be required to notify the customer of said changes using the communication channels adopted by the FCC regulation. The notice cannot disclose the nature of the change in the CPNI made ​​to their customer’s account. TELPRI is required to notify the relevant federal authorities of any violation or breach associated with its customers’ CPNI. Furthermore, TELPRI is required to notify its customers regarding said violation and/or breach and keep a record of it.

• Policy on the Protection of Privacy, Confidentiality and Use of Social Security
  TELPRI complies with the provisions of Act No. 198 of August 7, 2008, which amends Act No. 213 of September 12, 1996, which requires that telecommunications and cable television companies protect the privacy and confidentiality of user information and prohibits requiring a customer to submit their original Social Security card, nor leave a copy of the same to be kept by the company, as a condition to process a transaction or service request, except in those cases in which the law specifically so requires; and for other purposes. For further information, the text of the Privacy, Confidentiality and Use of Social Security Protection Policy Act is available by accessing the Legal and Regulatory.

• Consumer Code
  TELPRI has adopted a Consumer Code in order to provide its existing and potential customers with the information necessary for them to make an informed decision when choosing their telecommunications services. The TELPRI Consumer Code is available by accessing the Legal and Regulatory.

• Broadband Network Management Practices
  TELPRI has adopted practices in order to manage the TELPRI network. If you are a TELPRI customer and/or user that somehow interacts with the TELPRI Websites, we encourage you to review the TELPRI Broadband Network Management Practices prior to using our online services. The TELPRI Broadband Network Management Practices are for informational purposes and may be modified at any time.
  Acceptable Use Policy TELPRI has adopted an acceptable user policy for anyone that accesses its Websites. Said policy is available on our Website by accessing the Terms of Use in the Legal and Regulatory.

• Children’s Online Privacy Protection Act of 1998 (“COPPA”):
  Companies offering online services aimed at children under thirteen (13) years of age or other companies who have knowledge that they are collecting information from children under thirteen (13) years of age must comply with the requirements established in the “Children Online Privacy Protection Act” of 1998 or “COPPA”. In essence, COPPA requires that said companies obtain a verifiable consent from the parents of children under thirteen (13) years of age prior to collecting any personal information from such minors.
  The TELPRI Websites as well as the services and/or products available on its Websites are not aimed at children under thirteen (13) years of age. TELPRI does not collect or use or disclose Personal Information from a user who is under thirteen (13) years of age. Should TELPRI learn that they have inadvertently received information from a minor under thirteen (13) years of age they will proceed to remove the information from their records and systems, as appropriate.

• Update and Notification of Changes to the Privacy Policy.
  TELPRI reserves the right to update, modify, amend, add to and/or replace this Privacy Policy at any time, in whole and in part, by publishing the changes through the company’s available and applicable communication channels. In said notice TELPRI will disclose the date of effect of such updates, modifications, amendments, inclusions and/or replacements and will obtain the customers’ specific consent when the changes to this Policy are material or substantial changes that affect the commitments that were established at the time the information was collected from those customers. TELPRI’s use of any of the communication channels available and applicable to the company for notifying updates, modifications, amendments, inclusions and/or replacements shall be deemed sufficient notice thereof to the Customers and/or Users.

• Miscellaneous
  This Policy is consistent with the applicable laws and regulations aimed at protecting consumer privacy. If any provision of this Policy is declared null, invalid, illegal, unconstitutional or otherwise without legal effect, in whole or in part, by a competent court, the remaining provisions shall remain valid and continue to bind the parties to all legal effects.

• Contact Us
  If you have questions regarding this Privacy Policy, please contact us by filling out the contact form on our Website, www.claropr.com. You can also call 787-763-3333. For more information the ChatBot window on the Website has links to help that the users can use to send information updates.

APPLICATION
TELPRI will adopt and implement this Corporate Policy.

Subsidiaries or affiliates belonging 100% to TELPRI and subsidiaries or affiliates under their control, will adopt and implement this Corporate Policy.
A “controlled subsidiary or affiliate” is defined in terms of the Stock Exchange Commission as a domestic or international commercial entity whose financial results are consolidated with the financial results of TELPRI.

Subsidiaries not controlled by TELPRI shall comply with all the applicable laws and regulations. TELPRI strongly urges its non-controlled subsidiaries to adopt a policy that covers the main issue cured [sic: covered] by this Corporate Policy. Such a policy must require compliance with all the applicable legal and regulatory requirements governing the issue it covers, and must reflect the particular needs of each non-controlled subsidiary.

RESPONSIBILITY
Each TELPRI employee is responsible for protecting the information about our customers. Each employee must comply with this company’s Information Privacy Principles. Any breach of this policy will result in the disciplinary sanction that has been adopted by TELPRI, its subsidiaries or affiliates that are owned 100% by TELPRI.

TELPRI business partners (e.g. vendors, consultants, suppliers and contractors) must abide by and comply with the TELPRI Information Privacy Principles regarding customer information.

EXPIRY:
Unless it is adopted once again, this Policy expires five years from the date of its approval by the Chief Executive Officer.