Privacy Policy

Your privacy is important to us. This Global Tel*Link Corporation d/b/a ViaPath Technologies (“ViaPath”) Privacy Policy (“Privacy Policy”) applies to the personal information that ViaPath or one of our Affiliates collects and explains our information practices and your related choices with regard to such information.

ViaPath affiliates include, but are not limited to, TouchPay Holdings, LLC d/b/a GTL Financial Services, GTL Enhanced Services, LLC, DSI-ITI, LLC d/b/a ViaPath Technologies, Innertainment Delivery Systems, LLC Telmate, LLC d/b/a ViaPath Technologies, Public Communications Services, Inc. d/b/a ViaPath Technologies, Renovo Software, Inc., and Value-Added Communications, Inc. d/b/a ViaPath Technologies (individually “Affiliate” and collectively “Affiliates”). Products and services provided by ViaPath or any Affiliate will be referred to in this Privacy Policy as the “Service” or “Services”. This Privacy Policy is part of, and is governed by our Terms of Use, which is available at https://www.viapath.com/terms-of-use/. For purposes of this Privacy Policy, “we”, “us” or “our” refers to ViaPath and any Affiliate where the Affiliate or its products or Services are implicated.

TouchPay Holdings, LLC d/b/a GTL Financial Services (“TouchPay”), a subsidiary of ViaPath, is the owner and operator of websites www.viapath.com, www.touchpayonline.com, www.connectnetwork.com, www.gettingout.com, and www.tpgovtpay.com (the “Site” or “Sites”).

It is our policy to use the information we collect about you from the Services or the Sites in a manner that is consistent with this Privacy Policy. Accordingly, this Privacy Policy advises you about the types of information we collect when you use the Services and how we may use that information.

This Privacy Policy is part of, and is governed by our Terms of Use, which is available at https://www.viapath.com/terms-of-use/. All capitalized terms that are used but not otherwise defined in this Privacy Policy have the definitions assigned to them in the Terms of Use

By using the Services or Sites at any time, agreeing to our Terms of Use, creating an account by any method, including over the phone or through our Interactive Voice Response system, or clicking the “accept” button when you register to use the Service through the Site or when you are otherwise prompted to do so, you agree to be legally bound by this Privacy Policy.

If you have any questions regarding the Service or your account, or if you would like to cancel your account, please contact our Customer Service team using the information supplied through the “Contact Us” link on our website. If you have any questions about the Privacy Policy or our use of the information we collect from you in connection with the Service, you may contact us by email at privacyrights@viapath.com or by postal mail at c/o ViaPath Technologies, 3120 Fairview Park Drive, Suite 300, Falls Church, VA 22042, Attn: Legal Department

If your name, email address, mailing address, telephone number, or other contact information that you provide to us changes, you may update, correct or omit the relevant information by contacting our Customer Service team through the “Contact Us” link on our website.

Incarcerated Youth.

While our Services are not intended for individuals under the age of eighteen (18) years of age, we do provide certain Services to youth who are incarcerated. We understand the unique needs and circumstances of incarcerated youth and aim to support their rehabilitation and education through our Services. With the exception of incarcerated youth or as required by a correctional facility, we do not knowingly solicit or collect information from individuals who are not at least eighteen (18) years old.

Not Available for Use by Children.

We regret that the Service is not available to children under the age of thirteen (13). We will never knowingly collect contact information from children under the age of thirteen (13) without verifiable parental consent. If you are under the age of thirteen (13), please do not provide us with information of any kind whatsoever. If we become aware that a user is under the age of thirteen (13) and has submitted information to the Site without verifiable parental consent, we will remove his or her information from our files. We understand that children may not fully understand all of the provisions of this Privacy Policy or make informed decisions about the choices that are made available to adult users of the Site. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you are a parent or legal guardian and think that your child under 13 has given us their personal information you can email us at privacycentral@viapath.com and request this information be deleted. Please mark your request “Children’s Privacy Request.”

Internet, Usage, and Activity Information

When you visit or use our Site or Services we may send one or more “cookies” or “web beacons” to your computer or other device. A cookie is a small file containing a string of characters that is sent to your computer or other device when you visit a website. When you visit the website again, the cookie allows that Site to recognize your browser. We use cookies to improve the quality of our Service, including for storing user preferences. By clicking the “Accept All Cookies” button when our cookie message displays, you agree to be bound by the terms of this Privacy Policy. Web beacons are web page elements that can recognize certain types of information on your computer or mobile device such as cookies and the time and date of a page viewed.

Information that may be collected by cookies and web beacons when you use the Site may include, without limitation:

• Site usage information, such as the pages you visit, the date and time of your visit, the amount of time you spend using the Site, and the websites you visit before or after visiting the Site;

• Device, connection, and location information, such as your IP address, geolocation information, browser type and version, operating system, platform, and related computer or mobile device information; and/or

• Commercial information, such as your purchase history.

You may be able to set your browser to reject cookies or to notify you when you are sent a cookie. You can also purchase and download software that will allow you to use the Service without providing the information gathered by cookies. You are welcome to use the Service or visit the Site if you use this type of software, but your experience while visiting the Site or using the Service may not be optimal.

If you create an account to use the Service other than through the Site (such as through our Customer Service Representatives or interactive voice response system), and if you do not agree with or consent to the terms of this Privacy Policy, you will have thirty (30) days from the date you create the account with us to cancel the account. If you decide that you want to cancel the account within this thirty (30) day period, please contact our Customer Service team using the information supplied through the “Contact Us” link on the Site. If you cancel your account within the applicable thirty (30) day period, we will provide you with a refund of any fees you have paid and have not used in connection with the Service at the time of cancellation.

Identifiers/Customer Information

We may collect information from you that can be used to personally identify and/or contact you. Information collected through the Service may include your name, telephone number, physical address, mailing address, billing address, or email address. In addition to contact information, we may collect other personal information from you that may be associated with your contact information, such as your government issued form of identification, date of birth, username, and password. If you are using our Services to make payments, we are required to collect additional identification information, such as your driver’s license number and the last four numbers of your social security number.

Payment and Purchase Information

If you are using our Services to make payments or to purchase products or Services, we are required to collect certain financial information such as your credit card or other payment card information, the type of payment you are making, or information related to the purpose of the payment. We may need to run background checks on anyone involved in the transaction to satisfy our legal requirements.

Commercial Information

We collect information related to the products or Services you purchase.

Voice and Video Data, Images, and Recordings

When you use our Services to communicate with an incarcerated individual, ViaPath records and stores the communication, which may include your image, voice data, or any images or data transmitted during the communication. By using the Services, you are expressly providing consent for ViaPath to collect such data and to use them as described in this Privacy Policy and in accordance with the Terms of Use. ViaPath may also collect a copy of a government issued form of identification bearing your photograph.

Social Media

If you choose to connect your social media account to our Facebook and other social media outlets, certain personal information from your social media account will be shared with us, which may include personal information that is part of your profile or your friends’ profiles. You may revoke your consent to have the social media platform share information with us by changing your settings within such platform.

Information About Incarcerated Individuals

Incarcerated Individuals Service Usage Data. We may collect information about incarcerated individuals’ use of our Services, including search history, click paths, usage patterns, and other information about their interactions with our Services, including but not limited to information that incarcerated individuals enter or submit when interacting with the Services.

If you are a friend or family member of an incarcerated individual, we may also collect information from you about the identity of incarcerated individual(s) receiving funds from you or individuals with whom you communicate through the Service. If you provide this information, you represent and warrant that you have all necessary rights and authority to provide information about the applicable incarcerated individual(s) in connection with the Service and agree that you shall be solely liable in connection with your disclosure of any information regarding incarcerated individual(s) in connection with the Service.

Communication and Correspondence

If you send any personal communication or correspondence, by any means, to the Service, or to any of our employees, agents or representatives, the Service may collect additional information regarding that communication and include that information in our customer database.

Location Information

Mobile Applications

If you access the Service through one of our mobile applications, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device’s location services settings, or otherwise declining to provide access to your location when prompted to do so. For instructions on changing the relevant settings, please contact your service provider or mobile device manufacturer. If you choose not to share your location details with us, you may be denied access to the mobile application.

When You Receive a Phone Call through the Service

We collect the location of the phone you are using when you use the Service to help ensure accurate billing practices as well as for correctional facilities’ safety, security and investigative purposes.

You will be advised through a prompt on calls placed from an incarcerated individual at a correctional facility to the phone you are using when you use the Service that your phone location information will be obtained. By accepting the call, you agree to have your phone location obtained for 60 minutes after you accept the call. Your location will not be obtained if you do not accept the call. The location information collected in connection with each call will only be stored for one year from the date of the call and then deleted from our records. If you would like to opt out of having your phone location information obtained for any time remaining between when you terminate your call with the incarcerated individual and the above referenced 60 minute period, please call 1-800-483-8314.

Cellular Provider Information

The Service is not a Cellular Provider application. If you use the Service, it may require your Cellular Provider to disclose your customer information, including mobile phone location information, to us or some other third party. By providing your consent through the opt-in process described below, you authorize your Cellular Provider to disclose your information to us and to third parties to enable the Service. Please review this Privacy Policy and our Terms of Use for more information about how the Service will collect, access, use or disclose your information. If you aren’t comfortable with the terms of this Privacy Policy or our Terms of Use, you should not use the Service. You acknowledge and agree that (1) your relationship with us is separate from your relationship with your Cellular Provider; (2) your Cellular Provider is not responsible for the Service; and (3) you will hold harmless your Cellular Provider and its subsidiaries, affiliates, officers, employees, agents, successors and assigns from any judgments, claims, actions, losses, liabilities or expenses arising from or attributable to the Service or our acts or omissions.

Information Collected and Used by Third Parties

If you visit the Site from a third-party website the third-party website may give you a unique code, cookie or graphic which will uniquely identify you. This will only happen if you link directly from a third-party website to the Site. Your activities on the Site while this type of code is active may be reported back to the third-party website. The presence of a third-party navigation bar at the top of any page on the Site is an indication that the third-party website may be able to see your activity on the Site.

The Site may also include third-party advertising, links to other websites, and other content from third-party businesses. These third-party sites, businesses, and advertisers, may use web beacons and cookies to measure the effectiveness of their ads, personalize or optimize advertising content and to track users who click on the links made available through the Site. These third-parties may use persistent identifiers to track the actions of users online over time and across different websites or platforms to deliver targeted electronic advertisements to an individual user. We do not have access to or control over web beacons, cookies or persistent identifiers that these third parties may use. We are not responsible for the privacy practices or the content of these third-party websites. You are encouraged to review the privacy policies of the different websites you visit. For information about how tracking works for online advertising purposes you can visit http://www.aboutads.info/choices.

Some third-party advertising companies may provide a mechanism to opt-out of their technology. For more information about the opt-out process, you may visit the Network Advertising Initiative website, available at http://www.networkadvertising.org/managing/opt_out.asp.

We may also use analytics software service providers to gather and analyze anonymous information about users of the Site. These service providers may use cookies to collect information about your purchase history, the content you view, what websites you visit immediately prior to and after visiting the Site, and your system information. The information gathered by these service providers about your use of the Site may be transmitted to and stored by these service providers. If we use these service providers, the information collected about you by these service providers would allow us to analyze your use of the Site and the Service.

We may also use certain web analytics services, such as Google Analytics, to help us understand and analyze how visitors use our Services. We use this information to implement Google advertising features such as interest-based advertising, audience targeting, user segment analysis, and impression reporting. For more information on how Google Analytics uses data, visit https://support.google.com/analytics/answer/6004245. To opt out of Google Analytics cookies, visit https://myadcenter.google.com/ and https://tools.google.com/dlpage/gaoptout/.

Aggregate Information

We may share information relating to users of the Sites or the Services with affiliated or unaffiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.

We may use information described above for any of the following purposes:

• To provide, manage, support, and communicate with you about the Services, your account, and related transactions, including verifying your identity and carrying out our contractual obligations and rights.

• To comply with applicable legal, regulatory, contractual, recordkeeping, law enforcement, court order, and governmental requirements, and to support law enforcement and correctional facility activities and requests.

• To operate, administer, secure, troubleshoot, evaluate, and improve our Sites, Services, systems, business operations, products, features, and user experience, including through internal reviews, research, analytics, and understanding customer and market needs.

• To send information, advertising, and promotional materials about our company, products, Services, marketing partners, or other third parties, and for other business or marketing purposes consistent with this Privacy Policy.

• To use your information for purposes not otherwise described in this Privacy Policy, provided that we will notify you and, if necessary, obtain your consent before doing so.

We may also combine information we collect about you through the Service with other information about you that we receive from third party sources. By way of example and not limitation, we may use a change of address or other list service to ensure that our records for your account are accurate.

Description of Customer Proprietary Network Information (“CPNI”)

CPNI is proprietary information about you that includes (1) information on the quantity, technical configuration, type, destination, location, and amount of your use of ViaPath telecommunications Services, that you make available to ViaPath solely by virtue of the carrier-customer relationship; and (2) information contained in the billing statements you receive concerning your telecommunications Service. It does not include (1) your name, address, or phone number; (2) aggregated customer information that does not identify specific individuals; or (3) information about non-telecommunications Service, such as Internet access or electronic messaging. Under the CPNI rules adopted by the Federal Communications Commission (“FCC”), you have the right, and ViaPath has the duty, to protect the confidentiality of CPNI.

ViaPath’s Use of CPNI

Under FCC rules, ViaPath may use your CPNI without your prior approval for certain purposes. Specifically, ViaPath may use, disclose, or permit access to your CPNI without your consent, either directly or through its agents, for the purpose of (1) providing the Service, including initiating, rendering, billing, and collecting for the Service; (2) protecting ViaPath’s rights or property, or protecting ViaPath users and other providers from fraudulent, abusive, or unlawful use of, or subscription to, ViaPath services; (3) maintenance and repair; (4) to fulfill our contractual Service obligations with correctional facilities to allow them to offer you our products and Services; and (5) as required by law, including but not limited to complying with the orders or subpoenas of a court of competent jurisdiction. Other uses require your approval, as described below.

Required Customer Approval for Certain Uses of CPNI

As a leader in the corrections industry, ViaPath is continually developing new innovations in the fields of technology, education, and intelligence. From time to time, ViaPath may use and share your individually identifiable CPNI among its Affiliates and agents to inform you about communications-related products and Services or special promotions. Use of your individually identifiable CPNI enhances ViaPath’s ability to offer products and Services that are tailored to your needs.

You have 30 days from the date of this notice to inform us (see “Contacting ViaPath” above) if you do not wish ViaPath to use your individually identifiable CPNI for informing you about communications-related products and Services or special promotions. If you do not so inform us, ViaPath will assume you consent to this use of your individually identifiable CPNI.

At any time after this 30-day period has elapsed, however, you have the right to disapprove of our use of CPNI to inform you about communications-related products and Services or special promotions, and to limit or revoke access to your individually identifiable CPNI for this purpose by contacting ViaPath. A denial of approval will not affect ViaPath’s provision of the Services to you. Your approval or denial of ViaPath’s use of your individually identifiable CPNI for this purpose is valid until you affirmatively revoke or limit that approval or denial.

ViaPath will never disclose your individually identifiable CPNI to unaffiliated third parties without your express, opt-in consent, other than as set forth in this Privacy Policy (see How We Share Your Information below).

We may share the information we collect in connection with the Service (including, without limitation, your CPNI) with the following recipients:

Correctional Facilities and/or Law Enforcement

9.1.1 To fulfill our contractual Service obligations with correctional facilities to allow them to offer you our products and Services, we may disclose your information (including, without limitation, your CPNI) to correctional facilities and/or law enforcement. When you use our Services while incarcerated, or to communicate with or process a transaction on behalf of an incarcerated individual housed within a correctional facility, we process personal information for the facility, and the facility staff are able to access your personal information in order to operate these facilities, conduct investigations, and/or to verify transactions.

9.1.2 Under appropriate circumstances, we may share your personal information including but not limited to, CPNI, account information and history, call details, financial transactions and your voice and video records with law enforcement and/or correctional facilities and certain third parties for use in connection with and in support of law enforcement activities. All calls, visits, and communications through our Services will be recorded and may be monitored, with the exception of communications exempted by correctional facilities as set forth in our Terms of Use. All of this data may be stored, monitored, searched, analyzed and transferred among law enforcement agencies for law enforcement purposes.

9.1.3 Because safety and security are ViaPath’s top priority, you may not opt out of our sharing of your communications, personal information, and related data with correctional facilities and law enforcement. If you do not consent to the collection, use, and disclosure of this data to correctional facilities and law enforcement, please do not use the Sites or Services.

Service Providers

To support the Services we offer to you, we may disclose personal information with service providers that help us with our business activities.

Our Affiliates

We may share some or all of your information with our parent company, subsidiaries and corporate Affiliates, joint ventures, or other companies under common control with us. We will require these entities to comply with the terms of this Privacy Policy with regard to their use of your information.

Transfer or Assignment in Connection with Business Transfers or Bankruptcy

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from users of the Service to third parties. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Statement. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

Government Agencies, Judicial and Quasi-Judicial Bodies, Regulators, and Other Public Bodies and Third Parties

To the extent permitted by law, we may disclose your information to government and law enforcement agencies, judicial and quasi-judicial bodies, regulators, other public bodies, or third parties if: (a) required to do so by law, or in response to subpoenas, court orders, and/or other lawful requests by these entities; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect our property or other rights or those of other users of the Service, third parties or the public at large; (c) to fulfill our contractual Service obligations with correctional facilities to allow them to offer you our products and Services or (d) we believe that you have abused the Service by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws or in violation of our Terms of Use. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

Your Internet browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, we will not disable tracking technology that may be active on the Site in response to any “do not track” requests that we receive from your browser.

ViaPath does not sell personally identifying information about the users of our Services to any third parties in exchange for monetary compensation, but does share such information with law enforcement and correctional facilities to support law enforcement activities.

ViaPath complies with all required PCI standards (https://www.pcisecuritystandards.org) regarding our treatment of payment card data. Additionally, we have implemented commercially reasonable measures designed to secure your personal information from unauthorized access, use, alteration and disclosure. However, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal information transmitted via our Sites or Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites or in the Services.

We seek to use industry standard physical, technical and administrative security measures designed to protect your personally identifiable information. However, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us in accordance with the “Contacting ViaPath” section above.

Please note that emails you send to us through our Service are not encrypted, and we strongly advise you not to communicate any confidential information in your emails to us.

If you are located outside of the United States and choose to use the Sites or Services or provide your information to us, you should be aware that we may transfer your information to the United States and process it there. The privacy laws in the United States may not be as protective as those in your jurisdiction. Your consent to this Privacy Policy followed by your submission of information to us through the Site or in connection with the Services represents your agreement to the transfer of your information to the United States.

If we decide to change our Privacy Policy, we will post those changes to the Privacy Policy on our homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances we disclose it. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on our Services and Sites. Your continued use of the Services and Sites following these changes constitutes your acceptance of the revised Privacy Policy.

By accessing and using our Site, equipment, and Services, you hereby release and forever discharge ViaPath, its Affiliates and employees, contractors, agents, and all applicable law enforcement officials and correctional facilities from any and all liability, expense, cost or remedy which may arise as a result of your use of our Sites and Services as well as the use of your data and personally identifiable information in the manner described herein.

Certain U.S. states have adopted privacy laws that give certain rights to individuals over their personal data. We currently provide these rights to all consumers regardless of where they live. The rights available to consumers and how to exercise them are listed below.

17.1.1 Know/Access. The right to request to know and access the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.

17.1.2 Correction. The right to request that we correct or update inaccurate personal information that we maintain about you.

17.1.3 Deletion. The right to request the deletion of your personal information that we have collected, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. Please note there are situations where we are unable to delete your data, for example:

• To complete the transaction for which we collected the personal information, provide a good or Service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• When we have an overriding interest in continuing to process the data, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• To debug products to identify and repair errors that impair existing intended functionality.

• To ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• To comply with applicable law.

• To engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

• To enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• To comply with a legal obligation.

• To make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• To cooperate with and support law enforcement and correctional facility activities.

17.1.4 Data Portability. You may have the right to obtain a copy of the personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your personal data to another controller or business where the processing is carried out by automated means.

17.1.5 Opt out of sales and sharing. The right to opt-out of our sale and sharing of your personal information.

17.1.6 Limit uses and disclosure of sensitive personal information. The right to limit our use or disclosure of sensitive personal information to those authorized by the California Consumer Privacy Act (CCPA). As noted below, we do not use or disclose sensitive personal information beyond the purposes authorized under the CCPA; thus, this right is not available.

17.1.7 Non-discrimination. You have the right to not be discriminated against for exercising any of your privacy rights.

Submitting a Privacy Rights Requests Your privacy rights can be exercised through one of the following methods:

17.2.1 Logging into your account on one of our Sites (a link to an Exercise Your Privacy Rights form will display on the Site’s dashboard).

17.2.2 Completing the online form available at https://gtlprod.service-now.com/privacy.

17.2.3 By emailing us at privacycentral@viapath.com

17.2.4 Calling us by phone (toll-free) at:

• ConnectNetwork Customer Service: 877-650-4249

• GettingOut Customer Service: 866-516-0115

• VisManager Customer Service: 855-208-7349

• TouchPay Customer Service: 866-204-1603

Verifying Requests

When you submit a request to know/access, correct or delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide your name and contact information to verify your request. In some cases, we may request additional information, where necessary to verify or process your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity, your authority to make the request, and confirm that the personal information relates to you.

Requests Made Through Agents

Authorized agents may initiate a request on behalf of another individual by using the options listed above. Authorized agents must provide written proof of their authorization. We may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Response Timing

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

Appeals Process

If your request is denied you may have the right to appeal the denial in accordance with the instructions provided to you when the denial was made.

If we deny your appeal, you may be able to contact your state’s Attorney General to file a complaint related to the denial.

Requests to opt out/Browser opt out

Our Sites respond to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing on our Site (e.g., via cookies and pixels). More information about GPC is available at: https://globalprivacycontrol.org/. You may also opt your browser out of targeting and most cookies on one of our Sites (other than essential cookies) by clicking the “Your Privacy Choices” button on our Sites which will take you to our Privacy Preference Center where you can choose not to allow certain cookie types, except those that are essential for our Site to function properly. Note that if you come back to the Site from a different device or use a different browser on the same device, you will need to opt out of (or set GPC for) that browser and device as well.

Notice of Right to Opt-Out

If you wish to opt out of processing of personal data that is gathered when you visit our websites and other web-based Services for purposes of “sales” and/or targeted advertising, you may do so in one of the ways described below:

If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at info/choices(Digital Advertising Alliance). You may also download the DAA AppChoices (https://youradchoices.com/appchoices) tool in order to help control interest-based advertising on apps on your mobile device).

Our Sites respond to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing on our Site (e.g., via cookies and pixels). More information about GPC is available at: https://globalprivacycontrol.org/. You may also opt your browser out of targeting and most cookies on one of our Sites (other than essential cookies) by clicking the “Your Privacy Choices” button on our Sites which will take you to our Privacy Preference Center where you can choose not to allow certain cookie types, except those that are essential for our Site to function properly. Note that if you come back to the Site from a different device or use a different browser on the same device, you will need to opt out of (or set GPC for) that browser and device as well.

TouchPay Exemption:

Personal information that you provide in connection with TouchPay Services are exempt from applicable state privacy laws and are not subject to the privacy rights listed above.

Messages, photos, and videos sent between incarcerated individuals and their friends and family are retained for limited periods of time and may not be available to you or accessible by you indefinitely. The retention periods are subject to applicable laws, regulations, correctional facility requirements, and our records retention policy. By using our Services, you acknowledge and agree that once your message, photo, or video is deleted in accordance with our records retention policy or correctional facility requirements, it will no longer be available to you. If you would like continued access to a message, photo, or video, you may make a copy when you send or receive it.

Sales and Sharing of Personal Information

Under the California Consumer Privacy Act (CCPA), “sales” and “sharing” are broadly defined, respectively, and include disclosing or making available personal information in exchange for monetary or other valuable consideration, or for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA) internet and electronic network activity information to/with third-party data analytic, marketing, and advertising partners. We do so in order to improve and evaluate our advertising campaigns and better reach customers and prospective customers with more relevant ads and content. We also may “share” information with law enforcement and correctional facilities to support law enforcement activities. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old, except such information may be shared with law enforcement and correctional facilities to support law enforcement activities.

Sensitive Personal Information

We do not use or disclose sensitive personal information beyond the purposes authorized by the CCPA. The right to limit the use of sensitive personal information lets you ask us to limit the use and disclosure of sensitive personal information if we use that information for purposes beyond what is needed to provide the products and Services you request or for other reasons specified in the law. The other reasons specified in the law include: (i) helping to ensure security and integrity, including preventing, detecting, and investigating security incidents, (ii) detecting, preventing and responding to malicious, fraudulent, deceptive, or illegal conduct, (iii) ensuring the physical safety of a person, (iv) providing customer service or to verify your information, (v) verifying or maintaining the quality and safety of our Services, (vi) complying with our legal obligations, (vii) to our service providers who perform Services on our behalf, (viii) for purposes other than inferring characteristics about you and (ix) to cooperate with law enforcement agencies. ViaPath does not use or disclose sensitive personal information for other purposes beyond the purposes authorized by the CCPA.