California Consumer Privacy
Effective Date: January 1, 2022
This California Consumer Privacy Notice (“Notice”) applies to CoxCom, LLC and its communication related affiliates, (“Cox,” “us,” “we, “our”) and “Consumers” as defined by the California Consumer Privacy Act (together with related regulations the“CCPA”) and should be read along with our other privacy notices found on www.cox.com. In the event of a conflict between any other Cox policy, statement or notice and this Notice, this Notice will prevail as to California Consumers’ rights under the CCPA. There are other companies in the Cox corporate family that have their own California privacy notices and consumer rights programs. You will need to consult their policies and make requests to them separately.
To make this easier to read, we have abbreviated or summarized terms from the CCPA, but a full copy of the CCPA is available at Title 1.81.5. of the California Civil Code, California Consumer Privacy Act of 2018 section 1798.100 - 1798.199. Capitalized terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.
Sections 1 and 2 of this Notice covers our Collection, use, disclosure, and Sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, for the twelve months preceding January 1, 2022, .and will be updated annually. Our practices in calendar year 2022 may change and if we make material changes we will provide notice about the new collection or use. Sections 3 and 4 of this Notice describe the rights California Consumers have and includes notices to Californians required by other laws.
We may from time-to-time update information in this Notice regarding our data practices and your rights, modify our methods for responding to your requests, or supplement our responses to your requests as required to reflect updates to the law or guidance by the California Attorney General on how to interpret it. You can tell when this Notice was last updated by looking at the date at the top of the Notice. Any changes to this Notice will become effective upon posting of the revised Notice on the site. Use of the site, any of our products and services, and/or providing consent to the updated Notice following such changes constitutes your acceptance of the revised Notice then in effect.
This CCPA Notice does not apply to information collected from job applicants, current and former employees and contractors of Cox, and persons with whom we interact with in their capacity of representing another business. If we collect information about you in any of these contexts, this Notice will not be applicable to you.
This Notice contains a comprehensive explanation of our data practices and Consumer rights under the CCPA, but you can find a shorter explanation and FAQs here.
You can click on the following links to navigate to the different sections in this Notice.
a. Categories
b. Sources
c. Purposes
3. Your California Privacy Rights
a. Right to Know
b. Do Not Sell
i. Exercising DNS Rights
ii. Managing Cookie Preferences
c. Right to Delete
d. Non-Discrimination
f. Exercising Your CCPA Rights
g. Limitations on Your Rights
4. Additional California Notices
a. Third Party Marketing
b. Online Privacy Practices
i. Tracking and Targeting
ii. California Minors
5. Contact Us
1. PI We Collect
a. Categories
The table below provides the categories of PI we Collect about California Consumers, examples of the PI we Collect, and the types of recipients we share PI with, in connection with our Business, based on our 2021 practices.
For purposes of the table below customers services providers include call center vendors, field services technicians, security providers, and other similar types of vendors.
Category of PI
Examples of PI
Categories of Recipients with whom PI is Shared
1. Identfiers
This may include but is not limited to: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
Advertising networks, data analytics providers, credit and collection agencies, e-signature services, marketing services companies, data brokers, customer services providers, and other Service Providers.
Other third parties such as media measurement companies and TV programmers.
2. Personal Records
This may include but is not limited to: telephone number, employment details, credit or debit card number, or other financial information.
Data analytics providers, credit reporting agencies, e-signature services, marketing services companies, credit and collection agencies, customer services providers, and other Service Providers.
3. Customer Characteristics
This may include but is not limited to: age, veteran status, accommodations information, gender and interests.
Advertising networks, marketing services companies, data analytics providers, and other Service Providers.
4. Customer Account Details / Commercial Information
This may include but is not limited to: products or services purchased, obtained, or considered, other purchasing or consuming histories or tendencies.
Data analytics providers, marketing services companies, collection agencies, customer services providers, and other Service Providers.
5. Services Activity Information
This may include but is not limited to: information regarding your interactions with web sites, applications, or advertisements, service-related data such as the amount of Internet data used by your household, cable and telephone service activity, TV viewership activity, and home security.
Advertising networks, data analytics providers, marketing services companies, customer services providers like call center vendors, and other Service Providers.
6. Geolocation Data
This may include but is not limited to: market location or movements.
Data analytics providers, advertising networks, customer services providers, marketing services companies, and other Service Providers.
7. Sensory Data
This may include but is not limited to: audio recordings of customer care and sales calls, electronic, visual, or similar information.
Data analytics providers, marketing services companies, and other Service Providers.
8. Professional or Employment Information
This may include but is not limited to: professional, education, or employment-related information.
Data analytics providers, marketing services companies, and other Service Providers.
9. Inferences from PI Collected
This may include but is not limited to: creating a profile about a Consumer reflecting the Consumer’s characteristics, interests, and preferences.
Data analytics providers, marketing services companies, and other Service Providers.
In addition, each of the above referenced categories of PI may be shared with government agencies, other third parties as required by law or compelled by legal process, to the Consumer or other parties at the Consumer’s request, and to assignees as part of a merger or asset sale.
Further, we may deidentify or aggregate your PI, and as permitted by applicable law, we do not treat De-identified or Aggregate Consumer Information as PI. Similarly, as permitted by the CCPA, we may not treat publicly available data as PI.
b. Sources
Based on our 2021 practices, we collect PI directly from you, your devices or browser, vendors that assist us in providing our services and running our internal business operations, data analytics providers, advertising networks, operating systems, suppliers, public databases, social media platforms, data append services, other companies in the Cox family of businesses, and other data providers.
c. Purposes
In the preceding twelve (12) months, we collect PI for the following Business Purposes:
3. Your California Privacy Rights
To protect your privacy and comply with our obligations under the CCPA, requests you submit are subject to an identity and residency verification process as permitted or required by the CCPA. We will not fulfill your CCPA “Right to Know” or “Right to Delete” requests unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI (“Verifiable Consumer Request”). Please follow the instructions at our CCPA page here and respond to any follow up inquires we may make. For Consumers that cannot be verified through their Cox account credentials, we require verification through a third party service associated with a credit bureau that will ask you questions based on your consumer history in order provide us a sufficient degree of certainty that you are who you say you are. Otherwise, to protect your privacy, we will reject your request and refer you to this Notice for information on our data practices generally, and if you made a deletion request remind you how to opt-out of Sales.
We will make commercially reasonable efforts to identify Consumer PI that we Collect, use, and store in response to your California Consumer privacy rights requests. Some of the PI we Collect is voluminous, difficult to present to you, or generally not helpful, so we may provide a list of that PI and give you the opportunity to elect whether you want the rest or not. If you are a Cox customer or former customer, some of your PI is accessible to you through our self-service tools located in My Account or is otherwise readily available to you without the need to make a Right to Know request. For instance:
a. Right to Know
Your California CCPA Consumer privacy rights are as follows:
You have the right to send us a request, no more than twice in a twelve-month period, for the following information for the period that is 12 months prior to the request date (please note that PI is retained for various time periods so we may not have PI in all categories going back 12 month)
b. Do Not Sell
i. Exercising DNS Rights
You have the right to direct us to not Sell your PI. As discussed above, the CCPA’s definition of a “Sale” is both unique and broadly worded and may capture disclosures beyond what you might think of as a Sale. Our approach to your CCPA “Do Not Sell” opt-out rights are explained below. As the law evolves, we may change our approach, but in the interest of giving you control over your PI we have developed Consumer data control programs even where we do not think the law requires.
As discussed above, we may engage in Pseudonymous Data Transfers when we share household TV viewership data with advertisers and others, but we never include your name, address, e-mail, phone number or other contact information. We offer the ability to opt out of these disclosures in your My Account preferences. We treat this sharing of TV viewership data as a Sale under the CCPA’s broad definition of a “Sale,” and accordingly a “Do Not Sell” request will opt you out of Pseudonymous Data Transfers. You can also exercise your CCPA “Do Not Sell” rights here.
ii. Managing Cookie Preferences
We do not believe that third party cookies that facilitate online advertising or other activities in connection with our online services, which themselves Collect and share PI, are a Sale by us of your PI under CCPA and, accordingly, a “Do Not Sell” request to us will not affect the Collection activities by third party cookies. However, we provide Californians who use our online services a way to manage their cookie preferences based on categories of cookies through our management tool available here. You will need to do this on each browser that you use to access our websites and clearing cookies on your browser(s) may disable your preference settings. More information on how to exercise choices regarding third party cookies and interest-based advertising is available here.
In addition, some third-party cookie operators that collect PI in connection with our online services for advertising, analytics and other purposes offer you the ability to opt-out of their own downstream Sales. Please visit here to opt-out of the Sale of PI by these participating third parties. This is a third-party program and we are not responsible for its effectiveness. You must opt out on every device and browser you use in order to effectuate your “Do Not Sell” requests from these parties. However, opting out does not mean you will stop seeing ads and you may continue to still see interest-based ads. To learn more about interest-based advertising and additional opt-out choices related to it, please visit here.
We do not have actual knowledge of the age of Consumers under 16 and do not knowingly link PI with Consumers under age 16.
c. Right to Delete
You may request that we delete PI collected directly from you unless we need it for permitted purposes, such as to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, to protect against fraud, or for other legitimate internal Business Purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. We will not delete your PI that we are permitted to retain, for so long as the permitted retention purpose remains, after which we will delete the PI. In some situations, we may deidentify or aggregate data in lieu of deletion., To make a request, go here or call us at 1-800-699-0885 (service hours are Monday-Friday, 8-5 Pacific Time, except holidays). As with a Right to Know request, to protect you, we will require you (or your agent) to be verified before honoring your deletion requests.
Many Consumers, especially those that we currently serve, don’t really want us to delete all of their PI. Indeed, we can’t delete all of your data if you are a customer. However, we appreciate that you may want to limit our use and disclosure beyond what is needed to provide those services. You may choose to limit use of your PI by making selections in the Privacy Preference Center by visiting your My Account here. In addition, deletion for former customers is limited by exceptions permitted under the CCPA. Anyone who receives commercial emails from us may opt-out of future commercial emails by following the unsubscribe directions in the footer of those emails. You can exercise choices regarding cookie preferences as noted in the “Do Not Sell” section above.
d. Non-Discrimination
We will not discriminate against you in a manner prohibited by the CCPA because you exercised your CCPA rights.
f. Exercising Your CCPA Rights
We encourage Consumers, including current customers, to make CCPA requests via our privacy portal at www.cox.com/ccpa. Copies of PI available by the self-serve methods described above must be accessed using such methods.
We verify customers via their account, or for non-account holders through a third-party service that uses information about Consumer’s history to ask questions the answers to which will help us determine if you are who you say you are. We do this to protect your privacy and security and comply with the CCPA’s requirements. If you are not a Cox customer, you do not have to create a service account with Cox to make a request, but you will have to set up identity verification credentials to exercise your rights. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses unless you also gave it to us for another purpose
Authorized agents of Consumers can make a request here, which will also be subject to verification.
g. Limitations on Your Rights
Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law. In addition, we will not honor any of your requests to the extent doing so would infringe upon our rights or any other person or party’s rights or conflict with applicable law.
4. Additional California Notices
In addition to CCPA rights, Californians are entitled to certain other notices, including:
a. Third Party Marketing
We will not share personal information as defined by California Civil Code § 1798.83 (“Shine the Light” law or “STL”) with third parties, outside of the Cox family of companies, for their direct marketing purposes without your consent. You can make a request to receive details on our sharing of such personal information with members of the Cox family of companies for their direct marketing purposes within the prior 12 months, by sending an email to californiaprivacy@cox.com and indicating “Shine the Light” in the subject line or body of your email request. You can also make a request by mail to the address below:
CoxCom LLC6205-B Peachtree Dunwoody Road
Atlanta, GA 30328
Attn: Privacy Operations – 15th Floor
As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.
b. Online Privacy Practices
For more information on our online practices and your California rights specific to our online services see our Online Privacy Policy. Without limitation, Californians that visit our online services and seek or acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:
i. Online Tracking and Targeting
When you visit our online services, we and third parties may use tracking technologies to collect usage information based on your device for a variety of purposes, including serving you advertising, based on you having visited our services or your activities across time and third-party locations. Some browsers may enable you to turn on or off a so-called “Do Not Track” signal. Because there is no industry consensus on what these signals should mean and how they should operate, we do not look for or respond to “Do Not Track” signals. For more information on tracking and targeting and your choices regarding these practices, see our Online Privacy Policy. Consumers can also exercise preferences regarding cookies by following the instructions here.
ii. California Minors
Although our online service(s) are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the online service, can request removal by contacting us at californiaprivacy@cox.com detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.
5. Contact Us
For more information on your California privacy rights contact us at 1-800-699-0885 (service hours are Monday-Friday, 8-5 Pacific Time, except holidays) or email us at californiaprivacy@cox.com. You may also visit our Privacy Preference Center accessible via your My Account or our Consumer Rights Request page or write to us at:
Cox Communications
6205-B Peachtree Dunwoody Road
Atlanta, GA 30328
Attn: Privacy Operations – 15th Floor