Privacy Policy

Effective on: January 1, 2020

This Privacy Policy is intended to inform you about the information Telephone and Data Systems Inc. (“TDS”, “we”, “us” or “our”) collects, how we use it and with whom we share it.

We encourage you to read our Privacy Policy carefully. It explains:

• TDS Data Sharing and Security Policy
• Privacy Statement Changes
• How TDS protects Your Information
• Business Purpose of Collection and Use
• Data Collection Sources
• Types of Information TDS Collects, including:
  • Information Categories and examples
  • Collection Sources
  • Business Purpose(s) for Collection
  • Categories of third parties with whom TDS shares collected information
• TDS Cookie Policy
• State Consumer Privacy Rights
• How to contact us

TDS Data Sharing and Security Policy

TDS will not share your personal information with third parties other than to TDS subsidiaries, to trusted service providers who perform essential functions on behalf of TDS, or as otherwise specified in this policy. In addition, TDS does not sell your personal information for any purpose to outside vendors or third parties.

Disclosure of personal information may, however, be necessary in certain circumstances, such as when TDS in good faith believes that disclosure is required under the law or in order to protect our legal rights.

By using our website or services, you agree to our collection and use of your personal information as described in this Privacy Policy. If we change our Privacy Policy and procedures, we will post these changes on our web site: www.tdsinc.com. Your continued use of our site or services following the posting of any changes to these terms constitutes acceptance of those changes.

This Privacy Policy also applies to "Third Parties" whom we require to maintain appropriate privacy and data security measures consistent with this Privacy Statement when we share your information as described in this Privacy Statement. We use "Service Provider" to refer to agents, vendors, suppliers, subcontractors, and independent contractors with whom we have a business relationship.

This website and TDS’s other digital properties are not intended for children, and TDS does not collect Personal Information from children under the age of 13.

Privacy Statement Changes

TDS may update our Privacy Statement at any time, at least annually to reflect new legal requirements, changes within our business, or to clarify our practices. Please periodically refer back to this Privacy Statement to learn what changes, if any, have been made based on the effective date posted with the updated Privacy Statement. If we propose to use your information materially different than what was stated in the Privacy Statement at the time we collected it, TDS will obtain your consent in the appropriate manner, which may include an opt-out mechanism.

How TDS Protects Your Information

TDS implements and maintains reasonable security safeguards to protect against such risks as loss, unauthorized access, destruction, use, modification, or disclosure of information. TDS uses a variety of commercially reasonable and appropriate safeguards to protect information residing on its systems including, without limitation, server firewalls and physical facility security.

We restrict access to information to those who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We also have appropriate practices and procedures designed to protect your information. We train our employees on the proper handling and securing of information which includes reporting potential privacy concerns. TDS protects the security of your personal information by using Secure Sockets Layer (SSL) software, which encrypts the information you input.

We will not store Personal Information beyond what is necessary for business purposes, including for internal service evaluation and quality assurance purposes, except as otherwise required by law.

TDS has made all commercially reasonable efforts to maintain the security of its servers in order to prevent the loss, misuse, and modification of the Personal Information we control. Even though these steps have been taken, TDS cannot guarantee that “hackers” will not obtain access to the information on these servers. If you suspect an issue with access to your information, please contact us at TDSInfo@tdsinc.com or by calling 312-592-5352.

Business Purpose of Collection and Use

We may use, or disclose the Personal Information we collect for one or more of the following business purposes:

• Auditing the interaction with the data subject and concurrent transactions.
• Detecting or preventing security incidents or other illegal activity and prosecuting the responsible parties.
• Debugging to identify and repair errors that impair existing intended functionality.
• Providing support, safety, security, integrity of the Telephone and Data Systems, Inc. website.
• Internal Research for Technological and Product Development.
• Workforce Management

We do not use each piece of Personal Information in an individual category for every business purpose

Data Collection Sources

Information You Provide to Us

You provide information to TDS when you directly interact with us. When you call us, access our website, or e-mail us you may provide information such as your name, mailing address, telephone number or email address. When you apply for a position with TDS, you may provide your employment or education history, as well as, your authorization to collect your background information as part of the application process.

Information We Collect Automatically

We automatically collect your information when you access our Site through cookies and other tracking technologies. We may collect information about your series of page visits, including browsing history; clickstream data, IP address or domain type.

Information Collected from Others

We may collect Personal Information from Service Providers, other third parties, or publicly available sources. For example, we acquire information about you from independent third-party sources in the form of background checks during the hiring process. These entities may collect information from varying sources such as public records and social media.

The information we collect may include credit reports, consumer reports, criminal records, military records and references, and have information such as gender, age, education level, occupation, or marital status.

Types of Information TDS Collects

TDS may collect information when you apply for employment, request investor or other information and/or request to be placed on an email alert list for information about TDS, such as daily stock closing prices, new press releases, etc. If you do not want your personally identifiable information collected, you should not submit this information to TDS.

Personal Information

Personal Information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include anonymous or de-identified information that cannot personally identify you, your accounts or devices.

Credit and Financial Information

Credit and Financial Information is a specific type of Personal Information that relates to your financial or commercial relationship with us.

Network and Device Information

Network and device information is collected when you visit our Site. TDS often aggregates user-specific information on which pages are accessed by visitors. The aggregate data collected is used to perform statistical analyses of the collective characteristics and behavior of visitors to the Site, to measure overall patron demographics and interests regarding specific areas of the Site, as well as to analyze how and where to use TDS resources.

Location Information

Location Information is collected when you provide it directly to us and when you use our Site. Certain types of Location Information may be considered Personal Information.

Cookie Information

TDS uses cookies to protect our network and improve our website performance. For more details on Cookies please refer to our TDS Cookie Policy section below that describes the information we collect through Cookies, how we use it and how you can manage your Cookie Preferences.

California residents can also review the Additional TDS Cookie Policy Information for California Residents in the State Consumer Privacy Rights section at the end of this document.

Detail for Information TDS Collects

The following table provides a summary of:

• The categories of and representative examples of Personal Information we collect,
• The categories of sources from which Personal Information was collected,
• The business or commercial purpose for which Personal Information was collected, and
• The categories of third parties with whom TDS shares Personal Information.

Category	Examples	Source(s)	Business Purpose(s)	Category of Third Parties Shared With
Personal Information	Name, physical and email addresses, telephone numbers, date of birth, Social Security Numbers, Driver's License Numbers	Directly from you Information collected from others	Workforce Management Fulfill requests for investor or other information Fulfill requests for various email alerts (daily stock closing prices, new press releases, etc.)	Our Affiliates Our service providers Government authorities or other entities with the legal authority Authorized Third Parties
Protected classification characteristics under California or federal law*	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	Directly from you Third party data brokers and others	Workforce Management. Note that we do not collect protected classification characteristics of job applicants.	Agents and Affiliates Third Party service providers Government authorities or other entities with the legal authority
Professional or employment related Information	Prior employment and other information that may be on a resume	Directly from you Collected from third parties	Detecting and Preventing Security Incidents and Fraud Performing Services including Supporting Activities Workforce Management	Our Service Providers Government authorities or other entities with the legal authority
Education Information	Degrees obtained, transcripts and other information that may be on a resume	Directly from you Collected from third parties	Detecting and Preventing Security Incidents and Fraud Performing Services including Supporting Activities Workforce Management	Our Service Providers Government authorities or other entities with the legal authority
Credit and Financial Information	Directly from you Information collected from others	Credit History	Workforce Management	Our affiliates Our service providers Government authorities or other entities with the legal authority Authorized third parties
Network and Device Information	Domain type, IP Address, Operating System, Browser type, ?Clickstream? Information (series of page visits and associated clicks executed by a visitor when navigating the site) and Internet Service Provider (can sometimes be determined by IP address)	Information we collect automatically	Protect our network Enhance website functionality	Our affiliates Our service providers Government authorities or other entities with the legal authority Authorized third parties
Location Information	physical address, zip code, and geographic location of connection point (can sometimes be determined from an IP address)	Directly from you Information we collect automatically	Protect our network Enhance website functionality	Our affiliates Our service providers Government authorities or other entities with the legal authority Authorized third parties
Cookie Data	Location information, web usage, interactions with emails and advertising	Information we collect automatically Cookies	Protect our network Enhance website functionality	Our affiliates Our service providers Authorized third parties
Inferences drawn from other Personal Information	Information about typical online activities that assist in the detection of fraudulent IT system usage, employee profiles for talent management	Directly from you We collect automatically Third party data brokers and others From cookies	Detecting and Preventing Security Incidents and Fraud Identifying and Repairing Errors Performing Services including Supporting Activities Internal Research for Technological and Product Development Maintaining the Quality, Safety and Integrity of Services Workforce Management	Our Service Providers Government authorities or other entities with the legal authority

TDS Cookie Policy

California residents should refer to the State Consumer Privacy Rights section immediately below for additional information on their data rights under CCPA (California Consumer Protection Act).

TDS may store small data files, called cookies, on your computer when you visit the Site. Cookies allow TDS to personalize your service by collecting and storing information that will identify you when you visit a site. Our site does not respond to browser do not track signals.

TDS uses Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie (_ga) with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use GA to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. You can disable Google Analytics on your computer by deleting your _ga cookies and installing the Google Analytics Opt-Out Browser Add-On.

TDS can only protect the privacy of information it collects and is not responsible for the practices employed by web sites linked to or from the TDS Site nor for the content contained therein. The web sites and services you are able to access on the Internet are outside the control and limits of this Privacy Policy. Any information you provide to these organizations is at your own risk.

State Consumer Privacy Rights

The California Consumer Privacy Act of 2018 (CCPA) provides current California residents with specific rights regarding their personal information as defined by CCPA (“CCPA PI”), including the right to:

• Request categories of or the specific pieces of their CCPA PI which we have collected in the previous 12 months in readily usable format, (Right to Access);
• Receive a list of the categories of third parties with which the CCPA PI was disclosed or sold in the previous 12 months, (Disclosure of Personal Information);
• Request the erasure of their CCPA PI which we have collected, subject to certain exemptions, (Right to Deletion);
• Opt-out of the sale of CCPA PI, (Do Not Sell my Personal Information)
  • TDS does not sell personal information for any purpose to outside vendors or third parties
• The Right to be free from discrimination for exercising their privacy rights.

Not all of these rights may be applicable to all California residents, depending on their relationship with TDS or the nature of the data we maintain.

California residents may submit a request to us by contacting us at:

Email: TDSInfo@tdsinc.com

Phone: 312-592-5352

As a California resident you may be required to provide certain information for us to verify your identity before we process your request. Once we verify your identity and validate your request, we will communicate with you to fulfill your request, or explain why we are denying your request in whole or in part. We may not respond to your request or provide you with CCPA PI if we cannot verify your identity or authority to make the request and confirm the CCPA PI relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use CCPA PI provided in your request to verify your identity or authority to make the request.

TDS does not discriminate against California Residents for exercising any of their rights.

Right to Access

California residents have the right to request that we disclose certain CCPA PI to them about our collection and use of their personal information over the past 12 months. Once we receive the request and verify the requestor is authorized, we will disclose to them:

• The categories of CCPA PI collected about them.
• The categories of sources for the CCPA PI collected about them.
• Our business or commercial purpose for collecting or selling that CCPA PI.
• The categories of third parties with whom we share that CCPA PI.
• The specific pieces of CCPA PI we collected about them.
• If we sold or disclosed their CCPA PI for a business purpose, two separate lists disclosing:
• sales, identifying the CCPA PI categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the CCPA PI categories that each category of recipient obtained.

Right to Deletion

California residents have the right to request that we delete, and direct any service providers that have received that CCPA PI to delete, the CCPA PI about them that we collected and retained, unless an exemption applies. We may deny the deletion request, should the information be necessary for us or our service providers to:

• Complete the transaction for which we collected the CCPA PI, provide a good or service that was requested, take actions reasonably anticipated within the context of our ongoing business relationship with them, or otherwise perform our contract with them.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech; ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546seq.).
• 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 informed consent was previously provided.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on their relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which it was provided.

Do Not Sell My Personal Information

TDS does not, and will not, sell personal information to third parties for valuable consideration.

Right to Non-Discrimination

TDS does not discriminate against California residents for exercising any of their rights.

Additional TDS Cookie Policy Information for California Residents

TDS uses Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie (_ga) with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use GA to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. You can disable Google Analytics on your computer by deleting your _ga cookies and installing the Google Analytics Opt-Out Browser Add-On.

If you would like to exercise your rights under CCPA to access what browsing information has been collected by us - or ask us to delete any GA data - please delete your _ga cookies, reach out to us via at the email or phone number provided below, and/or install the Google Analytics Opt-Out Browser Add-On.

How to Contact TDS

You may contact TDS at TDSInfo@tdsinc.com or by calling 312-592-5352 if you have any further questions regarding this policy, or need a copy of this privacy policy in an alternative accessible format.