Effective date: June 30, 2023
Unless otherwise indicated by a separate privacy statement posted, this Privacy Statement applies to information gathered by Global Tel*Link Corporation/d/b/a ViaPath Technologies (“ViaPath”), or by one of its affiliates in connection with your use of the Site or your use of any of the products and services provided by ViaPath or any affiliate, including but not limited to GTL Financial Services, GTL Enhanced Services, LLC, DSI-ITI, Inc., Innertainment Delivery Systems, LLC, Public Communications Services, Inc., Renovo Software, Inc., and Value-Added Communications, Inc. (individually “Affiliate” and collectively “Affiliates”). Products and services provided by ViaPath or any Affiliate will be referred to in this Privacy Statement as the “Service”). For purposes of this Privacy Statement, “we”, “us” or “our” refers to ViaPath and any Affiliate where the Affiliate or its products or services are implicated.
If you are a resident of California, Virginia, Colorado, or Connecticut, please see the section below titled, “Additional Privacy Information for Certain Jurisdictions,” which includes additional information about privacy rights you may have under your state’s privacy law.
This Privacy Statement applies only to information we collect through electronic or digital means (individually or collectively referred to as our “Sites” or “Websites”), including our commerce websites located at: https://www.connectnetwork.com, https://www.gtlfsonlinepay.com/, and https://www.gtlvisitme.com/app, and https://www.gettingout.com/ (individually or collectively referred to as our “Sites” or “Websites”).
This Privacy Statement applies to personal information, which does not include publicly available information or anonymized/deidentified information.
It is our policy to use the information we collect about you from the Service in a manner that is consistent with this Privacy Statement. Accordingly, this Privacy Statement advises you about the types of information we collect when you use the Service and how we may use that information.
If you have any questions about the Privacy Statement or our use of the information, we collect from you in connection with the Service, you may contact us by email at [email protected] or by postal mail at c/o Global Tel*Link Corporation d/b/a ViaPath, 3120 Fairview Park Drive, Suite 300, Falls Church, VA 22042, Attn: Legal Department. 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 the Site, which provides contact phone numbers.
Correcting/Updating Your Information
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 using the information above.
Service/Site Age Limits
Must be over 18
The Service is not intended for visitors that are under eighteen (18) years of age. 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 Statement 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 [email protected] and request this information be deleted. Please mark your request “Children’s Privacy Request.”
Information We Collect
Usage and Activity Information
Information that may be collected by cookies and web beacons when you use the Site may include, without limitation:
- the pages you visit within the Site;
- the date and time of your visit to the Site;
- the amount of time you spend using the Site;
- the websites you visit before or after visiting the Site;
- the Internet Protocol (IP) address used to connect your computer or mobile device to the Internet;
- geolocation information;
- your computer or mobile device and connection information such as your browser type and version, operating system and platform; and/or
- 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 if you use this type of software, but your experience while visiting 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), and if you do not agree with or consent to the terms of this Privacy Statement, 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.
We may collect information from you that can be used to personally identify and/or contact you. Contact 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 birth date and your 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.
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.
Voice, Image, and Recording
When you use our services to communicate with an inmate, ViaPath records and stores the communication, which may include your image and/or voice. By using the services, you are expressly providing consent for ViaPath to collect your voice and image and to use them as described in this Privacy Statement, in accordance with the Terms and Conditions. ViaPath may also collect a copy of a government issued identification bearing your photograph.
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
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 who you communicate with, 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.
- Mobile Applications
In addition, 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 inmate 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 inmate and the above referenced 60 minute period, please call 1-800-483-8314.
Cellular Provider Information
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 share information relating to users of the Service 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.
Purposes For Which We Collect, Use, and Process Your Personal Information
We may use information described above for any of the following purposes:
- to provide you with the Service;
- to manage and service your account;
- to contact you when necessary about your account or your use of our Services;
- to comply with regulatory requirements for the maintenance of records;
- to send you by mail, phone, text or email, information and promotional materials about our products and Services as well as our company in general;
- to send you by mail, phone, text or email, information and promotional materials from our marketing partners and other third parties;
- for purposes of targeted advertising;
- to send you marketing and other emails;
- to help diagnose problems with our server;
- to administer our Site;
- to conduct internal reviews of our Service;
- to help us better understand visitors’ uses of our Service;
- to carry out our obligations and enforce our rights arising from any contracts entered into and between us and a correctional facility, or controlling entity, where an individual that you may communicate with is detained;
- to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- to verify your identity;
- to protect the security or integrity of our Service; and
- for any other business or marketing purposes that are not inconsistent with the terms of this Privacy Statement.
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 bills 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. 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) initiating, rendering, billing, and collecting for ViaPath service; (2) protecting ViaPath’s right or property, or protecting ViaPath users and other telecommunications carriers from fraudulent, abusive, or unlawful use of, or subscription to, ViaPath services; (3) maintenance and repair; and (4) complying with the orders or subpoenas of a court of competent jurisdiction. Other uses require your approval, as described below.
Required Customer Approval
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” below) if you do not wish ViaPath to use your individually identiﬁable CPNI for this purpose. 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 right to disapprove this use, and limit or revoke access to your individually identiﬁable CPNI by contacting ViaPath. A denial of approval will not affect ViaPath’s provision of services to you. Your approval or denial of ViaPath’s use of your individually identiﬁable CPNI 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.
How We Share Your Information
We may share the information we collect in connection with the Service with the following recipients:
Correctional Facilities and Law Enforcement
We may share contact information you provide, or location information we collect from your computer or mobile device, with correctional facilities or other law enforcement personnel upon their request. We may also share information concerning any payment transaction completed through the Service including, without limitation, your image as captured when you use a payment services kiosk and the identities of the parties contributing and receiving payment under the transaction and the amount of the payment, with correctional facilities or other law enforcement personnel upon their request. Because safety and security are ViaPath’s top priority, you may not opt out of the sharing of your communications with Law Enforcement, and all data associated with your communications. If you do not consent to the collection, use and disclosure of this type of data, please do not use the sites or services.
We may share your information with our service providers, vendors, suppliers and other services providers who provide services to us or on our behalf, such as operating and supporting the Service, analyzing data, performing marketing or consulting services, assisting us with the preparation and mailing of our business and marketing communications, and with service processing and fulfillment functions. For example, we may disclose your billing information to payment processors when you add money to your account or conduct other financial transactions through the Service.
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 Statement with regard to their use of your information.
Transfer or Assignment in Connection with Business Transfers or Bankruptcy
Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies
Do Not Track Requests
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.
Sale of Personal Information
ViaPath does not sell personally identifying information about the users of our Services to any third parties for monetary consideration; however, we may share internet and electronic network activity to/with third-party data analytic, marketing, and advertising partners, which may constitute a “sale in certain jurisdictions. 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.
How We Protect Your Information
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 services.
Security of Information
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.
Use of Information Outside of Your Country of Residence
The Sites and Services are directed to users located in the United States. 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 Statement 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.
Changes to this Privacy Statement
By accessing and using our website, equipment, and services, you hereby release and forever discharge ViaPath, its Affiliates and employees, contractors, and agents, all applicable Law Enforcement Officials, and the correctional facility 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 the personal information in the manner described herein.
Additional Privacy Information for Certain Jurisdictions
Residents of certain states have additional rights under applicable privacy laws, as described in this section.
If you are a resident of California, please review Subsection 1. below for additional information about your privacy rights under applicable California privacy laws.
If you are a resident of Virginia, Colorado, or Connecticut, please review Subsection 2. below for additional information about your privacy rights under applicable privacy laws.
- Additional Information for California Residents
Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make this type of request, please provide submit your request in writing to: [email protected], or to c/o Global Tel*Link Corporation d/b/a ViaPath , 3120 Fairview Park Drive, Suite 300, Falls Church, VA 22042, Attn: Privacy.
California Consumer Privacy Act
The California Consumer Privacy Act (CCPA) provides California residents with certain rights regarding their personal information (with some exceptions). The rights that may be available to California residents, and how to exercise such rights, are listed below. California residents who provide us personal information in connection with TouchPay services do not have the rights provided below, as the personal information that we collect under those circumstances is exempt under the CCPA.
Right to Know and Access
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information. The categories of third parties with whom we share that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Request Deletion
You have the right to request that we delete any of your personal information that we collected from you and retained, 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.
We may deny your deletion request if retaining the information is necessary for us or our service providers 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.
- 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 1546 seq.).
- 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.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your 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 you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Logging into your account on one of our sites (if you are a California resident, this request form will display on the site’s dashboard).
- Contacting our Customer Service team using the information supplied through the “Contact Us” link on the Site, which provides contact phone numbers.
Only you, or a person (including a person registered with the California Secretary of State) that you have authorized in writing to act on your behalf, may make a verifiable consumer request related to your personal information. If you are using an authorized agent to make a request on your behalf we have the right to require you confirm with us that you have provided your permission for the authorized agent to make such a request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. This information includes your first and last name, email address (and a verification sent to your email address), your account number, and your billing address. If we are unable to verify your identity using this information we may ask for additional verification information.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
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.
- Additional Information for Residents of Virginia, Colorado, and Connecticut
Residents of certain U.S. states, including Virginia, Colorado, and Connecticut have the right to receive certain disclosures regarding a business’ processing of “personal data,” as defined under applicable privacy laws. Residents of these states may have certain rights with respect to our processing of such personal data. To the extent you are a resident of Virginia, Colorado, or Connecticut and we collect, use or disclose personal data subject to your state’s privacy law, the following applies. For more information about the personal data we collect, use and disclose, please see “Information We Collect,” “Purposes For Which We Collect, Use, and Process Your Personal Information,” and “How We Share Your Information” sections above.
Residents of Virginia, Colorado, and Connecticut who provide us personal information in connection with their use of TouchPay services do not have the rights provided below, as TouchPay is exempt under each state’s privacy law as a financial institution.
- Your privacy rights
- Right to access. You have the right to confirm whether or not we are processing your personal data and to access such personal data.
- Right of 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.
- Right to delete. You have the right to ask us to delete certain personal data we have collected about you.
- Right to correction. You have the right to ask us to correct inaccuracies in the personal data we have collected.
- Right to opt out of sale. Under the VCDPA, a “sale” includes disclosing or making available personal data to a third party in exchange for money. We do not “sell” personal data as defined by VCDPA; thus, this right is not available to Virginia residents.
- Right to opt out of targeted advertising. You have the right to opt out of targeted advertising based on your personal data. To opt out of targeted marketing, please see our Notice of Right to Opt-Out. VCDPA provides the right to opt out of the processing of personal data for decisions that produce legal or similarly significant effects concerning you. We do not process personal data for such profiling; thus, this right is not available to Virginia residents.
- A. How to submit a request
If you are a resident of Virginia, Colorado, or Connecticut and wish to exercise these rights, you can reach us in one of the ways shown below.
Authorized agents may initiate a request on behalf of another individual by contacting us at the “Contact Us” link on the Site, which provides contact phone numbers and a “Contact Us Form”; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Right to Access / Portability / Delete / Correct:
- Contact our Customer Service team using the information supplied through the “Contact Us” link on the Site, which provides contact phone numbers and a “Contact Us Form”.
- Logging into your account on one of our sites and utilizing the request form on the site’s dashboard.
- See Section D below for instructions on how to opt-out of targeted advertising.
- B. Process to appeal a decision related to your rights
If we refused to fulfill your request to exercise your privacy rights in Section A, you may appeal this decision by contacting us at [email protected]. We will respond to your request with an explanation about our decision to fulfill or refuse your request.
If we deny your appeal, you may contact your state’s Attorney General to file a complaint related to the denial.
- C. 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 aboutads.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).
- If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies.