Privacy Policy
Last Updated: 18 June 2024
The GlobalNet Connect website (this “Site”) and GlobalNet Connect LLC services are provided by The Houghton Group, LLC. The following sets forth the Privacy Policy (“Privacy Policy”) of The Houghton Group, LLC and its affiliated companies (collectively, “THG,” “we,” “us,” or “our”) with respect to information collected through the Site or otherwise from THG customers, and is incorporated into and made a part of the THG Plans Terms and Conditions, available at “https://www.globalnetconnect.com/privacypolicy”, and the THG Terms of Use, available at “https://www.globalnetconnect.com/privacypolicy”. This Privacy Policy describes how information about you is collected, used and disclosed by us when you sign up for and use the THG service and it provides other important privacy information, describes when and how we may change this Privacy Policy, and tells you how to contact us with any questions or comments.
- Purpose of Privacy Policy
Your privacy is important to THG. Accordingly, THG provides these policies so that you understand how THG collects, uses and, in certain circumstances, discloses the information that you provide and/or that is automatically provided to THG as a result of your visiting and using the Site or purchasing or using THG products or services. This Privacy Policy also explains the steps THG has taken to secure your personal information. Finally, this Privacy Policy explains your options regarding the collection, use and disclosure of your personal information. By visiting this Site, purchasing, or using any THG product or service, you accept the practices described in this Privacy Policy. THG is not responsible for the content or privacy practices on any third-party website that may be linked to or from this Site. Any questions regarding this Privacy Policy should be directed to our customer service department via email at info@globalnetconnect.com or via phone at 877-246-2500.
- Collection and Use of Personal Information
Personal information is information that identifies or is associated with a specific individual, such as a name, address, email address, or telephone number. THG collects personal information about its customers. The ways in which we collect personal information about you include, but are not limited to, the following:
- Registration and Ordering. Before using certain parts of this Site or purchasing THG products or services, you must complete an online registration form or provide certain information to THG’s representatives. During registration (whether via this Site or otherwise), you will be prompted to provide to THG certain personal information, which may include, but is not limited to, your name, billing address(es), phone number, port-in phone number, email address, and credit card number. This personal information is used for billing purposes, fulfilling your orders, and communicating with you about your order and this Site, and for marketing purposes. If THG encounters a problem when processing your order, it will use your personal information to contact you.
- User Submissions. Certain areas of this Site may permit you to enter your email address and other contact information to receive further information about THG or for other purposes. Your submissions for these purposes are completely voluntary, so you have a choice whether to participate and disclose information to THG. Should you choose to submit information in response to these requests, THG may collect and publish your name, email address, geographic location and other information collected by THG to market THG products and services and any other products and services offered by THG.
- Automatically Generated and Collected Information. Automatically Generated and Collected Information In addition to information that you volunteer as described above, this Site utilizes technologies to collect information and track your user experience. THG will use this information to improve this Site and user experience. In addition, this Site automatically recognizes the Internet URL from which you access this Site and may also log your Internet protocol (“IP”) address (which may indicate the location of your computer on the Internet), Internet service provider, and date/time stamp for system administration, order verification, marketing, and system troubleshooting purposes.
- Information Collected by and/or Provided to Third Parties. We may obtain information about you and combine it with your account information. For example, we may receive information from the retailer from whom you purchased a THG product prior to your commencing service with us. In addition, we use a third-party service provider to serve ads and/or collect data on our behalf across the Internet and sometimes on this Web site. Some of these service providers may collect information about your visits to our Web site, and your interaction with our products and services to tailor marketing messages on this Web site and other sites or to trigger real time interaction, customize this Web site or enhance your profile. Some of these service providers may be able to collect personal information that you share with this site via a web form automatically and prior to your pressing a submit button; and they may be able to use information from your visits to this site to send marketing messages to you in a way that may personally identify you. This information is collected through the use of a cookie, JavaScript tag, and/or pixel, which is industry standard technology used by most major web sites. The information collected by these service providers may include your device’s IP address, user agent, email addresses (where hashed or otherwise rendered pseudonymous) and other user and device level pseudonymous information. Please keep in mind that your browser settings may not permit you to control the technologies utilized by these third-party companies. If you would like more information about these practices, please click: http://optout.aboutads.info/#!/.
Generally, THG collects information for the following purposes: (i) to improve your experience on this Site; (ii) to improve the products and services that THG sells to consumers; (iii) to communicate with you regarding this Site; (iv) to market and sell products and services to you and send you information about special offers; (v) to contact you about products or services you have purchased from THG (including but not limited to the THG service); (vi) to respond to your inquiries; (vii) to manage and develop our business and operations, administer accounts, and collect and process payments; and (viii) if you authorize text messaging, we will use your mobile number to communicate with you about your account and to send marketing text messages to you. If you decide that you no longer wish to receive emails or text messages from THG that you had authorized, you may opt-out of receiving emails and text messages by managing your account preferences on this Site or by any other reasonable opt-out method available to you. Please note that THG may have to communicate with you about product or service orders that you choose to place. You cannot opt-out of receiving product or service-related emails. THG will not sell, rent, trade, license or otherwise disclose your specific personal information or financial information to third parties, except as noted below. THG may sell, rent, trade, license, use and disclose all non-personal information and aggregate information, so long as such information does not personally identify you or any user, to any third party for any purpose, including, but not limited to, research and analytical purposes. Under federal law, you have a right, and THG has a duty, to protect the confidentiality of information regarding your telephone use, the services you purchase from us, the calls you place and the location of your device on our network when you make a telephone call. This information is referred to as, among other things, “Customer Proprietary Network Information.” We may share Customer Proprietary Network Information with our affiliates; provided, however, that we will first notify you of your rights under applicable law, describe how we intend to use the Customer Proprietary Network Information, and give you an opportunity to opt-out of such use (or opt-in, to the extent required by applicable law).
THG may disclose your personal information to third parties, including in the following circumstances:
THG uses third party service providers to perform specific functions on its behalf, and it must disclose personal information to help those parties perform their services (for example, THG would disclose your name, address and phone number to a commercial carrier such as Federal Express or UPS in order to deliver a physical product that you order, and it would disclose your name and credit card number and other information to financial services and credit card processing companies in order to process your orders).
- THG may be required to disclose personal information in response to a legal process, order, or investigation (for example, a subpoena or court order).
- THG may disclose personal information where disclosure is necessary to protect its legal rights or to protect itself or others (for example, in order to reduce the risk of fraud or illegal activities).
- THG may share personal information among its affiliated companies (for example, for the purpose of marketing products and services to you).
- THG may provide identity verification services to third parties, and your personal information may be included in the data transferred to third parties in connection with those services.
- THG may acquire, merge with or be acquired by another company, or it might sell some or all of its assets, and, in such a case, your personal information may be included in the transferred business assets. Also, in the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, your personal information may be included in the transferred assets.
- Cookies and Similar Online Tracking Technologies
“Cookies” are pieces of information that may be placed on your computer by a website for the purpose of facilitating and enhancing your communications and interaction with that website. Cookies may possibly be used for such things as: (1) to customize your visitation and shopping experience; (2) to deliver content consistent with your stated interests; (3) to provide you with custom-tailored content; or (4) to save your password in password-protected areas. The use of cookies is an industry-standard — you will find them at most major websites. Most browsers are initially set to accept cookies. If you would prefer, you can set yours to refuse cookies or to alert you when cookies are being sent. However, it is possible that some parts of this Site will not function properly if you do so. Cookies, by themselves, do not tell us your email address or other personal information unless you choose to provide this information to us. However, once you choose to furnish this Site with personal information, this information may be linked to the data stored in the cookie. We use cookies to understand usage of this Site and to improve the content and offerings on this Site. In addition, we may utilize web beacons to recognize you when you visit this Site. We may also use other technologies to provide us with other important anonymous information regarding the use of this Site. To the extent these online tracking technologies are deemed to be a “sale” or “sharing” (which includes targeted advertising) under California law, California residents can opt-out of these online tracking technologies by submitting a request via the “Do Not Sell or Share My Personal Information” link at the bottom of most of our website pages.
- Security
We take precautions and have implemented certain technical measures intended to protect against unauthorized access to, disclosure of, and unlawful interception of personal information submitted via this Site, including Secure Sockets Layer (“SSL”) for all financial transactions through this Site. However, your communications containing personal information may be unlawfully intercepted or accessed by third parties and/or this Site may be subject to network attacks or malfunctions. We cannot and do not guarantee the security of any information transmitted over the Internet. Once we receive your personal information, we take steps that we believe are reasonable to limit access to your personal information to only those employees and service providers whom we determine need access to the personal information to provide the requested products, services, offers or opportunities that may be of interest to you or that you have ordered, or that we otherwise disclose in accordance with Section 2 above. However, even after we receive your personal information, we cannot and do not guarantee that your personal information will not be accessed, disclosed, altered, or destroyed as a result of a breach of our security efforts or as a result of any other event beyond our reasonable control. Accordingly, we cannot and do not guarantee that your personal information or any other information is completely secure and safe from any risk.
- Protection of Children
THG does not knowingly solicit children to purchase services or products. If, however, you authorize a child to use our services or products by providing them a device associated with your THG account, any information associated with such use will be treated as your information in accordance with this Privacy Policy. This Site is not intended for children under the age of sixteen (16), and THG does not intentionally or knowingly collect personal information from anyone under the age of sixteen (16). We encourage parents and guardians to be involved in the online activities (including wireless Internet browsing) of their children to ensure that no information is collected from a child without parental or guardian permission.
- Advertisements and Links
This Site may display advertisements and links for third-party websites, products, and services. Information you provide directly to third parties and information collected from you by third parties in connection with your use of their websites, products or services will be subject to such third parties’ privacy policies and not this Privacy Policy.
- Your Account Preferences
Upon your request, THG will: (a) correct or update your personal information; (b) stop sending emails to your email address; (c) stop sending text messages to your mobile phone number; (d) stop sending mail (including promotional materials) to your mailing address; and/or (d) disable your account to prevent any future purchases through that account. You may make these updates / changes yourself by managing your account preferences on this Site or by any other reasonable account update mechanism available to you. You also have the ability, at any time, to click through an “Unsubscribe” link, contained in all marketing e-mails, in order to stop receiving such e-mails. You also may text STOP to +1 239-388-7851 (or in response to any marketing text message from THG), at any time, to unsubscribe from marketing text messages. You may also send your requests to: Attn: Customer Service, The Houghton Group, LLC, 6361 Presidential Court #3C Fort Myers FL 33919; or by phone at 877-246-2500. Please do not email your credit card number or other sensitive information. Please note that THG may have to communicate with you about product or service orders that you choose to place. Accordingly, you cannot opt-out of receiving product or service-related emails or mailings. Do Not Track (DNT) Disclosure: This Site does not currently respond to “Do Not Track” signals of web browsers in general, as there currently are no uniform technological standards for recognizing and implementing “Do Not Track” signals. However, this Site does respond to signals sent from California residents using a service called the Global Privacy Control (GPC), which may be considered a “Do Not Track” signal. For more information, see Section 9 below.
- Contact Us
For privacy related questions, comments and requests, please contact THG at:
The Houghton Group, LLC
Attn: Customer Service
6361 Presidential Court
Fort Myers FL 33919
Phone: 877-246-2500
- California Residents
California has a data protection law called the California Consumer Privacy Act (CCPA), as amended, and this Section 9 includes information THG is required to disclose under that law. This section applies to you only if you are a California resident.
Selling and Sharing Personal Information
The CCPA gives California residents certain rights, including the right to tell companies to not “sell” or “share” their personal information. In this Section 9, we use the terms “sell” and “share” as they are defined in the CCPA. The CCPA defines “sell” or “sale” broadly to include the sharing of personal information (including information that does not directly identify an individual) in exchange for anything of value, which is not limited to the exchange of money. “Share” is defined narrowly as providing personal information to a third party for cross-context behavioral advertising to a consumer based on information about their activity on multiple websites across the internet. We engage in certain activities (as described below) that may be considered selling or sharing personal information under the CCPA. That is why we include a “Do Not Sell or Share My Personal Information” link at the bottom of most of our website pages and in some of our apps. If you are a California resident, you can click this link to tell us to not sell or share your personal information. Note that according to the CCPA, certain exchanges of personal information are not considered selling or sharing. For example, if you specifically direct us to share your personal information, then we will do so. It is also not selling or sharing if we place ads based solely on information we collect when you visit our websites. Other examples include disclosures of personal information to service providers or other third parties as described in Section 2 above.
Global Privacy Control
THG participates in a service called the Global Privacy Control (GPC) that lets you set a “Do Not Sell or Share” preference at the browser level. You will need to have a GPC-enabled browser or browser extension that you will activate or turn on in the browser. When you visit a website, your browser will automatically send the site a “Do Not Sell or Share” signal and participating websites, like ours, will honor your preference. Note: Not all browsers and extensions offer a GPC setting. To download a GPC-enabled browser, go to the Global Privacy Control website. To check if our website received your GPC signal, click on the “Do Not Sell or Share My Personal Information” link in our footer. If we are receiving your GPC signal, we will automatically opt you out of the sale of your personal information and tell you that a GPC signal was used. When we are detecting your active GPC signal, we will not allow you to opt back into the sale or sharing of your personal information.
Personal Information We Collect, Disclose for a Business Purpose, and Sell or Share
The chart below summarizes the categories of personal information we may have collected from you in the past twelve (12) months, and how we collect, use, disclose and sell or share your personal information. THG does not have actual knowledge that we sell or share personal information of California residents under sixteen (16) years of age. We retain your personal information only as long as necessary to fulfill the business purposes outlined in this privacy policy unless a longer retention period is required or permitted by law. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to comply with our legal obligations; resolve disputes; enforce our agreements; protect against fraudulent, deceptive, or illegal activity; or for other related business purposes.
Categories of Personal Information | Sources of Personal Information | How and Why We Use This Information | Categories of Third Parties to Whom We May Have Disclosed This Information and Why | Categories of Third Parties to Whom We May Have Sold or Shared This Information |
Identifiers like your name, email, address, phone number and phone call records, account information, payment information, device information | You provide directly to us: contact and account information; authentication and security information; payment information, like your credit or debit card; preference information; and other information you choose to provide. | We may use your personal data to create and administer your account, verify your identity, complete transactions, payments, billing, and fulfill requests you may make related to our products and services. Other business purposes may include: 1. Personalize our products and services, respond to your inquiries, and perform our contractual obligations. 2. Conduct research and analysis. 3. Detect and protect against cybersecurity threats. 4. Protect you and others from unlawful activities. 5. Perform diagnostics and repair errors 6. Verify your identity. 7. Market and advertise our services or products to you. 8. Facilitate calculation of taxes, fees, or other obligations. 9. Cooperate with law enforcement and for legal or regulatory compliance. 10. Enforce our policies, terms and conditions, or other agreements. | We may disclose your identifiers to third parties for our business purposes; when you tell us to; or when you use our products or services to interact with third parties, whose separate privacy notices may apply to that data. These entities include: 1. Service providers or contractors who are required to treat your personal data as private (confidential) and to use it only for performing the services we have requested. 2. Other third parties such as credit bureaus or financial institutions for device financing. We may also share personal data to advertise and market our products and services to you. 3. Our affiliates. 4. Entities that provide fraud prevention services to THG. 5. Government authorities. | Third-party analytics, marketing, and advertising providers |
Commercial, financial, and transactional information from purchasing our services or products | You, when you buy our services or products from us or from our retail partners. We may obtain updated address information from our shippers. | In addition to any of the above business purposes: to provide effective customer service and to make your THG experience more relevant to you based on your history with us; to advertise and market our products and services to you. | Service providers, contractors, or other third parties, including our affiliates, as listed above. We may also share personal data with third-party providers to advertise and market our products and services to you. | Third-party analytics, marketing, and advertising providers |
Internet activity information, like browsing history, interactions with our website and online advertisements; unique identifiers including device identifiers; cookies or similar tracking technologies | Your browser or mobile device when you visit our website or engage with our online advertisements, or you when you buy services or products from us online. | In addition to any of the above business purposes: to provide effective customer service and to make your THG experience more relevant to you based on your history with us; to advertise and market our products and services to you. | Service providers, contractors, or other third parties, including our affiliates, as listed above. We may also share personal data with third-party providers to advertise and market our products and services to you. | Third-party analytics, marketing, and advertising providers |
Inferences we make about you based on the above information to predict your characteristics and preferences | Your browser or mobile device when you visit our website or engage with our online advertisements, or you when you buy services or products from us online. We may also obtain personal data from other third parties, like social media platforms, analytics providers, and consumer data resellers. | We may learn about your preferences or characteristics based on personal data we collect. | We may share personal data with third-party providers to advertise and market our products and services to you. | Third-party analytics, marketing, and advertising providers |
Sensitive personal information such as log-in credentials | You, when you create an account with us, or when you purchase our services or products. | To process, fulfill, and deliver products and services to you, to create an account for you, and to provide customer service to you. | Service providers or contractors who work for us may access your personal data to perform their services, and they are required to treat your personal data as private (confidential) and to use it only for performing the services we have requested. | None |
Audio recordings of calls or written correspondence between you and our Customer Care representatives | You, when you contact our Customer Care department. | Quality assurance, internal training, and customer service solutions | Government authorities, for legal processes to comply with laws, regulations, or to respond to lawful requests. | None |
Device provided data such as images, videos, audio, and other files | You, when you contact our Customer Care department | To provide customer service to you | Service providers or contractors, such as chat providers, who work for us may access your personal data to perform their services, and they are required to treat your personal data as private (confidential) and to use it only for performing the services we have requested. | None |
Professional or employment information included in materials like resumes and cover letters | You, when you apply for employment with our company. | To determine hiring and for human resources purposes only. | Service providers or contractors who work for us may access your personal data to perform their services, and they are required to treat your personal data as private (confidential) and to use it only for performing the services we have requested. | None |
Geolocation data (not precise geolocation data): ZIP code, IP address, or street address | You or your device, when you create an account with us, or when you purchase our services or products. | Any of the above business purposes or location-based services described in our Privacy Policy; to provide effective customer service; to advertise and market our products and services to you. | Service providers, contractors, or other third parties, including our affiliates, as listed above. We may also use you or your device’s approximate location (ZIP code or IP address) to advertise and market our products and services to you. | Third-party analytics, marketing, and advertising providers |
Sensitive Personal Information
California residents have the right to limit the use of “sensitive personal information” (as defined in the CCPA) to certain purposes specified in the CCPA. However, THG already only collects or processes sensitive personal information with your consent and for those purposes specified in the CCPA. THG also does not use sensitive personal information for inferring characteristics about you.
Privacy tools and choices for California Residents
You have the right to know the categories and, in some cases, specific pieces of personal information we have collected about you, the categories of sources from which the personal information was collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of personal information about you that we have either sold or shared for a business purpose, and the categories of third parties to whom we disclose personal information.
You have the right to request deletion of your personal data, but certain exceptions may apply. For example, we may keep personal information that is necessary to comply with a legal obligation, detect security incidents, or troubleshoot to identify and repair errors in our network.
You have the right to request correction of inaccurate personal data we maintain about you. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate personal information.
You have the right to opt-out of the sale or sharing of your personal information by clicking on the Do Not Sell or Share My Personal Information link at the bottom of most of our website pages, which is also available at the bottom of most of our website pages. For information on how we process opt-out preference signals, see the section above, Global Privacy Control.
You have the right to not be discriminated against for exercising your privacy rights under the CCPA.
To exercise any of the rights described above, please choose one of the following options:
- If you have a THG account, you can correct or make changes to your personal data directly through your account portal.
- For any changes that cannot be made through your account portal, call Customer Care at 877-246-2500.
- Submit a personal data request.
- Non-Customer
- THG Customer
- Current THG subscriber
- Former THG subscriber
Authorized Agents may act on your behalf by submitting an access, correction, or deletion request. To protect your information, we may request that you verify your own identity before fulfilling a request submitted by your agent.
Verification of your identity
We have to verify your identity before we can give you access to, or delete, your personal data. We may use information that you have provided to us, or information from a governmental identification, or through two step verification (where available) to verify your identity. If we can’t verify your identity, we’ll unfortunately have to deny your request. This is to protect you.
What to expect once you submit a request?
THG will confirm receipt of the request within 10 days via the email address you provide. Before we honor your rights to request information or delete information, we must verify your or your authorized agent’s identity. In certain cases, we may require you to provide additional information in order to verify your request.
- Ability to Accept Terms
You affirm that you are at least the age of majority in your state of residence and are fully able and competent to enter into and accept the terms set forth in this Privacy Policy.
- Revisions
From time to time, we may revise the Privacy Policy. Your use of the Site or any THG product or service following the posting of any revised Privacy Policy shall be deemed acceptance of the revised policy. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically reviewing this privacy policy to check for any changes. If you disagree with the terms of the Privacy Policy at any time, your sole remedy is to terminate your use of the Site and all THG products and services. Continued use of the Site or any THG product or service constitutes your agreement to any Privacy Policy as in effect.