Overview

TouchPay Holdings, LLC d/b/a GTL Financial Services (“TouchPay”), a wholly-owned subsidiary of Global Tel*Link Corporation d/b/a ViaPath Technologies (“ViaPath”) is the owner and operator of the touchpayonline.com website (“Site”) on which this Privacy Statement is posted. This Privacy Statement applies to information gathered by TouchPay, 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 ViaPath affiliate, including but not limited to TouchPay, GTL Enhanced Services, LLC d/b/a ViaPath, DSI-ITI, Inc. d/b/a ViaPath, Innertainment Delivery Systems, LLC d/b/a ViaPath, Public Communications Services, Inc. d/b/a ViaPath, Renovo Software, Inc. d/b/a ViaPath, and Value-Added Communications, Inc. d/b/a ViaPath (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”). This Privacy Statement is part of, and is governed by, the TouchPay Terms of Use set forth in the Site and applies to the collection of information anywhere where this privacy policy is linked or posted. 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.

Terms of Use

This Privacy Statement is applicable as of the Effective Date posted above. This Privacy Statement is part of, and is governed by, the Terms of Use set forth in the Site. 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.

Scope

This Privacy Policy 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: www.connectnetwork.com, www.gtlfsonlinepay.com, and www.gtlvisitme.com/app, www.gettingout.com, www.tpgovtpay.com and www.tpchildsupport.com.

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.

Contacting ViaPath

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 privacy@viapath.com or by postal mail at ViaPath Technologies, 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 privacy@gtl.net and request this information be deleted. Please mark your request “Children’s Privacy Request.”

Information We Collect
Data Collected Through Our Cookies or Web Beacons

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

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

• 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;
• 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.

Contact Information we Collect for Use of our Service

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.

Other Personal Information

In addition to contact information, we may collect other personal information from you that may be associated with your contact information. Other personal information collected through the Service may include your birth date, credit card or other financial account information, the last four numbers of your social security number, and your username and password.

Payment Information

If you are using our services to make payments, we are required to collect identification and financial information like your name, address, drivers’ license number, social security number, 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 and Image

When you use our services to communicate with an inmate, GTL records and stores the communication, which may include your image and/or voice. By using the services, you are expressly providing consent for GTL to collect your voice and image and to use them as described in this Privacy Policy, in accordance with the Terms and Conditions. GTL may also collect a copy of a government issued from of identification bearing your photograph.

Social Media

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

Information About Incarcerated Individuals

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.

Registration

In order to access our products and services you will need to register with the Service. You may register with the Service either through the Site or by phone when you speak with one of our authorized customer service representatives or use our automated voice service. As part of the registration process you may be asked to provide your name, mailing address, phone number, and email address, and to create a user name and password.

Purchases

If you wish to purchase products or services through the Service, we will require sufficient information to complete your purchase, including your credit card or other payment card information. We may also capture your image when you use one of our payment services kiosks.

Personal Communications to Us

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.

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.

Do Not Sell

ViaPath does not sell personally identifying information about the users of our Services to any third parties.

Location Information We Collect through 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.

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

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

Information Collected and Used by Third Parties

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

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

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

We may also use analytics software service providers to gather and analyze anonymous information about users of the Site. These service providers may use cookies to collect information about your purchase history, the content you view, what websites you visit immediately prior to and after visiting the Site, and your system information. The information gathered by these service providers about your use of the Site may be transmitted to and stored by these service providers. If we use these service providers, the information collected about you by these service providers would allow us to analyze your use of the Site and the Service. The Site uses Google Analytics, including its Demographics and Interests Reports feature, which in addition to the types of information described above, provides a breakdown of visitors to the Site on an anonymous aggregate basis by age group, gender and interests. To learn more about how Google Analytics collects and uses information, and how you can control information sent to Google you can visit https://policies.google.com/privacy.

Aggregate Information

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.

How We Use Your Information

We may use information collected from or about you 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;
• to deliver targeted display advertisements and offers by email;
• 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.
• for purposes not provided for in this privacy policy, but if we do, we will notify you (and, if necessary, obtain your consent) before using your personal information in this way

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.

Service Providers

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.

Our Affiliates

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

Transfer or Assignment in Connection with Business Transfers or Bankruptcy

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

Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies

To the extent permitted by law, we will disclose your information to government authorities or third parties if: (a) required to do so by law, or in response to a subpoena or court order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect our property or other rights or those of other users of the service, third parties or the public at large; or (c) we believe that you have abused the Service by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws or in violation of our Terms of Use. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

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 “Contact Us” 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.

California Residents Privacy Rights

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: privacy@gtl.net, 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 of 2018 (CCPA), effective January 1, 2020, provides California residents with rights regarding personal information listed below. To exercise these rights please review the sections below.

Right to Know

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 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.

Response Timing

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

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 Policy followed by your submission of information to us through the Site or in connection with the services represents your agreement to the transfer of your information to the United States.

Changes to this Privacy Statement

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

Release

By accessing and using our website, equipment, and services, you hereby release and forever discharge ViaPath, 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 websites and services as well as the use of the Data in the manner described herein.