This Subscriber Privacy Policy (“Privacy Policy”) describes how Hughes Network Systems, LLC (”Hughes”) collects information from and about you when you use the HughesNet® service, the www.myhughesnet.com site, and the HughesNet mobile app (collectively, the "Service"). This Privacy Policy also explains how Hughes may use and disclose such information, as well as your ability to control certain uses of it. This Privacy Policy does not apply to information collected from visitors or users of Hughes’ websites at www.hughes.com, www.hughesnet.com, or any other site maintained or operated by Hughes (collectively, the “Website”), which is subject to the Public Website Privacy Policy.

Hughes is committed to protecting the privacy of its subscribers. This Privacy Policy governs only Hughes’ treatment of information about subscribers of the Service. By applying for or continuing to use the Service, you agree to the terms of this Privacy Policy, as modified from time to time. This Privacy Policy does not apply to any goods or services controlled by third parties, even if those third parties are partners of Hughes.

Hughes reserves the right, in its sole discretion, to modify the terms of this Privacy Policy at any time. In the event of any material changes to the Privacy Policy, Hughes will provide appropriate notice to you. Your continued use of the Service after such notice constitutes your acceptance of the changes. You should visit this page to review the current Privacy Policy on a regular basis. The date of the last update will be posted at the end of this Privacy Policy for your convenience.

1. Information Collection

A. Personal Information

When you apply to become a subscriber of the Service, and at certain times throughout your relationship with Hughes, Hughes will ask you for personal information such as your name, address, telephone number, email address, and financial information, such as your credit card information.  

B. Usage and Service Information

When you use the Service, our systems automatically collect certain information regarding your Service use. This information may be in various formats (electronic, audio, and other), and may be collected through the HughesNet Wi-Fi Modem. Usage and Service information may include, but may not be limited to, modem and feature usage, website viewership, network traffic data, product and device-specific information and identifiers, service options you choose, and other similar information.

C. Third-Party Information and Combination of Information

Hughes may obtain additional information about you from other third-party sources and combine the information we receive from and about you, including information you provide to us and information we automatically collect through the Service, as well as information collected offline, and from third party sources.

2. Information Use

A. Use by or for Hughes

The information you provide to Hughes and the information Hughes obtains about you may be used (1) for billing and collections purposes; (2) to provide you with the products and services you request; (3) to anticipate and resolve problems with our products and services; (4) to process and respond to inquiries; (5) to contact you about products and services that may be of interest to you; and (6) for other purposes communicated to you at the time you provide or authorize the use of the information.

B. Use of your information for Advertising Purposes

Hughes may use information obtained about you through use of the Service or from third parties to provide you with marketing information and advertisements for Hughes products and services or to exclude you from certain advertisements. This “first party” advertising is part of our relationship with you.

3. Information Disclosures

Hughes does not rent, sell, or share your Personal Information with third parties other than as set forth in this Privacy Policy. Hughes may use or disclose information about you, including your Personal Information, under the following circumstances:

–Affiliates: We may share your information with a company controlled by, or under common control with, Hughes for any purpose permitted by this Privacy Policy.

–Service Providers: Hughes may share your information with third party service providers that provide business, professional or technical support functions for us (for example, to support the functions described in the previous section), help us operate our business and the Site, or administer activities on our behalf or to help you with a technical support issue and offer their owns services to you. This also includes outsourcing any of the tasks referenced in this Privacy Policy (e.g., billing, responding to inquiries).

–Credit Reporting Agencies: We may disclose your information to credit reporting agencies for reporting purposes or to obtain credit review services.

–Legal Matters; Safety: We may share your information with the proper authorities in response to a subpoena, legal order, or official request, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law. We may disclose your information to protect the security of our Service, servers, network systems, and databases. We also may disclose your information as necessary, if we believe you have acted in violation of our Terms of Use, any other legal document or contract related to our services, or the rights of any third party, or if we need to establish or exercise our legal rights or defend against legal claims.

–Sale or Transfer of Business or Assets: In the future, we may sell some or all of our assets or reorganize our corporate structure. In such transactions, customer information generally is one of the transferred business assets. In the event of a sale or reorganization of our assets, including our database, customer information may be transferred.

–Aggregate or Anonymous Non-Personal Information: Hughes may use and disclose non-personal, aggregate, de-identified, or summary information regarding users of our Service. This type of information will not identify you individually. This aggregate or de-identified data may be used, for example, to improve the Service, measure and analyze Service use, improve our other products and services, and to provide more relevant advertising.

4. Your Choices and Opt Outs

A. Cookies, Tracking Options and California Do Not Track Disclosures

Certain parts of our websites require cookies. You can adjust your device or Internet browser settings to limit certain tracking or to decline cookies. However, please note that disabling cookies may prevent you from taking advantage of certain features on the websites. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.

Our system may not recognize Do Not Track requests or headers from some or all browsers. We may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use. 

Some of our websites use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Spectrum websites, compile reports on the websites' activity, and provide other services related to website activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The websites do not use Google Analytics to gather information that personally identifies you and Google has committed not to re-identify the information it collects without your affirmative consent. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google's privacy policies. To learn more about Google's partner services and to learn how to opt out of tracking of analytics by Google click here.

B. Interest-Based Advertising Choices

To understand your choices for receiving more relevant advertising provided on our websites or across other websites and online services, please review the information below:

• To learn more about such interest-based advertising, and to opt out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit http://optout.aboutads.info.     
• To opt out from the use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) member companies, please visit http://www.networkadvertising.org/choices/. 
• To opt out of the use of your mobile device ID for targeted advertising, please see https://youradchoices.com/appchoices.   
• On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.
• You also may click on the “Ad Choice” icon on any Hughes interest-based ad that is served for more information or to opt out.

Even if you opt out, you still may receive advertising from us that is not customized based on your Website or usage information, or advertising from other third parties if they are not a DAA or NAI participating company.

C. Unsubscribing from Our Marketing Communications

We provide our customers with the opportunity to update their information or opt out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product order or servicing of your product. You may change your preferences relating to the receipt of Hughes marketing information by  unsubscribing from our email communications at any time by following the instructions contained within the email.

5. Updating Your Information

If you need to update your information, please call our Customer Service department at
1-866-347-3292 or visit myhughesnet.com and login under the "Account Information" section.

6. Your California Privacy Rights

If you are a California resident, you may request information about our disclosure of personal information to third parties or affiliated companies for their direct marketing purposes.  To make such a request, please contact us at privacy@hughes.com. You must put the statement “Your California Privacy Rights” in the subject field and provide your name and email. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. 

California residents may also take advantage of the following rights:

• You may request, up to two times each year, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information that we sold about you, the categories of third parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.
• You may request that we delete any personal information that we have collected from or about you.  Note that there are some reasons we will not be able to fully address your request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation.

Hughes does not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. 

For purposes of compliance with the California Consumer Privacy Act, in addition to the further details as described throughout this Privacy Policy, below are the categories of personal information that Hughes has collected from its consumers over the past twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA);
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Sharing your Personal Information

Hughes shares your personal information as described in Section 3 above.  In the preceding twelve (12) months, Hughes has disclosed the following categories of personal information for a business purpose with Service Providers or Credit Reporting Agencies: CATEGORIES A, B, D, and G.

Sales of your Personal Information

Hughes does not sell your personal information to third parties and has no plans to do so in the future.

How to Exercise Your California Privacy Rights

To exercise your California privacy rights, please submit a verifiable consumer request to us by either:

• Calling us at 866-569-5152
• Emailing us at privacy@hughes.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request 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.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Hughes 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.

Making a verifiable consumer request does not require you to create an account with us.

Hughes will only use personal information provided in a request to verify the requestor's identity or authority to make the request.

Hughes strives to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Non-affiliated third parties are independent from Hughes and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.

7. Minors

You must be 18 or older to apply or subscribe to the Hughes service. Hughes does not intentionally collect personal information from minors.

8. Security

We have taken certain physical, administrative, and technical steps to safeguard the personal information we collect from and about our consumers. While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.

9. Contact Us

Please direct questions, concerns, or comments about this Privacy Policy to our email address at privacy@hughes.com.

Last Updated: December 27, 2019