Network Management Policies

I. Commitment
Conneaut Telephone Company / Suite224 Internet is committed to providing broadband access service based on network management policies that protect and empower our broadband access customers, and maximize the benefits of the Internet experience for all customers.

II. General Policies
A. Conneaut Telephone Company / Suite224 Internet will manage its network and provide access in accordance with the Federal Communications Commissions's (FCC's) Open Internet Rules (adopted December 21, 2010) and in compliance with any future Internet policies or rules adopted by the FCC. To ensure Open Access to the Broadband Internet,
Conneaut Telephone Company, Inc. will not unjustly or unreasonably:

• Block, interfere with or degrade an end user's ability to access, use, send, post, receive, or offer lawful content (including fair use), applications, or services of the user's choice;

• Block, interfere with or degrade an end user's ability to connect and use the end user's choice of legal devices that do not harm the network;

• Prevent or interfere with competition among network, application, service or content providers;

• Engage in discrimination against any lawful Internet content, application, service or service provider with respect to network management practices, network performance characteristics, or commercial terms and conditions;

• Give preference to affiliated content, applications, or services with respect to network management practices, network performance characteristics, or commercial terms and conditions;

• Charge a content, application, or service provider for access to the Company's broadband Internet access service end users based on differing levels of quality of service or prioritized delivery of Internet protocol packets;

• Prioritize among or between content, applications, and services or among or between different types of content, applications, and services unless the end user requests to have such prioritization.

B. Conneaut Telephone Company / Suite224 Internet will
• Provide connections and transport servies to the public Internet customers;

• Negotiate in good faith with all requesting parties making a bona fide request for interconnection or wholesale services;

• Provide rates and terms for interconnection that are reasonable and Nondiscriminatory;

• Not forward outbound SMTP traffic on a dynamically assigned IP address in an attempt to reduce spam in the network

III. Network Security and Congestion Management Policies

For the safety and privacy of our access customers and with the respect for all customers, Conneaut Telephone Company / Suite224 Internet:

• Utilizes standard industry practices for safeguarding children, intellectual property rights and our customers' privacy and security;

• Follows standard best efforts for Internet delivery with respect to allocation of capacity without differentiation among applications, providers, or sources;

• Complies with applicable laws and regulations, including the Children's Online Privacy Protection Act, with requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13;

• Complies with the Online Copyright Infringement Liability Limitations Act, a portions of the Digital Millennium Copyright Act that allows Internet service providers to remove or disconnect customer access to copyright infringing material;

• Uses generally accepted technical measures to provide acceptable service levels to all customers, such as application-neutral bandwidth allocation, as well as measures to address service attacks, illegal content and other harmful activities to protect network integrity and reliability; and

• Reserves the right to prioritize traffic based on real time and non-real time applications during heavy congestion periods based on generally accepted technical measures.

IV. Commercial Pricing

Conneaut Telephone Company / Suite224 Internet, maintains a price guide for broadband access on its website, please click on the following link for pricing information

http://www.conneauttelephone.com/internet.html

Contact Us: Questions, Comments, and Concerns

If you have any questions about the Conneaut Telephone Company / Suite224 Internet Network and Management Policies:
• You may contact us by calling our business office at 440-593-7113
• You can write to us and send to the following address P.O. Box 579, Conneaut, Ohio 44030;
• Stop by our business offices at 224 State St., Conneaut, Ohio 44030
• Or email us at sales@suite224.net

Online Privacy and Data Security Policy

Conneaut Online Privacy and Data Security Policy
The Conneaut Telephone Co. is committed to protecting your privacy when you visit the
www.conneauttelephone.com website. Accordingly, Conneaut has instituted policies
intended to ensure that your personal information is handled in a safe, secure and
responsible manner. This privacy policy will inform you regarding the kind of
information that Conneaut collects, how it is used and with whom it may be shared. As
new technologies emerge, this policy may change at any time without advance notice.
Conneaut encourages you to review this privacy policy each time you visit the website.
Any changes will not affect Conneaut's usage or disclosure of information collected prior
to the change in policy.
Storage, Use and Disclosure of Customer Information
Collection of Personally Identifiable Information
To maximize your online experience, Conneaut may request that you provide
Personally Identifiable Information when you access your account online and/or
authorize an online payment. This may include your name, address, age, telephone
numbers, account number, service ID number, billing and transaction information, social
security number, user IDs and passwords, credit card information, e-mail addresses,
contact information and any other information you voluntarily provide to Conneaut.
Use of Personally Identifiable Information
Conneaut will use all of the Personally Identifiable Information provided by you at the
www.conneauttelephone.com website only to the extent necessary to provide you with
full access to the Conneaut website and services. Conneaut may also aggregate
information about customer and website users for a variety of purposes, including
disclosure to third parties. However, such aggregate information will contain no
Personally Identifiable Information and cannot be used to identify individual customers.
Conneaut will maintain a subscriber's Personally Identifiable Information only for so long
as the information serves a business purpose. Such business purposes include, but are
not limited to, the maintenance of records for financial and tax accounting purposes. In
the event that Conneaut determines that certain Personally Identifiable Information no
longer serves a business purpose, that information will be destroyed.
Disclosure of Personally Identifiable Information
Conneaut publishes and distributes without restriction telephone directories that include
customer names, addresses and telephone numbers. Conneaut is also required by law
to provide customer names, addresses and telephone numbers to unaffiliated directory
publishers for their use in creating telephone directories. If you do not wish to be
included in these directories you may choose to have a non-published number that will
not be included in the Conneaut directory nor provided to third parties. Conneaut will
not disclose any other Personally Identifiable Information obtained through the
www.conneauttelephone.com website to third parties outside of Conneaut and its
affiliates, vendors and business partners without the prior consent of the customer
unless Conneaut has the good faith belief that disclosure is necessary for the following
reasons:
• As required by law;
• To prevent unlawful or unauthorized uses of communication services;
• When Conneaut reasonably believes that disclosure is necessary to protect the
safety of its customers, employees, property or the public;
• To protect and defend Conneaut's property rights.
If Conneaut discloses your Personally Identifiable Information pursuant to one of the
above-mentioned conditions, it will do so only to the extent necessary.
In the event Conneaut receives a request for Personally Identifiable Information from
government or law enforcement personnel or a request for discovery pursuant to civil
litigation, Conneaut's policy is to cooperate only to the extent required by law.
Accordingly, Conneaut will voluntarily disclose to law enforcement, without providing
you with advance notice, Personally Identifiable Information and communications if
Conneaut reasonably believes that an emergency involving immediate danger of death
or serious injury requires disclosure without delay. Due to the number of requests
received by Conneaut and the disclosure prohibitions that oftentimes accompany
criminal subpoenas, Conneaut will not inform you of any such request.
To the extent that it is necessary for Conneaut to employ affiliates, vendors or other
third party partners to provide you with the requested services, Conneaut will only
disclose Personally Identifiable Information to such third parties if they maintain a level
of confidentiality comparable to that provided in this policy and, with the understanding
that the third parties may only use the Personally Identifiable Information to the extent
necessary to provide the requested service. Conneaut may share information pursuant
to the sale, transfer or merger of all or a portion of Conneaut's business.
Website Access Information
Conneaut will automatically collect website access information every time you access
the www.conneauttelephone.com website. This may include your IP address, domain
name, bandwidth used, URLs visited within Conneaut's website, system and connection
performance, type of browser and operating system, dates and time of access and the
Internet address of the website from which you linked directly to Conneaut's site. The
website access information is collected without any corresponding Personally
Identifiable Information. Most of this information is collected via cookies or other
analysis technologies.

Use of Website Access Information -- Cookies and Behavioral Targeting
Conneaut, its onsite advertisers or others with connections to the website may use
"cookies" to collect information about your website visit in effort to match the website's
functions to your preferences. A cookie is a piece of code that web servers store on a
user's hard drive that allows a website to store and later retrieve information from a
user's computer. It will only retrieve web access information, as described above, and
will not collect Personally Identifiable Information. The cookies will also recognize
repeat website users and allow for a personalized visit to the website by remembering
any options or preferences selected by the user on a previous visit. Conneaut may
choose to share website access information with vendors, advertisers and others.
Some of Conneaut's advertisers may utilize information collected by the cookies for
behavioral advertising. If you do not wish to permit data collection for this purpose,
advertisers that are members of the Network Advertising Initiative permit you to opt-out
of the behavioral advertising programs at the following website:
http://www.networkadvertising.org. If you wish to prevent cookies from being stored on
your hard drive, you can alter the settings on your web browser to prohibit storing any
new cookies as well as to delete any cookies previously stored in your files. However, if
you choose to delete the cookies, you may lose some functionality and personalization
of the website. Please note that your cookie preferences will be unique to each
computer used to access the website. If you access the website from a different
computer you will need to renew any opt-out choices.
Disclosure of Internet Access Information
Government entities may subpoena from Conneaut personal account information and
other internet access information. Conneaut does not assume any duty to notify you in
the event it receives such a request.
Internet Communications
Conneaut does not read email messages, instant messages, online chats or the content
of other online communications that reside on or pass through Conneaut's networks or
servers unless Conneaut is the designated recipient of such communication or unless
specifically authorized by the recipient of the communications as part of the technical
support process. If you provide your email address to Conneaut you give Conneaut
permission to reply via email to answer a specific inquiry or to provide follow-up contact.
Conneaut generally does not store copies of emails sent or received unless the user
stores the email in an account file or Conneaut is legally required to do so. Conneaut
will electronically scan incoming and outgoing email messages to identify and filter out
spam, viruses and related problems that could harm your equipment, the network or
other users.

Disclosure of Internet Communications
In general, Conneaut will not knowingly divulge to any third party the contents of a
communication stored on Conneaut's servers that has not been addressed to Conneaut
without the prior consent of the sender or the intended recipient. In general, the content
of Internet Communications may not be disclosed to law enforcement through the use of
a subpoena. However, Conneaut may voluntarily disclose, without prior notice, the
contents of Internet Communications if Conneaut has the good faith believe that
disclosure is necessary for the following reasons:
• As required by law;
• As necessary to forward the communication to its destination;
• As necessary to provide the requested service;
• As necessary to protect Conneaut's rights;
• In connection with a report for missing or exploited children;
• To a law enforcement agency if the contents were inadvertently obtained and
appear to pertain to the commission of a crime; or
• To a government entity if an emergency involving danger of death or serious
physical injury requires disclosure without delay.
Privacy Policies of Advertisers and Other Websites
This privacy policy applies only to users of the http://www.conneauttelephone.com/
website. Conneaut makes no endorsement or representations and is not responsible
regarding the content, features or privacy of any linked website. Any advertisers or
websites linked with the Conneaut website will have their own terms and conditions that
you should review on their websites.
Your Legal Rights
If you feel that Conneaut has infringed upon your legal privacy rights with its collection,
use or disclosure of your confidential information, you have the right to seek relief in a
civil action filed under federal law.
PLEASE NOTE: This Online Privacy Policy applies only to use of the
http://www.conneauttelephone.com/ website. CableSuite 541's Privacy Policy can be
reviewed here. Please contact the Conneaut Telephone Company for its policy
regarding Customer Proprietary Network Information (CPNI).
Data Security
Customer Responsibilities
You have a responsibility to maintain the security of your personal computer to ensure
your privacy is fully protected. Accordingly, you should use and regularly update your
antivirus software, firewall and operating system. You should never share personal
information with any entity whose identity you cannot confirm. Please visit the Federal
Trade Commission website for more tips and tricks on how to protect your online data
and privacy (http://www.ftc.gov/bcp/menus/consumer/data/privacy.shtm).
Conneaut's Data Security Measures
Conneaut uses 2048 bit RSA encryption technology to collect Personally Identifiable
Information through the http://www.conneauttelephone.com/ website. Conneaut then
stores all collected information in an encrypted format within controlled and secure
environments with restricted access. Conneaut is committed to taking all commercially
reasonable measures to protect the security of its customer data but does not
guarantee that its measures will prevent all unauthorized access. In the event that
Conneaut becomes aware of any unauthorized access it will promptly notify all effected
users of the breach.
Third Party Website
Conneaut's data security policies apply only to the www.conneauttelephone.com
website. Conneaut does not control the data security of any Websites you may access
using Conneaut or its affiliated internet services. Accordingly, you should review the
privacy policies of any accessed websites before disclosing any confidential information.

Website Terms and Conditions
Notification of Conneaut Services and Promotional Programs
Conneaut may send transactional and/or relationship messages to your personal email
account. If you do not wish to receive any marketing emails informing you about
Conneaut's services and promotional programs you may opt-out of receiving such
emails by updating your account information by calling 440-593-7140.
Minor's Access to the Website
Children under the age of 13 may not use the www.conneauttelephone.com website for
any purpose. Children under the age of 18 are not permitted to provide personal
information on the www.conneauttelephone.com website and Conneaut will not accept
orders from minors without the permission of their parents or guardians. If you believe
your child may have submitted personal information to the
www.conneauttelephone.com website, please contact us at 440-593-7140 and we will
delete the information.
Reviewing and Updating Account Information
If you need to review or update your account information, please contact a customer
care representative by email at billing@suite224.net or by telephone at 440-593-7140.
Limitation of Liability
Conneaut operates and maintains this site for the convenience of its customers and
visitors and is committed to abiding by the terms of this Privacy Policy. However, we do
not warrant against breaches of the Privacy Policy and make no promises to you,
express or implied, by posting this Privacy Policy.
Comments and Questions
For any comments or questions regarding this Policy, please contact us by email at
sales@suite224.net or by telephone at 440-593-7113.