PRIVACY POLICY

True Broadband Networks believes that when you use any True Broadband Networks product or service, you should understand when and how personal information is collected, used, disclosed and protected. That's why we have provided you with this Privacy Policy (the "Policy").

The Policy applies to all United States True Broadband Networks business units, and to all True Broadband Networks Internet traffic originated in the United States. International transactions are protected under applicable laws in the various nations where the transactions take place. The Privacy Policy applies to visits to or transactions with True Broadband Networks Websites such as www.trueh2o.com as well as to Internet services accessed through True Broadband Networks Internet services, Internet voice services, and Internet video products.

True Broadband Networks CUSTOMER INFORMATION PRIVACY PRINCIPLES

This section explains the five principles of the True Broadband Networks Privacy Policy.

True Broadband Networks protects the privacy of its Internet customers consistent with applicable law, such as the Federal Communications Commission's (FCC's) regulations that govern Customer Proprietary Network Information (CPNI).

CPNI is information that carriers of True Broadband Networks obtains or creates when it provides wireline or mobile wireless telecommunications services to a customer. CPNI includes the types of services purchased, how the services are used, and the billing detail for those services. CPNI includes, for example, the number and type of lines, class of service, current charges, calling plans, call detail records, and bill summary. The FCC does not deem a customer's name, service address or telephone number to be CPNI, consistent with the publication of this information in telephone directories. If you are a new customer of True Broadband Networks, you will receive a notice of your CPNI rights and further information on this topic from True Broadband Networks. When you have not already given carriers of True Broadband Networks your permission to use CPNI for certain marketing purposes, True Broadband Networks will give you 33 days after soliciting your consent before giving permission to our carriers to access your CPNI and True Broadband Networks will follow your directions if you choose not to provide your consent.

True Broadband Networks does not disclose CPNI outside True Broadband Networks or its authorized agents or vendors without customer consent except as required or allowed by law. When True Broadband Networks uses agents, contractors, or other companies to perform services on its behalf, True Broadband Networks requires that they protect CPNI or other sensitive personal information consistent with these Privacy Principles.

In the context of these Privacy Principles, personal information is information that is directly associated with a person such as his or her name, address, telephone number, e-mail address, activities and preferences. Nonpublic personal information generally means a subset of personal information, which is sensitive and not publicly available, such as credit card number, social security number, and bank account information. Publicly available information is information that is typically available from governmental records, telephone and other public directories, widely distributed media such as newspapers and radio, and from companies that provide demographic or marketing materials to others as a part of their business. Publicly available information includes contact information, such as name, address, telephone number, email address, activities, and preferences.

These principles apply generally within True Broadband Networks.

1. True Broadband Networks creates, obtains uses your personal information to provide you the products and services you order, and to present you with product and service offerings that we believe may interest you.
2. True Broadband Networks provides its customers opportunities to control whether True Broadband Networks (a) uses Customer Proprietary Network Information (CPNI) to sell them different categories of communications-related products and services, as well as non-communications related products and services, and (b) contacts them with offers on products and services.
3. True Broadband Networks does not disclose CPNI and other nonpublic personal information (such as credit card numbers), without your consent or direction, except to business partners involved in providing True Broadband Networks service to customers, or as required or allowed by law. When True Broadband Networks discloses CPNI or other nonpublic personal information to business partners, the True Broadband Networks contract with the business partner protects the nonpublic personal information from uses outside of those necessary to assist in providing True Broadband Networks service. True Broadband Networks will disclose CPNI and other nonpublic customer information as specifically directed by customers, such as when a customer has made another company the agent of the customer for purposes of arranging service.
4. True Broadband Networks endeavors to make CPNI and other nonpublic personal information contained in its records available to customers through its customer service representatives.
5. All True Broadband Networks associates are covered by a code of conduct, which makes them responsible for ensuring the privacy of CPNI and other nonpublic personal information.

These five Principles explain True Broadband Networks's commitment to protecting the privacy of nonpublic personal information. In order to serve customers, True Broadband Networks must develop, obtain and use sensitive nonpublic personal information and True Broadband Networks recognizes that its customers are rightfully concerned that their information be used for only appropriate purposes and that their nonpublic personal information be protected from inappropriate use or disclosure. True Broadband Networks's goal is simple: to balance the interests and concerns of our customers dealing with privacy of their information with their interest in receiving quality service and information about useful new products.

INFORMATION WE COLLECT ABOUT YOU

We collect personal information about users of our products or services in the normal course of our business. This is how we know where to send you a bill for service, for example, or to ensure you are qualified for the service plan you select, or to identify you when you call for customer assistance. The information we collect also helps us improve and keep you informed of new services and products.

Personal information is information that is directly associated with a specific person such as his or her name, address, telephone number, e-mail address, activities, and personal preferences. Our definition of personal information does not include de-identified information. This is information that we collect about users, a category of services, or customers and from which any personal information has been removed. This data helps us understand trends and customer needs so that we can better consider new services or tailor existing services to customer desires. De-identified data also might be purchased by or shared with a third party: for example, one interested in locating a business in a particular part of town.

For our business and government customers, our customer is the business or government entity purchasing the service or product for its employees or other authorized users. If you receive certain pricing, terms or other benefits through a business or government customer's agreement with us, this Policy governs your personal information. If the business or government customer requests information about your account or usage of the services, we may share such information. For example, we may need to provide such information to determine your continued eligibility to receive the services under an agreement or the law, such as in the case of priority access.

Here are some examples of the types of personal and other information we collect and when we collect it. You should refer to the rest of this Policy to see how we use, disclose and protect that information:

Information You Give Us: We collect personal information you give us when you purchase a True Broadband Networks product or use our services. When you purchase phones, accessories, or services, we may request information about you, such as the following types of information:

• Name
• Shipping and/or billing address
• Credit card number or account number
• Residential or business phone or fax number
• Email address
• Date of birth
• Social Security Number
• Driver's license number

For corporate accounts, we may ask you for one or more of the following types of information:

• Federal Tax ID
• Company name
• Other information your employer may ask us to collect, such as purchase order number, employee number, and the like

When you register for any of our services (such as our wireless, wireline, Internet, integrated voice response, or customer service), you may provide us with a user name, password, and/or response to a secret question.

You may provide information in response to surveys we conduct online or offline. If this information is connected directly to your identity, it is personal information under this Policy. Otherwise, it may be used in de-identified (or aggregate) form as described below.

You may also provide us with personal information whenever you interact with us, such as when you ask for customer service or technical assistance, or when you submit a job application.

You may have heard about "customer proprietary network information" or "CPNI." In general, this is information about your phone usage, which is a special category of personal information. A special section below explains your CPNI rights in detail.

Automatically Collected Information: We automatically receive certain types of information whenever you interact with us through our Website. For example, when you visit a www.trueh2o.com Website, our systems automatically collect your IP address, the type of browser you use, and the Website from which your visit originated. When you browse the wireless web or use our high-speed Internet services, our systems log the websites you visit. Similarly, our wireless communications systems know when your wireless device is turned on and approximately where it is located, what device you are using, and how you are using it.

Information from Other Sources: We may obtain information about you from outside sources and add it to or combine it with your personal information. For example, we may receive credit information when you initially subscribe for service. We also may use commercially available marketing information from third parties to help us better serve you or inform you about products or services that we think will be of interest to you. We sometimes receive updated delivery and address information from our shippers or other sources so that we can correct our records and deliver your next purchase or communication more easily. We often receive information from the dealer from whom you purchase your wireless phone or device prior to initiating service with us. We may receive personal information from those application service providers that bring you services through the True Broadband Networks network and with whom you subscribe. (You should always check the privacy policies of other service providers to ensure you understand your privacy choices before subscribing to any service.) And, we may purchase lists containing your personal information (postal address, phone number(s), and email address(es) from third parties for advertising purposes. Information we purchase from others is not protected as non-public personal information under this Policy.

CHILDREN'S ONLINE PRIVACY

True Broadband Networks understands that parents often purchase our products and services for family use, including for use by minors. You should be aware, however, that our products and services purchased for family use may be used by children under 13 without True Broadband Networks's knowledge. If that happens, any information collected from the usage will appear to be the personal information of the actual adult subscriber and treated as such under this Policy.

True Broadband Networks services are not intended for children and True Broadband Networks does not knowingly collect personal information from children under the age of 13.

USE OF PERSONAL INFORMATION

True Broadband Networks uses the information you provide for the purpose it was provided in the normal course of our business and to provide you with marketing communications, as detailed below. The following explains in more detail how we use personal information.

• Internal Business Use. Your personal information is used in many aspects of our business operations. We use personal information to provide you the services you request, to properly identify you when you contact us, to bill and collect for services, to ensure your creditworthiness for continued service, to determine appropriate state and local payment of taxes, to protect our rights or property, or to enforce the terms of any agreements or terms of service. We use personal information to communicate with you about your account or other matters, our services or products you use, or to respond to your requests.
• Marketing Communications. We use personal information to inform you about new products and services. We may contact you at your wireless, residential or business phone numbers, by email or text message, fax or by automated voice messaging and by direct mail. If you are a True Broadband Networks subscriber and want to change your preferences for receiving marketing communications, you may call us at the customer service number shown on your bill or send an email to info@trueh2o.com. While you may choose not to receive email or telephone marketing information from us, you will continue to receive invoices, customer service-related notifications, technical or network-related notifications and similar information from us electronically or otherwise.
• Do-Not-Call Policy. True Broadband Networks maintains its own "do-not-call" list to enable subscribers and potential customers to prevent future telephone marketing calls to any phone number. During a telemarketing call, you may be asked to contact True Broadband Networks Customer Care at a toll-free number given to you during the call if you wish to register a do-not-call request. You also may register your request by sending an email to info@trueh2o.com. True Broadband Networks will promptly record your preference, although you should allow up to thirty (30) days for your number to be removed from any True Broadband Networks sales campaign then underway. Any do-not-call request associated with a particular number will be respected by True Broadband Networks for a minimum period of five (5) years, or longer if required by law, and two (2) years for our business customers. In the event that you change your number, you should contact True Broadband Networks to remove your old telephone number and add your new number to True Broadband Networks's do-not-call list, if you want to maintain your do-not-call preference. Also, please remember, you still will receive customer service or account-related calls from True Broadband Networks. True Broadband Networks checks the telephone numbers of residential non-subscribers on the national and state do-not-call registries and does not call persons who have put their numbers on those registries, except as otherwise permitted by law. For example, True Broadband Networks may contact former customers or others with whom the company has an established business relationship unless you are listed on our internal do-not-call list.
• Wireless Commercial Mobile Messages. True Broadband Networks may send short-message (SMS) advertisements to your wireless device, but it provides you with the opportunity to opt out of such messages in the future. True Broadband Networks does not send mobile-message (i.e., text messages as opposed to SMS messages) advertisements to your wireless device without your prior consent. If you have consented to receive such commercial mobile messages from us, you may change your preference at any time by sending an email to info@trueh2o.com, by calling our Customer Care representatives at the number shown on your bill, or, by using the opt-out function in the message. The opt-out function will be operational for at least 30 days after you receive it. Remember, you will still receive customer-service or account-related messages from True Broadband Networks. Finally, if you opted in to receive commercial mobile messages from third parties, you must opt out with them directly. True Broadband Networks is not responsible for commercial mobile messages sent by unauthorized third parties, including those who purport to be selling True Broadband Networks products or services. True Broadband Networks maintains an anti-spam filter in an effort to block as many unwanted messages as possible but inevitably, some unwanted messages will get through the filter. You may report such messages to Customer Care.
• Email. True Broadband Networks maintains a "do-not-email" list for those recipients of commercial email messages from True Broadband Networks who have opted out of such communications. You may opt out of email by sending an email to info@trueh2o.com calling our Customer Care representatives at the number shown on your bill, or, by following the opt-out instructions in the email for up to 30 days after receipt. True Broadband Networks will honor your request within ten (10) business days. Remember, you may still receive customer-service or account-related messages from True Broadband Networks. True Broadband Networks is not responsible for commercial email messages sent by unauthorized third parties, including those who purport to be selling True Broadband Networks products or services but do not have our permission.

  True Broadband Networks or its agents may store e-mail messages for a brief period of time. True Broadband Networks or its partners may, without legal process, access and disclose the messages to protect both an individual during emergencies, or True Broadband Networks from unlawful or fraudulent use of its services. Additionally, you may store some information, such as pictures, for longer periods of time. True Broadband Networks may access and disclose such media without legal process to protect an individual during emergencies, or True Broadband Networks from unlawful or fraudulent use of its services.

• Direct Mail. Personal accountholders may request not to receive promotional direct mail from us by sending an email to info@trueh2o.com or calling our Customer Care representatives at the number shown on your bill. Of course, you will still receive account-related information (such as your invoice) by mail.
• Facsimile. True Broadband Networks does not send commercial information by fax, unless you request such information to be sent by fax. You may email our Office of Privacy at info@trueh2o.com or call our Customer Care representatives at the number shown on your bill if you believe you have received an unwanted fax from True Broadband Networks. Our business and government customers should contact their account representative. True Broadband Networks is not responsible for commercial fax messages sent by unauthorized third parties, including those who purport to be selling True Broadband Networks products or services but who do not have our permission.
• Customer Proprietary Network Information ("CPNI"). There are special rules related to the access, use and disclosure of customer proprietary network information or "CPNI." This Policy incorporates those rules throughout. You have a right, and True Broadband Networks has a duty, under the law, to ensure the confidentiality of CPNI. In other circumstances, we may also disclose your CPNI as permitted by law. Those circumstances are described in the Disclosure of Personal Information Policy which is available by contacting TBN via email with such request at info@trueh2o.com.

  Your name, address and phone number are not CPNI, but otherwise are covered by this Policy.

  We may use your CPNI to market additional communications and data products and services similar to the types you currently purchase from us. For example, a wireless customer can be marketed wireless Internet access, new messaging products, location-based services, interactive services, or photo or message storage, handsets or related equipment. With your opt-out permission we may also market additional products and services we and our partners sell. For example, we may sell long distance to you as a wireless customer. We may also use CPNI to contact former customers when permitted by law. And, to provide your service, we may use and disclose CPNI to our agents, affiliates, joint venture partners and independent contractors, but we restrict their use and limit disclosure of CPNI for purposes or providing service to you or to market products and services as previously described. We will also prohibit the third party from further disclosing the CPNI except as required by law and require the third party to implement safeguards to protect the confidentiality of the CPNI. If you are a new customer of True Broadband Networks, you will receive a notice of your CPNI rights and further information on this topic from True Broadband Networks. When you have not already given True Broadband Networks your permission to use CPNI for marketing purposes, True Broadband Networks will give you 33 days after soliciting your consent before using your CPNI and True Broadband Networks will follow your directions if you choose not to provide your consent.

  DISCLOSURE OF PERSONAL INFORMATION

  This section of the Policy explains when personal information may be disclosed.

  Vendors. We may share personal information with a third party to complete a transaction you have requested or to perform a service on our behalf. When the third party acts solely on our behalf, True Broadband Networks does not allow it to use your information for other purposes. For example, our vendors process and print your billing statement on our behalf. They can only use the personal information we give them to produce the billing statement.

  Your Disclosures to Third Parties Through Our Services. You may also want to take advantage of services and products offered by other companies through our wireless services. In those cases, you will be providing information to those companies directly, and information about you received by those third parties will be governed by their privacy policies, not this Policy. For example, if you are roaming on the network of another carrier, information about your usage and the numbers you dial will be available to the carrier providing the service. Also, as another example, if you purchase something using our mobile Internet service, you will be disclosing personal information directly to the company facilitating the transaction, a merchant bank and the merchant. And, if you bought your wireless device from a third party retailer or dealer, both they and True Broadband Networks will have personal information as a result of the transaction. Whenever third parties have a role in any such transaction, you should review their privacy policies as well.

  Contests and Promotions. From time to time you may be able to participate in contests, giveaways or other similar promotions we sponsor. Participation may require sharing your personal information with a sponsor of the contest, giveaway, or promotion, and you should check the rules to determine how your information will be used and shared with others. Some states also require that contest winners be filed with a state agency.

  Business Transfers. Information about our users, including personal information, may be disclosed as part of any merger, acquisition, sale of company assets or transition of service to another provider, as well as in the unlikely event of an insolvency, bankruptcy or receivership in which personal information would be transferred as one of the business assets of the company.

  Protection of True Broadband Networks and Others. We disclose personal information when we believe release is appropriate to comply with the law (e.g., legal process, E911 information); to enforce or apply our customer agreements; to initiate, render, bill, and collect for services; protect our rights or property, or those of users of our services; to protect other service providers from fraudulent, abusive, or unlawful use of, or subscription to, such services; facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government requirement, or eligibility for government benefits; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

  PRESENCE, LOCATION AND TRACKING INFORMATION

  To make wireless communications possible, our network knows the general location of your phone or wireless device whenever it is turned on. Your wireless device sends out a periodic signal to the nearest radio tower/cell site so that our network will know where to route an incoming communication and how to properly bill for the service. This is necessary to make wireless communications possible. Location information derived from providing our voice service, in addition to being covered by this Policy, is CPNI and is protected as described above.

  If you dial 9-1-1 for emergency services, we provide your call location to a public safety answering point, emergency medical service provider or emergency dispatch provider, public safety, fire service, or law enforcement official, or hospital emergency or trauma care facility. The law also permits us to disclose the call location of a device on our network without a user's consent (1) to a user's legal guardian or members of a user's immediate family in an emergency situation that involves the risk of death or serious physical harm, (2) to database management services or information providers solely to assist in delivering emergency services, (3) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires or justifies disclosure of a device's location on the network without delay, and (4) in "aggregate" form. Aggregate data is collective data that relates to a group or category of services or customers, from which individual customer identities and characteristics have been removed.

  We offer wireless location-based applications that use your wireless network location to provide the service you request. For example, you may choose to subscribe to a service that provides driving directions on your wireless device. Please review the terms and conditions for each service for additional information about how the location information will be used or disclosed. It is important to note, if you let others use location-based services to which you've subscribed as the account holder (or if you let others use your handset if such handset has location tracking capabilities), it is your responsibility to inform that user that his or her location may be tracked.

  Your wireless Internet service may also be personalized using your zip code or other location identifiers. We use this information to serve you relevant content, and we treat the information like any other personal information under this Policy.

  COOKIES AND WEB BEACONS ON THE WEBSITE

  Cookies are small files placed on your computer's hard drive by a Website when you visit. These files identify your computer and record your preferences and other data about your visit so that when you return to the site, the site knows who you are and can personalize your visit. For example, cookies enable a Website shopping cart to function so that you only have to check out once. Consequently, cookies are often tied to the use of personally identifiable information while using our site and some functionality may be lost if you choose not to accept the use of cookies.

  In general, we use cookies to collect information so that we can determine how to improve our site by seeing which areas, features and products are most popular; to personalize the site and make recommendations based on products you have liked in the past as well as to improve the site experience; and to complete transactions you have requested. Advertisers that serve ads on our site may also use their own cookies. Such outside cookies are governed by the privacy policies of the entities placing the ads, and are not subject to this Policy.

  We also use a session-based cookie that maintains a user's session for continuity of navigation while viewing the site. After closing the browser the session cookie simply terminates.

  With wireless Internet service, cookies are also used by our suppliers and third party vendors to facilitate the various services and information offered. Depending on the phone or device being used, cookies may be stored locally on the phone or device, or on servers operated by True Broadband Networks. This Internet cookie-like functionality is in place for the same reasons and designed for the same purposes as cookies placed on your computer when interacting with Internet Websites. Each site you visit while using the wireless Internet service is controlled by a separate company and their individual privacy policies will govern information they receive automatically from the cookie or information you voluntarily provide.

  A Web beacon, also known as a Web bug, is a small, graphic image on a Web page, Web-based document or in an e-mail message that is designed to allow the site owner or a third party to monitor the address and other information of the site viewing the item. Web beacons are often invisible to the user because they are typically very small (only 1-by-1 pixel) and the same color as the background of the Web page, document or e-mail message. Web beacons are represented as HTML IMG tags in the Web page; users can click on "view profiles" of the Web page to see whether the page is using a Web beacon. Web beacons collect the IP address of the computer to which the Web beacon is sent, the URL of the page from which the Web beacon comes, and the time it was viewed. Web beacons can also be linked to personal information.

  True Broadband Networks may place Web beacons on its site in conjunction with cookies to monitor how visitors are navigating and/or interacting with the site. True Broadband Networks does not link Web beacons to a visitor's personal information and generally does not permit third parties, other than those working on our behalf, to place them on our site.

  True Broadband Networks PLACEMENT OF BANNER ADS ON OTHER WEBSITES

  True Broadband Networks may use third-party advertising companies to place advertisements about our products and services on other Websites. The advertising companies may use cookies and other technology such as Web beacons or tagging to measure the effectiveness of our ads. To measure advertising effectiveness and offer selective ad content, the advertising companies may use anonymous information about your visits to our and other Websites. The use of such cookies is subject to the advertising company's privacy policy, not the policy of True Broadband Networks.

  NETWORK AND INFORMATION SECURITY

  We maintain a variety of physical, electronic, and procedural safeguards to guard your personal information. For example, we take a variety of steps to protect against unauthorized access to our systems that store personal information such as policies limiting access to those systems to authorized personnel.

  When you are ordering new services or products through the True Broadband Networks Website, we employ the Secure Sockets Layer (SSL) protocol for the transmission of the information from you to us. Also, we use encryption technologies to protect your account information when you are viewing your bill on our Website or via email. You should be aware that True Broadband Networks has no control over the security of other sites on the Internet you might visit, interact with, or from which you buy products or services.

  You should keep your user name, password or other access information safe and confidential to protect against unauthorized access to your account information and services. And you must adopt passwords that others may not guess easily.

  RETENTION OF INFORMATION

  True Broadband Networks retains all of the information it collects under this Policy for as long as there is a business need for it. In addition, we have a record retention policy that generally implements the broad range of regulatory requirements imposed on service providers for recordkeeping.

  UPDATING THIS POLICY

  True Broadband Networks will update this Policy if our practices change or if the law requires changes to it. If at any point we decide to use personally identifiable information in a manner that is materially different from what was stated at the time it was collected, we will notify you via posting on this page for 30 days before the material change is made and give you an opportunity to opt out of the proposed use at any time.

  CONTACTING US

  If you have any questions about, or complaints that concern, this Policy, please visit www.trueh2o.com or email us at info@trueh2o.com or call Customer Care at the number shown on your bill. If you prefer, you also may write us at Office of Privacy - Legal Department, True Broadband Networks, P.O. Box 13204, Edwardsville, KS 66113.  Our representatives will respond to your inquiries or help resolve any dispute concerning this Online Privacy Policy.