Tower Net Communications, Inc.

Customer Proprietary Network Information Policy

 

Tower Net Communications, Inc. (“Tower Net”) strives to maintain the privacy of its customers. Tower Net will give protections to certain information about how customers use Tower Net’s services. However, that information can help us customize and improve services we offer you.

CPNI PROTECTIONS

As a customer of Tower Net’s services, you have the right, and Tower Net has a duty, under federal law, to protect the confidentiality of certain types of services, including: (1) information about the quantity, technical configuration, type, destination, location, and amount of your use of your services, and (2) information contained on your telephone bill concerning your services you receive. That information, when matched to your name, address, and telephone number is known as “Customer Proprietary Network Information,” or “CPNI.” Examples of CPNI include information typically available from telephone-related details on your monthly bill, technical information, type of service, current telephone charges, long distance and local service billing records, directory assistance charges, usage data and calling patterns.

CPNI does not include things like customer name, address, or telephone number; aggregate information or data that is not specific to a single customer; customer premises equipment; and Internet access services.

Unless Tower Net obtains your approval, Tower Net may not use this CPNI to market products and services to you other than for services you currently purchase.

Customer proprietary network information (CPNI) is information related to the quantity, technical configuration, type, destination, location, and the amount of telecommunications a customer uses that Tower Net has access to by virtue of the customer-provider relationship. CPNI does not include the Customer name, address and telephone number, nor does it include Internet access services.

APPROVAL

From time to time, Tower Net would like to use the CPNI information it has on file to provide you with information about Tower Net’s communications-related products and services or special promotions. Tower Net’s use of CPNI may also enhance its ability to offer products and services tailored to your specific needs. Accordingly, Tower Net would like your approval so that Tower Net may use this CPNI to let you know about communications-related services other than those to which Customer currently subscribes that Tower Net believes may be of interest to Customer. IF YOU APPROVE, YOU DO NOT HAVE TO TAKE ANY ACTION.

However, you do have the right to restrict our use of your CPNI. YOU MAY DENY OR WITHDRAW TOWER NET’S RIGHT TO USE YOUR CPNI AT ANY TIME BY CALLING 1-352-398-4100. If you deny or restrict your approval for Tower Net to use your CPNI, you will suffer no effect, now or in the future, on how Tower Net provides any services to which you subscribe. Any denial or restriction of your approval remains valid until your services are discontinued or you affirmatively revoke or limit such approval or denial.

In some instances, Tower Net will want to share your CPNI with its independent contractors and joint venture partners in order to provide you with information about Tower Net’s communications-related products and services or special promotions. Prior to sharing your CPNI with its independent contractors or joint venture partners, Tower Net will obtain written permission from you to do so.

CUSTOMER AUTHENTICATION

Federal privacy rules require Tower Net to authenticate the identity of its customer prior to disclosing CPNI. Customers calling Tower Net’s customer service center can discuss their services and billings with a Tower Net representative once that representative had verified the caller’s identity. There are three methods by which Tower Net will conduct customer authentication:

  1. by having the Customer provide a pre-established password and/or PIN;
  2. by calling the Customer back at the telephone number associated with the services purchased; or
  3. by mailing the requested documents to the Customer’s address of record.

Passwords and/or PINs may not be any portion of the Customer’s social security number, mother’s maiden name, amount or telephone number associated with the Customer’s account or any pet name. In the event the Customer fails to remember their password and/or PIN, Tower Net will ask the Customer a series of questions known only to the Customer and Tower Net in order to authenticate the Customer. In such an instance, the Customer will then establish a new password/PIN associated with their account.

NOTIFICATIONS OF CERTAIN ACCOUNT CHANGES

Tower Net will notify customers of certain account changes. For example, whenever an online account is created or changed, or a password or other form of authentication (such as a “secret question and answer”) is created or changed, Tower Net will notify the account holder. Additionally, after an account has been established, when a customer’s address (whether postal or e-mail) changes or is added to an account, Tower Net will send a notification. These notifications may be sent to a postal or e-mail address, or by telephone, voicemail or text message.

DISCLOSURE OF CPNI

Tower Net may disclose CPNI in the following circumstances:

  • When the Customer has approved use of their CPNI for Tower Net or Tower Net and its joint venture partners and independent contractors (as the case may be) sales or marketing purposes.
  • When disclosure is required by law or court order.
  • To protect the rights and property of Tower Net or to protect Customers and other carriers from fraudulent, abusive, or unlawful use of services.
  • When a carrier requests to know whether a Customer has a preferred interexchange carrier (PIC) freeze on their account.
  • For directory listing services.
  • To provide the services to the Customer, including assisting the Customer with troubles associated with their services.
  • To bill the Customer for services.

PROTECTING CPNI

Tower Net uses numerous methods to protect your CPNI. This includes software enhancements that identify whether a Customer has approved use of its CPNI. Further, all Tower Net employees are trained on the how CPNI is to be protected and when it may or may not be disclosed.  All marketing campaigns are reviewed by a Tower Net supervisory committee to ensure that all such campaigns comply with applicable CPNI rules.

Tower Net maintains records of its own and its joint venture partners and/or independent contractors (if applicable) sales and marketing campaigns that utilize Customer CPNI. Included in this, is a description of the specific CPNI that was used in such sales or marketing campaigns. Tower Net also keeps records of all instances in which CPNI is disclosed to third parties or where third parties were allowed access to Customer CPNI.

Tower Net will not release CPNI during customer-initiated telephone contact without first authenticating the Customer’s identity in the manner set-forth herein. Violation of this CPNI policy by any Tower Net employee will result in disciplinary action against that employee as set-forth in Tower Net’s Employee Manual.

BREACH OF CPNI PRIVACY

In the event Tower Net experiences a privacy breach and CPNI is disclosed to unauthorized persons, federal rules require Tower Net to report such breaches to law enforcement. Specifically, Tower Net will notify law enforcement no later than seven (7) business days after a reasonable determination that such breach has occurred by sending electronic notification through a central reporting facility to the United States Secret Service and the FBI. A link to the reporting facility can be found at: http://www.fcc.gov/eb/cpni. Tower Net cannot inform its Customers of the CPNI breach until at least seven (7) days after notification has been sent to law enforcement, unless the law enforcement agent tells the carrier to postpone disclosure pending investigation. Additionally, Tower Net is required to maintain records of any discovered breaches, the date that Tower Net discovered the breach, the date carriers notified law enforcement and copies of the notifications to law enforcement, a detailed description of the CPNI breach, including the circumstances of the breach, and law enforcement’s response (if any) to the reported breach. Tower Net will retain these records for a period of not less than two (2) years.

NOTIFICATION OF CHANGES TO THIS POLICY

If we change this CPNI Policy, we will post those changes on https://www.towernetonline.com/legal or in other places we deem appropriate, so that you can be aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If you decide to continue receiving your services after we make any changes to this the CPNI Policy, you shall be deemed to have given express consent to the changes in the revised policy.

 

Tower Net Communication, Inc.’s Network Management Practices

Blocking

Tower Net believes in an open and free internet. As such, Tower Net does not block any access to lawful content, applications, service, or non-harmful devices.

Tower Net has created an Acceptable Use Policy. Any customer in violation of the Acceptable Use Policy risks termination of service.

Throttling

Tower Net does not degrade or impair access to lawful Internet traffic on the basis of content, application, service, user, or use of a non-harmful devices. Tower Net limits access speed to the network based on the advertised rate plan in based on reasonable network management. Any limitations on speed are disclosed to the customer.

Affiliated Prioritization

Tower Net does not engage in any practice that directly or indirectly favors some traffic over other traffic, including through use of techniques such as traffic shaping, prioritization, or resource reservation, to benefit an affiliate.

Paid Prioritization

Tower Net does not engage in any practice that directly or indirectly favors some traffic over other traffic, including through use of techniques such as traffic shaping, prioritization, or resource reservation, in exchange for consideration, monetary or otherwise.

Congestion Management

Tower Net does not engage in any congestion management practices.

Application-Specific Behavior

Tower Net does not block or rate-control specific protocols or protocol ports, modifies protocol fields in ways not prescribed by the protocol standard, or otherwise inhibits or favors certain applications or classes of applications.

Device Attachment Rules

Tower Net dot not have any restrictions on the types of devices or any approval procedures for devices to connect to the network.

Security

Tower Net believes in an open and free internet. As such, Tower Net only uses limited firewalls and security procedures which prevent access from unauthorized users accessing or attempting to tamper with its network from outside the network. Any specific securities should be secured on the customer site, where decisions about content filtering and restricted access can be made by the end user customer.

Tower Net does offer specific firewall services for customers at customer request.

Performance Characteristics

Service Description

Tower Net service is provided via wireless broadband technology. Tower Net transmits signal using 900mhz, 3.65ghz, and 5ghz. Access speeds are listed under the Price section below.

As a wireless technology, various factors can affect network performance and connection including weather and signal interference. Depending on these variables, customer access speeds may fluctuate, and Tower Net does not guarantee access to the listed speeds at all times.

Tower Net uses wireless technology that boasts very low latency. Depending on the service plan (see below), customers can use the service for most real-time applications including VOIP phone service, security camera service, streaming media, video conferencing.

Commercial Terms

Price

Plans:

Basic Plan: 5mbps/ 2mbps

$29.99 (excluding equipment lease fees).

No usage-based fees. No throttled service. Tower Net customers are free to upgrade or downgrade without any additional fees besides the difference in the cost of the plan. Contracts for 2 or 3 years. Early termination fees are equal to the contract balance.

Streaming Plan: 10mbps/4mbps

$59.99 (excluding equipment lease fees).

No usage-based fees. No throttled service. Tower Net customers are free to upgrade or downgrade without any additional fees besides the difference in the cost of the plan. Contracts for 2 or 3 years. Early termination fees are equal to the contract balance.

Business Lite Plan: 10mbps/10mbps

$99.99 (excluding equipment lease fees).

No usage-based fees. No throttled service. Tower Net customers are free to upgrade or downgrade without any additional fees besides the difference in the cost of the plan. Contracts for 2 or 3 years. Early termination fees are equal to the contract balance. Other network services involve networking multiple buildings and static IP addresses.

Business Standard Plan: 20mbps/10mbps

$199.99 (excluding equipment lease fees).

No usage-based fees. No throttled service. Tower Net customers are free to upgrade or downgrade without any additional fees besides the difference in the cost of the plan. Contracts for 2 or 3 years. Early termination fees are equal to the contract balance. Other network services involve networking multiple buildings and static IP addresses.

Privacy Policies

Tower Net is committed to respecting the privacy of its customers. As such, Tower Net does not inspect network traffic, store network traffic, or provide customer traffic information to third parties. Tower Net may look at customer data usage for network management purposes, however, such usage data contains no specific customer information.

See also Tower Net CPNI Policy https://towernetonline.com/faq/

Redress Options

Any questions, concerns, or comments should be directed to Tower Net’s home office.

Vice Presidents:

Drew Vermette

Matthew Middleton

Phone:

352-398-4100

Mailing Address:

PO Box 5159

Spring Hill, Fl 34609

Tower Net Communications, Inc.

Acceptable Use Policy

  1. INTRODUCTION

Tower Net Communications, Inc.’s (“Tower Net”) Acceptable Use Policy (“AUP”) is intended to help enhance the use of the Internet by preventing unacceptable use. All users of Tower Net’s Internet services (the “Services”) must comply with this AUP. Tower Net does not actively monitor, censor, or directly control any information that is stored or transmitted through the Services. We do not exercise editorial control over any content or uses of the Services except for our proprietary websites. But we reserve the right to delete any material, at our sole discretion, that may be illegal, subject us to liability, or violates the rules of this AUP. Violation of the rules of this AUP may result in any action detailed in Section 3 in addition to suspension or termination of your Services. Furthermore, we expressly reserve our rights under the law to take any other actions we deem necessary. You remain solely liable for your use of Tower Net’s services and any content that you upload, download, or transmit through them. You must exercise best efforts to ensure the security and integrity of your network or systems used to access the Services. This AUP should be read in conjunction with our Internet Service Agreement and other policies.

  1. VIOLATIONS OF TOWER NET’S ACCEPTABLE USE POLICY

The following uses of the Services are not allowed:

  1. Transmitting any material that, intentionally or unintentionally, violates any applicable local, state, national or international law, or any rules or regulations.
  2. Harming, or attempting to harm, minors in any way.
  3. Transmitting any material that threatens or encourages bodily harm or destruction of property or harasses another.
  4. Disseminating or posting harmful content including, without limitation, viruses, Trojan horses, worms, time bombs, zombies, cancelbots or any other computer programming routines that may damage, interfere with, secretly intercept or seize any system, program, data or personal information.
  5. Making fraudulent offers to sell or buy products, items, or services or to advance any type of financial scam such as “pyramid schemes,” “Ponzi schemes,” and “chain letters.”
  6. Forging of any TCP-IP packet header, e-mail header or any part of a message header. This prohibition does not include the use of aliases or anonymous remailers.
  7. Transmitting any unsolicited commercial e-mail or unsolicited bulk e-mail. Activities that have the effect of facilitating unsolicited commercial e-mail or unsolicited bulk e-mail, whether or not that e-mail is commercial, are prohibited.
  8. Accessing, or attempting to access, the accounts of others, or to penetrate, or attempt to penetrate, security measures of Tower Net’s or another entity’s computer software or hardware, electronic communications system, or telecommunications system, whether or not the intrusion results in the corruption or loss of data.
  9. Infringement of intellectual property rights or other proprietary rights including, but not limited to, material protected by copyright, trademark, patent, trade secret, or other proprietary rights of any third party.
  10. Collecting, or attempting to collect, personal information about third parties without their knowledge or consent.
  11. Reselling the Services without Tower Net’s authorization.
  12. Posting or sending software or technical information in violation of U.S. export laws.
  13. Engaging in any activity that adversely affects the ability of other people or systems to use Tower Net Services or the Internet. This includes “denial of service” (DoS) attacks against another network host or individual user. Interference with or disruption of other network users, network services or network equipment, whether intentional or unintentional, is prohibited.
  14. Using a personal account for high volume or commercial use. Users may stay connected so long as they are actively using the connection for email, newsgroups, file transfers, Internet chat, games, and browsing the World Wide Web. Tower Net maintains the right to terminate any user’s connection following any extended period of inactivity as determined by Tower Net. Pinging is expressly prohibited.
  15. VIOLATIONS OF TOWER NET’S AUP
  16. Tower Net may access, use and disclose information regarding your use of the Services to: (1) comply with the law; (2) enforce or apply our subscriber agreements; (3) initiate, render, bill, and collect for services; (4) protect our rights or property and those of our customers; or (5) protect users of those services and other carriers from fraudulent, abusive, or unlawful use of, or subscription to, such services.
  17. Tower Net may take any one or more of the following actions in response to complaints:

issue warnings: written or verbal

suspend the user’s newsgroup posting privileges

suspend the user’s account

terminate the user’s account

bill the user for administrative costs and/or reactivation charges

bring legal action to enjoin violations and/or to collect damages, if any, caused by violations.

  1. REVISIONS TO THIS ACCEPTABLE USE POLICY

Tower Net reserves the right to revise, amend, or modify this AUP, our Internet Service Agreement and our other policies and agreements at any time and in any manner. Any modifications are effective upon posting. By using the Services, you are agreeing to comply with the most recent AUP, so users should refer to the current version as posted.