Connect2First Internet, LLC

INTRODUCTION

Connect2First Internet, LLC (“Connect2First”) recognizes the importance of protecting your

personal information, and we are committing to safeguarding your privacy. Because

Connect2First respects its customers, and understands that you may be concerned about

privacy, we have instituted policies intended to protect your personal information in a safe and

responsible manner.

Connect2First’s Privacy Policy is an extension of our mission to provide quality service, excellent

support, and advanced technology. This Privacy Policy applies to the information we collect

when you subscribe to, access, or use Connect2First products, services, and websites. This

maintain, protect, and share this information. This Privacy Policy also tells you about the rights

and choices you may have when it comes to your personal information.

We take seriously the responsibility of protecting your privacy and the information we collect

about you. The objective is to protect this information to the extent reasonably possible in

accordance with this policy and normal business practices.

WHAT INFORMATION DO WE COLLECT?

To provide you with our Services, we may collect:

• Contact information which includes customer’s name, billing address, telephone

number, e-mail address as well as other information required to provide service and

billing to each customer. The use of Internet service from Connect2First shall give

Connect2First access to and collect information such as your computer’s Internet

Protocol (“IP”) address, browser type, browser version, as well as the time and date of

your use.

• Billing information, including account status and payment history. Connect2First does

not collect or store any Payment Card Industry (“PCI”) information for electronic

payments including card number, expiration date, and/or bank routing and account

numbers. All electronic payment information is stored with and processed by our

payment gateway.

• Responses to customer’s survey(s) conducted by Connect2First to identity needs or to

improve service.

•

dditional information about a customer or customer’s property and other matters

obtained through services offered by Connect2First.

When you visit our website, you may provide us with two types of information: personal

information that you knowingly choose to disclose that is collected on an individualized basis,

and website use information collected on an aggregate basis as you and others browse our

website.

Cookies are a standard feature of web browser software that allow web servers to recognize

the computer used to access a website. Cookies are small pieces of data that are stored by a

user’s web browser on the user’s hard drive. Cookies store select pieces of information that a

user accesses on a web page to simplify subsequent interactions with that website by the same

user or to use the information to streamline the user’s transactions on related webpages.

Cookies help us collect important business and technical statistics. For instance, we can use

cookies to analyze how users move from one page to another; this helps us improve navigation

on our website and make it easier for you to find things. We do not use these technologies to

capture your individual email addresses or any personally identifying information about you,

although they do permit us to aggregate information about your usage of our website.

If you choose to correspond to us through email, we may retain the content of your email

messages along with your email address and our responses. We also may send automated

messages to you pertaining to your account, such as billing invoices and other notices. We

provide the same protections for these electronic communications that we employ in the

maintenance of information received by mail or telephone. We ask that you not provide us with

confidential information such as social security through unsecured email.

If you need to update or correct your account information (such as your mailing address,

primary customer name, which services or features you subscribe to, or other details), please

call the customer service number shown on your bill.

HOW IS INFORMATION COLLECTED?

• When a customer creates an account and interacts with Connect2First regarding their

account or other services or participation in a program available through Connect2First.

• When a customer uses voice or internet service of Connect2First.

• When a customer interacts with Connect2First through its website.

• When Connect2First interacts with third parties regarding a customer such as a credit

reporting agency.

HOW DO WE USE THE INFORMATION THAT IS COLLECTED?

Connect2First collects and maintains customer information for purposes of its operations and

management. It shall not be used for any improper or unlawful purpose.

Connect2First uses the information about customers in defined and responsible ways in order

to manage, provide, and improve its products, services and operations for its customers. We

use the information we collect to:

•

Properly deliver, maintain and improve our products, services, websites and

applications;

•

Fulfill requests for new service or changes to your account or the products and services

you already receive;

•

Provide you with technical support and high quality customer service, including through

the use of recorded or monitored communications between you and our customer

service agents;

•

Create and administer a Connect2First account, including activating your service, billing,

invoicing, and debt collection activities;

•

Authenticate or otherwise provide you access to your Connect2First products and

services;

•

Provide updates, upgrades, repairs or replacements for any of our service-related

devices or software used in providing or receiving services;

•

Manage and configure our device(s), system(s) and network(s);

•

Understand how the service is being used, including through the creation of operational

and marketing reports based on de-identified and/or aggregated service usage

information;

•

Protect the security of the system, prevent fraud, detect unauthorized reception, use,

and abuse of any Connect2First product, service, website or application, and to enforce

any Connect2First policy or applicable terms of service;

•

Protect our rights, our personnel, our property, and the safety of others;

•

Maintain our accounting, tax and other records; and

•

Comply with applicable federal and state laws and regulations, as well as for the general

administration of our business.

We may use the information we collect to deliver and personalize our communications with

you. For example, if you respond to a survey, we may use that information and information

from your account to send you recommendations for additional Connect2First products or

services that may be of interest to you and to provide you with a more personalized experience.

We may use the information to remind you of a service appointment, to follow up with you

after a service request, and to send you important service-related notices and announcements.

We may send you promotional communications for products and services that may be of

interest to you through the mail, by phone or text messages, or online. Some of these

communications may be directed to you because of the Connect2First services to which you

already subscribe, and some may be directed to you because of your general geographic

location. For example, if we are launching a new service in a specific area, only residents of that

particular area will receive that promotional communication.

Data about customers’ internet usage may be complied in aggregate form, and such data may

be used by Connect2First to improve system operations, efficiency and overall customer

service.

Connect2First retains customer information for such periods of time as required by law or

regulation or as reasonably necessary to provide services.

HOW DO WE PROTECT YOUR INFORMATION?

•

Connect2First maintains customer information with reasonable and appropriate technical,

administrative, physical, and cyber safeguards to protect against loss, unauthorized access,

destruction, misuse, modification, and improper disclosure of customer information. We

strive to use commercially acceptable means to protect your personal information.

HOWEVER, UNDER NO CIRCUMSTANCES CAN CONNECT2FIRST GUARANTEE ITS ABSOLUTE

SECURITY AS NO SYSTEM CAN EVER BE FULLY PROTECTED AGAINST EVERY POSSIBLE

HAZARD.

•

Connect2First does not house or maintain any personal credit card data; such information is

handled by our payment processor. We periodically confirm that our payment gateway

provider remains in compliance with the Payment Card Industry Data Security Standard

governing the security and confidentiality of your personally identifiable information.

•

Our corporate values, ethical standards, policies and practices are committed to the

protection of customer information as described in this policy. In general, our business

practices limit employee access to confidential information, and limit the use and disclosure

of such information to authorized persons, processes, and transactions.

•

Connect2First requires its employees, affiliates, and contractors who have access to

customer information to comply with this privacy and confidentiality policy.

•

Customer information that customers may access through Connect2First’s online account

system is protected using cyber security protocols designed to prevent unauthorized third

parties from accessing such information.

DOES CONNECT2FIRST DISCLOSE OR SHARE CUSTOMER INFORMATION WITH THIRD PARTIES?

• Connect2First does not share customer information (e.g., a customer’s internet usage data

and information that can reasonably be used to identify an individual) with third parties,

except at the customer’s request, with the customer’s consent, or as described below.

• Information may be disclosed to affiliates or contractors hired by Connect2First to assist in

carrying out operations, such as service, maintenance, billing and management functions

including legal, audit and collection services. Information may also be shared with other

suppliers under shared service agreements or to meet operational requirements.

Information will only be disclosed to such persons to the extent necessary to render the

services, and only to those who agree to maintain the confidentiality and security of the

information.

•

Connect2First may disclose to and share information with commercial and consumer credit

reporting agencies for credit-related activities (e.g., the reporting of bad debts).

•

Aggregated information may be disclosed to third parties where necessary or beneficial for

Connect2First operations (for example, to improve efficiency and overall customer service).

•

We may disclose information when authorized or required by law, including a response to a

search warrant, subpoena or court or law enforcement order. For example, Connect2First

may be required by law to disclose information about you, including information that

personally identifies you, your use of our services, and the content of your communications,

to governmental entities upon receipt of valid legal process. These disclosures may be made

with or without your consent and with or without notice, in compliance with the law,

including the terms of process.

•

Connect2First may also disclose personally identifiable information about you, without your

consent, when we believe in good faith that it is necessary to protect our customers,

employees, or property; in emergency situations; to enforce our rights in court or

elsewhere, or directly with you, for violations of service terms, conditions or policies; and/or

as otherwise required by law.

•

Information may be shared with affiliates, including Connect2First’s parent company, and

partners of Connect2First, to the extent permitted by law and applicable regulations.

However, Connect2First does not sell, rent, loan, exchange or otherwise release customer

information to non-affiliated third parties or partners for their marketing purposes. While

Connect2First has no plans to do so, if Connect2First ever changes this business practice,

Connect2First will provide customers with advance notice and obtain their express consent.

•

Connect2First may partner with another party to provide specific services or goods. When

the user signs up for these services or goods, we will share names, or other contact

information that is necessary for the third party to provide these services or goods. These

parties are not allowed to use personally identifiable information except for the purpose of

providing these services or goods.

WHAT ARE YOUR RIGHTS AND OUR LIMITATIONS UNDER FEDERAL LAW?

Section 222 of the Federal Communications Act of 1934 (the “Communications ct”) imposes

limitations on Connect2First’s collection, use, and sharing of information that personally

identifies you when you subscribe to telecommunications services, including voice telephony.

This Privacy Policy is designed to comply with those requirements.

Section 222 provides privacy protections for information about the quantity, technical

configuration, type, destination, location, and amount of your use of telecommunications

services, including Connect2First Voice Services, and the information about those services

contained on your bills for those services. This information is known as customer

proprietary network information or “CPNI.” CPNI does not include your name, address, or

telephone number, which is defined by the Communications ct as “subscriber list

information.” However, that information is otherwise considered personally identifiable

information.

If you are a customer of Connect2First Voice Service, or another service that is subject to

these requirements, you have the right, and Connect2First has a duty, under the

Communications ct to protect the confidentiality of your CPNI. In addition, the FCC’s rules

provide additional privacy protections and choices regarding use and sharing of that

information.

CHANGES TO THIS PRIVACY POLICY

The most current version of our Privacy Policy is published and maintained at

www.connect2first.net. The needs of our customers and the business may change from time to

time and, when that happens, we may need to modify this Privacy Policy. If we change our

privacy policies and procedures, we will post those changes on our website to keep you aware

of what information we collect, how we use it, and under what circumstances we may disclose

it.

CONTACT CONNECT2FIRST

If you have questions about this Privacy Policy, the practices of this website, or use of customer

information by Connect2First, please contact customer service, which can be reached by phone

at 1-833-411-2234 or by email at support@connect2first.net