General Policy Statement:

 The following policies apply to mass market broadband Internet services offered by Cordova Telephone Cooperative, Inc. (CTC) and CTC’s subsidiary company, Cordova Wireless Communications, Inc. (CWC).  CTC/CWC also offers enterprise level services that can be individually tailored to customer needs.  Information on CTC/CWC enterprise services can be obtained by calling #907-424-2345 (CTC) or #907-424-2300 (CWC) or stopping by the CTC business office at 611 Second St. or CWC business office at 621 Second St., Cordova, Alaska. You can also visit CTC’s website, www.ctcak.net, or /CWC’s website at www.cwcak.net and look for the internet links. It is CTC/CWC’s policy to provide robust and reliable access to the Internet for all of its residential and commercial mass market end user customers.

 Because network resources are shared by all users, CTC/CWC has implemented the following policies to govern mass market Internet service.  These policies are designed to: (i) ensure that shared network resources are allocated fairly among all users; (ii) allow users and prospective users to understand service policies and any significant limitations on the service;  and (iii) provide a foundation that assures customers that they can rely on consistently receiving the level and quality of service to which they subscribe.

 CTC/CWC does not block access to, nor discriminate against, any lawful website or Internet application and, with respect to fixed Internet access services, CTC/CWC supports the ability of users to select and attach the equipment of their choice to the network so long as that equipment: (a) is used for a lawful purpose consistent with CTC/CWC’s Acceptable Use Policy; and (b) does not harm the network or degrade network performance for other users.

 Customers are encouraged to familiarize themselves with the following policies which are deemed part of their Internet Service Agreement. CTC/CWC gives a copy of the Internet Services Agreement and Acceptance Use Policy to the customer upon purchasing their Internet Services from CTC &/or CWC.  By using CTC/CWC’s Internet Service, the customer accepts, agrees to be bound by and to strictly adhere to, these policies.  The customer also agrees to be responsible for compliance with these policies by third parties, such as friends, family members or guests that make use of the customer’s service accounts or equipment to access the network for any purpose, with or without the permission of the customer.

 The Internet Service Agreement is posted on CTC/CWC websites and emailed to all users annually.

Acceptable Use Policy:

 1.  General Policy.  CTC/CWC reserve the sole discretion to deny or restrict your service, or immediately to suspend or terminate your service, if the use of your service by you or anyone using it, in our sole discretion, violates the CTC/CWC’s Internet Service Agreement or is objectionable or unlawful, interferes with the functioning or use of the Internet or the CTC/CWC network by or other users, or violates the terms of this Acceptable Use Policy (“AUP”).

 2. Specific Examples of AUP Violations.  The following are examples of conduct which may lead to termination of your Service. Without limiting the general policy in Section 1, it is a violation of the Agreement and this AUP to: (a) access without permission or right the accounts or computer systems of others, to spoof the URL, DNS or IP addresses of CTC/CWC or any other entity, or to penetrate the security measures of CTC/CWC or any other person's computer system, or to attempt any of the foregoing; (b) transmit uninvited communications, data or information, or engage in other similar activities, including without limitation, "spamming", "flaming" or denial of service attacks; (c) intercept, interfere with or redirect email or other transmissions sent by or to others; (d) introduce viruses, worms, harmful code or Trojan horses on the Internet; (e) post off-topic information on message boards, chat rooms or social networking sites; (f) engage in conduct that is defamatory, fraudulent, obscene or deceptive; (g) violate CTC/CWC’s  or any third party's copyright, trademark, proprietary or other intellectual property rights; (h) engage in any conduct harmful to the CTC/CWC network, the Internet generally or other Internet users; (i) generate excessive amounts of email or other Internet traffic; (j) use the service to violate any rule, policy or guideline of CTC/CWC; (k) use the service in any fashion for the transmission or dissemination of images containing child pornography or in a manner that is obscene, sexually explicit, cruel or racist in nature or which espouses, promotes or incites bigotry, hatred or racism; or (l) download or use the Service in Cuba, Iran, North Korea, Sudan and Syria or in destinations that are otherwise controlled or embargoed under U.S. law, as modified from time to time by the Departments of Treasury and Commerce.

3.  Copyright Infringement/Repeat Infringer Policy. CTC/CWC respects the intellectual property rights of third parties. Accordingly, you may not store any material or use CTC/CWC systems or servers in any manner that constitutes an infringement of third party intellectual property rights, including under US copyright law. In accordance with the Digital Millennium Copyright Act (DMCA) and other applicable laws, it is the policy of CTC/CWC to suspend or terminate, in appropriate circumstances, the service provided to any subscriber or account holder who is deemed to infringe third party intellectual property rights, including repeat infringers of copyrights.

In addition, CTC/CWC expressly reserves the right to suspend, terminate or take other interim action regarding the service of any user or account holder if CTC/CWC, in its sole judgment, believes that circumstances relating to an infringement of third party intellectual property rights warrant such action. These policies are in addition to and do not affect or modify any other rights CTC/CWC may have under law or contract. If you believe that copyrighted material has been used in violation of this policy or otherwise been made available on the service in a manner that is not authorized by the copyright owner, its agent or the law, you may contact our Designated Agent as follows:

Howard Shapiro

Law Firm of Bennet & Bennet

4350 East West Highway, Suite 201

Bethesda, Maryland  20814

#202-371-1500  #202-371-1558  Fax

hshapiro@bennetlaw.com

4. CTC/CWC may, but is not required to, monitor your compliance, or the compliance of other subscribers, with the terms, conditions or policies of the Internet Service Agreement and AUP. You acknowledge that CTC/CWC shall have the right, but not the obligation, to pre-screen, refuse, move or remove any content available on the service, including but not limited to content that violates the law or this Agreement.

I.                   SYSTEM PERFORMANCE

 Performance Disclosure:

 CTC/CWC provides residential and commercial mass market customers with a choice of data plans to meet their needs. CTC/CWC also provides enterprise level services that are custom tailored to a specific project and individually priced based on the needs and criteria established by the Enterprise customer.

 1.  CTC/CWC broadband service is delivered to our customers by a high performance undersea fiber optic cable to the world; plan options/speeds, maximum usage and prices are outlined on the CTC/CWC web sites, www.ctcak.net and www.cwcak.net.

 2. CTC/CWC ensues that our shared network resources are allocated fairly among all users and our ISP broadband capacity exceeds twice the amount needed for peak usage.

CTC/CWC offers the following mass market services and typical speed ranges.

The below speeds were calculated based upon real time performances.

 Service                        Download (Mbps)       Upload (Mbps)            Latency (ms)

256                  .25                               .25                               64

512                  .50                               .50                               64

1 MB               1                                  1                                  64

2 MB               2                                  2                                  64

3 MB               3                                  3                                  64

4 MB               4                                  4                                  64

10 MB             10                                5                                  64

While CTC/CWC provisions its network and equipment to ensure that its customers can enjoy the speeds to which they subscribe, Internet speeds generally result from a “best effort” service and are dependent on a number of variables, many of which are outside the control of an Internet Service Provider.  Such variables include: the age and processing capability of the user’s terminal device or computer;  the number of applications running simultaneously;  the presence of viruses or malware; whether the terminal equipment is connected to the network by wire or by wireless; the distance the data packets must travel between  the user and the website; the presence of congestion on and technical configuration of any intervening networks; any gating or congestion management schemes employed by websites to limit download or upload speeds in cases where multiple users are served simultaneously.  CTC/CWC does not guarantee that a customer will achieve the speeds set forth above at all times. Rather, the foregoing data speeds represent the best information available to CTC/CWC of the typical speeds a customer can expect to experience under normal operating conditions.

 Speed tests that allow customers to test the upload, download and latency performance of their broadband data services are available free of charge from a number of sources. Generally, these tests are influenced by the same variables that affect Internet speed set forth above.  Accordingly, the speed results would not be expected to match a test of the CTC/CWC network conducted under laboratory conditions.  Please note, however, that all speed tests use different methodologies to calculate Internet connection speed so each of the tests would be expected to yield different results.  Accordingly, each of these tests should be viewed as a helpful guide rather than as a definitive measurement of performance. The following are several sites, unaffiliated with CTC/CWC that provides speed testing:

 http://www.speedtest.net

http://netalyzr.icsi.berkeley.edu

http://speedtest.anc.acsalaska.net

II.   NETWORK MANAGEMENT

 Network Management Policy

 CTC/CWC utilizes a fully redundant network architecture that is designed to provide users with true broadband speeds and reliability even during times of peak demand. The network has been constructed to meet projected traffic demands and is fully scalable to allow for capacity to be added to meet customer needs and to support newly developing and increasingly sophisticated applications well into the future.  However, congestion can occur on any IP network, and, when it does, packets can be delayed or dropped, leading to service degradation and delays.  Because network resources are shared by all end users, CTC/CWC has implemented a traffic management policy designed to ensure that all users are able to utilize their fair share of network resources during periods of high demand.

 CTC/CWC employs a protocol agnostic congestion management policy that does not discriminate against particular applications.  Users remain free to access the websites of their choice and run the applications of their choice consistent with the AUP. CTC/CWC deploys quality of service and network management servers and software that constantly monitor aggregate network traffic levels.  When traffic levels exceed 80% of provisioned capacity at any node, the system software examines the level of customer usage at a particular node for the past one minute. If a particular customer or group of customers is determined to be the source of high volume of network traffic, the traffic from that customer or group is temporarily assigned a lower priority status. Typically, with the sophisticated equipment CTC/CWC now operates this practice, is seldom, if ever, enforced.  Once traffic levels drop below the levels that triggered the congestion management sequence for a period of fifteen minutes, the traffic of the high capacity users is returned to normal priority status.  It should be noted that when a user’s traffic is assigned a lower priority status, their data packets will not be delayed or dropped as long as the aggregate traffic on their segment does not exceed provisioned capacity for the segment as a whole.  However, in cases where demand exceeds capacity, it is possible that the data traffic of any user could be delayed.

 Prioritization of packets can be used for other purposes as well, such as to ensure the reliability of applications that demand real time or near real time communications such as public safety communications and, in the context of mobile data services, E-911 communications.  Generally, provisioned data speeds for CTC/CWC’s mass market services are sufficient to support such applications as Voice over IP (VoIP), gaming, web surfing, or most streaming video.  However, because CTC/CWC’s residential, mass market broadband service generally does not prioritize such traffic it is possible that certain applications requiring real time communications may perform at less than optimal levels.

 CTC/CWC does take measures to protect its network and ensure that its AUP is enforced.  For example, CTC/CWC has installed the most sophisticated and modern equipment the industry has to offer to prevent spam, viruses, and other malware and to monitor and prevent denial of service attacks. CTC/CWC does not generally interfere with or manage the use of specific protocols or ports. 

Device Attachment/App Policy:

 CTC/CWC provides both fixed and mobile data services.

  With respect to fixed broadband services, users may generally attach the devices of their choice and run the applications of their choice, subject to the limitations of their data plan and the terms of their service agreement and AUP. While many devices such as routers, Bluetooth and WiFi cards, laptops,  notebooks and tablets are readily available from third party sources, such as consumer electronics retailers, other devices, such as DSL modems, proprietary network gateways, and WiMax base stations must be provided by or leased from CTC/CWC.  Users are advised to contact CTC ISP www.ctcak.net, click on the Internet link, Services, before purchasing any third party equipment to ensure compatibility with the network. CTC/CWC is not responsible for the compatibility, suitability or functionality of any equipment that is provided by the customer or any third party, and the customer remains fully responsible for ensuring that any such equipment does not cause any harm to the network or degrade the service of other users.

 Mobile handsets are offered as part of CWC’s mobile data service plans.  Customers are provided with a variety of handset options and a choice of data plans tailored to their individual needs and circumstances. It may not be possible to use the handsets utilized by one mobile data provider with services offered by another mobile data provider due to differences in spectrum, data platform and air interface.

 All users, fixed and mobile are fully responsible for securing their equipment, including wireless routers, to prevent unauthorized access to the network by third parties and will be held fully responsible for the actions of such third parties that gain unauthorized access to the network through unsecured end user equipment.

 III.  COMMERCIAL TERMS

 Pricing/Minimum Terms:

 CTC/CWC ISP service is on a month to month basis; if customers choose to sign on a longer term we have provisions to accommodate that request. Our pricing and service plans with options are listed on our Internet application and websites at www.ctcak.net, click on the Internet link, Services and www.cwcak.net.

 A. If your service plan does not include a minimum service term or, if it does and you reach the end of the minimum service term, your service term will be “month-to-month” and will not be subject to an Early Termination Fee if you cancel your service.

 B. If your service term is month-to-month, CTC/CWC can change the price of your service by providing you at least one billing cycle’s notice of the change.

 Maximum Monthly Data Caps:

 A. Your service order indicates whether you are subject to a maximum monthly data cap on your service.  The cap states the aggregate number of megabytes of data that you may send and receive using the service in a single billing cycle.  If your use of the services exceeds the cap in any billing cycle, you will be subject to an additional charge of $.01/MB. The amount of this charge appears on your service order. CWC’s local data plan in unlimited and has no maximum usage limits; however, there may still be limits on data roaming.

 B. CTC/CWC will attempt to contact each customer via e-mail or SMS before monthly caps are exceeded. However, it is each customer’s responsibility for keeping track of his or her data use.  CTC/CWC makes current data usage information available to its customers. You may track your usage of the CTC DSL service by visiting CTC’s website at www.ctcak.net and clicking on the Internet link, Internet usage. At the present time CWC does not have the capability to track roaming data usage.  Any unused data in a given billing cycle does not “roll over” to future billing cycles.

  Changing or Cancelling Service:

 A. If you cancel your service, in addition to any applicable Early Termination Fees as stated in the CTC ISP application and CWC agreement, you must pay for your use of the service up until the date on which you cancelled, including charges for exceeding any data cap that applied to your account, and applicable taxes.

 B. If, during the minimum service term, you decide to change to another CTC/CWC service plan (for example, one with different rates or usage allowances) or to add additional services, such as international roaming, to your plan, then CTC/CWC have the right to restart the minimum service term from the beginning of the change in plan or addition of service.

 C. If, during the minimum service term, CTC/CWC materially changes the terms of your service you may terminate the service without paying an Early Termination Fee.

 For complete details please visit our web sites for review of the Internet Service Agreement, www.ctcak.net, & www.cwcak.net and click on the Internet link.

Privacy Policy Related to Network Management Practices:

 If you subscribe to CTC/CWC Internet access services, we may automatically measure and monitor network performance and the performance of your Internet connection to improve your, or our, overall service levels.  If you contact us for service support, we also may access information about your computer, wireless device or other device settings to provide customized technical support or to install specific applications or services that you use or that are necessary to the applications or services you use.

 CTC/CWC will not gather information from your use of our Internet access services to direct customized advertising specifically to you based on your visits over time and across different non-CTC/CWC websites, unless we first provide you with notice of our plan and obtain your affirmative consent.

 Please note that CTC/CWC is not responsible for information, content, applications or services provided by others. Before you access, use, link to or download a service or application on your computer or wireless device, you should review the associated terms of service and privacy policy. Personal information you submit in those contexts may be read, collected or used by the service or application provider and others associated with these forums in a manner different from that described here.

 For more information on CTC/CWC privacy practices click on our websites at www.ctcak.net  and www.cwcak.net   and click on the Privacy Statement link at the bottom of the home page.

Information Provided to Us by Third Parties

 When you purchase products or apply for service with us, we may obtain credit information about you from outside credit reporting agencies to help us with customer authentication and credit-related decisions.

 CTC/CWC obtains information from outside companies that collect consumer information such as demographic and interest data. We use this data and combine it with other information we have about you to help us predict customer preferences and to direct marketing offers that might be more relevant to you.

 We may also obtain contact information and other marketing lead information from third parties, and may combine it with information we have to contact you or direct CTC/CWC's marketing offers to you.

 Cookies:

 A cookie is a small data string that is written on your computer hard drive by a web server. (A web server is the computer that hosts a website and responds to requests received from your computer). Cookies can play an important role in providing a good customer experience using the web, such as enabling a website to maintain information when a user's web browser requests a series of web pages.

 Cookies generally hold information, including data strings that contain a unique user ID which allow websites, including CTC/CWC websites, to customize your experiences on the sites and gather information about your navigation of the sites. Information gathered from cookies also helps us understand how our sites are performing and provides website usage information to support customizing and improving our sites and their messaging and advertisements. We also use cookies to help verify the identity of a website user or to recognize you as a registered user and remember your settings and preferences.

 You can manage cookies by using features and functions available on most Internet browsers. For example, most browsers will allow you to choose what cookies can be placed on your computer and to delete or disable cookies. You can find instructions for managing cookie controls on websites for particular browsers. Please note that disabling cookies may prevent you from using specific features on our sites and other websites, such as ordering products or services and maintaining an online account.

 Cookies associated with your Flash Player may be removed by managing your settings with Adobe by visiting this web site:  http://www.adobe.com/products/flashplayer/security/.

 Web Beacons

 CTC/CWC and third-party advertisers may use web beacons. Some CTC/CWC websites contain web beacons in the form of clear .gif files, which are electronic images that allow for the collection of information about your interactions on our sites. Web beacons may be used to place advertisements, to understand website traffic patterns and the number of visitors to our website, and to measure the effectiveness of advertisements or email advertising messages.

 Additional Information for Mobile Wireless Customers

 CTC/CWC collects and uses mobile device location data for a variety of purposes, including providing our mobile voice and data services and emergency services such as E-911.

 Many types of wireless applications and services use mobile device location data, including applications provided by other companies and wireless device operating systems. When you are considering new applications or services, you should carefully review the location-based services' or application providers' privacy policies to learn how they collect and use your information.

Redress Options:  End User Complaints/Questions

 CTC/CWC customers are encouraged to contact CTC/CWC to discuss questions or complaints that they may have regarding their CTC/CWC Internet/data services by visiting or calling the appropriate office at (CTC)  #(907) 424-2345, 611 Second Street, PO Box 459, Cordova, AK  99574 and/or  (CWC) #(907) 424-2300, 621 Second St., PO Box 438, Cordova, AK  99574.