Veraciti: Your Technology Company


Veraciti Online Privacy Policy

Our Commitment: Respecting and Protecting Our Customers' Privacy

Your privacy is important to us. Veraciti respects and protects the privacy of our customers. We carefully ensure the confidentiality of each customer's account information. And we recognize that, as the provider of telecommunications services, we must also ensure the privacy of each customer's telephone calling information.

All Veraciti employees are subject to Veraciti's Code of Business Conduct. The Code requires all Veraciti employees to follow every law, rule, regulation, court and commission order that applies to our business at all times. In addition, the Code specifically requires compliance with legal requirements and company policies relating to the privacy of communications and the security and privacy of customer records. Employees who fail to meet any of the standards embodied in the Code of Business Conduct may be subject to disciplinary action, including but not limited to dismissal.

THE SCOPE OF THIS PRIVACY POLICY
This Privacy Policy addresses the privacy of Veraciti retail customers and Web visitors in the United States. It identifies the type of data and information Veraciti collects, how we use it, and the steps we take to protect privacy.

All members of the Veraciti family of companies that collect and/or use customer information have agreed to the privacy practices in this Privacy Policy. These members are referred to in this Privacy Policy as Veraciti or Veraciti Member(s).


SUMMARY OF OUR PRIVACY PRACTICES
To provide our customers with their own accurate, detailed billing information, we maintain detailed records. We will not sell this Customer Proprietary Network Information (CPNI) - in any form, including billing records, calling habits or type of service - to unaffiliated third parties

We will not provide customer email addresses to outside parties for the marketing of their products.

To ensure that you will not receive recurring marketing information from us unless you choose to, we will provide you with simple instructions on each marketing email from Veraciti for you to let us know that you have chosen to stop receiving such emails from us.

We will keep customers' personal information secure and confidential through safeguards such as secure encryption technology and by requiring user names and passwords to access personal information.


WHAT INFORMATION WE COLLECT, HOW WE USE IT AND HOW YOU CAN CONTROL ITS USE
Information we collect, use and disclose to provide products and services
Veraciti collects and uses customer information or "individually identifiable information" such as name, address or phone number to monitor our customers' quality of service and to provide products and services.

Veraciti collects email addresses from customers to provide purchase confirmation and product/service information. Veraciti also collects customer email addresses from third parties in order to complete a customer profile. Email addresses may be used for marketing Veraciti-offered products and services. Veraciti email marketing practices are described elsewhere in this Privacy Policy.

We may share necessary information with outside parties, such as shipping companies, to complete an order.

We may, where permitted by law, provide information to credit bureaus, or provide information and/or sell receivables to collection agencies, to obtain payment for Veraciti-offered products and services.

Veraciti or one of our authorized agents may also use customer name, address, phone number and email address to market and sell Veraciti-offered products and services.

Information we disclose to third parties
Veraciti, as a rule, allows customers to control the disclosure of their personal information (such as name, address and telephone number) to third parties for the marketing of third-party products and services.

Veraciti must disclose information, when requested, to comply with court orders or subpoenas. We will also share information when necessary to prevent unlawful use of communications services, when necessary to repair network outages, and when a customer dials 911 and information regarding their location is transmitted to a public safety agency.

Your name and number may also be transmitted and displayed on a Caller ID device unless you have elected to block such information. Please note that Caller ID Blocking does not prevent the display of your number when you dial certain business numbers, 911, 900 numbers, or toll-free 800, 888, 877 or 866 numbers.


BACKGROUND ON CUSTOMER PROPRIETARY INFORMATION (CPNI) AND HOW WE USE IT

Background on CPNI
In the normal course of providing service, Veraciti collects and maintains certain information about customer accounts. This information, when matched to a customer's name, address and calling or originating billing telephone number is known as "Customer Proprietary Network Information," or CPNI for short.

Examples of CPNI include information typically available from details on a customer's monthly bill -- the type of service, technical characteristics, class of service, current charges, usage data and patterns.

Veraciti does not sell CPNI to third parties and abides by the federal and/or state CPNI rules that apply to all web hosting providers.
Information on restricting our use of your CPNI
If you would like to restrict the use of your CPNI for the marketing of certain products and services, please contact us. Restricting use will not eliminate all Veraciti marketing contacts.


WHAT ONLINE INFORMATION WE COLLECT AND HOW WE USE IT
When you visit our Web site
A Web visitor may choose to provide such information as name, address telephone number and email address when ordering a product or service, sending us an email, registering on a company Web site or entering surveys, contests or sweepstakes. And, Veraciti customers may choose to provide such information in conjunction with online billing.

Veraciti or one of our authorized agents may use such information to market and sell Veraciti-offered products and services.

Our email marketing practices
We periodically send customers news via email regarding products, new offers and special promotions.

We use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

If you do not wish to receive email marketing messages, you can tell us by visiting the online "unsubscribe" page accessible from Veraciti's Web site home pages. In addition, every email correspondence Veraciti sends contains instructions on how to stop additional marketing emails.

How we use and handle electronic data
When you visit Veraciti Web sites, we track information including the domain name and the name of the Web page from which you entered our sites, and how much time you spend on each of our pages.

We also collect information that is combined with other Web visitors' information, such as how many times our visitors click on each of our pages and the methods by which our site was found.

An IP address is a number that is assigned to your computer when you are using your browser on the Internet. We may collect IP addresses and Web site usage information from you when you visit our sites via the use of "cookies."
Cookies:
• A cookie is a small file that is stored on the hard drive of your computer ready for future access when you return to our sites.
• We use cookies to deliver Web content specific to you and to keep track of your online order activity. Cookies cannot pass viruses, harm your computer or pass on private information such as an email address without the computer user's intervention.
• Cookies contain session identification numbers that allow our systems to recall previous sessions for authentication efforts and assemble information from our gathered data.
• You can configure your computer's browser to alert you when a site is attempting to send you a cookie and allow you to accept or refuse the cookie.
On some Web sites, Veraciti may use small bits of computer code called "one-pixel gifs," "clear gifs," or "Web beacons" embedded in Web pages to monitor the activity on our Web sites.

We use collected electronic data and may share such data with outside parties to better design our Web sites. For example, we may share how many individuals visited our Web site and, on average how long they stayed on each page.

Third parties may collect data on Veraciti's behalf using cookies and clear gifs. This collected data is used solely to enable Veraciti Web site functionality and to better design Veraciti Web sites.

How we protect your data
We maintain and protect the security of our servers and your personal information.

To secure the information collected online, prevent unauthorized access, maintain data accuracy and ensure only appropriate use of information, Veraciti has established appropriate physical, electronic and management safeguards.

We require user names and passwords to access sensitive data.

Upon request, we will use industry standard encryption methods to protect your data transmission, e.g. SSL.

When you link from our Web site to other Web sites
Veraciti Web sites may contain links to other external Web sites. We are not responsible for the content or privacy of other Web sites.

Our policy on online access by children
Protecting the privacy of the very young is especially important.

Veraciti corporate Web sites are not designed to attract children under the age of 13 and Veraciti does not knowingly collect personal information from children on our Web sites.
Ordering online products and services from Veraciti is limited to adults age 18 or over or as otherwise legally defined.

PRIVACY POLICY UPDATES
This Privacy Policy supercedes and replaces all previously posted Privacy Policies.

Our Privacy Policy is regularly reviewed and revised to make sure we continue to serve the best interests of our customers.

We reserve the right to update this Privacy Policy to reflect any changes.

If we decide to change our Privacy Policy, we will post those changes to this Policy, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If, however, we are going to use personally identifiable information in a manner different from that stated at the time of collection we will notify Web visitors by posting a notice on our Web site for 30 days.


CONTACTING US: QUESTIONS, COMMENTS, CONCERNS

Veraciti will happily address any concerns about inaccuracies regarding your personal or Individually Identifiable information. Please contact us via telephone.

Veraciti will happily address any concerns about its online privacy practices and policies; please email us at Customerservice @ Veraciti.com.

Veraciti or one of our authorized agents may use such information to market and sell Veraciti-offered products and services.

If you have questions or concerns regarding this statement, you should contact us via email at Customerservice @ Veraciti.com .

Effective 12/13/02

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