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Privacy Policy

Personally Identifiable Information

Grid4 does not share, disclose or sell any personally-identifiable information (such as your name, address, telephone number or e-mail address) collected online on Grid4 sites with other unaffiliated companies or organizations for non-Grid4 marketing purposes. In the future, should Grid4 decide to share such data with third parties for marketing, it will provide notification and the opportunity for its users to indicate whether they would prefer that the Company not provide such information about them to third parties. Because this information is a critical part of our business, it would be treated like our other assets in the context of a merger, sale or other corporate reorganization or legal proceeding. Grid4 also does not market to, or knowingly collect personal information from, children under the age of 13 on Company sites.

How We Use Information

Grid4 uses the personally-identifiable information we collect online principally to provide you with the service(s) you have ordered and to let you know about other offerings which may be of interest to you. Postal and e-mail address information, for example, enables communication about services offered and ordered, as well as the proper provisioning and billing of those services.

Because Grid4 makes many special benefits available to you through relationships with other businesses, Grid4 shares personally-identifiable online customer information with those businesses so that you receive the benefits to which you are entitled. We also sometimes use this information to extend special offers to you jointly with our partners.

Like most large businesses today, Grid4 uses vendors to carry out certain functions in marketing and delivering services to you (such as processing data files and sending you new order fulfillment information), and so shares online data with those vendors to the extent necessary for them to perform their work. Of course, such partners and vendors must use that personally-identifiable information only for the purpose(s) for which it was shared and protect it from any further use. Grid4 also shares such information with other industry and credit-related organizations to improve operations and to protect against fraud, security and credit risks.

We also provide personally-identifiable online information in response to subpoenas and other legal demands, and where we believe that disclosing this information is necessary to identify, contact or bring legal action against individuals who may be endangering public safety or interfering with Grid4 property or services, or with our customers’ or others’ use of them.

How We Collect Information

Grid4 collects information online by asking you for it, for example, when you order a service, apply for a job, or respond to a survey. A customer’s name, address (postal and e-mail) and telephone number are the most important pieces of information, but we might request other information, based on, for example, the service(s) being ordered or promoted.

Grid4 may also use “cookies” and similar technology to obtain information about your visits to our sites or your responses to e-mail from us – both individually and in aggregated data that does not identify you. These reporting tools tell us the parts of our web sites or e-mails in which you showed an interest or took some action, and help us improve the quality and usefulness of our sites. At Grid4, we primarily use cookies to determine what services or promotions you are interested in. While cookies help us improve your experience while visiting our sites and customize our communications to the services you may desire, you have the option to block them through your Internet browser or other commercially available software. However, doing so may make some of our sites’ features unavailable to you.

Another way we collect information online is through our affinity program partners who may provide us with information they already obtained from you online. For example when you are on a partner’s site and click on a Grid4 banner that takes you to a Grid4 site, information that the partner has received from you already may be passed to Grid4.

Security

We use encryption, firewall’s and other technology and security procedures to help protect the accuracy and security of your personal information and prevent unauthorized access or improper use. For example, you will note that while using some features of the Grid4 Web sites and online services, you will need to submit a password or some other type of authenticating information.

Your Access to Information

You may review or update the available personally identifiable information that we received from you online by accessing your account online, by contacting Consumer Service through the toll free number or e-mail address on your invoice, or through the Company contact information below. Please note that in order to better protect you and safeguard your information, we take steps to verify your identity before granting access or making corrections to your information.

Grid4 may use e-mail addresses you provide us online on Grid4 sites to send you e-mail related to Grid4 products and services or if you have affirmatively indicated a desire to receive additional information. If at any time, you would prefer not to receive further e-mail communications at that e-mail address, please contact Customer Service through the toll free number or e-mail address on your invoice. You may also send an e-mail to privacy@grid4.com.

Customer Notification Regarding Customer Proprietary Network Information (CPNI)

Grid4 is committed to maintaining the privacy of its customers. In addition to protecting your personal information as outlined in Grid4’s Privacy Policy, Grid4 employs a number of comprehensive safeguards to protect the privacy of your personal telephone records and information about how you use your services under federal law.

This document serves to explain how Grid4 is complying with Federal Communications Commission (“FCC”) rules related to the privacy of customer information and your role as our customer in assuring that your CPNI information is well protected.

What is Customer Proprietary Network Information (CPNI)?

CPNI is simply defined as a customer’s individual information that relates to the quantity, technical configuration, type, destination, location and amount of use of your telecommunications service, including the information contained in your bill. That information when matched to your name, address and telephone number is known as “Customer Proprietary Network Information” or “CPNI” for short. CPNI does not include however your published directory information or any information that is already in the public domain, such as your name, address, published telephone number or aggregate information or data that is not specific to a single customer.

Examples of CPNI include information about which services you purchase, the amount of your long distance bill or call detail information. These examples are the kind of information that Grid4 possesses because we need that information to serve you.

How do we comply?

Grid4 has established procedures and trained all employees having access to the customer data to identify what constitutes CPNI data consistent with the definition of CPNI under the Section 64.2003(g) and Section 222(f)(1) of the Communications Act of 1934 as amended (47 U.S.C. § 222(f)(1)), to identify uses of CPNI not requiring customer authorization under Section 64.2007 and to identify prohibited uses of CPNI.

Permitted Use of CPNI by Grid4 Without Your Permission Grid4 may disclose CPNI in the following circumstances: • When the Customer has approved the use of their CPNI • When disclosure is required by law or court order (i.e. emergency services, law enforcement assistance, etc.) • To protect the rights and property of Grid4 or to protect Customers and other carriers from fraudulent, abusive or unlawful use of services • To provide the services to the Customer, including assisting Customer with troubleshooting and provisioning of the purchased services. • To bill the Customer for services

Approval or Opt-Out for Marketing Communication Grid4 does not provide CPNI to other parties for marketing and thus, at this time, has not used Opt-Out notifications for this purpose. Prior to any planned CPNI disclosure to outside parties, Grid4 will initiate Opt-Out notifications.

From time to time however, Grid4 would like to use the CPNI information it has on file to provide you with information about Grid4’s communications-related products and services or special promotions. Grid4’s use of CPNI may also enhance its ability to offer products and services tailored to your specific needs. Accordingly, Grid4 would like your approval so we may use CPNI to let you know about communications-related services other than those to which you currently subscribe and which we believe may be of interest to you.

IF YOU APPROVE, YOU DO NOT HAVE TO TAKE ANY ACTION. You need to respond only if you wish to deny permission to use your information in our marketing plans. Please contact care@Grid4.com or call 888.474.3444 if you would like to deny or restrict our use of your CPNI.

Any denial or restriction of your approval remains valid until your services are discontinued or you affirmatively revoke or limit such approval or denial.

Please note your denial of use of your CPNI by Grid4 will not affect the provisioning of any services you subscribe to.

Notification of Changes to this Policy Grid4 reserves the right to change this CPNI policy at any time. Any changes to the CPNI policy will be posted to at least one of our websites, including at http://www.Grid4.com/legal-notices/.

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