OPTIMUM NETWORKING is committed to providing privacy protection in today’s ever evolving world. The goal of this Policy is to assure customers that OPTIMUM NETWORKING is serious about privacy. If you have any questions about our policy, please visit us at www.optimumnetworking.com or call (720) 248-3580.

This Policy applies to the use of “individual customer information,” meaning, information about specific customers. Generally, information that does not reveal a customer’s identity is not considered to be individual customer information. As a specific example, “aggregated information,” such as the number of individuals that access a website on a particular day, does not raise a privacy concern and is not covered under this policy.

INFORMATION COLLECTION AND USE

OPTIMUM NETWORKING obtains and uses individual customer information for business purposes only. We obtain information about our customers that helps to provide them with OPTIMUM NETWORKING services. This information may also be used to protect customers, employees and property against fraud, theft or abuse; to conduct industry or consumer surveys; and to maintain good customer relations.

Customers have many opportunities to control how we use their individual information to introduce them to new products and services. For example, OPTIMUM NETWORKING will not call customers who have expressed to us a preference not to be called for marketing purposes. Customers can also have their names removed from direct mail lists that we use. The same will be true for email if OPTIMUM NETWORKING decides to use email to send new product information to its customers.

However, we do use individual customer information internally for our own general marketing and planning purposes. Unless we have your consent, such information is combined into aggregations that do not include individual customer identities. Under certain circumstances, we are required by law to disclose the aggregated information to other companies, but in such cases customer identities are not included.

INFORMATION ABOUT COOKIES, GOOGLE ANALYTICS, AND LEADLANDER

Cookies are very small text files stored on your computer by your web browser. Our web calendar places a cookie on your computer. This website also uses Google Analytics, a web analytics service provided by Google, Inc., and ORBTR, which both use javascript and cookies to help us analyze how visitors use the site.

By using this site, you accept these cookies. By accepting cookies, you consent to the processing of data in the manner and for the purposes set out in this privacy notice.

DISCLOSURE OF INDIVIDUAL CUSTOMER INFORMATION

OPTIMUM NETWORKING allows customers to control how and if OPTIMUM NETWORKING discloses individual information about them to other persons or entities, except as required by law or to protect the safety of customers, employees or property.

For example, if OPTIMUM NETWORKING is served with valid legal process for customer identification, we may be required to release this information. In addition, under certain circumstances, we share customer information with other carriers and with law enforcement to prevent and investigate fraud and other unlawful use of communications services.

Subject to legal and safety exceptions, OPTIMUM NETWORKING will share individual customer information only with persons or entities outside the company when the customer has consented to such action, or when we have advised the customer of the opportunity to “opt-out” (to choose not to have the information disclosed). We are required to provide directory publishers with listings information — name, address and phone number — for purposes of publishing and delivering directories. Persons can ask to not be published in directories and/or directory assistance. However, if OPTIMUM NETWORKING enters into a merger, acquisition, or sale of all or a portion of its assets, a customer’s personally identifiable information will, in most instances, be transferred as a part of the transaction. In addition, 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 OPTIMUM NETWORKING billed products and services.

INFORMATION MANAGEMENT AND SECURITY

All OPTIMUM NETWORKING employees are responsible for safeguarding individual customer communications and information. OPTIMUM NETWORKING requires OPTIMUM NETWORKING personnel to be aware of and protect the privacy of all forms of customer communications — whether they are voice, data or image transmissions — as well as individual customer records. OPTIMUM NETWORKING makes clear that employees who fail to follow this Privacy and Customer Security Policy will face disciplinary action, which can include dismissal. All employees are trained regarding their responsibilities to safeguard customer privacy.

OPTIMUM NETWORKING strives to ensure that information we have about our customers is accurate, secure and confidential, and to ensure that our employees comply with our privacy policy. We will not tamper with, intrude upon or disclose the existence or contents of any communication or transmission, except as required by law or the proper management of our network. Access to databases containing customer information is limited to employees who need it as part of their job performance — and such employees follow strict guidelines when handling such information. OPTIMUM NETWORKING uses safeguards to increase data accuracy and to identify and authenticate the sources of customer information. We use locks and physical security measures, sign-on and password control procedures, internal auditing techniques and other types of security as appropriate for the information stored to protect against unauthorized use of terminals and entry into our data systems.

OPTIMUM NETWORKING requires that records be safeguarded from loss, theft, unauthorized disclosure, and accidental destruction. In addition, sensitive, confidential, or proprietary records must be protected and maintained in a secure environment. It is our policy to destroy records containing sensitive, confidential, or proprietary information in a secure manner. Hard copy confidential, proprietary, or sensitive documents must be made unreadable before disposition or recycling, and electronic media must be destroyed using methods that prevent access to information stored in that type of media. Just as employees would report stolen property, employees must report missing records and suspicious incidents involving records.

We encourage our employees to be proactive in implementing and enforcing the OPTIMUM NETWORKING Privacy and Customer Security Policy. If employees become aware of practices that raise privacy concerns, they are encouraged to report them to their supervisors as soon as reasonably possible.

COMPLIANCE WITH LAWS AND PUBLIC POLICY PARTICIPATION

OPTIMUM NETWORKING complies with all applicable privacy laws and regulations. Customer and policymaker perceptions of privacy have changed over time and will continue to do so. Changes in technology can also alter what is appropriate in protecting privacy. Laws may change accordingly. We will regularly examine – and update, if necessary – the OPTIMUM NETWORKING Privacy and Customer Security Policy.