OUR COMMITMENT: RESPECTING AND PROTECTING YOUR PRIVACY
THE SCOPE OF THIS PRIVACY POLICY
WHAT PERSONAL IDENTIFYING INFORMATION WE COLLECT, HOW WE USE IT AND HOW YOU CAN CONTROL ITS USE

• Personal identifying information we collect and use
• Personal identifying information we disclose to third parties  
• Customer Proprietary Network Information

WHAT ONLINE INFORMATION WE COLLECT, HOW WE USE IT AND HOW YOU CAN CONTROL ITS USE

• Web usage information we collect and use
• How we use cookies, Web beacons, etc.
• Our e-mail marketing practices
• Our policy on online access by children
• Linking to other sites

HOW WE PROTECT YOUR INFORMATION
PRIVACY POLICY UPDATES
CONTACTING US: QUESTIONS, COMMENTS, CONCERNS

OUR COMMITMENT: RESPECTING AND PROTECTING YOUR PRIVACY
Satcom Direct, Inc. ("SD") recognizes that the trust of our customers and Web visitors requires vigilant, responsible privacy protections.

• We respect and protect the privacy of our customers. As a provider of telecommunications and related services and products we recognize that we must maintain the confidentiality of every customer's telephone calling and other account information.
• We also respect and protect the privacy of our Web visitors. The expansion of online services and changing technologies continues to create unique privacy concerns and we recognize the need to maintain the confidentiality of information that Web visitors reasonably expect to remain private.
• We have a long history of vigorously protecting customer and web visitor privacy. Our customers and web visitors expect, deserve and receive nothing less than our fullest commitment to their privacy. We also have an obligation to assist law enforcement and other government agencies responsible for protecting the public welfare, whether it be an individual or the security interests of the entire nation. If and when we are asked to help, we do so strictly within the law and under the most stringent conditions.

THE SCOPE OF THIS PRIVACY POLICY

• This privacy policy addresses the privacy of Satcom Direct, Inc. customers and Web visitors.
• This policy identifies the types of data and information we collect, how we use it, how you can control its use and the steps we take to protect it. The primary focus of this policy is non-public information that identifies or that is linked to the identity of a customer or Web visitor ("personal identifying information").
• In this policy, SD means Satcom Direct, Inc. and its subsidiary and affiliated entities.
• When you sign up for certain SD-offered services, you may agree to additional privacy policies that address service-specific privacy practices.

WHAT PERSONAL IDENTIFYING INFORMATION WE COLLECT, HOW WE USE IT AND HOW YOU CAN CONTROL ITS USE

Personal identifying information we collect and use

• We collect personal identifying information regarding our customers, including information customers give us, information collected as a result of the customer's relationship with us and information we obtain from other sources. Examples include name; address; e-mail address; telephone number; billing, payment, usage, credit and transaction information (including credit card numbers, account numbers and/or social security number); and demographic information.
• We also collect personal identifying information that our Web visitors choose to provide to us (e.g., name, address, telephone number, e-mail address) when registering on our Web sites; ordering SD-offered products or services; sending us e-mail; responding to our surveys; or in connection with online ordering or billing functions.
• We use the personal identifying information of a customer to provide, confirm, change, bill, monitor and resolve problems with the quality of SD-offered products and services. We also use the personal identifying information of a customer or Web visitor to develop, market and sell our products and services.
• We may aggregate the personal identifying information of different customers or Web visitors to produce data about a group or category of services, customers or Web visitors.

Personal identifying information we disclose to third parties

• We do not provide personal identifying information to third parties for the marketing of their products and services without your consent.
• We may provide personal identifying information to third parties where required to provide certain SD-offered products and services.
• We may also provide personal identifying information to third parties who perform functions or services on our behalf.
• When we provide such personal identifying information to third parties to perform such functions or services on our behalf, we require that they protect personal identifying information consistent with this policy and do not allow them to use such information for other purposes.
• We may, where permitted or required by law, provide personal identifying information to third parties (including credit bureaus or collection agencies) without your consent:
• To obtain payment for SD-offered products and services, enforce or apply our customer agreements, and/or protect our rights or property.
• To comply with court orders, subpoenas, or other legal or regulatory requirements.
• To prevent unlawful use of communications or other services, to assist in repairing network outages, and when a emergency call is made from a customer phone.
• To notify a responsible governmental entity if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires or justifies disclosure without delay.
• A customer's name and telephone number may also be transmitted and displayed on a Caller ID device unless the customer has elected to block such information.

Customer Proprietary Network Information

• In the normal course of providing telecommunications services to our customers, we collect and maintain certain customer proprietary network information, also known as "CPNI". Your CPNI includes the types of telecommunications services you currently purchase, how you use them and related billing information for those services. Your telephone number, name and address are not CPNI.
• Protecting the confidentiality of your CPNI is your right and our duty under federal law. We do not sell, trade or share your CPNI — including your calling records — with anyone outside of the SD or with anyone not authorized to represent us to offer our products or services, or to perform functions on our behalf except as may be required by law or authorized by you.
• As a general rule, we are permitted to use CPNI in our provision of telecommunications services you purchase, including billing and collections for those services. We are permitted to use or disclose CPNI to offer telecommunications services of the same type that you already purchase from us. We may also use or disclose your CPNI for legal or regulatory reasons such as a court order, to investigate fraud or to protect against the unlawful use of our telecommunications network and services and to protect other users.

WHAT ONLINE INFORMATION WE COLLECT, HOW WE USE IT AND HOW YOU CAN CONTROL ITS USE

Web usage information we collect and use

• When Web visitors access our Web sites we automatically receive certain "Web usage" information. For example, our Web servers automatically collect the visitor's IP address, the visitor's Web browser and operating system types, and the identity of the Web page from which the visitor's browser entered our Web site.
• We use Web usage information to facilitate and enable the functioning of our Web sites and to expand and improve our Web visitors' online experience. We may also aggregate such Web usage information with other visitors' Web usage information to assess trends and better design, monitor and otherwise improve our Web sites, as well as to focus our marketing efforts.

How we use cookies, Web beacons, etc.

• Cookies are alphanumeric identifiers that a Web server sends to your computer when you visit a Web site. Cookies can contain a variety of information, such as a simple count of how often you visit a Web site or information that allows us to customize our Web site for your use. Web beacons (also known as "clear gifs" or "one-pixel gifs") are small graphic images on a Web page or in an e-mail that allow us to monitor the activity on our Web sites or to make cookies more effective.
• We, or a third party acting on our behalf, may use "cookies" to tailor and improve the content we deliver to our Web visitors, to improve our Web sites by assessing which areas, features, and products are most popular, and to personalize our Web sites and make recommendations based on information, including product choices, a particular visitor has previously provided. For example, we may use a cookie to identify your state so we do not ask you to enter it more than once. We also use cookies to store user preferences, complete online order activity and keep track of transactions.
• We, or a third party acting on our behalf, may use Web beacons in certain of our Web pages and e-mails to gauge the effectiveness of our marketing campaigns and e-mail correspondence. For example, we may use Web beacons in our HTML-based e-mails to let us know which e-mails have been opened by the recipients.
• You can configure your Web browser to alert you when a Web site is attempting to send a cookie to your computer and allow you to accept or refuse the cookie. You can also set your browser to disable the capacity to receive cookies or you can delete cookies previously accepted. Some SD Web pages (and other Web pages) may not work correctly if you have cookies disabled.

Our e-mail marketing practices

• We periodically send customers news and updates via e-mail regarding SD-offered services, products, and special bulletins.
• We do not provide your e-mail address to third parties for the marketing of third-party products without your consent.

Our policy on online access by children

• SD Web sites are not designed to attract children under the age of 13. We do not target children for the collection of information online and do not knowingly collect personal identifying information from anyone under the age of 18.
• Ordering online products and services from SD is limited to adults (age 18 or over or as otherwise legally defined).
• We comply with all applicable laws and regulations, including the Children's Online Privacy Protection Act (COPPA), which requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13.

Linking to other sites

• Our Web sites may provide links to third party sites. We are not responsible for the privacy, security or content of such sites. If you are asked to provide information on one of these Web sites, we encourage you carefully to review their privacy policy before sharing your information.

HOW WE PROTECT YOUR INFORMATION

• All SD employees are subject to the SD Code of Business Conduct and certain state-mandated codes of conduct. The SD Code requires all our employees to follow every law, rule, regulation, court and/or commission order that applies to our business at all times. In addition, the Code specifically requires compliance with legal requirements and company policies related 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, up to and including dismissal.
• We employ security measures designed to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data, including personal identifying information. We have implemented technology and security features and strict policy guidelines to safeguard the privacy of your personal identifying information, and we will continue to enhance our security procedures as new technology becomes available.
• If we determine that a security breach has occurred and that such breach creates a risk of identity theft or service disruption, we will make reasonable attempts to notify you.

PRIVACY POLICY UPDATES

• This privacy policy supersedes and replaces all previously posted privacy policies.
• We want you to be aware of the information we collect, how we use it and under what circumstances, if any, we disclose it. We reserve the right to update this privacy policy to reflect any changes we make in order to continue to serve the best interests of our customers and Web visitors and will timely post those changes. If we make a material change to this privacy policy, we will post a prominent notice on our Web sites.
• If we intend, however, to use personal identifying information in a manner materially different from that stated at the time of collection, we will attempt to notify you at least 30 days in advance using an address or e-mail address, if you have provided one, and by posting a prominent notice on our Web sites, and you will be given a choice as to whether or not we use your information in this different manner.
• Please periodically check our Web sites for changes to this privacy policy.

CONTACTING US: QUESTIONS, COMMENTS, CONCERNS

• SD honors requests from customers and Web visitors to review their personal identifying information that we maintain in reasonably retrievable form and we will gladly correct any such information that is inaccurate. You may verify that appropriate corrections have been made. Please contact an SD service representative.