Open Internet Policy

Network Management Practices Policy Disclosure

Pursuant to the Federal Communications Commission’s newly enacted Open Internet Rules found in Part 8 of Title 47 of the Code of Federal Regulations, the policies of Independent Telecommunication Systems dba ITS Communications, (“Provider”) regarding network management practices, performance characteristics, and commercial terms are provided in entirety so that Provider’s current customers, prospective customers, third-party content providers and other interested parties can make informed choices regarding the broadband Internet access services offered by Provider, and the extent Provider’s network management practices may affect those services.

Network Management Practices

In the interest of providing the best online experience possible for all of Provider’s customers, Provider utilizes reasonable network management practices tailored to achieve legitimate network management purposes. Because bandwidth is a limited resource for broadband Internet service providers, it is essential that Provider reasonably manages its network to promote the use and enjoyment of the Internet by all of Provider’s customers. By engaging in reasonable and responsible network management, Provider prevents its customers from being subjected to the negative effects of spam, viruses, security attacks, network congestion, and other risks that threaten to degrade service. The network management practices employed by Provider are consistent with industry standards.

Congestion Management

Congestion is an Internet access service problem that can slow web browsing, downloading, and other activities of the customers during certain peak usage periods. Congestion may be caused by capacity limits and bottlenecks in a service provider’s own network, or by limitations in the capacity of the Middle Mile transport facilities and services that many service providers must purchase from unrelated entities to carry the traffic of their customers between their service areas and the closest Internet nodes.

Provider constantly monitors its network to manage congestion avoiding over utilization of circuits. Provider maintains sufficient bandwidth to service its customers.

Application-Specific Behavior

Provider does not make use of any application-specific network management practices. Provider does not favor, modify, inhibit, rate control or block any specific protocols, protocol ports or fields, or any applications or classes of applications. Customers may use any lawful and commercially available application. Provider’s network does not discriminate against particular types of content. Peer to Peer, streaming video, VoIP, and video downloads are all classified as content neutral.

Provider does not normally monitor the contents of the traffic or applications of its customers. It undertakes no obligation to monitor or investigate the lawfulness of the applications used by its customers unless mandated by law that Provider do so.

Device Attachment Rules

In order for a device to be approved for use on the Provider’s network, the device must conform to publicly available industry standards and be non-harmful to Provider’s network. Provider reserves the right to disable devices that cause disruptions to Provider’s customers or that are not in compliance with industry standards. In the event that Provider disables a device or denies access to application providers, prompt notice will be given of the decision to deny access to the network or disable a device.

Security

Provider offers its customers unrestricted access to all of the lawful content, services, and applications available on the Internet. Provider uses industry standard tools and generally accepted best practices and policies to protect our customers from spam, phishing, and other unwanted or harmful online content and activities. In the instances where these tools and policies identify online content as harmful or unwanted, the content may be prevented from reaching customers, or customers may be permitted to identify or inspect content to determine if it is harmful or unwanted. Provider’s security methods are not intended to prevent end-users from running any specific applications.

Provider employs commercially appropriate security procedures to protect its network and its customer records from unauthorized access by third parties. Provider does not guarantee that it can protect customers from any and/or all security breaches.

Traffic Blocking

Provider does not block any lawful content, applications, services and/or non-harmful devices.

Provider does not knowingly and intentionally impair, degrade or delay the traffic on its network so as to render effectively unusable certain content, applications, services and/or non-harmful devices.

Provider does not charge edge service providers of content, applications, services and/or devices any fees simply for transporting traffic between them and its customers.

Performance Characteristics

Many of the service and performance characteristics of the Provider’s broadband Internet access services are contained in the service offering portions of this website.

Provider offers broadband Internet access service via Digital Subscriber Line (“DSL”). DSL is a wireline transmission technology that transmits data faster over traditional copper telephone lines already installed to homes and businesses.

The advertised speed of Provider’s Internet service is the maximum speed achievable with the technology utilized by Provider. While the maximum advertised speed is attainable for end users, several factors may affect the actual speed of Provider’s Internet service offerings, including, but not limited to: the distance of the consumer’s home or office from Provider’s central office (i.e., the further away the customer is from the central office, the slower the broadband speed), the end user’s computer, modem or router, activity during peak usage periods, and other Internet traffic.

The actual speeds achieved with Provider’s Internet service offering make Provider’s Internet service suitable for real-time applications, such as Voice over Internet Protocol (“VoIP”).

Commercial Terms

The commercial terms and conditions of the Provider’s broadband Internet access services are contained in greater detail in the service offering and acceptable use portions of this website. This section provides a brief overview or reference to terms and conditions detailed elsewhere, plus discussions of other terms and conditions required by the FCC’s Open Internet Framework.

No Unreasonable Discrimination

Provider does not unreasonably discriminate in its transmission of traffic over the broadband Internet access services of its customers. It endeavors to give its customers as much choice and control as practicable among its different service offerings and among the content, application, service and device offerings of edge service providers. When reasonable network management practices entail differential treatment of traffic, Provider does not discriminate among specific uses, or classes of uses, of its network.

Provider does not impair, degrade or delay VoIP applications or services that compete with its voice services and those of its affiliates.

Provider does not impair, degrade, delay or otherwise inhibit access by its customers to lawful content, applications, services or non-harmful devices.

Provider does not impair free expression by actions such as slowing traffic from particular websites or blogs.

Provider does not use or demand “pay-for-priority” or similar arrangements that directly or indirectly favor some traffic over other traffic.

Provider does not prioritize its own content, application, services, or devices, or those of its affiliates.

Privacy Policy

The various network management tools and techniques utilized by Provider do not monitor, inspect or store the network activity and traffic of its Internet service users. Further, as part of its network management practices, Provider does not distribute information on network activity and/or traffic to any third party, or use network traffic information for any non-network management purpose.

Provider affords full access to all lawful content, services and applications available on the Internet and does not routinely monitor, inspect or store the network activity and traffic of its Internet service users. However, Provider reserves the right to monitor bandwidth, usage, transmissions and content for purposes of protecting the integrity of the network and Provider’s Internet access service through reasonable network management practices.

Provider may collect equipment information to identify the equipment customer is using on the network, including, but not limited to: equipment type, serial number, settings, configuration and software. Provider may also collect performance information to examine the operation of the equipment, services and applications the customer may use on the network, including, but not limited to: IP addresses, URLs, data transmission rates and latencies, location information, security characteristics, and information about the amount of bandwidth and other network resources customer is using in connections with uploading, downloading or streaming data to and from the Internet.

Network traffic, activity, performance information, and equipment information monitored or collected by Provider is done so for the sole purpose of reasonable network management purposes.

Provider is required to comply with relevant laws, regulations and judicial orders. Information covered under this Privacy Policy, as well as other categories of information, may be disclosed to third parties if Provider determines, in its sole discretion, that such a disclosure is necessary or required. Provider may also disclose this information if, in its sole discretion, such a disclosure is necessary or required to protect our interests or the interests of our customers. Provider may also disclose this information in connection with the sale of our business.

The Provider’s network management practices as discussed herein are intended solely to provide the best online experience possible for all of Provider’s customers by safeguarding our network and its users from spam, viruses, phishing, and other unwanted or harmful online content and activities. Provider’s network management practices are not intended, nor implemented, to block consumers from accessing the content and applications of their choice, deprive consumers of their entitlement to competition, or discriminate against or in favor of certain network traffic. End users with questions, concerns or complaints regarding Provider’s network management practices are encouraged to contact Provider for issue resolution.

Contact Us

If you have any questions regarding Provider’s Network Management Practices Policy or would like to file a complaint with Provider regarding its network management practices, please contact Provider at:

Independent Telecommunications Systems
4079 Park East Court SE
Grand Rapids, MI 49546

Further, if you believe that Provider is in violation of the FCC’s Open Internet Rules, you may file either an informal or formal complaint with the FCC.
http://esupport.fcc.gov/complaints.htm

Additional Disclaimers

The Open Internet Rules, as adopted, and Provider’s Network Management Practices Policy are not intended to affect, alter or otherwise supersede the legal status of cooperative efforts by broadband Internet access service providers and other service providers that are designed to curtail infringement in response to information provided by rights holders in a manner that is timely, effective, and accommodates the legitimate interests of providers, rights holders, and end users.

Furthermore, the Open Internet Rules, as adopted, and Provider’s Network Management Practices Policy do not prohibit Provider from making reasonable efforts to address the transfer of unlawful content or unlawful transfers of content.