Policies

Network Management Policy 

McCormack/Ellington Telecom (“We”, “Our”, “Us”) provides this Network Management Policy (“Policy”) in accordance with Federal Communications Commission (“FCC”) requirements to disclose certain network management practices, performance characteristics, and commercial terms. Additional information about our broadband policies and practices is available at https://www.mccormacksolutions.com/ (“Website”).  

Network Practices 

We engage in network management practices that are tailored and appropriate for achieving optimization on our network, considering the particular network architecture and technology of our broadband Internet access service. Our goal is to ensure that all our customers experience a safe and secure broadband Internet environment that is fast, reliable, and affordable. We want our customers to experience all the Internet offers, whether it is social networking, streaming videos, listening to music, or communicating through email and videoconferencing.   

We manage our network using various tools and industry-standard techniques to ensure fast, secure, and reliable Internet service.  

1. Blocking: We do not block or discriminate against lawful Internet content, applications, services, or non-harmful devices.  We conduct only reasonable network management.   
2. Throttling: We do not throttle, impair, or degrade lawful Internet traffic based on content, application, service, user, or use of a non-harmful device. We engage in only reasonable network management practices.  
3. Affiliated Prioritization: We do not favor any Internet traffic over others, including through the use of techniques such as traffic shaping, prioritization, or resource reservation, to benefit an affiliate, and we have no plans to do so. 
4. Paid Prioritization: We have never engaged in paid prioritization. We do not favor or prioritize any Internet traffic over others, and we do not prioritize Internet websites over others in exchange for any consideration to benefit any content, applications, services, or devices.  

Network Management Practices 

Our network management practices are intended to ensure that we provide our customers with the best possible Internet access. We do not inspect traffic for any other purposes other than to keep track at the network level, where traffic flows, ensuring that the network is adequate for the demands of customers. To achieve this goal, we employ network management techniques such as identifying spam and preventing its delivery to customer email accounts, detecting malicious Internet traffic, and preventing the distribution of, or inadvertent access to, malware, phishing, viruses, or other harmful code or content. 

1. Congestion Management 

We monitor the connections on our network in the aggregate for all types of traffic to determine the utilization rate. We may take appropriate measures to relieve undue congestion if it occurs on the network.   

Our network and congestion management practices do not discriminate based on the type of application being used, nor are they based on any particular customer’s aggregate monthly data usage. We examine only current network conditions, not our customers’ online activities.  

We also check for abnormal traffic flows, network security breaches, malware, loss, and damage to the network. If a breach is detected or high-volume users are brought to light by complaint, we provide notification to the customer.  

Customer conduct that abuses or threatens our network or violates our Acceptable Use Policy, Terms and Conditions, or other policies will be asked to stop immediately. If a customer fails to respond or cease such conduct, we may suspend service or terminate the user’s account.   

If we take any congestion management actions, the vast majority of our customers’ Internet activities will be unaffected. Some customers may, however, experience more extended download or upload times or slower surf speeds.

2. Application-Specific Behavior 

Except as may be provided elsewhere herein, we do not engage in any application-specific network management activities on our network. Customers may use any lawful applications with us. We do not inhibit or favor applications or classes of applications over our High-Speed Internet/broadband data network. All traffic is treated in a “protocol-agnostic” manner, which means management is not based on applications and is also content neutral. We do not block or rate-control specific protocols or protocol ports, modify protocol fields, or otherwise inhibit or favor certain applications or classes of applications.  

3. Device Attachment Rules 

For best results, modems, wireless modems, or other proprietary network gateways used on our broadband network should be provided by us. Customers may, however, attach their own devices to their modems, including wired or wireless routers, laptops, desktop computers, video game systems, televisions, or other network-enabled electronics equipment. Customers are responsible for ensuring that their equipment does not harm our network or impair other customers’ service. We are not responsible for the functionality or compatibility of any equipment provided by our customers. Customers are responsible for securing their own equipment to prevent third parties from unauthorized access to our broadband network and will be held responsible for the actions of such third parties who gain unauthorized access through unsecured customer equipment. If we discover a customer device is harmful to our network, we have the right to request that the customer remove such device. 

4. Security 

We know the importance of securing our network and customers from network threats and annoyances. We promote the security of our network and our customers by protecting them from threats like spam, viruses, firewall issues, and phishing schemes.  

We also deploy spam filters for our email service to divert spam from an online customer’s email inbox into a quarantine file while allowing the customer to control which emails are identified as spam. Customers may access spam files through the email program.  

As normal practice, we do not block protocols, content, or traffic for network management, but we may block or limit traffic such as spam, viruses, malware, or denial-of-service attacks to protect network integrity and the security of our customers.   

These tools and practices may change from time to time to keep up with changing network technologies and new and innovative ways our customers use the network. 

Performance Characteristics 

1. Service Description 

We offer Internet service over Fiber-to-the-Home (“FTTH”). Information about our different service offerings can be found at https://www.mccormacksolutions.com/.  All our broadband services are best effort and can support real-time applications. 

2. Network Performance 

We make every effort to support advertised speeds and will dispatch repair technicians to customer sites to perform speed tests as needed to troubleshoot and resolve speed and application performance caused by our network.  

The FCC requires that we disclose information regarding the expected and actual speed and latency of our Internet access service offerings. Latency measures the average time it takes for a data packet to travel from one point on a network to another. It is typically measured by round-trip time in milliseconds. While latency generally does not significantly impact day-to-day Internet usage, certain applications, such as high-definition multiplayer online games, may be particularly affected by it. 

Our advertised speeds are estimates that we target to achieve for our customers. We cannot guarantee that a customer will achieve those speeds at all times. The actual speeds achieved by customers may vary based on a number of factors, including, but not limited to: (a) the performance and capabilities of the customer’s computer; (b) the connection between a customer’s computer and service demarcation, such as the use of wireless routers; (c) variances in network usage; (d) the distance a packet of information must travel from the customer’s computer to its final destination on the Internet; (e) congestion or variable performance at a particular website or destination; or (f) performance characteristics of transmissions over the Internet that are outside of our control. Accordingly, customers should consider the capabilities of their own equipment when choosing broadband service. Customers may need to upgrade their computers and other networks in their homes or offices to take full advantage of the chosen broadband plan. 

There are a number of available tools online that customers may utilize to measure Internet performance. Please note that all speed tests have biases and flaws and should be considered a guide rather than a conclusive measurement of performance. 

We test each service for actual and expected access speeds at the time of network installation to demonstrate that the service is capable of supporting the advertised speed. 

The following table shows our internal testing results. 

Residential and Business Speeds 

3. Impact of Non-BIAS Data Services 

The FCC defines Non-Broadband Internet Access Services (“Non-BIAS”) to include services offered by broadband providers that share capacity with Broadband Internet Access Services (“BIAS”) (previously known as “Specialized Services”) also offered by the provider over the last-mile facilities. At this time, the Company is not offering any non-BIAS data services. 

Commercial Terms 

1. Pricing 

We offer multiple levels of internet service, all with no monthly data cap. The current pricing and other terms and conditions of the various tiers can be found at https://www.mccormacksolutions.com/. Prices do not include applicable federal, state, or local taxes and regulatory fees. Prices and packages are subject to change.  

2. Privacy Policies 

We value the privacy of our internet service customers. Like most companies, we collect certain information about our customers and use it to provide our services. We collect information when our customers interact with us, when our customers use our internet service, and when our customers visit our website. This information is used to deliver, provide, and repair our services and establish and maintain customer records and billing accounts. We protect the information we have about our customers and require those we share it with to protect it. We do not sell, license, or share information that individually identifies our customers with others without your consent, except as necessary when working with vendors and partners for business purposes and when necessary for them to do work on our behalf. 

3. Broadband Facts Labels 

Our Broadband Facts labels provide detailed information about our standalone broadband services. The information for all current plans is available in a machine-readable file, which is available for download. 

4. Redress Options 

We strive to provide excellent customer service and resolve any issues promptly. If you have questions, complaints, or need additional information, please call 573-663-2000 or email info@mcmo.net. We review all correspondence in the order received and attempt to respond as soon as possible. 

Privacy Policy 

McCormack/Ellington Telecom (collectively hereinafter “McCormack,” “Company,” “our,” “us,” or “we”) is committed to respecting and protecting the privacy of our customers.  

This Privacy Policy applies to the information we collect when you use or interact with our products, services, and networks (“Services”), including https://www.mccormacksolutions.com/ (“Website”), but it is not exclusive to it. This Privacy Policy applies to everyone, including, but not limited to, visitors, users, and others who wish to access our Services or Website. By using McCormack’s internet access services, telephone services, and related services, or by visiting our Website, you consent to our information-gathering and use practices. 

Protecting your personal information or Personally Identifiable Information is our priority. This Privacy Policy explains the types of personal information we collect, how we collect, use, maintain, protect, and share it. This Privacy Policy also tells you about the rights and choices you may have regarding your personal information. This Privacy Policy will be continuously assessed against new technologies, business practices, and our customers’ needs. 

Please read this Privacy Policy carefully to understand our policies and practices regarding your information.   

Definitions 

• Personal Identifiable Information or “personal information” refers to any information that can be used to identify a specific individual. This includes information that is directly linked to a person, such as their name, date of birth, social security number, or email address, as well as information that can be used to identify them indirectly, such as their physical characteristics, biometric data, or online identifiers like IP addresses or device identifiers. 

• Allowable Tracked Information refers to the specific types of data that a website or application is permitted to collect, use, and share with third parties. Examples of allowable tracked information that a website or application may collect and use could include: User behavior data, such as website usage patterns, search history, or clickstream data; location data, such as GPS data or IP address; demographic information, such as age, gender, or occupation; contact information, such as email address or phone number; or financial information, such as credit card numbers or payment information. 

• Third Party refers to any entity that is not directly affiliated with us or our Website that is collecting or processing user data. This can include companies that provide services or products to the Company, analytics providers, or other third-party service providers.  Examples of third parties that may be involved in the collection and processing of user data include: Analytics providers that collect data on user behavior and provide insights to the organization, or payment processors or financial institutions that process transactions and collect payment information, etc. 

• Cookies refer to text files placed on a computer, mobile phone, or other device used to navigate the internet. Cookies transmit information back to the website’s server about the browsing activities of the user and may also be used to collect and store information about your preferences after you visit a website. 

Collection of Your Personal Information 

We limit the collection, use, retention, and disclosure of personal information to what is reasonably necessary and proportionate to achieve the purposes for which the information was collected or processed. We also limit secondary use to purposes compatible with the original purpose of the collection. 

When you visit our Website, you may provide us with two types of information: personal information that you knowingly choose to disclose that is collected on an individualized basis, and website use information collected on an aggregate basis as you and others browse our Website. 

You may also be required to provide certain personal information to us when you elect to use certain products or services, such as, but not limited to,(a) registering for an account, (c) signing up for special offers (d) sending us an email message, and (e) submitting your credit card or other payment information when ordering and purchasing products and services.  

We will use your information to communicate with you about services and/or products you have requested from us, including, but not limited to, providing them. We use customer information in defined and responsible ways to manage, deliver, and improve our products, services, and operations. This information will be used for internal purposes only and will not be shared with any third party. It shall not be used for any improper or unlawful purpose.  

We retain customer information for such periods of time as required by law or regulation or as reasonably necessary to provide services.  

Sharing Information with Third Parties 

We do not share customer information with third parties, except at the customer’s request, with the customer’s consent, or as described below. We do not sell, rent, or lease our customer lists to third parties. 

We may share allowable tracked information with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. This information will not include personal information.  All such third parties are prohibited from using your personal information except to provide these services to the Company, and they are required to maintain the confidentiality of your information. 

Representative third parties include:  

Vendors: We may provide information to our vendors who help us provide service features, monitor Website activity, maintain databases, and assist us in hosting, and who may observe information about you in the same way as described herein. We also use third-party vendors to provide services related to hosting the Website, providing technical support, updating records in our database, and sending or coordinating marketing communications on our behalf. 

Marketing: The information you provide on the Website may also be used by us for marketing purposes, such as when you subscribe to receive marketing communications or newsletters. Your information will not be provided to third parties for any third-party marketing purposes. You may choose to stop receiving our marketing communications at any time by contacting us to be removed from future mailings. 

Third-Party Support: While not routine, we may provide your information to persons or entities in connection with our own business operations, such as to contractors, our auditors or counsel, or in connection with a major change in our business (such as an acquisition). In these instances, the Company will ensure that such persons or entities are subject to obligations to keep the information confidential and use the information only for the purpose for which we provided it to them. 

We may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on the Company or the site; (b) protect and defend the rights or property of the Company; and/or (c) act under exigent circumstances to protect the personal safety of users or the public. 

Right to Review and Update Your Personal Information 

You may have a right to correct, update, or request access to the personal information that you have provided to us. 

If you would like to stop receiving future communications, or change or modify information previously provided, please call the customer service number shown on your bill or contact us at 573-663-2000.  

For your protection, we will only implement requests with respect to personal information about you (not anyone else), and we may need to verify your identity before implementing your request. We may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations. And even if you have a right to deletion, some of your information may remain within our systems and other records or archives, in compliance with applicable law. 

Tracking User Behavior 

We may keep track of the websites and pages our users visit to identify trends among our services. We may use this data to deliver customized content and advertising to customers whose behavior indicates that they are interested in a particular subject area. 

Automatically Collected Information 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect allowable tracked information about your equipment, browsing actions, and patterns, including: 

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data, and the resources that you access and use on the Website. 

• Information about your device and internet connection, including your IP address, operating system, domain names, access times, and browser type. 

We use this allowable tracked information to operate the Website, maintain the quality of the Website, and assess Website usage. 

Links and Other Non-McCormack Sites 

This Privacy Policy applies solely to information collected by us from our provision of internet access, telephone service, and related services, and from our Website. However, our Website may contain links to other sites or may display notices or advertisements from outside companies. Often, links to other websites are provided solely as pointers to information on topics that may be useful or of interest to the users of our Website. We are not responsible for the privacy practices of sites other than our own. We cannot make any representations about the practices and policies of these companies, and we do not warrant their products or services. McCormack encourages customers to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information. 

Use of Cookies 

The Website may use “cookies” to personalize your online experience. Cookies are small pieces of data that are stored by a user’s web browser on the user’s hard drive. One of the primary purposes of cookies is to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize website pages or register with our Website or services, a cookie helps us to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, etc. When you return to the same website, you can easily retrieve the information you previously provided.  

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our services or our Website. 

E-mail Communications 

From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. To improve our services, we may receive a notification when you open an email from us or click on a link therein. 

If you would like to stop receiving marketing or promotional communications via email from us, you may opt out of such communications by contacting us at 573-663-2000. 

If you choose to correspond with us through email, we may retain the content of your email messages along with your email address and our responses. We may also send automated messages to you pertaining to your account, such as billing invoices and other notices. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail or telephone. We ask that you not provide us with confidential information, such as social security or account numbers, through unsecured email. You may also contact us by phone, U.S. mail, or by visiting our location. 

Children  

We do not provide services to children, as defined under applicable law. Our Website and information gathering practices do not target or market to children. We respect the privacy of your children, and we comply with the practices established under the Children’s Online Privacy Protection Act. We do not knowingly collect or retain personally identifiable information from children. If you believe that a child has provided their information to us through our Website or Services, please contact us at 573-663-2000 so that we can take steps to delete it. 

Security of Your Personal Information 

All our employees are responsible for safeguarding individual customer communications and information. 

• We take reasonable precautions to protect personal information against unauthorized access. In general, our business practices limit employee access to confidential information and limit the use and disclosure of such information to authorized persons, processes, and transactions.  

• We secure all customer personal information from unauthorized access, use, or disclosure with Secure Sockets Layers protocol (SSL). This technology encrypts, or scrambles, your information so it’s virtually impossible to read by anyone other than employees at our company. SSL technology secretly encodes information that is being sent over the Internet between your computer and our website, helping to ensure that the information remains confidential. 

• We use SSL protocol to protect your personal information when you interact with a third-party website (such as when making a payment). Once the data is transmitted, the third party’s policies will govern the protection of your personal information.  

We strive to take appropriate, commercially acceptable security measures to protect against unauthorized access to or alteration of your personal information. While we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet that are beyond our control; and (b) security, integrity, and privacy of information and data exchanged between you and us through this Website cannot be guaranteed; and (c) no method of transmission over the internet, or method of electronic storage is one hundred percent secure. Any transmission of information over the internet is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website by any person or entity. 

Changes to Our Privacy Policy 

We reserve the right to change, modify, or update this Privacy Policy at any time without notice. In the event of any modification, we will post the changes in this Privacy Policy so that you will always know what information we are gathering and how we might use that information. Accordingly, you should periodically visit this page to determine the current Privacy Policy to which you are bound. 

Contact Information 

If you have a question or comment about this Privacy Policy, please call 573-663-2000 or email info@mcmo.net.