PONDEROSA EDGE PRIVACY POLICY

Effective Date: August 27, 2012

READ THIS PRIVACY POLICY CAREFULLY BEFORE USING PONDEROSA'S WEBSITES.

OUR COMMITMENT TO PRIVACY.

Ponderosa Edge ("Ponderosa") is committed to respecting the privacy rights of our customers, visitors, and other users of Ponderosa's Website (the “Site”). We believe that when you use any of our products or services, you should understand when and how personal information is collected, used, disclosed and protected. We created this Privacy Policy (the “Policy”) to give you confidence as you visit and use the Site, and to demonstrate our commitment to fair information practices and privacy protection. This Policy is only applicable to the Site, and not to other services offered by Ponderosa nor any other websites that you may be able to access from the Site. By using the Site, you are consent to our collection and use of your personal information as described in this Policy.

YOUR CALIFORNIA PRIVACY RIGHTS.

California customers have a right to obtain a list of all personal information that Ponderosa may have disclosed to related companies for marketing purposes or to unaffiliated third parties for their own marketing purposes. Ponderosa, as authorized by the Federal Communications Commission, shares personal information between its agents for its own marketing purposes, but Ponderosa does not disclose customers' personal information to third parties for the third parties' direct marketing purposes, as governed by California Civil Code 1798.83. A California customer may contact Ponderosa and request the general list of information shared and the companies among which it is shared. This request may be made by contacting us at 559.822.3343, emailing us at privacy@ponderosaedge.com, or sending any correspondence to Eric Vargas, Customer Operations Director, Ponderosa Internet, PO Box 21, O'Neals, and CA 93645.

INFORMATION WE COLLECT ABOUT YOU.

         ■   Name
        ■   Address
        ■   E-mail address, content of e-mail messages, and responses
        ■   Credit card number
        ■   Social Security number

        ■   Employer information
        ■   Date of birth
        ■   Driver's license number
        ■   Telephone numbers
        ■   Other personal information (e.g., mother's maiden name)

Website Information

Our web servers automatically receive certain types of information when you use our site our Site, for example, your domain name and IP address(es), date and time of visits, the type of browser you use, the website from which your visit originated, page visits, time spent on web pages, and other similar website “traffic data”. No personal information about you is revealed in this process. We do not set any personally identifiable information in cookies. We only use cookies to collect website use information so that we can determine how to improve our Site, complete transactions you request, and track your selections in order to make appropriate recommendations about Ponderosa products and services. You can generally choose whether to accept cookies by changing the settings on your website browser. However, if you choose to disable this function, your experience at our Site may be diminished and some features may not work as they were intended.

Information from Other Sources

We may obtain information about you from outside sources and add it or combine it with your account information. For example, we may receive credit information when you decide to subscribe to one of our services. We may also use marketing information from third parties to help us better serve you or inform you about other products or services. We sometimes receive updated delivery and address information from our shippers or other sources. We also receive information from agents from whom you purchase our products and services.

USE AND SHARING OF PERSONAL AND AGGREGATE INFORMATION.

We use your personal and website use information in order to provide optimal customer service, engage in our business activities, and inform you about other products or services.

Use of Personal Information
We do not share your personal information with any third parties without your consent. We may use your personal information to verify your identity, to check your qualifications for services, or to follow up with transactions initiated on the Site. We may also use your contact information to send you additional information about Ponderosa. If at any time you do not wish to receive these communications, please let us know (see contact information below). When we use other agents, contractors, or companies to perform services on our behalf, we advise them that they are to protect your confidential information, and not disclose such information except in limited circumstances.

Use of Website Information
We use aggregate information to analyze our Site traffic, but we do not examine this information for individually identifying information. We may use anonymous IP addresses to help diagnose problems with our server, to administer our Site, or display website content according to your preferences.

Use of Information in Business Transfers
Information about our users, including personal information, may be disclosed as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the unlikely event of an insolvency, bankruptcy, or receivership in which personal information would be transferred as one of the business assets of the company.

Use of Information to Protect Ponderosa and Others
We will disclose personal information only if required to do so by law, or in good faith-belief that we need to do so to (1) conform or adhere to legal requirement, (2) protect and defend the rights or property of Ponderosa or the users of the Site, or (3) act in case of emergency to protect the safety of the public or users of the Site.

CUSTOMER PROPRIETARY INFORMATION.

Under federal law, you have the right and Ponderosa has the duty to ensure the confidentiality of information about your telephone usage, the types of telephone services purchased, who you call, telephone usage, bill summary, and current charges. This information is sometimes referred to as "Customer Proprietary Network Information," or "CPNI." Ponderosa does not disclose this information with outside affiliates other than Ponderosa's authorized agents. Before we share your information with any person or entity other Ponderosa's authorized agents, we will first notify you of your rights under the law, describe how we intend to use the CPNI and give you the option to opt-out of such information usage.

CHILDRENS' ONLINE PRIVACY PROTECTION ACT.

Our Site is a general audience site, and we do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children's privacy online. We also recognize that many parents purchase products and services for family use, including use by children under the age of 13, without our knowledge. Any information collected from such accounts would appear to Ponderosa as the personal information of the subscribing adult customer, and will be treated as such under this Policy. If we make available offers and products online where a child informs us that he or she is under the age of 13, we will ask a parent to confirm his/her consent in advance of further collection, use or disclosure of personal information from that child. At any time, parents may review the personal information collected, ask to have it deleted, and refuse to allow any further collection or use of the child's information.

PRESENCE, LOCATION AND TRACKING.

If you call 9-1-1 for emergency services, we provide your location to a public safety answering location, emergency dispatch provider, fire services, law enforcement officials, or hospital emergency or trauma care facility. The law may permit us to disclose the location of a device on our network without a user's consent to (1) a user's legal guardian or member of user's immediate family; (2) database management services or information providers solely to assist in delivering emergency services; or (3) a government entity if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure without delay.

NETWORK AND INFORMATION SECURITY.

We maintain a variety of physical, electronic, and procedural safeguards to prevent the loss, misuse, and alteration of the information that we obtain from you, but we cannot guarantee our ability to prevent loss, misuse or alteration.

THIRD PARTY WEBSITE AREAS BEYOND COMPANY'S CONTROL.

The Site may contain links to other websites. If you choose to visit other websites, our policy is no longer in effect. We are not responsible for the privacy practices or content of other websites, and it is your responsibility to review the privacy policies of other websites to ensure that agree to their policies.

 UPDATING THIS POLICY.

Ponderosa may revise, amend, or modify this Policy from time to time. Notice of any revision, amendment, or modification will be posted on the Site, and/or on your start pages, and/or buy e-mail and/or in mailings to your primary Ponderosa email account, and will be effective on the date noted in the posting. This Policy may not be amended or modified by your except by means of a written document signed by both you and an authorized representative of Ponderosa. By continuing to use Ponderosa's services and products after the amendments are effective, you accept and agree to abide by them.

CONTACTING US.

If you have any questions, comments or complaints concerning this Policy, please contact us at 559.822.3343, email us at privacy@ponderosaedge.com, or send any correspondence to Eric Vargas, Customer Operations Director, Ponderosa Internet, PO Box 21, O'Neals, CA 93645. Our representatives will endeavor to contact you within fifteen (15) days of your inquiry.