This disclosure provides Easy Telephone Services Company d/b/a Easy Wireless (“Easy Wireless,” the “Company,” “we,” “us,” or “our”) customers (“you” and “your”) with information about the network management practices, performance characteristics, and commercial terms applicable to our mass market wireless mobile broadband Internet access services (“Mobile Broadband Services”) and our Iserv Powered by Easy Wireless Fixed Broadband Internet Access Service (“Fixed Broadband Services”) (together “Broadband Services”), consistent with the Federal Communications Commission’s Transparency Rule and applicable state laws and regulations. Broadband Services provide customers with the ability to transmit and receive data from all or substantially all Internet endpoints. As a Mobile Virtual Network Operator (“MVNO”), we provide our Mobile Broadband Services entirely by using the facilities of our underlying carrier, which is a leading nationwide mobile network operator (“Underlying Carrier”). Likewise, we provide our Fixed Broadband Services using the in-building Wi-Fi infrastructure facilities of our Fixed Broadband Infrastructure Provider. As a result, while we have some control over the network management practices and performance characteristics applicable to the Broadband Services you receive from us, we do not actively manage all aspects of networks and their performance—our Underlying Carrier and Fixed Broadband Infrastructure Provider (together our “Underlying Providers”) retain control.

Nothing in this disclosure changes your rights and obligations, or ours, under our Terms and Conditions, available at https://myeasywireless.com/terms-of-use/, or our Privacy Policy, available at https://myeasywireless.com/privacy-policy/. This disclosure is provided for informational purposes only and we may change it at any time, without notice. Your broadband access will be provided as described in your specific service plan, which governs in case of any contradictions with this Transparency Disclosure. Network Management Practices

How does Easy Wireless manage congestion with respect to its Broadband Services?

Easy Wireless strives to provide a high-quality Internet experience for all our customers via the resale of services on our Underlying Providers’ networks. Because bandwidth is a limited resource and the networks of our Underlying Providers are shared among Easy Wireless’ customers and other users of our Underlying Providers’ networks, it is essential that our Underlying Providers engage in reasonable network management practices to benefit all users of the network. Legitimate network management purposes typically include reasonable security practices by providing: confidentiality, integrity and availability of network services, reasonable measures to address traffic that is harmful to the network and providing services or capabilities consistent with customer’s choices regarding services offered.

When congestion occurs, you may experience reduced throughput or speed compared to non-congested times or to other users. Our Underlying Providers may independently prioritize service of certain subscribers which may result in your network speeds being reduced during times of network traffic congestion as determined by our Underlying Providers. Our Underlying Providers may also use network management techniques to ensure the best possible experience for the most possible customers, including modifying the manner in which streaming video is delivered. Our Underlying Providers also may prioritize emergency communications, including by law enforcement, public safety officials, or national security authorities, consistent with or as permitted by applicable law, which may impact other users of its network, including our customers. Does Easy Wireless limit data usage or provide customers with tools to monitor and control their data usage?

Easy Wireless offers wireless service plans with pre-established allotments of data at designated speeds per month and the opportunity to purchase additional data. Certain uses of the Mobile Broadband Services may not count against a customer’s data allotment, check your specific service plan for details. 

If you use the Broadband Services in a manner that violates our Terms and Conditions, including our Acceptable Use Policy, available at https://myeasywireless.com/terms-of-use/, we may suspend, terminate, or restrict your data session, switch you to a more appropriate data plan, or terminate your service. Mobile Broadband Services customers may determine their remaining data balance by contacting customer service at help@myeasywireless.com or 1-877-476-3451. 

Does Easy Wireless block or throttle lawful Internet traffic based on content, application, service, or use of non-harmful devices or modify particular protocols?

No, Easy Wireless does not block or throttle (including impair or degrade) lawful Internet traffic on the basis of content, application, content provider, or use of non-harmful devices on its Broadband Services, subject to reasonable network management. Nor do we modify particular protocols, protocol ports, or protocol fields in ways not prescribed by the protocol standards. 

Our Underlying Carrier optimizes streaming video to deliver video in DVD-quality (up to 2.5 Mbps). Your plan may additionally be subject to data caps and throttling; please check your service plan for details. 

As outlined in the Acceptable Use Policy in our Terms and Conditions, we or our Underlying Providers may need to block or limit the flow of traffic from certain locations or take other appropriate actions in response to a specific security threat against the networks of our Underlying Providers or our customers.

Does Easy Wireless directly or indirectly favor some traffic over other traffic in its provision of the Broadband Services either in exchange for consideration from a third party or to benefit an affiliate?

No, Easy Wireless does not directly or indirectly favor some traffic over other traffic (such as through prioritization, resource reservation, or traffic shaping) in its provision of the Broadband Services for any type of consideration from a third party or to benefit an affiliate. During natural disasters and other emergencies, our Underlying Providers may prioritize emergency communications, including those of law enforcement, public safety officials, or national security authorities, consistent with or as permitted by applicable law.

Does Easy Wireless require consideration from edge providers in exchange for the

non-discriminatory treatment of their content, application, service, or non-harmful device?

No, Easy Wireless does not require consideration, monetary or otherwise, from edge providers (i.e., individuals or entities that provide any content, application, service, or non-harmful device) in exchange for the non-discriminatory treatment of their content, application, service, or non-harmful device, including, but not limited to, in exchange for transmitting traffic to and from our end users or preventing the blocking or throttling (including impairment or degradation) of the edge provider’s content, application, service, or non-harmful device.

Does Easy Wireless unreasonably interfere with or unreasonably disadvantage: (1) an end user’s ability to select, access, and use the Broadband Services; (2) the lawful content, applications, services, or devices of the end user’s choice; or (3) an edge provider’s ability to make lawful content, applications, services, or devices available to end users?

No, subject to reasonable network management, Easy Wireless does not unreasonably interfere with or unreasonably disadvantage: (1) an end user’s ability to select, access, and use the Broadband Services; (2) the lawful content, applications, services, or devices of the end user’s choice; or (3) an edge provider’s ability to make lawful content, applications, services, or devices available to end users.

What practices has Easy Wireless adopted to manage network security?

Easy Wireless takes the security of our customers very seriously. As an MVNO and a reseller of mobile Internet access services, Easy Wireless does not have the ability to manage the security of its Underlying Providers’ networks. However, it is our understanding that our Underlying Providers have implemented reasonable physical, technical, and administrative safeguards to help guard against a wide range of security threats. Specifically, our Underlying Providers proactively monitor network activity to help guard against a wide range of security threats, including viruses, botnets, worms, distributed denial of service attacks, spam, and other harmful activity. Our Underlying Providers also take steps to neutralize identified threats. Easy Wireless uses industry-accepted security measures to secure our network. Despite these security practices, Easy Wireless cannot guarantee that you will not encounter unwanted, harmful, or malicious Internet traffic while using our Broadband Services or that information, during transmission through the Internet, while stored on our system, or otherwise in our care, will be safe from intrusion by others, such as hackers. We encourage you to adopt your own reasonable security practices. For additional information on our network security, please refer to the Service Security and Optimization section of our Terms and Conditions.

Does Easy Wireless restrict the types of devices that customers can use with its Broadband Services?

Easy Wireless customers may use 1) any 4G or 5G-capable devices of their choice with our Mobile Broadband Services, and 2) any appropriate Internet-abled device with our Fixed Broadband Services, so long as the devices are compatible with and do not harm or interfere with the networks of our Underlying Providers and comply with all applicable laws, rules, regulations, and standards. 

What is geolocation data, and does Easy Wireless collect or share my geolocation data?

Geolocation Data is generally understood to be subscribers’ real-time location information or other information used to determine subscriber physical location when using Easy Wireless’ services. As an MVNO and a reseller, Easy Wireless does not collect, store, use or share subscriber geolocation data, except to the extent that such information is included on records reported from our Underlying Providers. Our Underlying Providers may use and collect geolocation data as needed to support the services we provide to you. Our Privacy Policy, located at https://myeasywireless.com/privacy-policy/ outlines Easy Wireless’ privacy practices in detail including any that relate to Geolocation Data.

While Easy Wireless does not collect, use, or share Geolocation Data other than described above, please be aware that applications on your Easy Wireless device or on any device you use to connect to our Broadband Services could collect and share data; please visit those applications’ Terms and Conditions, Privacy Policies, and other documentation to determine data collection and sharing by applications you access using your Easy Wireless or other device. 

Network Performance Characteristics

What factors affect the performance of Easy Wireless’ Broadband Services?

Although our Underlying Providers’ engineers and manages their networks to provide optimal performance to all users and user types, including based on average and anticipated peak usage of the networks, the end-to-end performance of our Broadband Services can depend on a variety of factors, many of which cannot be anticipated or are outside of our and our Underlying Providers’ control, including: your location relative to our wireless coverage area or our W-Fi service transmission point, your proximity to a cell site, the capacity of the cell site, the number of other customers connected to the same cell site, the number of customers simultaneously using the network, the number of devices you have connected to the Fixed Broadband Service network, the services other users are using, topography, weather, obstructions, use inside a building or a moving vehicle, radio frequency interference, the capabilities of your device, the applications you are using, the server with which your device is communicating, the source or destination of your Internet traffic, overall traffic on the Internet, whether there are network outages, and applicable network management practices discussed above. These factors can impact the availability of network resources for Broadband Services at any time. 

What performance can I expect from Easy Wireless’ Broadband Services?

Easy Wireless offers Mobile Broadband Services using its Underlying Carrier’s 4G LTE and 5G networks. Easy Wireless offers Fixed Broadband Services using its Fixed Broadband Infrastructure Provider’s in-building Wi-Fi infrastructure.

Performance of broadband Internet access services is generally evaluated based on speed and latency. Because, as described above, our reasonable network management practices and a variety of other factors can affect the performance of our Broadband Services, neither we nor our Underlying Providers guarantee specific performance when you use our Broadband Services. Additionally, the specific terms of your service plan may limit the amount of high-speed data included with your service plan and the actual speeds associated with data allocations included in your service plan. Reduced network speeds may increase the latency you experience.

Speed

Speed reflects the rate at which Broadband Services can transmit data packets. This capacity is typically measured in the number of kilobits, megabits, or gigabits that can be transmitted in one second (kbps, Mbps, or Gbps). Some applications, like a short email without attachments or basic web browsing, do not require high-speed service to function optimally. Other activities, like transferring large data files, can be performed faster with higher-speed services. Applications involving real-time or near real-time, high bandwidth uses, such as streaming video or video conferencing, may require high-speed service to function optimally.

With respect to our Mobile Broadband Services, the maximum download speeds achievable on the network of our Underlying Carrier are typically between 73 – 341 Mbps for 5G devices and 9 – 48 Mbps for 4G LTE devices. The maximum upload speed is typically between 7 – 32 Mbps for 5G and 3 – 18 Mbps for 4G LTE devices. Easy Wireless provides its Services at speeds of at least 128 kbps download and upload, where the network will support such performance. After you use your monthly high-speed data allotment included in your service plan, your data speed may be reduced or your data access may be suspended for the remainder of the billing cycle, please check your service plan for details. Customers can receive additional data by upgrading their service plan to one with a higher data allotment or by purchasing a data top-up. 

With respect to our Fixed Broadband Services, iServ powered by Easy Wireless provides its service at the maximum advertised download speed of 50Mbps, maximum advertised upload speed of 50Mbps, actual fixed download speed of 50Mbps, and actual fixed upload speed of 50Mbs. 

Latency

Latency is the time that a data packet takes to travel between two points on the Internet, usually expressed as the round-trip time in milliseconds (ms). Some applications, such as email, can tolerate a substantial amount of latency without any noticeable impact on the application’s performance. Other applications, such as real-time video conferencing, require lower latency to function properly. Latency may increase as speeds are reduced. The minimum round-trip latency achievable on the network of our Underlying Carrier is typically between 19 – 37ms for 5G and 24 – 40ms for 4G LTE devices. The minimum round-trip latency for our Fixed Broadband Services is 27ms.

Commercial Terms

Where can I find the rates and other fees that apply to Easy Wireless’ Broadband Services?

Descriptions of the rates and fees applicable to our Broadband Services are described in our service plan offers and in our general Terms and Conditions, available on our website, https://myeasywireless.com/terms-of-use/. Easy Wireless does not charge termination fees and is not responsible for any termination fees that may be imposed by another carrier that ports your number or benefits (e.g., Affordable Connectivity Program) to the Easy Wireless platform.

Where can I find the Terms and Conditions and Acceptable Use Policy that apply to Easy Wireless’ Broadband Services?

The Terms and Conditions (including our Acceptable Use Policy) can be found at https://myeasywireless.com/terms-of-use/.

What are Easy Wireless’ privacy practices for its Broadband Services?

Easy Wireless’ Privacy Policy for our Broadband Services is set forth in our Privacy Policy located at https://myeasywireless.com/privacy-policy/.

How can I get assistance if I have a question, concern, or complaint or need more information about Easy Wireless’ Broadband Services?

If you have questions or concerns about our Broadband Services, please contact us using the following information:

Email:  help@myeasywireless.com

Phone: 1-877-476-3451 during normal business hours: Monday through Saturday from 9 am to 6 pm EST.