Mountain Rural Telephone Cooperative Corporation, Inc. SpreeTV by MRTC Application Privacy Policy

What is covered by this Privacy Policy

This Privacy Policy (the "Privacy Policy") covers Mountain Rural Telephone Cooperative Corporation, Inc.'s privacy and security policies for personal information collected by Mountain Rural Telephone Cooperative Corporation, Inc. (the "Provider") in connection with the SpreeTV by MRTC application (the "App"). For this Privacy Policy, personal information refers to information relating to an identified or identifiable natural person with reference to an identifier, such as a name, an email address, an online identifier such as login credentials, or any other identifier by which that natural person may be contacted online or offline.

The Provider understands the importance of privacy and security and is committed to providing a secure environment to protect the personal and private information provided by you in connection with your use of the App. Accordingly, this Privacy Policy sets out:

• The personal information that is collected when you download, install, register for and/or use the App; and
• The Provider's practices associated with collecting, using, retaining, disclosing, and protecting the information associated with your use of the App.

What is not covered by this Privacy Policy

This Privacy Policy DOES NOT apply to information:

• The Provider collects on its website; or
• The Provider may collect unrelated to the Provider's provision of the App.

Information collected on the Provider's website at www.mrtc.com is subject to the Provider's privacy policy in the footer of the website pages (accessible at https://www.mrtc.com/terms_of_use/index.html).

Personal information does not include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

Privacy Policy applies for any use of the App

Please read this Privacy Policy carefully to understand the Provider's policies and practices regarding your information and how such information will be treated. If you do not agree with the Provider's policies and practices, you should not install, use or access the App. By accepting and agreeing to the service agreement, or by using or accessing the App, you agree to this Privacy Policy. This Privacy Policy may be updated from time to time. You should review this Privacy Policy periodically for updates and changes. Your continued use of the App after the Provider revises this Privacy Policy means you accept those revisions.

Children Under the Age of 16

The Provider does not knowingly collect personal data of children under 16. If the Provider learns that personal data from a child under 16 has been obtained or received without verification of parental consent, the Provider will delete that information. If you believe the Provider might have any information from or about a child under 16, please contact the Provider at service@mountaintelephone.com.

How the Provider Collects Your Information

The Provider collects and processes information provided directly by you when you install the App and register for an account to use the App. Specifically, this information includes:

• Your login credentials used to access your account;
• Your IP address, to authenticate your ability to use the app; however, no precise geographic information is used;
• Data insights the Provider attains based on correlation and analytics of your information collected in providing the App, which may be used in aggregated and dis-aggregated formats or to obtain trend analytics, to provide the App; and
• Use of the above-described collected information in aggregated and disaggregated formats to enhance our current App or to provide App features.

How the Provider Uses the Information

The Provider uses the information collected as described in this Privacy Policy, including personal information, to:

• Provide you with the App as described
• Implement, improve and/or enhance the App, including to make future releases available to you;
• Carry out the Provider's obligations as described or authorized
• Enforce the Provider's rights arising from the service agreement between you and the Provider; and
• Fulfill any other purpose authorized by you and reasonably required for the App.

The Provider may also use the information collected as described in this Privacy Policy, including personal information, to inform you about goods and services that may be of interest to you. The Provider does not contact you unless and only to the extent expressly authorized by you in writing.

Disclosure of Information

The Provider does not sell or otherwise distribute or disclose your information to third parties other than as described or authorized in the service agreement, including this Privacy Policy. The Provider discloses the information to its subsidiaries, affiliates and certain third-party vendors and contractors that provide development, integration, web hosting and consulting services to the Provider for the purpose of providing you with the App, to maintain, support, develop, improve and/or enhance the App and to fulfill the Provider obligations associated with the App. The Provider may be required to disclose information under certain circumstances:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce the Provider's rights arising from the service agreement entered into between you and the Provider;
• If the Provider believes disclosure is necessary or appropriate to protect the rights, property, or safety of the Provider, its customers or other third parties; or
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Provider's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which you and/or you subscriber held by the Provider are among the assets transferred.

Your Choices About Our Collection, Use, and Disclosure of Information

The provision of the information described in this Privacy Policy is necessary in order for you to use the App.

Your information is retained and used as described in this Privacy Policy. In the event you delete your account for the App in accordance with the terms of the service agreement, your information will be deleted within 30 days of the deletion of such account or within such other timeline as may be mandated by applicable law. You will no longer be able to access the App when your account is deleted.

Data Security

All information you provide to us is stored on our secure servers behind firewalls. The Provider utilizes mechanisms such as intrusion detection systems, intrusion prevention systems, firewalls and encryption to secure information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The Provider deploys Intrusion Detection Systems (IDS) and Intrusion Prevention Systems (IPS) to alert and proactively contain potential threats. Enhanced security visibility and coverage is enabled through added layers of firewall and IDS beyond the network perimeter. Management connections to servers are always authenticated and encrypted via Secure Shell (SSH) when administration access is required for troubleshooting, patch management, and upgrades.

The Provider runs automated vulnerability scanning on all perimeter systems to identify potential security risks. Scanning applications are regularly updated to remain current and up to date on important security vulnerabilities. Patches are applied to all relevant systems, unless a compensating control is implemented.

The Provider uses a variety of industry-standard security technologies and best practices to help protect information from unauthorized access, use, or disclosure. All data stored on the Provider systems is encrypted following industry standards using the strongest keys and ciphers. All communications with the App are protected with industry standard security protocols.

You control access to your account and you are obligated to keep your login credentials and passwords secure and protected and maintained as confidential. Although the Provider implements measures that are reasonably designed to protect you, information may nevertheless be transmitted outside of the Provider's systems. Any such transmission of information is at your own risk, and the Provider is not responsible for any circumvention of any privacy settings or security measures provided.

Changes to this Privacy Policy

The Provider may update this Privacy Policy from time to time. If the Provider makes material changes to how the Provider treats personal information under this Privacy Policy, the Provider will notify you by email or other communication. The date the Privacy Policy was last revised is identified at the end of this Privacy Policy. You are responsible for ensuring the Provider has an up-to-date active and deliverable email address for you and for periodically visiting this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and the Provider's privacy practices, contact the Provider via e-mail at service@mountaintelephone.com.

Last modified: April 24, 2023