Open Internet Disclosure

General Overview

The Canadian Radio-Television and Telecommunications Commission (“CRTC”) requires that we provide you with the following information regarding our mass market retail Internet access services, including information regarding any network management practices that we employ, the performance characteristics of our services, and the commercial terms of our service offerings. These disclosures relate solely to that portion of our overall network devoted to providing mass market retail Internet access service and are intended to be relied upon by current and prospective subscribers to that service as well as by the providers of “edge” products (i.e., providers of applications, devices, services, and content accessed over or connected to SparkSignal™ Internet access service).

Network Management

SparkSignal™ Wireless Network and the Management of Our Wireless Network In order to make sure that all Subscribers have the best possible online experience, SparkSignal™ has employed management practices. SparkSignal™ wireless network operates as a point to multipoint network, allowing subscribers to connect wirelessly to the best access point in their area. In order to manage network congestion, SparkSignal™ uses a variety of reasonable and appropriate practices to protect Subscribers from activities that can unreasonably burden our wireless network or cause service degradation. These techniques consist of but are not limited to utilizing industry-standard traffic management technology or allocating a fixed amount of maximum bandwidth to the Subscribers based on each monthly service plans allotment. Most subscribers will not notice any change in their internet experience as a result of these techniques. In addition, the following disclosures should be read in conjunction with SparkSignal™ “Acceptable Use Policy” (“AUP”), and with our “Terms & Conditions,”. Consistent with the CRTC’s rules, SparkSignal™ reserves the right to employ additional types of “reasonable network management” practices commonly used in the industry to protect consumers from activity that can unreasonably burden our network and cause service degradation. If and when we deploy specific network congestion management tools, we will update this disclosure statement accordingly.

SparkSignal™ does not discriminate against or prevent users of its Internet access service from sending and receiving the lawful content of their choice; running lawful applications and using lawful services of their choice; or connecting their choice of legal devices, provided that such applications and services do not harm the network or the provision of broadband Internet access service, facilitate theft of service, or harm other users of the service. Similarly, SparkSignal™ does not impair or degrade particular content, applications, services or non-harmful devices so as to render them effectively unusable, subject to the reasonable network management practices outlined herein.

Usage Limits

To ensure that the activity of a small percentage Subscribers does not degrade, inhibit, or interfere with the use of the wireless network by others and for the reasons described above, SparkSignal™ maintains an excessive use policy to address “data” consumption by Subscribers that is wholly uncharacteristic of a typical user of the Service as determined by SparkSignal™ sole discretion. Each monthly Subscriber who uses their internet connection “excessively” will be notified via email that they are using what SparkSignal™ believes to be an excessive amount of data.

Network and End-User Security

SparkSignal™ also employs certain practices to protect the security of our customers and our network from unwanted and harmful activities. These include practices designed to protect our servers against Denial of Service attacks and to prevent viruses, worms, spyware, spam, and identity theft. In order to ensure the effectiveness of our security practices, we do not publicly disclose specific information detailing the levels and types of activities that may trigger our deployment of security protection measures. When security measures are employed, they may affect performance characteristics of service or the ability to access certain suspicious websites, but such measures are employed in a manner designed to have non-discriminatory impact on all similarly situated customers.

Description of Service

SparkSignal™ offers high-speed internet service to rural and urban Alberta homes and businesses. All our plans offer unlimited “data” usage. Not all plans are available in all areas.

The CRTC requires that we disclose information regarding the expected speed and latency of our internet access service offerings. SparkSignal™ provisions its wireless equipment on customers’ addresses to maximize our customers’ ability to receive the maximum speed levels for each monthly plan offering. However, SparkSignal™ does not guarantee that a customer will achieve those speeds at all times. Similar to other ISP’s, SparkSignal™ advertises its speeds as “up to” a specific level based on the monthly service plan the customer is subscribed. The “actual” speed a subscriber experiences may vary based on a number of factors and conditions, many of which are beyond SparkSignal™ control.

The conditions include:

• The Performance of a customer’s computer, including its age, memory, processing capability, its operating system, the number of applications running simultaneously, and the presence of any adware or viruses has an effect on a computer’s ability to communicate with the Internet. Often, increasing the amount of RAM in a computer can have a positive effect on how quickly a computer can communicate with the Internet. Subscribers should make sure they are running the most up-to-date operating system on their computer can handle (with all available patches installed) to maximize its connection speeds.
• Type of router being used. If a router is being used to create a Wi-Fi network and allow multiple devices to connect, the connection speed experienced can often depend on the router model as well as how the router settings are adjusted.
• The distance packets travel (round trip time of packets) between a customer’s computer and its final destination on the Internet, including the number and quality of the networks of various operators in the transmission path. The Internet is a “network of networks.” A customer’s connection may traverse the networks of multiple providers before reaching its destination, and the limitations of those networks will most likely affect the overall speed of that Internet connection.
• Congestion or high usage of a particular website or service. If a large number of visitors are accessing a website or service simultaneously, the speed of your connection will seem slower if the website does not have sufficient capacity to serve all of the visitors at the same time.
• Gating of speeds or access by the website or destination. In order to control traffic or performance, many websites will limit the speeds at which a visitor can download from their site. Those limitations will inevitably seem to slow your connection speed.

Performance Test

The performance of your specific monthly internet plan can easily be tested using the third-party site: http://speedtest.net. The results of this test will give users an accurate look at how their internet plan is performing.

Commercial Terms

Pricing

As noted above, SparkSignal™ provides both Residential and Business Internet access service. The current pricing and other terms and conditions of these tiers (including information regarding fees for early termination or additional network services) can be found at www.sparksignal.net or obtained by calling our customer service at (403) 845-4677. The pricing and other commercial terms of our Internet access services are subject to change and the information provided in this disclosure statement is not intended to supersede or modify any of the terms and conditions of service as applicable to a particular customer.

Privacy Policies

Your privacy is very important to us. Personal information you provide to SparkSignal™ is governed by the SparkSignal™ Privacy Policy and is subject to change from time to time. Personal information provided by you to SparkSignal™ is used primarily to provide a customized experience as you use our services and is not shared with third parties. SparkSignal™ reserves the right, as required, or permitted by law, to provide account and user information, including email, to third parties and to cooperate with law enforcement authorities in the investigation of any criminal or civil matter. Such cooperation may include, but is not limited to, monitoring of SparkSignal™ wireless network consistent with applicable CRTC law.

Redress Options

For immediate assistance with issues or complaints involving your broadband Internet access service, please contact our customer service at (403) 845-4677. We are available M-F 9:00am to 5:00pm. Customers can also leave a voicemail 24 hours a day, 7 days a week. Customers can also email us at info@sparksignal.net. Written complaints can also be sent via Canadian mail to: SparkSignal™, 4920 51 Avenue, Rocky Mountain House, AB T4T 1J6. The CRTC has established procedures for addressing informal and formal complaints relating to its “Open Internet” rules. For information concerning these formal and informal complaint procedures, please refer to the FCC’s website at https://crtc.gc.ca/eng/contact/.