Network Management Policy
SUBJECT: Network Management Policy
POLICY #: Canopy-100-01
EFFECTIVE DATE: 01-01-2024
APPROVED BY: Jose A. Valdez
POLICY: To establish and explain the Network Management Policy utilized by DigitalC for practices related to Application-Specific Behavior, Device Attachment Rules, Security Practices, Performance Characteristics, Privacy Policies, and Customer Redress Options.
Network Management Policy
DigitalC is committed to providing our customers with the best online experience possible. DigitalC uses reasonable network management practices consistent with industry standards and uses minimally invasive tools and technologies. Just as the Internet continues to evolve, so too, will our network management policies. Should DigitalC not apply reasonable network management practices, our customers could be subject to the negative effects of, among other risks, security attacks, resulting in possible degradation of services.
Network Overview
DigitalC operates a state-of-the-art broadband network whereby next generation Fix Wireless Access (ngFWA) is brought past each home. DigitalC collocates on a tower/rooftop Radios (Base Nodes) that over spectrum connect to a CPE (Remote Node) at any home that purchases services and where access is granted. It should be noted that not all residential apartment buildings and multi-tenant units allow access and where possible DigitalC provides alternatives solutions. The broadband network enables us to bring the benefits of the extraordinary bandwidth carrying capacity of our solution to each of DigitalC’s customers.
Questions, Answers & Information Regarding Our Network Practices.
The FCC requires us to provide descriptions of our Network Management Practices to include Application-Specific Behavior Practices, Device Attachment Rules, Security Practices, Performance Characteristics, Privacy Policies, and Customer Redress Options.
Congestion Management
Given the current bandwidth capacity, no congestion management practice is required, nor is a practice being employed today other than network monitoring. DigitalC makes all efforts to ensure adequate bandwidth is available to all customers and reserves the right to employ congestion management practices in the future.
Application-Specific Behavior
Does DigitalC block or rate-control specific protocols?
1. DigitalC uses advanced monitoring technologies to identify various types of DDoS attacks. Once an attack has been identified certain traffic may be mitigated to protect DigitalC customers and network assets.
2. If DigitalC did not block and/or control these types of activities, DigitalC high speed internet customers could experience network instability and/or bandwidth slowdowns.
3. DigitalC does not block any other kinds of traffic. DigitalC subscribes to the philosophy of complete network neutrality, and we treat traffic to and from all customers the same.
Does DigitalC modify protocol fields in ways not prescribed by protocol standard?
DigitalC does not modify protocol fields not prescribed by protocol standards.
Does DigitalC inhibit or favor certain applications or classes of applications?
DigitalC does not inhibit or favor applications or classes of applications over its High-Speed Internet/broadband data network. All traffic is treated in a “protocol-agnostic” manner, which means management is not based on the applications and is also content neutral.
Device Attachment Rules
Does DigitalC restrict the types of devices that it allows to connect to the network?
DigitalC does not allow residential customers to connect switches or hubs directly to the backhaul transport layer of the network.
Security
What are the practices used to ensure end-user security or security of the network?
DigitalC uses the following practices to ensure end-users security and network security:
1. DigitalC attaches an identifier for all traffic on the network that tells the network what part of the network the traffic originated on.
2. The DigitalC network utilizes network separation, and the data from every customer is isolated from other users to stop unlawful access to specific traffic.
Performance Characteristics
Service Description: A general description of the service offered, including Service Technology, Expected and Actual Speeds, Expected and Actual Latency, Suitability of the Service for Real-time Applications follows:
1. Service Technology
1. DigitalC uses a ngFWA access system to deliver broadband services to customers. The ngFWA system standards is based on WiFi 801.11 technologies. Up to one hundred (100) remote nodes customers (RN) share a Radio Sector Base Node (BN) in each tower/rooftop. The system delivers symmetrical 100 Megabits per second to the subscribers.
2. In the DigitalC ngFWA network, there are no electronics between the substation and the customer. No electronics means that there are fewer failure points in the network and superior service quality for our customers.
2. Expected and Actual Speeds
1. DigitalC offers High Speed Internet access speeds between 100 to 1,000 Mbps Download and 100 to 400 Mbps Upload. The expected speeds are the line rate of the subscribed package minus any network protocol overhead such as TCP and UDP. Thus, it is possible for customers to experience slower speeds on the open Internet, but slower Internet speeds are due to the nature of the open Internet and not due to any blockage or congestion on the DigitalC network.
3. Expected and Actual Latency
1. Latency is another measure of Internet performance. Latency is the time delay in transmitting or receiving packets on a network. Latency is primarily a function of the distance between two (2) points of transmission and is typically measured in milliseconds. The DigitalC network is designed to have a local operating latency as great as milliseconds. However, in real practice, the actual local latency is generally around 10 milliseconds or less. The network distance and bandwidth constraints of the far end service being accessed will determine overall latency. DigitalC has no ability to control latency beyond its network edge.
4. Suitability of the Service for Real-time Applications
1. The DigitalC network is one of the fastest and most accessible networks available for the City of Cleveland that can achieve the speeds on our network that they subscribe to without slowdowns or blockages on our networks.
System and Network Security
Users are prohibited from violating or attempting to violate the security of DigitalC Broadband, including, without limitation, (a) accessing data not intended for such User or logging into a server or account which such User is not authorized to access, (b) attempting to probe, scan, or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization, (c) attempting to interfere with, disrupt or disable service to any user, host or network, including, without limitation, via means of overloading, flooding, mail bombing or crashing, (d) forging any packet header or any part of the header information in any E-mail or newsgroup posting, or (e) taking any action in order to obtain services to which such User is not entitled. Violations of system or network security may result in civil or criminal liability. We may investigate occurrences that may involve such violations, and we may involve and cooperate with law enforcement authorities in prosecuting Users who are alleged to be involved in such violations.
Suspension or Termination
Any User which DigitalC determines, in its sole discretion, to have violated any element of this Network Management Policy shall receive a written warning, and may be subject at our discretion to a temporary suspension of service pending such User’s agreement in writing to refrain from any further violations; provided that DigitalC may immediately suspend or terminate such User’s service without issuing such a warning if DigitalC Broadband, in its sole discretion deems such action necessary. If we determine that a User has committed a second violation of any element of this Network Management Policy, such User shall be subject to immediate suspension or termination of service without further notice, and we may take such further action as we determine to be appropriate under the circumstances to eliminate or preclude such violation. DigitalC shall not be liable for any damages of any nature suffered by any customer, User, or any third party resulting in whole or in part from DigitalC exercise of its rights under this Policy. Additional requirements and/or penalties apply as found in DigitalC’s Acceptable Use Policy (AUP).
Service Monitoring
DigitalC has no obligation to monitor individual services but may do so and disclose information regarding the use of the services for any reason if we, in our sole discretion, believe that it is reasonable to do so, including to satisfy laws, regulations, or other governmental or legal requirements or requests; to operate the services properly, or to protect itself and its subscribers.
Privacy
Any User interacting with our site and providing DigitalC with address, telephone number, email address, domain name, or URL, or any other personally identifiable information, permits DigitalC to use such information for commercial purposes of its own, including contacting Users about products and services which may be of interest. All information concerning our users shall be kept in accordance with the DigitalC then applicable Privacy Policy and the requirements of applicable law.
Network Inspection
Do network management practices entail inspection of network traffic?
DigitalC examines traffic to the extent needed to utilize the network safety features for intercepting network attacks. DigitalC does not inspect traffic for any purposes other than to keep track at the network level, where traffic flows to make certain that the network is adequate for the demands of customers.
Is traffic information stored, provided to 3rd parties, or used by the ISP for non-network management purposes?
The only time that any stored information is provided to any 3rd party is in response to a court order from a valid and qualified law enforcement agency.
Complaint Redress Options
What are DigitalC’s practices for resolving end-user and edge provider complaints and questions?
1. DigitalC first logs all complaints of trouble as a trouble ticket in a trouble log system. This allows for numeric identification of each trouble reported on the network. Trouble tickets can be generated by customers or self-generated by alarms located on the DigitalC network.
2. Secondly, DigitalC assigns a priority to each trouble ticket based upon the perceived severity of the problem. For example, outages involving multiple customers are given a higher priority than a minor network glitch affecting one customer.
3. DigitalC attempts to identify and address problems from its Network Operations Center (NOC). If the NOC is unable to clear a reported problem, then a technician in a truck is dispatched to address the problem.
4. If the problem is of such severity or of a nature that a field technician cannot solve the problem, the problem is escalated to an engineer. If the engineer is unable to solve the problem, it is generally escalated to an external engineer or consultant or to the vendor that made the equipment in question. DigitalC contracts with experienced vendors for as-needed troubleshooting and resolution in support of the network.
5. Finally, the customer may be notified depending upon the severity and type of problem.
6. Trouble tickets are retained permanently so that DigitalC can view a history of trouble at a specific customer site, a specific neighborhood or with a specific brand or piece of equipment.
Treatment of Inappropriate Content and Transmission
DigitalC reserves the right to refuse to transmit or post, and remove or block, any information, or materials, in whole or in part, that DigitalC Broadband, in its sole discretion, deems to be in violation of our posted Policies. While DigitalC has no obligation to monitor transmissions or postings made on the service DigitalC has the right to monitor these transmissions and postings for violations of DigitalC Policies and to disclose, block, or remove them in adherence with our Customer Service Agreement and our Acceptable Use Policy (AUP), and applicable law.
No Waiver/Severability
Any failure of DigitalC to enforce this Policy shall not be construed as a waiver of any right to do so at any time. If any portion of this Policy is held invalid or unenforceable, that portion will be construed consistent with applicable law, and any remaining portions will remain in full force and effect.
DigitalC reserves the right to modify this Network Management Policy at any time (subject to Executive approval). We will notify customers of any material changes via written, electronic, or other means permitted by law, including by posting it on our website. If you find the changes unacceptable, you have the right to cancel the Services. If you continue to use the Services after receiving notice of such changes, we will consider that as your acceptance of the changes.
