Network Management

Broadband Transparency Disclosure

This Transparency Disclosure (“Disclosure”) provides customers (“you” and “your”) of Consumer Cellular, Incorporated (“Consumer Cellular,” “we,” “our” or “us”) with information about the network management practices, performance characteristics, and commercial terms applicable to our mass market wireless broadband Internet access services (“Broadband Services”), consistent with the Federal Communications Commission’s Transparency Rule. Broadband Services provide customers with the ability to transmit and receive data from all or substantially all Internet endpoints. Consumer Cellular provides our Broadband Services entirely by using the facilities of the leading nationwide mobile network operator(s) (“Underlying Carriers”). 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 the network and its performance—our Underlying Carriers do. The information provided in this Disclosure relates to your experience while using the networks of our Underlying Carriers and may not describe the practices, performance, or terms you may experience while using extended coverage networks or roaming, also called “off-net” or “off-network” usage – both domestic and international –on affiliated networks. We do not guarantee the availability, quality of coverage or speed for data servicesthat are accessed using other carrier networks and we may reduce speeds to 2G speeds or suspend thedata service available on these networks at any time without notice. Customers should see their rate plansfor roaming details.

Nothing in this Disclosure changes your rights and obligations, or ours, under our Wireless Customer Agreement, available at consumercellular.com/agreement, Acceptable Use Policy (“AUP”) at consumercellular.com/aup, or Privacy Policy at consumercellular.com/legal/privacyandsecurity. 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 Disclosure. With certain service plan offerings, unlimited data will be subject to speed thresholds and limitations and data beyond a threshold allocation may be provided in additional increments, as described in specific service plan offerings.

Network Management Practices

How does Consumer Cellular manage congestion with respect to its Broadband Services?

We strive to provide a high-quality Internet experience for all customers via the resale of services on the networks of our Underlying Carriers. Because bandwidth is a limited resource and the networks of our Underlying Carriers are shared among Consumer Cellular’s customers and other users of the network of our Underlying Carriers, it is essential that our Underlying Carriers engage in reasonable network management practices to benefit all users of the network based on a variety of factors and their technical expertise. 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. Nonetheless, temporary congestion may occur when a large number of users in a concentrated area access the network at the same time, such as at large events, or during planned network maintenance.

Congestion-Based Data Management. When congestion occurs, you may experience reduced throughput or speed compared to non-congested times or to other users of the network. Our Underlying Carriers may independently prioritize service for certain of its users, which may result in your network speeds being reduced during times of network traffic congestion as determined by our Underlying Carriers. Our Underlying Carriers may also use network management techniques to ensure the best possible experience for the most possible users, including modifying the manner in which streaming video is delivered. They 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 their network, including customers.

Video Pacing. With the increase in smart phone and tablet usage on wireless networks, and the prevalence of video downloads, our Underlying Carriers may use a reasonable network management video optimization technique in their mobile data networks. That technique delivers recorded video to the user’s device in a “just in time” fashion (“Buffer Tuning”). Buffer Tuning only applies to internet browser traffic for recorded video downloads, regardless of the source, and does not affect real-time streaming video. Without Buffer Tuning, video content may be completely delivered to the device and charged against the user’s data plan regardless of whether it is viewed. With Buffer Tuning, a sufficient amount of video is delivered to the device so that the user can start viewing the video, and the remainder of the video is delivered just in time to the device as needed for uninterrupted viewing. Additionally, this frees up network resources for all users. Buffer Tuning does not alter video content and should not adversely impact the viewing experience.

Video Management. Another network management practice we and/or our Underlying Carriers use to efficiently manage their wireless network resources is video management. Video management is a feature that applies to real-time streaming video and is automatically included with all our wireless data plans. This optimizes the user’s data plan consumption and allows you to watch more video over the network while using less data by streaming certain high-definition video at standard definition quality, similar to DVD (about 480p). It renders content identified as streaming video at a maximum speed of 2 Mbps for customers on 5G enabled devices or 1.5 Mbps for devices not compatible with 5G, which is generally well suited to viewing on a smartphone and may help control your data usage.

Does Consumer Cellular limit data usage or provide customers with tools to monitor and control their data usage?

We offer service plans with unlimited data and pre-established allotments of data at designated speeds per month and the opportunity for customers to change to a different data plan with additional or less data. Unlimited data will be subject to speed thresholds and limitations and data beyond a threshold allocation may be provided in additional increments, as described in specific service plan offerings. For customers on an unlimited data plan who exceed, for example, 50GB of high-speed data in a billing cycle, the customer’s service over the cellular network will transmit data at a maximum of 512 Kbps for the remainder of the billing cycle. Once speeds are limited like this, the customer’s connection over the cellular network should still allow viewing static web pages or checking email, but bandwidth-intensive activities such as audio and video streaming, picture and video messaging, and apps/services that use large amounts of data will be impacted and may not be fully functional. But, when the next billing cycle begins, the customer will once again have high speed data access. When connected to a Wi-Fi network, the customer’s speed will not be impacted nor will overages apply, if applicable.

Customers without unlimited data plans can receive additional data by upgrading their service plan to one with a higher data allotment or by selecting to have their plan automatically upgraded to the next tiered data plan after the current data allotment is exhausted with our SmartFlex™ feature. SmartFlex™ allows customers to avoid slower data speeds or overage fees, if applicable. Customers will remain on the new data plan unless they choose to return to their original plan at the start of the next billing cycle. Customers can choose a different data plan and/or disable SmartFlex™ at any time by contacting customer service or at consumercellular.com by logging into My Account. If you disable the automatic upgrade feature on your account and exceed your plan’s monthly data limit, you will experience slower speeds for the remainder of the billing cycle (currently set at a maximum speed of 64KB per second).

If you use the Broadband Services in a manner that violates our Wireless Customer Agreement, including the Acceptable Use Policy, each available respectively at consumercellular.com/agreement and consumercellular.com/aup, we may suspend, terminate, or restrict your data session, switch you to a more appropriate data plan, or terminate your service. Customers may determine their remaining data balance by contacting customer service, at consumercellular.com by logging into My Account, or through My CC, our mobile app. Customers can also choose to be notified, by email, text message or both, during each billing cycle when their data usage reaches 50% or 75% of their monthly high-speed allotment (or at both intervals). We also notify customers when they reach 100% of their monthly high speed data allotment so that they are aware of their amount of data usage and can make adjustments to avoid slower speeds or charges for upgraded data plans with SmartFlex™.

Does Consumer Cellular favor certain websites or Internet applications by blocking or throttling traffic, modifying particular protocols, or prioritizing certain traffic on its Broadband Services?

We do not favor certain websites or Internet applications by blocking or throttling lawful internet traffic on the basis of content, application, service, user, or use of non-harmful devices on our Broadband Services. Nor do we modify particular protocols, protocol ports, or protocol fields in ways not prescribed by the protocol standards, subject to reasonable network management. Additionally, Consumer Cellular does not directly or indirectly favor some traffic over other traffic (such as through prioritization, resource reservation, or traffic shaping) for any type of consideration. In response to a specific security threat against the network of our Underlying Carriers or customers, we or our Underlying Carriers may occasionally need to limit the flow of traffic from certain locations or take other appropriate actions. Additionally, our Underlying Carriers may favor some traffic over other traffic to address the needs of emergency communications, law enforcement, public safety, or national security authorities, consistent with or as permitted by applicable law.

Does Consumer Cellular restrict the types of devices that customers can use with its Broadband Services?

Customers may use any 4G LTE or 5G-capable devices of their choice with our Broadband Services, so long as the devices are compatible with and do not harm or interfere with the networks of our Underlying Carriers and comply with all applicable laws, rules, regulations, and standards. Devices must also be used in a manner consistent with our Wireless Customer Agreement, including the Acceptable Use Policy.

How does Consumer Cellular handle alleged copyright infringement by customers to its Broadband Services?

Our Underlying Carriers utilize a copyright alert process to respond to alleged copyright infringement activities using peer-to-peer file sharing and attempt to educate users about the importance of protecting copyright and lawful use of content available over the Internet. Under the program, content owners may notify our Underlying Carriers of alleged copyright infringement based on the IP address of a user. Our Underlying Carriers will pass the request to us, and then we will attempt to identify the customer account based on that IP address and forward a copyright alert to that customer, advising the customer of the allegation and providing information about online copyright infringement, so that the customer, as the account holder, can take steps to prevent any future possible infringement using the Broadband Services. If a customer receives additional alerts, we may temporarily redirect the customer to a webpage where the customer must review material on the importance of copyright and the lawful use of content available over the Internet. Upon completion of this review, such redirection will be discontinued, and the customer’s Broadband Services will be restored to normal. If a customer continues to receive alerts, we or our Underlying Carriers may take action consistent with the Digital Millennium Copyright Act, which may result in termination of the customer’s Broadband Services. The customer’s personal information is protected throughout this process—we will not provide such information to content owners unless required to do so by court order.

What practices has Consumer Cellular adopted to manage network security?

We take security very seriously. As a reseller, we do not have the ability to manage the security of the network of our Underlying Carriers. However, our Underlying Carriers have implemented reasonable physical, technical, and administrative safeguards to help guard against a wide range of security threats. Specifically, our Underlying Carriers 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 Carriers also take steps to neutralize identified threats. Consumer Cellular uses industry standard security measures to help secure its network. Despite these security practices, we 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.

What is geolocation data, and does Consumer Cellular collect or share my geolocation data?

Geolocation data is generally understood to be users’ real-time location information or other information used to determine subscriber physical location when using our services. As a reseller, we do not collect, store, use or share customer geolocation data, except to the extent that such information is included on records reported from our Underlying Carriers. Our Underlying Carriers may use and collect geolocation data as needed to support the services we provide to you. Our Privacy Policy, available at consumercellular.com/legal/privacyandsecurity outlines Consumer Cellular’s privacy practices in detail including any that relate to geolocation data. While we do not collect, use, or share Geolocation Data other than described above, please be aware that applications on your device could collect and share data.

Network Performance Characteristics

What factors affect the performance of Consumer Cellular’s Broadband Services?

Although our Underlying Carriers manage their network to provide optimal performance, including based on average and anticipated peak usage of the network, 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 the control of Consumer Cellular and our Underlying Carriers, including: your location relative to our coverage area, 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 users simultaneously using the 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 Consumer Cellular’s Broadband Services?

We offer mobile broadband Internet access service using our the 4G LTE and 5G networks of our Underlying Carriers. Performance of broadband Internet access services is generally evaluated based on speed and latency. Because, as described above, reasonable network management practices and a variety of other factors can affect the performance of our Broadband Services, neither we nor our Underlying Carriers 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.

The maximum download speeds achievable on the network of our Underlying Carriers are typically between 35 – 158 Mbps for 5G devices and 11 – 64 Mbps for 4G LTE devices. The maximum upload speed is typically between 3 – 21 Mbps for 5G and 1 – 10 Mbps for 4G LTE devices. After you use your monthly high-speed data allotment included in your unlimited service plan, your data speed will be reduced to a maximum of 512 Kbps for the remainder of the billing cycle. Customers without unlimited data plans can receive additional data by upgrading their service plan to one with a higher data allotment or by selecting to have their plan automatically upgraded with SmartFlex™ to the next tiered data plan after the current data allotment is exhausted. If you disable the automatic upgrade feature on your account and exceed your plan’s monthly data limit, you will experience slower speeds for the remainder of the billing cycle (currently set at a maximum speed of 64KB per second).

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 Carriers is typically between 24 – 32 ms for 5G and 28 – 47 ms for 4G LTE devices.

Commercial Terms

Where can I find Consumer Cellular’s rates and other fees that apply to its Broadband Services?

Descriptions of the rates and fees applicable to our Broadband Services are described in our service plan offers, including the amount of tethering (or mobile hotspot) data usage available to you during any billing cycle, which may vary by rate plan, and in our Wireless Customer Agreement, available on our website at consumercellular.com/fcclabels, consumercellular.com/shopping/choose/plan, and consumercellular.com/agreement. A link to the information published in our broadband labels in a machine-readable format is available at consumercellular.com/fcc-labels-machine-readable. Consumer Cellular 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 us.

Where can I find Consumer Cellular’s Terms and Conditions and Acceptable Use Policy that apply to its Broadband Services?

Our Wireless Customer Agreement (including the Acceptable Use Policy available at consumercellular.com/aup) can be found at consumercellular.com/agreement.

What are Consumer Cellular’s privacy practices for its Broadband Services?

Our Privacy Policy for our Broadband Services is set forth in Privacy Policy at consumercellular.com/legal/privacyandsecurity.

How can I get assistance from Consumer Cellular if I have a question, concern, or complaint or need more information about its Broadband Services?

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

Email: legal@consumercellular.com
Phone: (800) 686-4460
Mail: Consumer Cellular, Incorporated
Attn: General Counsel; Broadband Services
12447 SW 69th Ave.
Portland, OR 97024

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