Transparency Disclosure


Zirrus (“Zirrus” or “Company”) provides this Disclosure in order to describe its network
management practices in accordance with the FCC’s Open Internet and Transparency Rules.
Information about Zirrus’ other policies and practices concerning broadband are available at (“Zirrus Website”).

Zirrus manages its network to ensure that all of its customers experience a safe and secure
broadband Internet environment that is fast, reliable and affordable. Zirrus wants its
customers to indulge in all that the Internet has to offer, whether it is social networking,
streaming videos and music, to communicating through email and videoconferencing.

Zirrus manages its network for a number of reasons, including optimization, as well as
bandwidth utilization and security-protocol management. Zirrus’ customers generally will not
be impacted by the protocols and practices that Zirrus uses to manage its network.

Zirrus’ Network Management Practices

Zirrus uses various tools and industry standard techniques to manage its network and deliver
fast, secure and reliable Internet service. Such management tools and practices include the


      I.               Managing Bandwidth Utilization

Zirrus manages bandwidth utilization by periodically monitoring every interface throughout its
core network. Zirrus uses software that takes snapshots and produces graphs at regular intervals
to depict bandwidth utilization. This method is used and checked daily. Zirrus manages
bandwidth usage on its network in the aggregate and in order to decrease instances of
congestion on the network, Zirrus may increase its backbone and uplink capacity. Zirrus is
currently transitioning its subscriber network to Fiber-To-The-Home (FTTH) technology.

On Zirrus’ network, all customers have access to all legal services, applications and content
online and, in the event of network congestion, most Internet activities will be unaffected.
Zirrus has re-designed its network to add redundancy in both hardware and fiber ensuring
traffic will re-route around any network issue without the end-user realizing a change has

Customers exhibiting conduct that abuses or threatens the Zirrus network or which violates
the company’s Acceptable Use Policy, Internet service Terms and Conditions, or the Internet
Service Agreement will be asked to stop any such use immediately. A failure to respond or to
cease any such conduct could result in service suspension or termination.

Zirrus’ network and bandwidth utilization management practices are ‘application-agnostic’,
based on current network conditions, and are not implemented on the basis of customers’
online activities, protocols or applications. Zirrus’ network management practices do not
relate to any particular customer’s aggregate monthly data usage.

      II.             Network Security, Application Specific Behaviors, & Device Attachment Rules

Zirrus knows the importance of securing its network and customers from network threats and
annoyances. The company has implemented Greymail to filter customers’ incoming emails and
quarantine any messages that may be perceived as a threat. Customers may access and control
whether these messages are kept or discarded. Customers may forward any messages deemed
safe to the customer’s inbox. Greymail may be viewed for 14 days and it is then deleted.
Greymail is accessible by logging into Webmail or by going to the MyAccount login.


Except as may be provided elsewhere herein, Zirrus does not currently engage in any
application-specific behaviors nor does it employ any device attachment rules for its network.

      III.             Blocking

As its normal practice, Zirrus does not block any protocols, content or traffic for purposes of
network management except that the company may block or limit such traffic as viruses,
malware, or denial of service attacks to protect network integrity and the security of our
customers. Protocols that are heavily used for malicious activity and rarely used for
legitimate traffic are, or may become, blocked long-term.

      IV.            Throttling

Zirrus does not engage in any practice that degrades or impairs access to lawful Internet
traffic on the basis on content, application, service, user, or use of a non-harmful device.

      V.             Affiliated Prioritization

Zirrus does not engage any practice that directly or indirectly favors some traffic over other
traffic including through the use of techniques including traffic shaping, prioritization, or
resource reservation to benefit an affiliate. Please see Specialized Services below for a
description of traffic-type and VLAN prioritization that Zirrus does employ.

      VI.            Paid Prioritization

Zirrus does not employ any practice that directly or indirectly favors some traffic over other
traffic including through the use of techniques including traffic shaping, prioritization, or
resource reservation in exchange for consideration, monetary or otherwise.

      VII.           Monitoring Schedule

Zirrus monitors the aggregate bandwidth utilization on its network daily. Zirrus also checks for
abnormal traffic flows, network security breaches, malware, loss, and damage to the network.
If a breach is detected or high volume users are brought to light by complaint, Zirrus provides
notification to the customer via email or phone. If a violation of Zirrus’ policies has occurred
and such violation is not remedied, Zirrus will seek to suspend or terminate that customer’s


      VIII.          Network Management Technology

Zirrus employs a variety of industry-standard tools, applications and devices to monitor, secure
and maintain its network, including technology network graphing solutions, which Zirrus uses
to analyze the condition of its network.

      VIII.          Service Descriptions

A description of Zirrus’ services and pricing may be found on the Zirrus website.

      IX.            Network Performance Characteristics

Zirrus makes every effort to support advertised speeds. The company recommends where its customers may test actual download and upload speeds. Zirrus strives
to meet internal service level targets. However, customer’s service performance may also be
affected by one or more of the following:

(1) the particular websites being accessed;
(2) capacity in the public Internet beyond Zirrus’ network;
(3) customer’s computer and equipment (including wireless router);
(4) inside wiring at customer’s premise.

      XI.           Specialized Services

Zirrus provides Internet-Protocol-Television (IPTV) services to end users. Throughout the core
of the network, IPTV and voice traffic are prioritized over data by segregating into separate
virtual router functions within each router. In this way, both IPTV and voice maintain separate
routing processes from data traffic. In the last mile, voice, data and IPTV traffic are separated
into separate virtual local area networks (VLANs). No VLAN is given priority over another at this

      XII.          Commercial Terms

In addition to this Network Management Policy, patrons may also find links to the following on
Zirrus’ website:

      ▪ Frequently Asked Questions(“FAQs”)
      ▪ Acceptable Use Policy
      ▪ Internet Service Agreement
      ▪ Privacy Policy

For questions, complaints or requests for additional information, please contact Zirrus at: