At TowardEX, we are committed to protecting our customer privacy. Our privacy commitments are fundamental to the way we do business every day. Our commitments apply to everyone who has a relationship with TowardEX, including our customers and web site visitors.

The Information We Obtain and How We Use It

The information we obtain from you is generally necessary for us to provide your services and design new services for your future use. For example, we need to know your name, address and the services you buy from us to properly provide and bill for those services. When you call us, our representatives pull up account records and may refer to your bill, your product or service usage patterns, and other information we have to answer questions you may have or recommend how we can best serve you.

We may also use information in our records to protect our customers, employees or property - for instance, to investigate fraud, harassment or other types of unlawful service activities involving TowardEX or other providers that we do business with. In some cases, it may be necessary to provide this information to the government or third parties who make a lawful demand for it.

We share information within our TowardEX companies to enable us to better understand our customers' product and service needs, and to learn how to best design, develop, and package products and services to meet those needs. Like any growing business, we may structure our company to include a number of smaller companies or product divisions. Currently, our primary lines of business include server hosting, cloud hosting solutions, colocation, managed data center services, Internet access for businesses and consumers and wireless services.

Accuracy of the Information We Hold

We want the information we obtain and use about customers to be accurate. If your service information or your point of contact information changes or you see an inaccuracy on your TowardEX bill or notifications, let us know so we can correct it.

Security of Information and Accountability

We have information systems that collect and store customer information in addition to systems that store our own business records. These systems have different types of security as appropriate for the information stored. TowardEX requires employees to keep customer information confidential and we hold them accountable for their actions. Moreover, pursuant to the Massachusetts consumer privacy protection laws, we constantly audit and review our internal systems security and business operating processes to ensure and maintain compliance with 201 CMR 17.00.

Information Disclosure Outside of TowardEX

As a general rule, TowardEX does not release customer account information to unaffiliated third parties without your permission unless we have a business relationship with those companies where the disclosure is appropriate. For instance, we may hire outside companies as contractors or agents; or we might be engaged in a joint venture or partnership with a company. Upon occasion, TowardEX may decide to stop providing a service or may decide to sell or transfer parts of our business to unaffiliated companies. When this happens, we may provide confidential customer information to these companies so that they can offer you the same or similar services. In all of these situations, we provide information to these other companies only as needed to accomplish our business objectives and the companies are bound by requirements to keep TowardEX customers' information confidential.

However, there are also exceptions to the general rule. For example, we might provide information to regulatory or administrative agencies so that they can accomplish their regulatory tasks (such as responding to a customer complaint) or to maximize the efficiencies of our own processes (such as getting mailing addresses correct, for example). Other disclosures will be driven by legal requirements imposed on TowardEX. TowardEX complies with "legal process," such as a subpoena or court order or other similar demand, associated with either criminal or civil proceedings.

Disclosure of Customer Account Information

If you tell us in writing to release your account information to someone, we will honor your request and provide that information.

We may provide account information to collection agencies when customers do not pay their bills. We restrict the use that can be made of this information to collection activities only for our charges and for the charges we bill for others.

Other providers use TowardEX to bill for their charges. In this case, they provude with information about you, including your service or product usage patterns, and we bill you on their behalf. In turn, we provide them with non-sensitive information about your service, such as the date your service was established or disconnected; type of products and/or services being used, how you pay your bills and if they are paid on time.

Your Control Over the Disclosure of Information

TowardEX or its business partners may use e-mail to communicate with customers about events or new products and services or to respond to visitor's e-mails. If you receive unwanted email from us you may also remove yourself from our email list by simply following the "unsubscribe" instructions in the email. We will not send commercial solicitations to customers who request it not be sent. Please note that if you do go through this process, some e-mail messages may still come to you, although not those dealing with commercial solicitations. For example, we may e-mail you about system maintenance, changes to your service, or other types of product advisories.

We will honor for two years the request of individuals not to receive direct mail marketing materials.

We honor customer requests to have their names removed from lists that TowardEX might provide to firms desiring to do product promotions. Customers with non-listed and non-published numbers are not included on the lists. For individuals with listed information, if you do not wish to have your name included on such lists, just tell us and we will remove your name.