Customer Privacy Statement
REVISED January 2007

CUSTOMER PROPRIETARY NETWORK INFORMATION (CPNI)

It is the official policy of the Cooperative that all access, use, disclosure or distribution of CPNI be in accordance with the customer privacy safeguards set forth in the Communications Act and the Federal Communications Commission (“FCC”) Rules, and that all Cooperative employees, agents and independent contractors who handle the Cooperative’s CPNI are aware of these customer privacy safeguards and comply fully with them.

CPNI is defined in Section 222(f) of the Communications Act as (A) information that relates to the quantity, technical configuration, type, destination, and amount of use of a telecommunications service subscribed to by any customer of a wireline or wireless telecommunications carrier, and that is made available to the carrier by the customer solely by virtue of the carrier-customer relationship; and (B) information contained in the bills pertaining to telephone exchange service or telephone toll service received by a customer of a carrier (except that CPNI does not include subscriber list information).

Generally, CPNI includes personal information regarding a consumer’s use of his or her wireline and/or wireless telecommunications services.  CPNI encompasses information such as: (a) the telephone numbers called by a customer; (b) the frequency, duration and timing of a customer’s phone calls, and (c) the telecommunications and information services purchased by a customer (including, but not limited to, local exchange, toll, cellular, paging, data transmission, call waiting, call forwarding, call blocking, Primary Interexchange Carrier (PIC) freeze, three-way calling, conference calling, voice mail, Internet access, call back, caller identification, call trace and toll denial services).

Additional information on CPNI and the Cooperative’s adherence procedures may be obtained from the Cooperative.

Customer Privacy Statement
REVISED February 28^th, 2001

Like you, we at Halstad Telephone are concerned about customer privacy. We have a long history of maintaining the privacy of information we obtain in the normal course of providing our services. While we are working hard to serve you in new and exciting ways, our commitment to maintaining your privacy remains as strong as ever.

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 your records and may refer to your bill, your calling 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 Halstad Telephone or other carriers 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 Halstad Telephone 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 best meet those needs. Like any large business, we may structure our company to include a number of smaller companies. Currently, our primary lines of business include local and long distance services, wireless services, cable services, dedicated web hosting, dedicated Internet access for businesses and consumers, on-line services, and directory publishing. We also offer other products and services, for example, Frame Relay, Asynchronous Transfer Mode (ATM), telephone equipment, voice mail services, and directory advertising.

Accuracy of the Information We Hold
We want to make sure the information we obtain and use about customers is accurate. To that end, we strive to verify that our customer records are correct. Much of this information is reflected in your monthly bill. If you see an inaccuracy on your Halstad Telephone bill, and you let us know, we can correct it.

Security 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. Halstad Telephone requires employees to keep customer information confidential and we hold them accountable for their actions.

Providing Services to Enhance Your Privacy
Non-published numbers, Caller ID and Caller ID blocking services, Anonymous Call Rejection, and No Solicitation are among the privacy services Halstad Telephone offers to enhance your privacy.

Disclosure of Information Outside Halstad Telephone
As a general rule, without your permission, Halstad Telephone does not release confidential customer information to unaffiliated third parties unless we have a business relationship with those companies where the disclosure is appropriate. For example, we may hire outside companies as contractors or agents; or we might be engaged in a joint venture or partnership with a company. We provide information to these other companies only as needed to accomplish our business objectives and the companies are bound by requirements to keep Halstad Telephone customers' information confidential.

There are exceptions to the general rule. For example, we might provide information to regulatory or administrative agencies so that they can accomplish their regulatory tasks (for example, 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 Halstad Telephone. Halstad Telephone complies with "legal process," such as a subpoena or court order or other similar demand, associated with either criminal or civil proceedings; and, if not prohibited by the legal document, we will advise you of the demand.

Disclosure of Account Information
If you tell us in writing to release your account information, we will do so and provide that information to the person you tell us to.

Your account information is released to other carriers when you give us your permission. This most often occurs with respect to a sale of service they want to make or have made to you. Unless we are advised that permission from you has been granted, we do not release the 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 carriers use Halstad Telephone to bill for their charges. In this case, they provide us with information about you, including your calling 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; whether you have toll or 900 blocking services, whether you have a calling card or not and when it was issued, how you pay your bills and if they are paid on time.

Disclosure of Customer Telephone Numbers, Names and Addresses
Telephone number, name and sometimes address information is "released" by Halstad Telephone in different ways. It is sometimes released as "lists" to entities that are entitled by law to receive the information or which have entered into contracts with Halstad Telephone to receive it. The information is sometimes released through the network "transactionally," such as when your phone number and name are released through a Caller ID mechanism. Sometimes the information is provided in reports to those persons who are being called by you and want to know more about who is calling them and when. Whether a number is recognized as "published" or not will generally depend on the medium by which the number is captured and released.

For example, a person can ask Halstad Telephone to include them in directories (that is "publish" their number) or not. Persons can ask to not be published in directories but included in Directory Assistance (non-listed numbers). Or persons can ask not to be either in directories or Directory Assistance (non-published). All of these terms refer to a "listing" status.

However, the telephone network does not recognize a number as published/listed or non-listed or non-published. Thus, the network will "pass" that number to interconnecting carriers (local, long distance, wireless) and to called parties. Only if the network (a) has the capability to block the number; and (b) you have invoked a blocking mechanism will the called party (but not the carriers in between) be unable to see the calling number. And, where both the calling number and name are "carried" as part of the network call, generally either both will be displayed or both will be blocked.

In some cases, such as on some party- or coin-operated lines, as well as calls to pay-per-call (900) or toll-free numbers (such as 800/888/877 numbers), the network does not have the capability to block your underlying phone number even if you invoke Caller ID blocking. And there may be other services that rely on this type of automatic number identification (ANI) technology, such as cable companies that offer movies keyed to the automatic delivery of your phone number or pizza companies that route your calls to the closest stores based on your number. There are a variety of businesses that subscribe to these types of services. By federal regulation, however, businesses that utilize this technology can only use it to provide you the service in question or one directly related to it. And, because federal law requires phone numbers associated with facsimile transmissions to be released as part of the facsimile, these phone numbers are not blocked either.

In addition to the above types of disclosures, Halstad Telephone is required, by law, to make disclosures of customer telephone number, name and address information in certain circumstances, including those described below.

• We are required to provide listed customer names, addresses and telephone numbers to directory publishers – our own and others. Halstad Telephone and other directory publishers may publish this information in alphabetical or reverse directories that take the form of paper directories, electronic directories over the Internet, or on CDs. We also provide customer name and addresses for all customers (including non-listed and non-published customers) to directory publishers to allow for directory deliveries, but only for that purpose.
• We are required to provide customer names, addresses and telephone numbers to directory assistance and operator services providers. This information includes non-listed information, as well as the name and address of non-published customers. We restrict the use of this information to directory or operator services only. Some of these providers offer Internet or online directory assistance services.
• In some cases, when you dial 911, your name, address and telephone number information is provided to the emergency service provider. And, by law, we are required to provide this information, including non-listed and non published information, to emergency service providers and emergency support services providers upon request in a more comprehensive format.
• If you place a long distance call using a provider other than the one you use on your home phone — for example, if you place a calling card or third number billed call from a pay phone — Halstad Telephone is required by law to provide billing name and address information to the service provider. This includes names and addresses associated with non-published and non-listed information where the individual has not objected. This information cannot be used for marketing purposes. Similar information is provided with respect to the provision of services by non Halstad Telephone carriers.
• We might provide your name and address to administrative agencies where we are working with them to minimize costs and maximize accuracy. For example, we might share this information with the Post Office so that we continue to get reduced postage rates and you get your bills and other information from us in a cost-efficient, reliable and timely fashion.
• We also compile lists of customer names, addresses and telephone numbers of the type printed in the White Pages directories and provide these lists to qualified companies that are conducting product promotions on behalf of Halstad Telephone. Non-published and non-listed numbers are not included in these lists and we remove other customers from these lists by request.

Your Control Over the Disclosure of Information
You tell us the telephone listings you want to include in our directories and in directory assistance. You also may choose to have a non-published or non-listed number, or to exclude your address from your listing.

As we addressed above, in certain cases you can block the transmission of your telephone number (and name) to those persons you call.

We may provide you with information about new products and services or special promotions. However, consumers who do not wish to receive such information can "opt out" or have their names removed from the direct mail, email, and telemarketing lists associated with Halstad Telephone. Just call us to have your name removed from our direct mail and telemarketing lists. Our residential local telephone service customers may also visit our www.halstadtel.com  web site, Email Contact Preferences page to add or remove themselves from our email lists. If you receive unwanted email from us you may remove yourself by simply following the "unsubscribe" instructions in the email. Please understand that making this type of request may mean that you will be unaware of services or discounts that you might find useful.

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 at no charge.

Privacy Over the Internet
Halstad Telephone sets high standards and has a strong commitment to protect customers' privacy on all of its Web sites. We pledge that as we gather and use information about you, we do so responsibly.

Cookies: Some of Halstad Telephone's Web sites may use "cookies" to improve our level of service and speed up the delivery of information to our visitors. Cookies are lines of text that are transmitted to your Web browser when you click on a site. They provide a way for a server to recall a previous request or previous registration, or to keep track of a transaction as it progresses, so that information does not have to be repeated. Your browser stores the information on your hard drive and when you return to that site later, the cookie is transmitted back only to the servers that originally sent it to you. To be notified when you are about to receive a cookie you can configure your browser to alert you when a site is attempting to send you a cookie and at that time you will have the option of refusing the cookie. You can check your hard drive for cookie files in a "cookies" folder for Internet Explorer, a "cookies.txt" file for Netscape, and under "magic cookies" on a Macintosh.

Advertisers that serve ads on our Web sites may also use their own cookies. These cookies collect their own information independent of Halstad Telephone. You can disable this cookie capability as described above.

How on line information Halstad Telephone collects is used: The only individually-identifiable information Halstad Telephone obtains about individual visitors to our Web sites is information supplied voluntarily by the visitor. This means that you can visit our Web sites without telling us who you are or revealing any information about yourself. To gauge the effectiveness of our Web sites, we do collect some non-individually-identifiable generic information about our visitors. Our Web servers automatically recognize a visitor's Internet service provider, the IP address, the domain name, the type of browser, and the operating system. In addition to, which pages are viewed on our sites, the Web page you were on when you link to our sites, how much time a visitor spends on each page and other information related to the operation and interaction of Halstad Telephone Web sites. This information does not reveal a visitor's identity. We aggregate this information and use it to evaluate and improve our Web sites.

You can choose to provide individually-identifiable information to Halstad Telephone in a number of ways through our Web sites – by ordering a service from us, sending us email, registering to receive news or information, applying for a job, or entering a contest. When visitors supply information about themselves for a specific purpose, Halstad Telephone uses the information for that purpose (such as to provide the information the visitor has requested or to consider a visitor for a particular job). In addition, when visitors use our Web sites to order services, or to request information about our services, we may use the individually-identifiable information as we would use the same information obtained off-line – for example, to evaluate your service needs and contact you regarding additional services you may find useful.

A user may choose to provide us individually-identifiable information to customize a personal home page. We use this information to better understand and serve our customers, but we do not share that information outside of Halstad Telephone. This information may be compiled on an aggregated basis and shared with our advertisers or business partners.

For our Halstad Telephone customers – as part of our ongoing efforts to improve our service, we or someone acting on our behalf may monitor Internet activity. This means that a user's session may be tracked, but the user will be anonymous. This process does not capture or transmit any personally identifiable information and the anonymous or aggregated information may be provided to third parties for other purposes.

We do not sell or disclose individually-identifiable information obtained on-line about our visitors, to anyone outside of Halstad Telephone except as described above (when Halstad Telephone is in a business relationship with an unaffiliated party and then under confidentiality restrictions) unless you specifically authorize it, it is required by law (including the service of subpoenas or court orders in either civil or criminal lawsuits), or disclosure is necessary to protect the safety of customers, employees or property. If you provide individually-identifiable information to us in the context of an event Halstad Telephone sponsors with another company, such as a contest, or if you register on a co-sponsored site or feature, you may also be providing the individually-identifiable information to the co-sponsor. The Halstad Telephone Web sites may contain links to other sites. We are not responsible for the content or privacy practices employed by other sites. Other Web sites may have different privacy policies or no policy. Users should review the privacy policies of any Web site before providing personal information.

E-Mail Communications: Halstad Telephone, or those with whom Halstad Telephone has a business relationship, will use email to communicate with our customers, respond to visitors' emails, or to inform about events or new products. Halstad Telephone will not send commercial solicitation via email to individuals who request it not be sent.

Children: Halstad Telephone does not currently target its online services to children under 13 years of age; and Halstad Telephone has no intention of collecting any information from children under 13 years old. However, some of our sites may contain links to content providers that collect such information. These companies are expected to comply with all laws pertaining to the collection of information from children. Because the Internet offers open access to a wide range of information, it is important that parents supervise and prevent access to inappropriate content, email or chat sessions.

To improve the services it can offer you, Halstad Telephone may opt to expand its capabilities for obtaining information about users in the future.
Halstad Telephone is committed to maintaining the privacy of customer information.
At Halstad Telephone, your privacy is a priority.

Life Line Support For Low Income Customers

The Low Income Program of the Universal Service Fund, which is administered by the Universal Service Administrative Company (USAC), is designed to ensure that quality telecommunications services are available to low-income customers at just, reasonable, and affordable rates. Similar programs have existed since at least 1985. The Telecommunications Act of 1996 reiterated their importance by including the principle that "consumers in all regions of the nation, including low income consumers . . . should have access to telecommunications and information services . . ."

Additional Information can be found at www.lifelinesupport.org