Lakeside Networks Privacy Policy

1. Who and what this policy covers

This Privacy Policy is issued by Lakeside Networks, LLC, which also does business as Tonka Networks ("Lakeside," "we," or "us"). It applies to our website at tonka.network(also reachable at lakeside.network, and references to either domain include the other and their subdomains), our customer portal at panel.tonka.network, our internet service, our voice service, the managed Wi-Fi networks we operate at buildings, marinas, and other properties, and our installation and support work. It covers customers, people who inquire about service, visitors to our website, and people who use a Wi-Fi network we operate. If you use another Lakeside service under a separate agreement that includes its own privacy terms, those terms apply to that service. Until a separate service has its own privacy terms, this policy applies to the information we collect to provide it.

This policy describes our intentional practices. The equipment, software, and vendor systems we use to run a network and a business generate technical and diagnostic records in the ordinary course of operation. We do not use those records to track or profile you, and this policy explains the ones we rely on. This policy is part of our Internet Service Agreement, and Sections 10 and 13 of that Agreement apply to any claim about it. The time periods and safeguards it describes are our practices, not a guarantee that no error or incident will ever occur.

2. What we collect

We collect information in five ways: you give it to us, our network generates it when we deliver service to you, our website and portal collect it when you use them, our technicians and staff create records when they install and support your service, and, in limited cases, we receive it from others.

We do not intentionally collect government identification numbers, and we do not ask for a Social Security number. If we ever need to verify your identity to prevent fraud, we will tell you what we need and why.

3. What we do not do

• We do not sell, rent, or trade personal information, and we do not provide it to data brokers.
• We do not use what you do on your internet connection to target advertising or to build advertising profiles.
• We do not intentionally track or record the websites you visit, the services you use, or the content of what you send and receive. Our network carries your traffic; it is not designed to catalog it.
• We do not sell sensitive information, such as precise location or information about children.
• We do not sell advertising on our website, and we do not use advertising networks that track visitors for other companies. The only advertising tool we use is Google Ads for our own ads, described in Section 8.

Apart from the Google Ads remarketing described in Section 8, we do not use your information for targeted advertising or profiling, and we do not sell personal information, so there is nothing else in those categories to opt out of. If your browser sends a Global Privacy Control signal, we treat it as a request to opt out of remarketing.

4. The network records we do keep, and why

Running a network requires a set of technical records. We want to be clear about them so that the statements in Section 3 mean something. We keep:

• IP address assignment records (which address was assigned to which account, and when), so that we can route your traffic, respond to abuse reports and lawful requests, and identify the account behind a copyright notice without revealing your identity to the sender. These are generally retained for about 90 days.
• Data usage totals for your connection, so that we can operate your plan and answer your questions about usage. These are generally retained for about 12 months.
• Signal, performance, and equipment health readings, so that we can maintain and troubleshoot your connection. These are generally retained for about 12 months.
• Voice call detail records (numbers, times, durations), which we must keep for billing, 911, and legal purposes. These are generally retained for about 24 months.
• Security event records, such as blocked attack traffic and logins to your portal account, generally retained for about 12 months.

Network equipment and the vendor platforms we use may also generate other diagnostic logs as part of normal operation. We do not use any of these records to track your browsing or to build a profile of you, we do not sell them, and we disclose them only as described in Section 6. Retention periods are targets rather than guarantees; records may persist for a time in backups or vendor systems before they are removed.

5. How we use information

We use information to: check whether we can serve your address and quote service; install, provide, maintain, and repair the service; bill you and process payments; respond to support requests; keep the network and your account secure and detect fraud and abuse; send service notices about outages, maintenance, billing, and changes to our terms; tell you about our own services and offers, which you can opt out of at any time; meet our legal obligations; and understand how our website is used so we can improve it. We use aggregated or de-identified information, which does not identify you, to plan network capacity and report on our business.

We do not use automated profiling to make decisions that have legal or similarly significant effects on you. Decisions such as whether to require a deposit are made by a person using your payment history with us.

6. When we share information

We share personal information in the following situations, and in each case only the information the situation reasonably requires.

• Companies that work for us. We use a billing and customer portal platform, a payment processor, our voice service platform, network management and monitoring tools, an email and text messaging service, scheduling and mapping tools, website tools, and independent installation technicians. Each is permitted to use your information only to perform its work for us and is expected to protect it. Installation contractors receive the details of the job.
• Voice service partners. If you subscribe to voice service, we share your name, telephone number, and Registered Location with the carriers and 911 database operators that route calls and emergency services, and with the carrier involved when you port a number.
• Legal requests. We disclose information to a government agency or private party when the law requires it or in response to a subpoena, court order, search warrant, or other legal process, and to emergency responders when we reasonably believe disclosure is necessary in an emergency involving a danger of death or serious physical injury. Where the law allows and it is practical, we may notify you before responding to a request for your information.
• Copyright notices. When a copyright owner sends a notice about an IP address, we may forward it to the account holder. We do not identify you to the sender unless legal process requires it.
• Protecting people and the network. We may share information with other network operators, our vendors, and law enforcement when it is reasonably necessary to investigate fraud, abuse, or a security threat, to enforce our agreements, or to protect the safety of a person.
• A sale of the business. If Lakeside is sold or merges with another company, your information transfers with the business, and the buyer takes on the commitments in this policy for the information it receives.
• At your direction. For example, if you ask us to speak with a family member, landlord, or IT provider about your account.

7. Voice customers: your call records (CPNI)

Federal law treats information about your voice service, such as the numbers you call and the services you subscribe to, as Customer Proprietary Network Information (CPNI) and gives you specific protections. We use CPNI to provide, bill, and support your voice service and to respond to lawful requests. We do not use your call records to market to you, and we do not share them for marketing. Before we discuss call records or make changes to your voice account, we will verify your identity with your account password or PIN, or by other methods the FCC permits. If a breach of CPNI occurs, we will notify law enforcement and you as the FCC's rules require.

8. Cookies, tags, and website tools

Our website uses cookies and similar tools. Some are ours and some belong to the companies that provide the tools we use. They fall into these groups:

• Site operation. Our website platform sets cookies that make the site work and keep basic visit statistics (for example, whether you have visited before). Our customer portal uses cookies to keep you signed in.
• Google tags. We use Google's tag to measure how visitors find and use our site (Google Analytics) and, when we advertise, to measure whether our own advertising leads to inquiries (Google Ads conversion measurement). Google may set cookies and receive your IP address and the pages you visit on our site, and may use that data as described in Google's privacy policy. We also use Google Ads remarketing, which may show you our ads on other websites after you visit ours; you can opt out at adssettings.google.com or by blocking cookies. Our forms use Google reCAPTCHA to block automated submissions, which also sends technical data to Google.
• Embedded widgets. Some pages embed content from other services, such as our network status badge and other display widgets. Those services may set cookies or collect technical data when the widget loads.

You can block or delete cookies in your browser settings, and you can opt out of Google Analytics with Google's browser add-on. If you block cookies, the site will still work, although a form may not remember what you typed. We do not use these tools to track what you do on your internet connection, and we do not connect website analytics to your customer account.

9. Your rights and choices

We honor the following requests from anyone this policy covers. You may:

• Ask what personal information we hold about you and receive a copy in a common, portable format. We provide the account, billing, support, and network records described in Sections 2 and 4, in the form we keep them.
• Ask us to correct information that is inaccurate.
• Ask us to delete personal information. We will delete it unless we need to keep it to provide service you still receive, to bill or collect an amount you owe, to meet a legal obligation, or to handle a dispute, and we will tell you which of those applies.
• Opt out of marketing messages at any time by using the link in any marketing email, replying STOP to a text, or contacting us. We do not send marketing text messages unless you have agreed to receive them, and we do not share mobile numbers or text messaging opt-in information with any third party, including our affiliates, for marketing or promotional purposes. You will still receive service messages such as outage, maintenance, billing, and legal notices.
• Object to a use of your information that you believe is inconsistent with this policy.
• Appeal our response. If we decline a request, we will explain why, and you may ask us to reconsider. We will answer an appeal in writing, generally within 45 days, and if you are still not satisfied you may contact the Minnesota Attorney General's Office.

To make a request, email questions@tonka.network or call (612) 444-8664. We will confirm that the request comes from the account holder or an authorized person (for voice call records we follow the FCC's authentication rules, which may mean sending records to the address on your account) and respond, generally within 45 days. For complex requests we may take up to 45 more days and will tell you why. We do not charge for reasonable requests and we do not treat you differently for making one. An authorized agent may make a request on your behalf with your written permission.

10. How we protect information

We use administrative, technical, and physical safeguards that fit the size of our business and the sensitivity of the information, including encryption of your connections to our website and customer portal, hashed storage of portal passwords, access limited to people who need information to do their jobs, and logging of sign-ins to the systems that hold customer records. No system is perfectly secure, and we cannot promise that unauthorized access will never occur. This section describes our current practices, not a guarantee. If a breach affects your personal information, we will notify you as Minnesota Statutes section 325E.61 and applicable federal rules require.

You can help by using a strong, unique password for the customer portal, keeping your Wi-Fi password private, and keeping the devices on your network updated. If you believe your account has been accessed without your permission, contact us right away.

11. How long we keep information

We keep personal information as long as we reasonably need it for the purpose we collected it, and then we delete or de-identify it in the ordinary course. In general: account, billing, and support records are kept while you are a customer and for about six years afterward, which is the period in which billing disputes and legal claims can arise; the network records in Section 4 are kept for about the periods stated there; inquiry and waitlist information for people who do not become customers is kept so that we can let you know when service reaches your area, and is removed whenever you ask; website analytics data is kept for about 14 months; recordings of support calls are kept for about 12 months; and managed or guest Wi-Fi connection records are kept for about 90 days. We may keep information longer when a legal obligation, a dispute, a lawful request, or a backup cycle requires it.

12. Children

Our website and services are intended for adults. Only a person who is at least 18 years old can open an account. We do not knowingly collect personal information from children under 13, and our website is not directed at them. If you believe a child has provided us with personal information, contact us at questions@tonka.network and we will delete it.

13. Where we operate

Lakeside provides service in Minnesota, and our website is intended for residents of the United States. Your information is stored and processed primarily in the United States by us and by the service providers described in Section 6.

14. Changes to this policy

When we change this policy, we will post the new version on our website with a new "Last modified" date. If a change materially affects how we collect, use, or share your information, we will give you at least 30 days' notice by email, bill message, or another method described in our Internet Service Agreement before the change takes effect. We do not anticipate ever selling personal information; if that ever changed, we would tell you and give you a choice before it took effect. Earlier versions are available on request.

15. Contact us

Questions, requests, and concerns about privacy: Lakeside Networks, LLC, 4154 Shoreline Drive, Suite 210, Spring Park, MN 55384, (612) 444-8664, questions@tonka.network. To report a security concern, use the same address and put "Security" in the subject line.