CUSTOMER PROPRIETARY NETWORK INFORMATION POLICY

Satcom Direct, Inc/Satcom Direct Communications, Inc. and their affiliates (collectively known as "Satcom Direct") are committed to maintaining the privacy of their customers. In addition to protecting your personal information as outlined in Satcom Direct's Privacy Policy, we are obliged to give additional protections to certain information about how you use your services. In this section, we describe what information we protect and how we protect it.

CPNI PROTECTIONS

As a Customer of our services, you have the right, and Satcom Direct has a duty, under federal law, to protect the confidentiality of certain types of information that Satcom Direct has access to by virtue of the customer-provider relationship, including: (1) information about the quantity, technical configuration, type, destination, location, and amount of telecommunications a customer uses and (2) information contained on your bill concerning the services you receive. That information, when matched to your name, address, and telephone number is known as "Customer Proprietary Network Information," or "CPNI" for short. Examples of CPNI include information typically available on your monthly bill, technical information, type of service, current charges, billing records, usage data and calling patterns.

CPNI does not include things like customer name, address, or telephone number; aggregate information or data that is not specific to a single customer; customer premises equipment; and Internet access services. Unless Satcom Direct obtains your approval, Satcom Direct may not use your CPNI to market products and services to you other than for products and services you have already purchased.

HOW WE USE CUSTOMER INFORMATION

We use CPNI primarily to conduct business activities such as account administration, service provisioning, operations, billings and collections, customer service, technical support, and fraud prevention. These purposes may specifically include the following uses of CPNI to:

• Ensure that you receive the services to which you have subscribed and execute requests that you make;
• Facilitate billing and collections functions and obligations;
• Provide you with accurate and high quality customer service, including responding to customer inquiries and troubleshooting;
• Comply with tax obligations, accounting rules, and contractual obligations to vendors;
• Ensure that you receive information about products and services to which you currently subscribe;
• Ensure compliance with applicable laws and the terms, conditions and policies governing Satcom Direct products and services;
• Protect our rights, such as preventing fraud, service theft, and abusive practices; and
• Improve our facilities and the products and services that we provide through them.

Individuals who may have authorized access to CPNI include our employees, agents, and affiliates, though we seek to limit access to individuals on a need to know basis. Sometimes, we may provide access to certain information to select third parties to assist us in providing services or for other legitimate business purposes. For example, we may provide access to certain information to companies providing services to us, including suppliers, installation and repair, billing, bill collection, auditing and accounting, credit reporting, and legal services. Furthermore, we may provide access to certain information to third party companies providing services to your aircraft’s satellite communication system including the manufacturer, installation and repair centers, and trip planners. We require that outside third parties maintain at least the same level of confidentiality that we maintain. In addition, any use by a third party may not exceed that needed to provide its service. We do not share your information with other third parties without your consent.

APPROVAL

From time to time, Satcom Direct would like to use the CPNI information it has on file to provide you with information about Satcom Direct's communications-related products and services or special promotions. Satcom Direct’s use of CPNI may also enhance its ability to offer products and services tailored to your specific needs. Accordingly, Satcom Direct would like your approval so that Satcom Direct may use this CPNI to let you know about communications-related services other than those to which Customer currently subscribes that Satcom Direct believes may be of interest to Customer. IF Y0U APPROVE, YOU DO NOT HAVE TO TAKE ANY ACTION. However, you do have the right to restrict our use of your CPNI. YOU MAY DENY OR WITHDRAW SATCOM DIRECT’S RIGHT TO USE YOUR CPNI AT ANY TIME BY EMAILING US AT LEGAL@SATCOMDIRECT.COM. If you deny or restrict your approval for Satcom Direct to use your CPNI, you will suffer no effect, now or in the future, on how Satcom Direct provides any services to which you subscribe. Any denial or restriction of your approval remains valid until your services are discontinued or you affirmatively revoke or limit such approval or denial.

CUSTOMER AUTHENTICATION

Federal privacy rules require Satcom Direct to authenticate the identity of its customer prior to disclosing CPNI. Customers calling Satcom Direct's customer service center can discuss their services and billings with a Satcom Direct representative once that representative has verified the caller's identity. There are three methods by which Satcom Direct will conduct customer authentication:

1. by having the caller provide Customer’s name and the associated Satcom Direct customer account number;
2. by calling the Customer back at the telephone number associated with the services purchased; or
3. by mailing the requested documents to the Customer’s address of record.

In the event the Customer fails to remember their Satcom Direct customer account number, a Satcom Direct representative will ask the Customer a series of questions known only to the Customer and Satcom Direct in order to authenticate the Customer.

NOTIFICATIONS OF CERTAIN ACCOUNT CHANGES

Satcom Direct will notify customers of certain account changes. For example, when a customer’s address (whether postal or e-mail) changes or is added to an account, Satcom Direct will send a notification. These notifications may be sent to a postal or e-mail address, or by telephone, voicemail or text message.

PROTECTING CPNI

Satcom Direct uses numerous methods to protect your CPNI, including software enhancements that identify whether a Customer has approved use of its CPNI. Further, all Satcom Direct employees are trained on the how CPNI is to be protected and when it may or may not be disclosed.

Satcom Direct will not release CPNI during customer-initiated telephone contact without first authenticating the Customer's identity in the manner set-forth herein. Violation of this CPNI policy by any Satcom Direct employee will result in disciplinary action against that employee as set forth in Satcom Direct's Employee Manual.

BREACH OF CPNI PRIVACY

In the event Satcom Direct experiences a privacy breach and CPNI is disclosed to unauthorized persons, federal rules require Satcom Direct to report such breaches to law enforcement. Specifically, Satcom Direct will notify law enforcement no later than seven (7) business days after a reasonable determination that such breach has occurred by sending electronic notification through a central reporting facility to the United States Secret Service and the FBI. A link to the reporting facility can be found at: www.fcc.gov/eb/cpni Satcom Direct cannot inform its Customers of the CPNI breach until at least seven (7) days after notification has been sent to law enforcement, unless the law enforcement agent tells the carrier to postpone disclosure pending investigation. Additionally, Satcom Direct is required to maintain records of any discovered breaches, the date that Satcom Direct discovered the breach, the date carriers notified law enforcement and copies of the notifications to law enforcement, a detailed description of the CPNI breach, including the circumstances of the breach, and law enforcement’s response (if any) to the reported breach. Satcom Direct will retain these records for a period of not less than two (2) years.

NOTIFICATION OF CHANGES TO THIS POLICY

If we change this CPNI Policy, we will post those changes on www.satcomdirect.com/main/legal-notices/cpni-rights.aspx or in other places we deem appropriate, so that you can be aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If you decide to continue receiving your services after we make any changes to this the CPNI Policy, you shall be deemed to have given express consent to the changes in the revised policy.

Date of Last Revision: August 29, 2011