BROADBAND TRANSPARENCY DISCLOSURE
To help keep customers informed about our mass market wireless broadband Internet access services (“Broadband Services”), this disclosure describes the Broadband Services we offer and provides information about the network management practices, performance characteristics, and commercial terms applicable to our Broadband Services, consistent with the Federal Communications Commission’s (“FCC’s”) Transparency Rule. Broadband Services provide subscribers with the ability to transmit and receive data from all or substantially all Internet endpoints. As a Mobile Virtual Network Operator (“MVNO”), we provide our Broadband Services using the facilities of our underlying carrier, a leading nationwide wireless provider (“Underlying Carrier”). As a result, while we have some control over aspects of your Broadband Service, we do not actively manage the network you use to receive Broadband Services from us—our Underlying Carrier does.
The information provided in this statement should help customers make informed choices about the purchase and use of our Broadband Services, and will assist providers of Internet applications, content, and services in developing, marketing, and maintaining their Internet offerings. The information provided relates to your experience while using the network of our Underlying Carrier and may not describe the practices, performance, or terms you may experience while using extended coverage networks or roaming on affiliated networks. We encourage mass market customers and other users of our Broadband Services to familiarize themselves with this information and to provide us with feedback about our Broadband Services so that we can continue to provide an excellent experience.
How does PureTalk manage congestion with respect to its Broadband Services?
PureTalk, through its Underlying Carrier, which owns and operates the network PureTalk uses to provide service, strives to provide a high-quality Internet experience for all of our customers. Like the other networks that make up the Internet, the network of our Underlying Carrier is a shared network, which means that the transmission links and other network resources used to provide Broadband Services are shared among PureTalk’s subscribers and other users of our Underlying Carrier’s network. Our Underlying Carrier manages its network for the benefit of all users based on a variety of factors and its technical expertise. Nonetheless, temporary congestion may occur when a large number of customers in a concentrated area access the network at the same time or when some customers consume a very large amount of network capacity during busy periods, such as at stadium events, during peak usage times, or during planned network maintenance.
Congestion-Based Data Management. During periods of congestion, our Underlying Carrier may use Congestion-Based Data Management to manage the network. With Congestion-Based Data Management, customers with unlimited data plans may experience reduced data speeds and increased latency as compared to other customers using the same cell site. However, even when subject to this congestion management practice, the amount of data these customers may use will never be limited and they will never be subject to data overage charges. Reduced speeds and increased latency may cause websites to load more slowly or affect the performance of data-heavy activities such as video streaming or interactive gaming. Customers subject to Congestion-Based Data Management will experience reduced speeds and increased latency only when they use data at a cell site experiencing network congestion at the same moment. As soon as the congestion at the cell site abates, or if the customer’s session migrates to an uncongested cell site, speed and latency will return to normal. In addition, this network management practice adjusts dynamically to address the amount of congestion, which can start and stop over a very short time period (often measured in fractions of a second), further minimizing any customer impact. Because the amount of congestion at a cell site can vary significantly, the performance impact for affected unlimited data plan customers may also vary significantly, but such impact will last only as long as the site is congested.
Buffer Tuning. With the ever increasing growth in smart phone and tablet usage on wireless networks, and the growing prevalence of video downloads, our Underlying Carrier has deployed a reasonable network management video optimization technique in its mobile data network. That technique delivers recorded video to the user’s device in a “just in time” fashion (“Buffer Tuning”). Buffer Tuning only applies to internet browser traffic (HTTP, port 80) for recorded video downloads, regardless of the source, and does not affect real-time streaming video. Without Buffer Tuning, video content may be completely delivered to the device and charged against the user’s data plan regardless of whether it is viewed. With Buffer Tuning, a sufficient amount of video is delivered to the device so that the user can start viewing the video, and the remainder of the video is delivered just in time to the device as needed for uninterrupted viewing. This optimizes the user’s data plan consumption. Additionally, this frees up network resources for all users. Buffer Tuning does not alter video content and should not directly introduce any adverse impact to the viewing experience.
Does PureTalk limit data usage or provide customers with tools to monitor and control their data usage?
PureTalk offers prepaid plans with pre-established allotments of data. Customers may determine their remaining data and account balance by calling customer service.
Does PureTalk favor certain websites or Internet applications by blocking or throttling traffic, modifying particular protocols, or prioritizing certain traffic on its Broadband Services?
No, PureTalk does not favor certain websites or Internet applications by blocking or throttling lawful internet traffic on the basis of content, application, service, user, or use of non-harmful devices on its Broadband Services. Nor does PureTalk modify particular protocols, protocol ports, or protocol fields in ways not prescribed by the protocol standards, subject to reasonable network management. Additionally, neither PureTalk nor PureTalk’s Underlying Carrier directly or indirectly favor some traffic over other traffic (such as through prioritization, resource reservation, or traffic shaping) for any type of consideration. In response to a specific security threat against the networks of our Underlying Carriers or our customers, we or our Underlying Carrier may occasionally need to limit the flow of traffic from certain locations or take other appropriate actions. Additionally, our Underlying Carrier may favor some traffic over other traffic to address the needs of emergency communications, law enforcement, public safety, or national security authorities, consistent with or as permitted by applicable law.
How does PureTalk handle alleged copyright infringement by subscribers to its Broadband Services?
Our Underlying Carrier utilizes a copyright alert process to respond to alleged copyright infringement activities using peer-to-peer file sharing and attempts to educate customers about the importance of protecting copyright and lawful use of content available over the Internet. Under the program, content owners may notify our Underlying Carrier of alleged copyright infringement based on the IP address of a user. Our Underlying Carrier will pass the request to us, and then we will attempt to identify a subscriber account based on that IP address and forward a copyright alert to that subscriber, advising the subscriber of the allegation and providing information about online copyright infringement, so that the subscriber, as the account holder, can take steps to prevent any future possible infringement using the Broadband Services. If a subscriber receives additional alerts, we may temporarily redirect the subscriber to a webpage where the subscriber must review material on the importance of copyright and the lawful use of content available over the Internet. Upon completion of this review, such redirection will be discontinued and the subscriber’s Broadband Services will be restored to normal. If a subscriber continues to receive alerts, we or our Underlying Carrier may take action consistent with Section 512(i) of the Digital Millennium Copyright Act, which may result in termination of the subscriber’s Broadband Services. Subscriber personal information is protected throughout this process—we will not provide such information to content owners unless required to do so by court order.
What practices has PureTalk adopted to manage network security?
As an MVNO, PureTalk does not have the ability to manage the security of its Underlying Carrier’s network. However, our Underlying Carrier proactively monitors network activity to help guard against a wide range of security threats, including viruses, botnets, worms, distributed denial of service attacks, SPAM, and other harmful activity. We cannot guarantee that you will not encounter unwanted, harmful, or malicious internet traffic while using our Broadband Services and encourage you to adopt your own reasonable security practices.
If our Underlying Carrier detects a security threat, it will typically attempt to isolate the threat and minimize the impact to network services. It may use a variety of security measures to protect the network, including blocking malicious or unlawful traffic, redirecting the flow of traffic over some portions of the network, or taking other actions to address the threat. For example, it blocks certain ports that transfer malicious or disruptive traffic (such as Ports 25, 135, 139, 445, and 1900) and may block additional ports in the future based upon threat assessments. It also attempts to limit actions to the specific portions of the network or customer base impacted by the security threat and only for as long as necessary to mitigate the threat.
Our Underlying Carrier may scan or analyze network addresses that are registered through the Underlying Carrier, including addresses that may have been delegated to customers, and/or routes that originate from the Underlying Carrier’s networks to detect vulnerabilities that might be used to compromise the assets of PureTalk, our Underlying Carrier, its subscribers, or our subscribers or that might be used in attacks against others. In doing so, it seeks to avoid disrupting network service to customers. We and our Underlying Carrier may use information derived from these activities to identify and address security issues or to notify subscribers of issues.
Does PureTalk restrict the types of devices that customers can use with its Broadband Services?
PureTalk’s customers may attach 3G- or 4G-capable devices of their choice to our Broadband Services, so long as the devices are FCC-approved, are compatible with the technology used in our Underlying Carrier’s network, do not harm the network or other users, and are not designed only for accessing data services. Devices must also be used in a manner consistent with our Terms and Conditions, including our Authorized Use policy. For example, some data plans are designated for use with only a basic phone or smartphone, in which case customers may not use their devices as a personal hotspot while other plans explicitly allow customers to use their devices as a personal hotspot. Our Underlying Carrier has retired its 2G network, and as a result, 2G-only capable devices will not be activated to attach to our Broadband Services.
What factors affect the performance of my Broadband Services?
End-to-end performance of your service can depend on a variety of factors, many of which are outside of our control, including: your location relative to our coverage area, your proximity to a cell site, the capacity of the cell site, the number of other subscribers connected to the same cell site, the number of subscribers simultaneously using the network, the services other users are using, topography, weather, obstructions, use inside a building or a moving vehicle, radio frequency interference, the capabilities of your device, the applications you are using, the server with which you are communicating through your usage, the destination of your Internet traffic, overall traffic on the Internet, whether there are network outages, and applicable network management practices as discussed above. In addition, our Underlying Carrier has designed its wireless services to provide our customers with a high-quality voice experience during simultaneous voice and data sessions, which may affect data performance, including, but not limited to, a temporary reduction in speed to minimize the likelihood of dropped calls. Although our Underlying Carrier engineers its network to accommodate all users and user types based on a variety of factors, including average and anticipated peak usage of the network, many factors cannot be anticipated or are outside of our and our Underlying Carrier’s control. These factors can impact the availability of network resources for Broadband Services at any particular time.
What performance can I expect from PureTalk’s Broadband Services?
We and our Underlying Carrier each strive to manage the networks to provide you optimal performance. However, because many different factors can affect the performance of Broadband Services, as discussed above, neither we nor our Underlying Carrier guarantee specific performance levels of our Broadband Services. Broadband Service performance is generally evaluated based on speed and latency. The speed and latency you can expect to receive using our Broadband Services are described below. Our speed and latency measurements are based on data from third-party, crowd-sourced testing of actual network performance compiled by our Underlying Carrier. The ranges provided below represent network performance nationally between the 25th and 75th percentile and you may occasionally experience performance levels outside our estimated ranges.
Speed reflects the capacity at which Broadband Services can transmit data. This capacity is typically measured in the number of kilobits, megabits, or gigabits that can be transmitted in one second (kbps, Mbps, or Gbps). Some applications, like a short email without attachments or basic web browsing, do not require high-speed service to function optimally. Other activities, like transferring large data files, can be performed faster with higher-speed services. The speeds you receive from our Broadband Services may not be optimal for certain applications, particularly those involving real-time or near real-time, high-bandwidth uses, such as streaming video or video conferencing.
We do not offer Broadband Services in different speed tiers. Some plans provide customers with a monthly per line allotment of data after which the data transmission speeds will be limited to a significantly slower speed (e.g., 128 Kbps) for the remainder of the bill cycle, as set forth in the terms and conditions of the plan. Similarly, for unlimited data plans, data transmission speeds may be limited to a significantly slower speed (e.g., 128 Kbps) once the unlimited data plans’ data usage threshold is met for the remainder of the bill cycle.
We expect our customers will typically experience speeds within the following ranges, which do not necessarily reflect speeds achievable along the entire end-to-end transmission path to all Internet destinations:
|Technology||Download Range (in Mbps)||Upload Range (in Mbps)|
|3G||1.4 – 5.3||0.3 – 1.2|
|4G||2.4 – 7.1||0.6 – 1.4|
|4G LTE||9.7 – 50.2||2.8 – 12.5|
Latency, also known as delay, is the amount of time from when a data packet is sent to when it is received. For Broadband Services, latency is usually expressed as the round-trip time in milliseconds (ms) that it takes for a data packet to travel between two end points on the Internet (from point A to point B and then back to point A). Some applications, such as email, can tolerate a substantial amount of latency without any noticeable impact on the application’s performance. Other applications, such as real-time video conferencing, require lower latency to function properly. End-to-end latency reflects the cumulative effect of the individual latencies that occur along the end-to-end network path.
We expect our customers will typically experience the following round-trip latencies when accessing the Internet using our Broadband Services:
|Technology||Time in milliseconds|
|3G||55 – 106|
|4G||49 – 77|
|4G LTE||31 – 49|
Where can I find the prices and other fees that apply to PureTalk’s Broadband Services?
Descriptions of the prices and fees applicable to our Broadband Services are available on our website. For more information, please review our rate and data plan information at https://www.puretalkusa.com/cell-plans. PureTalk does not charge termination fees.
Where can I find the Terms and Conditions and the Authorized Use policy that apply to the PureTalk’s Broadband Services?
The Terms and Conditions, which includes the Authorized Use policy, can be found at https://www.puretalkusa.com/terms.
What are PureTalk’s privacy practices for its Broadband Services?
How can I get assistance if I have a question or concern or need more information about PureTalk’s Broadband Services?
If you have questions or concerns about our Broadband Services, please contact us using the following information:
Phone: 1-877-820-7873 or 611 from your device during normal business hours:
Monday - Friday: 9AM - 11PM EST
Saturday: 10AM - 9PM EST
Sunday: 12PM - 9PM EST
Mail: Pure TalkUSA, PO Box 2840, Covington, GA 300155