Open Internet Disclosure Statement

The Federal Communications Commission requires (“FCC Requirements”) that WorldNet Telecommunications Inc. (“WorldNet”) and other providers of mass market retail broadband Internet access service (“Applicable Services”) publish information regarding the network management practices, performance, and commercial terms of such service. This information is intended to fulfill such requirement and to be relied upon by existing and potential subscribers to such service and by the providers of “edge” products (i.e., providers of applications, devices, services, and content access over or connected to such service). These disclosures should be read in conjunction with WorldNet’s “Acceptable Use Policy” (“AUP”), available at www.worldnetpr.com/ESP/AUP. These disclosures relate solely to the Applicable Services, which as of this date include WorldNet DSL service, which provides for speeds of 1, 2, or 5 mbps download and 768 kbps upload. The information provided herein may be revised from time to time as WorldNet deems appropriate.

Network Management

WorldNet seeks to provide subscribers with a consistently high quality online experience. The bandwidth and network resources employed to deliver high-speed Internet service are limited and shared among users and thus it is essential that WorldNet be able to efficiently manage our network in a manner that is designed to deliver the greatest benefit to the greatest number of subscribers. To this end, we can and if needed will employ various “network management” tools and techniques that are commonly used in the industry to protect consumers from activity that can unreasonably burden our network and may cause service degradation, including security attacks and network congestion.

These network management tools and techniques may include detecting malicious traffic patterns and preventing the distribution of viruses or other malicious code, limiting the number of peer-to-peer sessions a user can conduct at the same time, limiting the aggregate bandwidth available for certain usage protocols such as peer-to-peer and newsgroups, rate limiting of email, rejection or removal of “spam” or otherwise unsolicited bulk email, port blocking, measuring subscriber bandwidth usage, bandwidth allowances, traffic prioritization and other tools and techniques that WorldNet may from time to time determine are appropriate. New network management techniques are being developed on an ongoing basis and WorldNet may elect to use some or all available network management techniques on a temporary or as-needed basis.

The network management tools and techniques employed by WorldNet do not and will not target specific usages or applications (such as peer-to-peer) and instead focus in a content-neutral manner on overall bandwidth usage in real time, with the goal of providing reasonable and equitable access to the network for all similarly situated customers. In other words, to the extent that the use of network management practices may affect the performance or other characteristics of Applicable Services, they are designed to affect all similarly situated customers equally.

If and when implemented, the use of network management tools and techniques to conserve bandwidth may cause all users to notice a temporary slower Internet performance, such as longer download and upload times or slower responses while surfing the Internet or playing games. The effects of network management typically will be noticeable only for a brief period of time, if at all. While it is not possible to predict in advance precisely when WorldNet will determine that conditions warrant the activation of various network management tools and techniques or the impact such techniques may have on performance or other characteristics of Internet service, WorldNet anticipates, based on its experience and that of others in the industry, that use of network management tools and techniques if implemented, will be rare.

WorldNet monitors the total bandwidth usage and sets thresholds to ensure we have adequate bandwidth capacity for our complete customer base. If unusual peaks occur that impact our overall bandwidth and affect our customer base we investigate and correct the problems manually. There are currently two network management tools in use to monitor our Internet traffic which are CACTI and Netflow. CACTI provides specific alarms and notices if at any given time the bandwidth reaches a preset high or low threshold which are immediately investigated and addressed. Netflow provides more granular information that can be analyzed to get more specific information regarding the type of traffic, source and destination.

Consistent with FCC Requirements, and subject to the reasonable network management practices outline herein, WorldNet does not block lawful content, applications, services, or non-harmful devices, does not impair or degrade lawful Internet traffic on the basis of Internet content, application, or service, or use of a non-harmful device, and does not unreasonably interfere with or unreasonably disadvantage (i) end users’ ability to select, access, and use broadband Internet access service or the lawful Internet content, applications, services, or devices of their choice, or (ii) edge providers’ ability to make lawful content, applications, services, or devices available to end users. In addition, consistent with and subject to FCC Requirements, WorldNet does not directly or indirectly favor some traffic over other traffic, including through use of techniques such as traffic shaping, prioritization, resource reservation, or other forms of preferential traffic management, either (a) in exchange for consideration (monetary or otherwise) from a third party, or (b) to benefit an affiliated entity.

As described above, WorldNet reserves the right to employ network management practices, e.g., to prevent the distribution of viruses or other malicious code, as well as to block, in accordance with applicable law, transfer of unlawful content such as child pornography or the unlawful transfer of content. In addition, WorldNet may enter into arrangements to provide Internet service to third party establishments (such as coffee shops, bookstores, hotels or libraries) who then may offer such service to their customers, guests or others. Nothing herein is intended to address network management practices, performance characteristics or commercial terms that may be adopted by such third party premise operators in connection with the provision of Internet service to others.

WorldNet requires customers to use the modem that is provided upon service activation or a compliant modem to connect to its network. WorldNet recommends that customers replace non-compliant equipment with a compliant device.

For WorldNet’s broadband ADSL service, the company provides the modem to the customer preconfigured for the contracted services. The customer may elect to use their own modem at their own expense and responsibility. We will continue to provide assistance but the customer is responsible for the administration and operation of the customer provided modem and/or additional equipment. Use of a non-compliant modem may be subject to service interruption due to network updates and may limit any technical support or troubleshooting assistance that can be provide by our personnel. For additional information on compliant modems please call our DSL technical support personnel (787) 277-0210.

WorldNet also employs certain practices to protect the security of our customers and our network from unwanted and harmful activities. WorldNet utilizes FortiNet Mail platform applications (FortiMail) to provide protection against SPAM from the Internet to our customers. For blocking SPAM from our customers to the Internet once WorldNet identifies a particular ADSL service user that utilizes WorldNet’s domain, the Internet service to that specific user will be disconnected and a notification will be provided informing of the spamming activity from his/her account so they can address and eliminate the cause of the problem from the network. Once confirmation is received from the customer that the problem has been corrected and they have eliminated the virus, defective PC or other cause of the problem, upon verification we will proceed to reconnect the services. When security measures are employed, they may affect performance characteristics of service or the ability to access certain suspicious websites, but such measures are employed in a manner designed to have non-discriminatory impact on all similarly situated customers.

Performance Characteristics

WorldNet provides what is known as a “fixed broadband” Internet access service that is designed to provide the capability to transmit data to and receive data from all or substantially all Internet end points. WorldNet offers multiple packages of Internet access service for residential or commercial use with varying speeds, features and bandwidth usage limitations that may affect the suitability of such service for real-time applications. The features, pricing and other commercial terms of our service offerings are modified from time to time, and not all packages are available in all areas. Each package is priced to reflect the particular speed, features and bandwidth usage limitations of that package. Full descriptions of currently available packages and pricing can be found on WorldNet’s website at www.worldnetpr.com/internetservices. To reiterate, these disclosures apply solely to the Applicable Services.

Internal performance lab testing conducted periodically by WorldNet shows that for our typical ADSL services of 1,2 and 5 mbps download and 768 kbps upload speeds from 7:00 pm 12:00 am nightly and weekends normally queue above 95% of the configured throughput and a latency from our internet router (Gateway to Internet) and the modem of 8 ms or less. Performing the same test during business hours and extending it to various locations in the island we obtain a throughput average of 80% configured speed with an average latency or delay of 29ms. Test result show that as we move out of the metropolitan areas we experience degradation in performance which can be influenced by various reasons as described below. Tools for subscribers to measure the Internet performance of WorldNet’ DSL service are available at http//www.speed.wntpr.com. The test tool provided by WorldNet provides you with the typical speed at which your line will transfer Internet traffic between the router/modem located at the customer premises and WorldNet’s Internet router equipment. Note that the results of these tests can and are influenced by a subscriber’s home network configuration and equipment and do not account for Internet backbone inherent delays or user demand at any given time and may also have built-in biases and flaws. Consequently, the results of these tests should not be regarded as precise measurements of performance or as guarantees. If you wish to measure your Internet speed accounting for the Internet backbone response timeframes you may use any external speed test tools and for this purpose we also include an independent external speed test which may access at http//www.speedtest.net.
Advertised speeds and other performance characteristics are subject to numerous factors including telephone line cooper loop quality and distance from the Central Office and variances in network usage and third party inputs, and thus are provided on a best efforts basis and cannot be guaranteed. Among the factors that may impact the actual speed that a subscriber experiences are (i) the capabilities and capacities of the customer’s computer and/or local area network (LAN) devices such as wireless routers; (ii) latency (i.e., the time delay in transmitting or receiving packets as impacted in significant part by the distance between points of transmission); (iii) the performance of the content and application providers the consumer is accessing, such as a search engine or video streaming site; and (iv) performance characteristics of transmissions over portions of the Internet that are not subject to WorldNet’s control.

Commercial Terms

As noted above, WorldNet offers multiple service options, the pricing and other terms and conditions of which can be found at https://www.worldnetpr.com/internetservices and for details specific to the customer accepted service offer please refer to the customer Service Agreement (or, if and where applicable, tariff) which is provided to the customer upon service acceptance.

Internet packages are offered as part of a service contract between you and the WorldNet. The duration of these service contracts varies. In the event that a service contract is terminated by the customer prior to its specific end date, the customer may be responsible for payment of an early termination fee. The customer Service Agreement (or, if and where applicable, tariff) will include the applicable early termination fee or penalty as per the specific service type and contract duration.

Your privacy is very important to us. Personal information you provide to WorldNet is governed by the Company’s Privacy Policy, which is posted in WorldNet’s Website at https://www.worldnetpr.com/ESP/PrivatePolicy and is subject to change from time to time. Personal information provided by you to WorldNet is used primarily to provide a customized experience as you use our services, and is generally not shared with third parties. WorldNet reserves the right, as required or permitted by law, to provide account and user information, including email, to third parties and to cooperate with law enforcement authorities in the investigation of any criminal or civil matter. Such cooperation may include, but is not limited to, monitoring of WorldNet’s network consistent with applicable law.

Complaints, concerns and questions about the WorldNet’s network management practices may be directed to our Customer Service Department, which can be contacted at (787) 277-0210. In addition, the Federal Communications Commission has established processes for addressing formal and informal complaints. For more information, see http://www.fcc.gov/guides/getting-broadband.

Non-Broadband Internet Access Services (“Non-BIAS Services”)

WorldNet reserves the right under FCC Requirements to offer non-BIAS Services over its network. In general, non-BIAS Services are services that share capacity on WorldNet’s network with Applicable Services that are not used to access large parts of the Internet are not a generic platform, but are a specific “application level” service. Such services may include things like cloud computing services, data hosting, IT, tele-medicine, and such other non-BIAS Services as WorldNet may develop. For such non-BIAS Services, WorldNet may, consistent with and subject to FCC Requirements, use network management to isolate the capacity used by these services from that used by Applicable Services in order to ensure the priority and quality of such specialized services. Such steps may have the effect of impacting from time to time the speed, quality, or available bandwidth of Applicable Services on the network.