This document provides information about the network practices, performance characteristics, and commercial terms applicable to CGI-Communication;s Broadband Internet Access Services, consistent with the Federal Communications Commision’s Open Internet Rules.
CGI-Communication is committed to providing its customers with the best possible online experience. We follow industry-leading network security standards to ensure the integrity, confidentiality and availability of our customers’ network and confidential information. We view network management as critical to the many services we provide our customers. Managing our network well is one of the most important parts of our business. It ensures that our customers have access to the content and applications that they need and enjoy.
The information contained in this document is not a contract and does not change the terms and conditions associated with your service. It is provided for informational purposes only and may be changed at any time, without notice.
Congestion Management Policy
CGI-Communication monitors and proactively reinforces our network with additional capacity in areas where growth trends identify a need. If network congestion occurs, CGI-Communication employs various techniques to ensure a positive customer experience and fair distribution of network resources.
Currently, based on our experience, if CGI-Communication customers encounter any congestion, it is during the hours of peak usage – between 7 p.m. and 11 p.m. local time. During peak hours, the majority of our residential customers are attempting to use the Internet simultaneously, giving rise to a greater potential for congestion.
When network congestion is identified, we may limit the number of customers that can be served on a particular network node until additional capacity can be added. Also, we may seek to ensure that our customers are not excessively using the service. In very rare cases, we may need to downgrade the service available to existing customers or in extreme instances – even disconnect services.
The circuits CGI-Communication and other networks use to exchange traffic may also become congested at times. CGI-Communication devotes considerable resources to maintaining adequate traffic exchange arrangements with these other networks and has entered into commercially negotiated agreements to exchange traffic with them on mutually agreeable terms wherever possible. Consistent with its agreements with those other networks and its long-standing practices, CGI-Communication will work to establish or expand the connections between its network and other networks on mutually agreeable terms when needed. But, sometimes this is not possible due to circumstances beyond CGI-Communication’s control. For example, in some instances, other networks refuse to make adequate arrangements. In other instances where adequate arrangements are in place, some edge providers or their intermediaries (other networks) choose to route traffic in ways that result in congestion when there are other choices. If CGI-Communication is unable to reach agreement on the terms of its interconnection or network expansion with these other networks, or if some of these other circumstances occur, it could affect a customer’s ability to upload or download data via Internet endpoints connected to those networks. Unfortunately, CGI-Communication cannot guarantee that it will be able to establish or expand the connections between its network and other networks, or that subscribers will be able to upload data to or download data from Internet end points connected to other networks at any particular speed.
When you provide personally-identifiable information through the CGI Site/Services, it will be used to fulfill your specific request. Absent any instructions from you, CGI may use information you provide to inform you about additional services and products offered by CGI and other goods and services providers with whom CGI has relationships. CGI will not, however, sell or trade your personally identifiable information unless authorized or legally required to do so. CGI does not associate sensitive data, such as your race, religion, or political affiliations, with personally identifiable information. CGI takes precautions to segregate any sensitive data you may provide that reference your race, religion, sexual orientation, ethnicity or political affiliations.
In those instances when you may provide CGI with credit card or other ordering information via the web, CGI protects and secures this information by employing commercially customary web-based security and encryption protocols, examples of which include Secure Socket Layer (SSL) and Secure Electronic Transaction (SET). On those sites where you voluntarily offer any feedback, data, answers, questions, comments, suggestions, ideas or the like, CGI will treat that portion of the information as non-confidential and non-proprietary and, except as otherwise expressed in this privacy statement, CGI assumes no obligation to protect such information from disclosure.
Although CGI takes commercially reasonable steps to protect your information, and please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through communications services, such as chats, communities, instant messaging, or other services provided by CGI or third parties, this information may be collected and used by others. CGI encourages you to review the privacy statements of websites you choose to view so that you understand how those websites collect, use and share your information. CGI is not responsible for the privacy statements or other content with respect to any third party websites.
Excessive Use Policy
The Excessive Use Policy includes, for most customers – Upload and Download Guidelines, that are based on the High-Speed Internet service plan that a customer purchases.
Download Guidelines: CGI-Communication is committed to providing a great Internet experience for every customer we serve. To accomplish this, CGI-Communication needs to ensure that customers are on the rate plan that meets their data requirements.
Of the thousands of CGI-Communication High-Speed Internet customers, only a very small fraction have exceeded the data usage limits provided with their monthly plan. However, this number is increasing daily due to various online streaming applications and their increasing popularity. It is for these reasons that CGI-Communication has made the decision to place data limits on residential plans.The “Download Guidelines” only impact residential customer plans’ data usage; specifically the per-cycle agregated upload and download, expressed in Gigabyte. It does not currently impact Business-class High-Speed Internet plans.
CGI-Communication will weigh variables such as network health, congestion, availability of customer usage data, and the line speed purchased by the customer as factors when enforcing this policy. Customers who are subject to enforcement will receive a web or email notification and possibly a postal mail notification from CGI-Communication providing notice that they have exceeded their usage limit.
Customers are given options to reduce their usage, subscribe to a higher speed residential plan, or migrate to an alternative business class High-Speed Internet service. Our policy is application neutral; it only considers the total usage (bytes transferred) over a defined period of time that is independent of protocols, applications, or the content that is generating the excessive usage.
The CGI-Communication download guidelines are designed to support today’s usage patterns and may be modified without notice to you.
Our plans include the following usage limits:
Customers who exceed their High-Speed Internet usage limit by the amounts listed below will be billed in arrears the following additional amounts in each monthly billing cycle where the limit is exceeded:
| 50 GB or less | Over 50 GB but less than 100 GB | Over 100 GB but less than 150 GB | Over 150 GB but less than 200 GB | 200 GB or |
$10 | $20 | $30 | $40 | $50 |
Although the maximum additional charge for data usage is capped at $50, paying the $50 does not mean a Residential High Speed Internet customer is entitled to unlimited usage. Data usage that repeatedly exceeds the usage caps and interferes with other customers’ use of the service may be addressed under the CGI-Communication High-Speed Internet terms of service.
Expected Performance Policy
When you order CGI-Communication High-Speed Internet access service, the service we quote you is based on an advertised “up to” connection speed. We continually upgrade our network, but our quoted speed is based on the characteristics of the relevant network facilities at the time you order. We will confirm your advertised speed at the time of installation.
The actual throughput you experience may vary. During most periods, based on CGI-Communication’s evaluation, most customers can generally expect average speeds at or above 95% of the advertised “up to” speed and many can generally expect speeds above that level. Less than 20 percent of customers can expect average speeds below 80% of the advertised “up to” speed. In rare cases, average speed may be significantly less than this level.
The service speed is provisioned between the network device and the on-premises equipment and may vary due to physical condition of the connection and other factors. The percentage of throughput achieved will vary depending on the amount of bandwidth our network uses in delivering service to you, as well as other factors outside of CGI-Communication control such as customer location, the quality of the inside wiring within the home, the websites accessed by the customer, usage of the network during peak periods of the day and the customer’s equipment within the home or premises.
Latency (the time it takes for a data packet to travel from one point to another in a network) is also highly variable depending on the network path, other providers in the path, as well as the actual distance to the destination and performance of the end destination servers. It generally increases with distance of the route between the source and destination and with any congestion on the route, and decreases as actual speed increases. CGI-Communication measures latency by measuring the round-trip time from the consumer’s home to the closest measurement server and back. CGI-Communication High-Speed Internet customers should expect roundtrip latency to most general Internet sites in the range from 50-500 milliseconds.
Packet loss (the percentage of packets that are sent by the source but not received by the destination) is also highly variable. The most common reason that a packet is not received is that it encountered congestion along the route. A small amount of packet loss is expected, and indeed some Internet protocols use the packet loss to understand Internet congestion and to adjust the sending rate accordingly. CGI-Communication denotes a packet as lost if the latency exceeds 3 seconds or if the packet is never received. CGI-Communication High-Speed Internet customers should generally expect to experience packet loss at the rate significantly below 1% or at levels unlikely to significantly affect customer experience.
Network speeds for CGI-Communication High-Speed Internet services provided wirelessly (via Wi-Fi) may vary beyond the scope defined above. The performance the user experiences, once they connected to the Wi-Fi, will vary based on any number of factors such as: the maximum bandwidth allocated for services, the number of other users trying to use the same Wi-Fi at the same time, the user’s computer or wireless device, the Wi-Fi receiving antenna, and the distance from the Wi-Fi router, etc. Most Wi-Fi routers use spectrum that the FCC has allocated for “unlicensed” use, which means that the use of this spectrum is not protected from interference from other devices using the same spectrum in the same geographical area. This makes it inherently difficult to predict what kind of performance you can expect.
If, after purchasing your service, you are not satisfied with the performance you are receiving, please contact CGI-Communication Technical Support at (520) 421-3333 opt. 2.
Application and User Specific Policy:
CGI-Communication High-Speed Internet customers receive full access to all of the lawful content, services, and applications that the Internet has to offer. As described more fully below, CGI-Communication deploys Type of Service (ToS) and Differentiated Service (DiffServe) capabilities at the customer equipment and in network equipment deployed across the CGI-Communication High-Speed Internet network for the CGI-Communication Voice over IP telephone service (a non-BIA or specialized service). The network equipment enabled with this capability will honor ToS and DiffServe settings of any third-party network consistent with the National Standards recommendations described in the Internet Engineering Task Force (IETF) RFC 1349 and RFC 2474.
CGI-Communication does not otherwise block, prioritize, or degrade any Internet sourced or destined traffic based on application, source, destination, protocol, or port unless it does so in connection with a security practice described in the security policy section below.
CGI-Communication also deploys certain user-specific policies (i.e. practices that are applied to traffic associated with a particular user or user group). Currently, these are limited to its Excessive Use policies, practices described above, and the security practices described in the security policy section below.
Security Policy
CGI-Communication engineers are dedicated to managing our network to ensure that all customers receive the most secure online experience. We use industry-leading security practices to manage our network, provide services to our customers, and ensure compliance with our Acceptable Use Policy and the terms of our High-Speed Internet agreement. These tools and practices may change from time to time to keep up with the new and innovative ways that customers use the network and to keep up with changing network technologies.
When malicious behavior is identified, CGI-Communication engineers employ various techniques to help provide a positive customer experience. Our security management techniques include ensuring that customer systems are not propagating viruses, distributing spam email, or engaging in other malicious behavior. For example, we use industry best practices to prevent virus/spam delivery to customer email accounts.
Specific security practices deployed by CGI-Communication may include but are not limited to:
IP Spoofing Detection and Prevention
The basic protocol for sending data over the Internet network and many other computer networks is Internet Protocol (IP). The header of each IP packet contains, among other things, the numerical source and destination address of the packet. The source address is normally the address that the packet was sent from. By forging the header so it contains a different address, an attacker can make it appear that the packet was sent by a different machine. The machine that receives spoofed packets will send a response back to the forged source address, which means that this technique is mainly used when the attacker does not care about the response or the attacker has some way of guessing the response.
CGI-Communication applies security measures to prevent an attacker within the network from launching IP spoofing attacks against these machines and flooding the network with unwanted data that can cause congestion.
DoS/Distributed DoS Monitoring and Mitigation
A denial-of-service attack (DoS attack) or distributed denial-of-service attack (DDoS attack) is an attempt to make a computer unavailable to its intended users. Although the means to carry out, motives for, and targets of a DoS attack may vary, it generally consists of the concerted efforts of a person, or multiple people, to prevent an Internet site or service from functioning efficiently or at all, temporarily or indefinitely.
CGI-Communication applies various security measures to prevent someone within the network from launching DoS or DDoS attacks to ensure that customers can access the Internet when needed.
CGI-Communication may block or rate-limit connections on other ports that are commonly used to exploit other customers or non-customer computers.
CGI-Communication may block sites that are used in a malicious manner to infect customers, perform fraud against them and otherwise as needed to protect our network and our customers.
Port 25 Blocking
CGI-Communication may filter port 25 to reduce the spread of email viruses and spam (unsolicited email). Email viruses allow malicious software to control infected computers. These viruses direct the infected machines to send email viruses and spam through port 25. Port 25 filtering is a recognized Internet industry best practice for service providers like CGI-Communication to filter e-mail traffic. The Messaging Anti-Abuse Working Group (MAAWG), a global organization focused on preserving electronic messaging from online exploits and abuse with the goal of enhancing user trust and confidence, recommends that “providers block incoming traffic to your network from port 25.”
Port 137, 138, 139, and 445 Blocking
CGI-Communication may filter UDP ports 135, 137, 138, and 139 as well as TCP ports 135, 137, 138, 139 and 445 to reduce the risk of botnets, worms, and other malicious attacks carried out against vulerable systems. Ports 135-139, known technically as the NETBIOS trio, or ‘NBT over IP’, Port 445 is ‘SMB over IP’. These protocols operate in the application-layer of the network protocol primarily used for offering shared access to files, printers, serial ports, and other sorts of communications between nodes on a network. These ports have many known vulnerabilities and exploits that can be used to gain control of a remote computer.
UDP Port 1900 Blocking
CGI-Communication may filter User Datagram Protocol (UDP) port 1900 to prevent DoS attacks across the network. SSDP (Simple Service Discovery Protocol) runs on UDP port 1900 and is part of the Universal Plug and Play (uPnP) protocol that allows discovery and configuration of devices on a local network. Normal use of the protocol is limited to a local network, but the protocol is used by attackers in reflective DoS across the backbone.
Viruses and Malware
CGI-Communication has voluntarily undertaken a program to help curtail the spread of viruses and malicious software (malware), including botnets, throughout the Internet; and to assist its customers whose computers are infected with viruses and malware.
The program is available to CGI-Communication residential and small business broadband customers on who subscribe to the CGI-Communication High Speed Internet service and provides information assistance on the mitigation of virus and malware infections, including botnets, once such infections have been detected either by the end user or by CGI-Communication.
If a customer tries to remove a virus or malware using information provided in our Knowledge Base, and still has problems, the customer may call CGI-Communication technical support and ask for a recommendation on what to do next.
If the customer has a virus or malware infection that cannot be removed using commercially available Anti-Virus or Anti-Malware software, CGI-Communication encourages the customer to get assistance from a certified computer repair technician.
CGI-Communication will not scan customers’ computers for viruses or malware – nor does CGI-Communication remove viruses or malware from computers for customers.
