Code of Practice

Company Vision and Code of Practice as of September-2020

Wireless Connect Ltd. was founded by engineers with a vision of connecting the unconnected in rural Ireland. We set about solving the rural broadband deficit problem at a local level using our skills learned in school, in Dublin City University and in our experience working after we had finished college. When Michael Cotter our founder, returned to Borrisokane after college, saw the need that his friends and neighbours had for connectivity, he stepped up and asked what can he do to make a difference, and he challenged his friends to step up also and help him achieve his vision for connecting the midlands with high speed internet access. It is around that vision our company is founded, and every day, every hour that our staff who are the best in the business, are also challenged to live up to.
This document sets out to codify the spirit and approach taken by Wireless Connect in working with our customers to deliver support for the internet services we deliver to our customers.

Integrity
Our team will be clear with our customers about the Packages available for each one of our customers, the customers’ rights, and our responsibility to our customers. We ask our customers to be honest with our staff who are working to help them. Our staff will use best endeavours to be clear with our customers. We ask our customers to be clear and accurate when dealing with our staff.

Commitment to Quality
Our installers shall aim to provide our clients with a quality high speed install and service thereafter. Our support team will provide quality support to our customers who seek support. We will show all our customers a path to resolving the issue they raise. If the issue is on our side, we will fix it if we can. If the issue is uneconomic or beyond our control, we will demonstrate this to our customers and give the customer honest clear advice on how to resolve their issue.

Complaints
Without prejudice to any legal rights of action which may apply, we have implemented the following Code of Practice in order to try to settle unresolved disputes, including complaints, between Subscribers and the Company arising under the European Communities (Electronic Communications Networks and Services) (Universal Service and Users’ Rights) Regulations 2011.

First point of Contact for complaints
In the event our customers encounter an issue with the service our customers are always welcome to contact support on our dedicated support line at 0505 36007 and at Support@wirelessconnect.ie.

Our support staff will:

1. Respond to the customers’ request for help
2. Engage fully with the customer to find the source of the issue.
3. As a result of the mutual co-operation between the customer and support staff, our support staff shall:
   • Work to resolve the issue remotely and expeditiously with the customer’s co.operation.
   • For signs of malfunctioning equipment, Wireless Connect will either use a courier/postal service to deliver new equipment or direct one of the field team of engineers to call out to the customer.
   • To provide follow up support if necessary i.e. connecting devices etc.
   • For customers who are not satisfied we have a complaints email address Complaints@wirelessconnect.ie
   • If a customer declares that they are not happy with how their support case is being dealt with our support staff shall outline how the customer can escalate the complaint as far upwards as necessary including ultimately to to a director.
   • Our staff shall endeavour to record customer issues in our dedicated support ticketing system.
   • In the event that the customer genuinely doesn’t understand or does not have the ability to test the connection we shall offer the customer a callout to diagnose the issue and clearly stating that there is a charge and the amount if the issue found is not on our side.
   • We will only charge for that callout if the issue is on the customer side.
   • We will explain clearly what occurred to the customer and clearly explain how to avoid it in the future.

Complaints Handling Procedure
We want to succeed in providing our customers with a service that makes their lives easier. Where a customer has a negative experience, we want to help turn that around for the customer as quickly as possible.

All complaints that are escalated, either written or on the phone shall be analysed and responded to by a trained senior member of staff. All complaints will be given due consideration. Generally, we aim to respond to written complaints within 2 business days. Our Complaints handling team will:

1. Acknowledge the customers complaint via email and provide them with the following information:
   • A unique reference number for the complaint which will be generated based on the date and time the complaint was sent. If a letter is received it is assigned a number according to the date of the letter.
   • A link to the Code of Practice on our website.
2. Analyse the complaint, check our support systems to see what notes are available and try to get an understanding of the issue.
3. If necessary, contact the customer and listen to their complaint, try to understand the complaint and seek clarifications where necessary.
4. Then analyse the detail learned while listening to the customer and check with other staff that may have been handling the customer issue.
5. Come up with a remediation plan so that:
   • If there is a problem, we can try to remediate it and or,
   • Even if there is only a perception of a problem, try to remediate it.
6. Contact the customer with the proposed remediation plan and with the customer’s co-operation agree to implement it with them as soon as practically possible.
7. Instruct technical staff to implement the agreed remediation plan.
8. Not close off a complaint until the customer confirms that it has been dealt with satisfactorily.
9. In the rare case that a customer prevents us from resolving the complaint we shall endeavour to explain how the customer is preventing a resolution and outline how they can facilitate a resolution.

In the rare case that we identify the problem but where there will be a will be a delay in excess of 10 working days in implementing the remediation, subject to Force Majeure and conditional on the customer fully co-operating with us to identify and resolve the issue, we will suspend charges on request from the customer until the service has been restored to the specification of their package.

In the rare case that we can no longer serve the customer to the required specification e.g. due to Force Majeure, we will release the customer from the contract on request from the customer and remove our equipment from the customer premises.

Internet needs evolve and so where a customer is no longer satisfied with the speed they are getting on a legacy product (but are still getting speeds greater or equal to that which they subscribed to/signed up for) we endeavour to explain that the customer will see a significant improvement if they purchase the installation of new technology on the latest generation service that we offer in their area.

Records of Complaints
We retain records of complaints as well as of support request notes and emails for the duration that a customer remains with us, and in the event a customer leaves we retain those records for no longer than 2 years after they leave us.

Customer Privacy
Customer issues are only dealt with by authorised staff that can assist the customer with their query. We will only discuss issues with the account holder or someone that the account holder authorises us to deal with.

We only collect sensitive usage data per public IP on a sampled basis (the sample ratio is typically no more than 1 sample per10,000 packets) to facilitate the detection of Denial of Service and other types of cyber-attacks. This data is kept on a very short retention of less than 1 week, and only data that has been captured as part of a suspected attack is retained for further analysis to mitigate similar attacks in the future. This data is only analysed by our staff or consultants retained to assist with preventing negative impacts of the attacks in future.

We do not sell lease, share customer specific usage data with third parties.

We do monitor and record the total usage on a given subscriber connection for the purposes of measuring total bytes downloaded and total bytes uploaded on sample periods. We also monitor latency to customer subscriber units in order to allow us to validate that the customer is receiving a quality service.

We process expeditiously lawful requests for information signed by a Superintendent in the Garda Computer Crime investigation Bureau. These are handled with advice from the hotline.ie (formerly ISPAI) using the Memorandum of Understanding (2011) between ISPAI and, An Garda Siochana, the Permanent Defence Forces and the Revenue Commissioners.

Combating Illegal content online
We believe in a free and open Internet. We believe all children must be cherished and protected from predators. The scourge of child pornography and sharing and distributing obscene images of children compounds the abuse of the victim the child. That is why we support hotline.ie whose staff do excellent work processing reports of child pornography from internet users in Ireland and who co-ordinate with their international partners, the Gardai and Interpol to identify, and remove harmful illegal Child Sexual Abuse Material. Our staff undertake to co-operate fully executing Take Down notices if child sexual abuse material (CSAM) is found to be present on systems connected to our ISP service.

Net neutrality and Quality of Service
We believe that our customers should have unrestricted high-quality access to the internet. We do not throttle or restrict any third party service for commercial gain. We do not do any unethical practices such as delaying connectivity to a content provider (e.g. to force them to pay an access fee to our customers) We endeavour to ensure customer connectivity between their CPE (customer premises equipment) and any professional content provider or content delivery network. It is our policy to upgrading our Edge network capacity to keep capacity at least 20% over peak demand for so long as this remains economic.
The only throttling we do is an exception as a last resort in response to network congestion events such as DDoS or failure of a primary link. In that situation we reserve the right to schedule / prioritise traffic according to purely technical engineering criteria such as;

1. Network critical traffic such as BGP, OSPF, ICMP being prioritised over all other traffic,

2. Real time traffic such as VoIP (voice over IP) being prioritised over web browsing traffic.

3. Web browsing traffic being prioritised over SMTP mail traffic.

4. SMTP traffic being prioritised over Bulk FTP downloads / Peer to Peer traffic.

Again, this is only done to minimise impact to customers where there is a sudden constraint on bandwidth or a sudden surge in demand. We undertake to resolve congestion issues as soon as technically feasible. We have never and will never seek to gain a commercial advantage through the restriction of traffic that our customers solicit. We must however reserve the right to defend our network and our customers’ devices against attacks but our response in such circumstances is purely defensive and technical in nature and not in any way done to disadvantage a competitor or their services.

Where a customer utilises amateur streaming services and they are experiencing an issue with the streaming service, we do try to identify if there is an issue on our network, usually we will ask them to check if there are any issues with commercial / professional streaming services. If we cannot find an issue with our network and other streaming services are functioning normally, we recommend the customer contact their streaming support service. We work with content providers who have professional infrastructure to deliver content internationally and to our network so as to ensure that our network connectivity evolves and grows as users’ habits and expectations grow.

Internet Security
We believe in protecting our customers. If we identify any potential security issues, we will take prudent, expeditious actions to reduce the risk of our network and our customers’ network. We do not censor. However it is sometimes necessary to disconnect temporarily a customer’s device, When and if we have to take that action we will act transparently and inform customers of our actions taken and we shall also try to point the customer in right direction in order to reduce their risk. We believe in protecting internet users from bad actors accessing our network and if we identify such actions, we do try to mitigate them and their harmful effects on our network, other people’s networks and other customers.

Internet Censorship
We believe strongly in the freedom of thought and freedom of expression. We do not advocate or implement internet censorship. We do however recognize that parents and school administrators have a legitimate right to protect young children in their care from harmful content and we do facilitate filtering of such sites if a parent / school administrator requests it. We advocate for a free and open internet and do not support blanket censorship and we work to inform state authorities during consultation periods when given the opportunity to do so.

This Code of Practice does not form part of the terms and conditions of the Company’s contract with Subscribers. Instead it is intended to be a declaration of the Company’s intent in how it handles the ever-changing nature of the internet and Subscriber’s interaction with both it and the Company.

Contact, support and complaints information
All enquiries and Customer service requests should be directed to the following contacts
according to Subscribers’ requirements:
(a) Sales: sales@wirelessconnect.ie 1890 253106
(b) Technical Support: support@wirelessconnect.ie 050536007
(c) Complaints: complaints@wirelessconnect.ie 016205585