Effective Date: December 1, 2024
Last Updated: June 1, 2025

AS393941 LLC ("AS393941," "Company," "we," "us," or "our") is committed to protecting the privacy and security of personal information. This Privacy Policy describes how we collect, use, disclose, and protect information when you use our telecommunications services, ground-to-space communications, fiber connectivity, IT services, and cybersecurity solutions.

We may collect the following types of personal information:

• Contact Information: Name, business address, email address, phone numbers
• Account Information: Username, account credentials, billing information
• Business Information: Company name, industry type, authorized representatives
• Technical Information: IP addresses, network configurations, service usage data
• Communication Records: Service requests, support communications, transaction history

• Network traffic data and usage patterns
• System logs and performance metrics
• Device and connection information
• Geographic location of service delivery points

For medical and critical infrastructure customers, we may process:

• Protected Health Information (PHI) subject to HIPAA compliance
• Critical infrastructure operational data
• Security-related information necessary for cybersecurity services

• Providing telecommunications and network services
• Operating ground-to-space communication systems
• Delivering fiber connectivity and internet services
• Maintaining IT infrastructure and cybersecurity protection

• Processing billing and payments
• Customer support and technical assistance
• Network monitoring and optimization
• Compliance with legal and regulatory requirements

• Analyzing usage patterns to improve service quality
• Developing new telecommunications solutions
• Enhancing cybersecurity capabilities
• Optimizing network performance

AS393941 does not sell, rent, or trade personal information to third parties for marketing purposes.

We may share information in the following circumstances:

• Service Partners: With trusted vendors and contractors who assist in service delivery
• Legal Requirements: When required by law, court order, or regulatory mandate
• Emergency Situations: To protect life, safety, or prevent serious harm
• Business Transfers: In connection with merger, acquisition, or sale of assets
• Consent: When you have provided explicit consent for disclosure

For customers in critical infrastructure sectors, information sharing may be necessary for:

• Cybersecurity threat intelligence
• Incident response coordination
• Regulatory compliance reporting
• National security requirements

We implement comprehensive security measures including:

• Encryption of data in transit and at rest
• Multi-factor authentication systems
• Network segmentation and access controls
• Regular security audits and assessments
• Employee security training and background checks

For medical customers, we maintain HIPAA-compliant systems including:

• Business Associate Agreements (BAAs)
• Administrative, physical, and technical safeguards
• Breach notification procedures
• Access logging and monitoring

We follow industry best practices and federal guidelines for protecting critical infrastructure data and communications.

• Service Records: Retained for the duration of service plus 7 years
• Billing Information: Retained per applicable tax and accounting requirements
• Technical Logs: Retained for 12-24 months unless required longer for security purposes
• Medical Records: Retained per HIPAA requirements and state regulations

We securely dispose of personal information using industry-standard data destruction methods when retention periods expire.

You have the right to:

• Access personal information we maintain about you
• Request correction of inaccurate information
• Request updates to contact or account information

You may opt out of non-essential communications while maintaining service-related notifications.

Where technically feasible, we can provide data in a portable format upon request.

We comply with FCC regulations and telecommunications privacy requirements.

For medical customers, we maintain compliance with:

• Health Insurance Portability and Accountability Act (HIPAA)
• State healthcare privacy laws
• Health Information Technology for Economic and Clinical Health (HITECH) Act

We adhere to relevant cybersecurity frameworks and critical infrastructure protection guidelines.

If we transfer data internationally, we ensure appropriate safeguards are in place consistent with applicable privacy laws.

Our services are designed for businesses and organizations. We do not knowingly collect personal information from children under 13.

We may update this Privacy Policy periodically. We will notify customers of material changes through:

• Email notification to account contacts
• Posted notice on our website
• Direct communication for significant changes affecting service terms

For privacy-related questions, concerns, or requests:

AS393941 LLC Privacy Office
Email: privacy@as393941.com
Address: 17610 Woodinville Snohomish Rd NE Unit 564, Woodinville, WA 98072

Data Protection Officer (for HIPAA and critical infrastructure matters):
Email: dpo@as393941.com

This Privacy Policy is effective as of the date listed above and applies to all information collected by AS393941 LLC.

This Privacy Policy is designed to comply with applicable federal and state privacy laws. Customers with specific regulatory requirements may have additional privacy protections under separate service agreements.