Sterling LAMB (Local Area Municipal Broadband)

What is covered by this Privacy Policy

CommandIQ (branded as Sterling LAMB) is an application developed by Calix, Inc. for use by subscribers of
broadband service providers (BSPs) including Sterling LAMB who purchase cloud and software services from Calix, Inc.
Calix, Inc. is a processor of (or service provider for) Sterling LAMB’s subscriber personal information under applicable

privacy and data protection laws. Sterling LAMB is the controller of (or business for) its subscriber personal information.
In other words, Sterling LAMB determines how and why your information is processed.

Privacy Policy applies for any use of the App

This Privacy Policy applies to the App described in the CommandIQ Mobile Application End User

License Agreement (the “Agreement”). Please read your BSP’s privacy notice and this Privacy Policy

carefully to understand how information collected by the App will be treated. If you do not agree

with your BSP’s privacy notice and this Privacy Policy, you should not install, use, or access the

App.

Children Under the Age of 16

The App is not intended for children under 16 years of age, and on behalf of Sterling LAMB, we do

not knowingly collect personal data of children under 16, without parental consent. If we learn

that personal data from a child under 16 has been obtained or received without veriﬁcation of

parental consent, we will delete that information. If you believe we might have any

information from or about a child under 16, please notify us by completing a Request Form

(clicking the link will take you to TrustArc, whom we have engaged to assist with personal

information requests).

How Calix Collects Your Information

On behalf of Sterling LAMB, Calix collects and processes information provided directly by you when you

install the App and register for an account to use the App. Speciﬁcally, this information includes:

Your name, email address, password/pin, preferred language, and your account number with Sterling LAMB;

Information about the equipment deployed at your premises that you choose to connect to the App such as the MAC address, serial number or other unique identiﬁer for your router;

Data insights Calix attains based on correlation and analytics of your information collected in providing the App, and user-associated analytics to improve the quality of the app experience.

How Calix Uses the Information

On behalf of Sterling LAMB, Calix uses the information collected as described in this Privacy Policy, to:

Provide you with the App and the Services/notiﬁcations provided through the App as described in the Agreement;

Implement, improve and/or enhance the App or to provide App features, including to make future releases available to you;

Carry out Calix’s obligations as described or authorized in the Agreement, Sterling LAMB’s privacy notice, and this Privacy Policy;

Enforce Calix’s rights arising from the Agreement between you and Calix; and

Fulﬁll any other purpose authorized by you and reasonably required for the App.

Disclosure of Information

Sterling LAMB and Calix does not sell or otherwise distribute or disclose your information to third parties other

than as described or authorized in the Agreement, including this Privacy Policy.

Calix discloses the information to its subsidiaries, affiliates and certain third-party vendors and

contractors that provide development, integration, web hosting and consulting services to Calix to

provide you with the App, to maintain, support, develop, improve and/or enhance the App and to

fulﬁll Calix obligations associated with the App.

We may be required to disclose information under certain circumstances:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request;

To enforce Calix’s rights arising from the Agreement entered into between you and Calix;

If Calix believes disclosure is necessary or appropriate to protect the rights, property, or safety of Calix, its customers or other third parties; or

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Calix’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which your information and/or your subscriber information held by Calix are among the assets transferred.

Your Choices About Our Collection, Use, and Disclosure of Information

The provision of the information described in this Privacy Policy is necessary for you to use the App.

Your information is retained and used as described in this Privacy Policy. If you delete your

account for the App in accordance with the terms of the Agreement, your information will be deleted

within 30 days of the deletion of such account or within such other timeline as may be mandated by

applicable law. You will no longer be able to access the App when your account is deleted.

Accessing and Correcting Information

You can (a) access and review your contact information, and (b) correct your contact information,

by logging into the App and visiting the settings page. To access, review or correct any other

information, please reach out to Sterling LAMB.

Data Security

All information you provide to us is stored on our secure servers behind ﬁrewalls. Calix utilizes

mechanisms such as intrusion detection systems, intrusion prevention systems, ﬁrewalls and

encryption to secure information from accidental loss and from unauthorized access, use,

alteration, and disclosure.

Calix deploys Intrusion Detection Systems (IDS) and Intrusion Prevention Systems (IPS) to alert and

proactively contain potential threats. Enhanced security visibility and coverage is enabled through

added layers of ﬁrewall and IDS beyond the network perimeter. Management connections to servers are

always authenticated and encrypted via Secure Shell (SSH) when administration access is required

for troubleshooting, patch management, and upgrades.

Calix runs automated vulnerability scanning on all perimeter systems to identify potential security

risks. Scanning applications are regularly updated to remain current and up to date on important

security vulnerabilities. Patches are applied to all relevant systems unless a compensating control

is implemented.

Calix uses a variety of industry-standard security technologies and best practices to help protect

information from unauthorized access, use, or disclosure. All data stored on the Calix systems is

encrypted following industry standards using the strongest keys and ciphers. All communications

with the App are protected with industry standard security protocols.

You control access to your account. You must keep your login credentials and passwords secure and

protected and maintained as conﬁdential. Sterling LAMB is not responsible for any circumvention of any

privacy settings or security measures provided.

Changes to this Privacy Policy

The date the Privacy Policy was last revised is identiﬁed at the end of this Privacy Policy. You

are responsible for periodically visiting this Privacy Policy to check for any changes.

Contact Information

For questions about your service, please contact Sterling LAMB directly. To ask questions or comment

about this Privacy Policy and Calix’s privacy practices for the Cloud Services provided to your

BSP, contact Sterling LAMB or complete this Request Form (clicking the link will take you to TrustArc,

whom Calix has engaged to assist with personal information requests).

Last Updated August 13, 2024