1. Introduction

This Privacy Policy describes mStreet Fiber (hereafter, “mSF” ” “we,” “us,” or “our”), headquartered at 1700 Pennsylvania Avenue NW, 6th Floor, Washington, D.C. data collection and maintenance procedures for its Website (“Online Policy”). 

By continuing to use our Website and Apps, you are agreeing to the terms of this Online Privacy Policy and Our Terms of Service, which can be found here: (LINK TO TERMS OF SERVICE). If you do not agree, then please stop using our Website and Apps. 

2. Definitions 

• “Consumer” means a natural person who visits and uses Our Website and Apps;

• “Personal Information” means any information relating to an identified or  identifiable individual that is collected via Our Website and Apps. Personal Information may include a Consumer’s: full name, physical address, email address, IP address, or other identifier such as from a Cookie.   

Personal Information does not include any aggregate or anonymized data that may have been created from Personal Information but can no longer be used to identify, relate to or could reasonably be linked to a Consumer. 

• “You” or “Your” means a Consumer. 

3. Information We Collect from You When You Visit Our Website and Apps

We collect certain Personal Information from you in order to operate our Websites and Apps effectively and provide you with the best experiences when you visit and use them. 

3.1 Information Provided by You

When You register for an account online via our investor’s platform, we will collect certain Personal Information about You such as Your name, address, e-mail address, and telephone number, and possibly, employer name. We will also collect certain Personal Information about You when you fill out a contact form or subscription form on Our website, or if You apply for a job with us. 

3.1 Information Collected on Our Websites and Apps

We also may use various technologies to collect information from Your computer or device and about Your activities on Our Websites or Apps.

• Information collected automatically: We may automatically collect information from You when You visit Our Websites and Apps. This information may include Your IP address, location data, Your browser type and language, access times, the content of any undeleted cookies that Your browser previously accepted from us, referring or exit website address, internet service provider, date/time stamp, operating system, locale and language preferences, and system configuration information. We use Google Analytics to collect information about Your use of Our Website as well. 

• Cookies: When You visit our Websites and/or Apps, We may assign Your device one or more cookies to facilitate access to Our site and to personalize Your online experience. Through the use of a cookie, we also may automatically collect information about Your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. 

A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate Our website. A persistent cookie remains on your hard drive for an extended period of time. 

We use cookies to personalize Your experience on Our website, to provide social media features and to analyze Our traffic. 

When you first visit Our site, We provide You with a choice to either accept or deny certain cookies. If You choose to decline cookies please note that some of the features and services of our Websites and/or Apps may not function as well as intended. Even if You choose to accept cookies, You are always free to change Your mind and revoke that consent. 

4. Why We Collect Your Information

4.1 To Service Our Website and Apps

We use information collected to ensure that Our Website and Apps are working as intended and for analytics purposes, to understand how Our Website and Apps are operating and learn how they can be improved. We use this information as needed for auditing purposes as well.  

4.2 For Marketing Purposes 

If You have filled out a contact or subscription form with Us or provided Your information in relation to the development of any of Meridiam’s projects, we may use this information to send You marketing materials including newsletters and presentations. You can opt out of receiving these communications at any time by clicking the “opt out” link at the bottom of these emails.

4.3 In Order to Respond from Requests from You

If you have requested further information or in any other way requested that We contact You, we will use Your Personal Information to respond to such a request.   

4.4 For Our Legal Purposes 

We also collect information in order to comply with certain legal rules and regulations that We are subject to.  

5. How Long do We Store and Maintain Your Personal Information?

We only store and maintain Your Personal Information for as long as is necessary to fulfill the purpose for which it was collected. For example, if You sign up to receive Our newsletters or marketing communications, we will store and maintain Your Personal Information to continue to send You these materials until You opt out of receiving such communications. 

6. Do We Sell Your Personal Information? 

Meridiam does not under any circumstances sell any Personal Information that it has collected to any third parties. 

7. Who Do We Share Collected Personal Information With?

Meridiam only shares Your Personal Information when necessary to members of Our internal team and Our service providers.  

Meridiam uses services from selected service providers and, when necessary to share Your Personal Information with such service providers, ensures that they are contractually obligated to secure Your Personal Information in the same way that We do and further that they cannot sell or further share Your Personal Information without consent.  

Specifically, the third parties that We may share Your Personal Information with are:

• IT service providers for hosting, management of IT systems, backup, provision and maintenanceo f IT networks, backup networks, etc.; and
• Service providers for archiving, etc.

Depending on the need, We may also have to share Your Personal Information with: 

• Our legal representatives; and 

Authorized third parties such as courts, supervisory authorities and auditors. 

8. How do We Secure Your Personal Information? 

Meridiam maintains a comprehensive information security program that employs commercially available physical and IT securitization tools, including but not limited to:

• Commercially available and sufficient firewalls; 
• Segmented data storage; 
• Multi-factor authentication; and  – Policies providing for least privileged access to data across Our organization. 

9. California Consumer Privacy Act of 2018 (“CCPA”) Law Notice 

9.1 Sale Of Your Personal Information 

We do not sell Your Personal Information. 

9.2 Categories of Personal Information that We Collect: 

Categories of Personal Information	Categories of Sources of This Information
Identifiers (i.e., a legal name, nickname, physical home address, internet protocol address, email address, phone number, an online identifier, driver’s license number, etc.)	Information You provide directly to Us or collected from You via our data analytics providers from Your use of Our Website and Apps.
Internet activity (i.e., browsing history, Wi-Fi use, and internet search history)	Information You provide directly to Us, collected from You from our data analytics providers, or allow Us to collect and use from Your devices.

9.3 Why We Collect this information from You?

We use this information from You for our business purposes as outlined above in Section 4. 

9.4 Categories of Personal Information that We Share for Our “Business Purposes”:  

Even though we do not sell Your information, we still need to share it to support and continually improve the Our Website and Apps and for other business purposes. Specifically, these categories of “business purposes” are: 

• Service Improvements – We may share this information with our third-party vendors, other partners, and service providers in order to improve Our services, create new services and products, offer new products, and to ensure that Our services are working as intended (to identify bugs and errors, and repair them). 
• Service Partners – We may share this information our third-party vendors, other partners, and service providers in order to have them perform their services for Us, pursuant to a written contract that includes the notified purposes permitted by the CCPA.
• Security and Legal Issues – We may share this information with law enforcement or other individuals pursuant to a valid subpoena or other legal obligation, our third-party vendors, other partners, and service providers in order to detect, prevent, and investigate security incidents, violations of Our Terms of Service or content standards, or other applicable laws. 

9.5 Your Rights Under the CCPA

• You, or Your authorized agent, can request a copy of Your Personal information by sending an email. You can also request that We disclose how we have collected, used and shared Your personal information over the past 12 months, including the categories of personal information We collected and Our purposes for doing so. You may also request the categories of the sources of that information, the categories of the third parties with whom We have shared this information with for a business purpose, and our business purpose for doing so.  
• You have the right to Opt out of Sale of Your Information, but as noted above, We do not sell Your information.  
• You have a right to be notified when we collect information from You, and We cannot collect new categories of information from You without notifying You first.  
• You have the right to limit Our sharing of Your Personal Information.  
• You have the right to not be discriminated against for exercising these rights.  
• You have the right to delete Your Personal Information, which you can do by terminating Your account with Us, if you have one. You can also email Us at it.support@meridiam.com to request that We delete any of Your Personal Information that We may be in possession of. We will honor such requests and unless an exception applies or we are legally obligated to keep a copy of Your information, We will close Your account if You have one, and delete Your information.  

9.6 How to Exercise Your Rights 

If You would like to exercise any of the rights listed above with regards to Your information, then please contact Us, or have Your registered agent contact Us, at   it.support@meridiam.com and state the same. 

If you want to review and request changes to Your Personal Information, You may also email or call Us as noted below, and we will then provide you with detailed instructions on how to do so. 

10. Children’s Personal Information

We do not knowingly collect personal information from children under the age of 16. Our services, Websites and Apps are not marketed to or geared for children under the age of 16. 

11. Third-Party Tracking on Our Website and Apps 

Third parties may be using cookies or other technologies to collect Your personal information as You navigate through the internet including from Our Website and Apps. As described above, You may decline these third-party cookies by changing Your browser settings. 

12. Do Not Track (“DNT”) Settings 

DNT is a setting on some web browsers or mobile devices that can be turned on to instruct websites to disable tracking of your web browsing activities. DNT is not currently widely adopted  and does not have clear standards or guidelines as to how websites are to interpret it. Additionally, its signals can affect the functioning of certain websites. As such, Meridiam does not generally respond to these signals.  

13. Changes to this Online Policy 

Any changes to this Online Policy will be posted directly on our Websites and Apps and reflected with a new Effective Date at the bottom of this Online Policy. We encourage You to review the Online Policy each time You visit our Websites and Apps to see if it has been updated since Your last visit.