Privacy Policy

APEX Business Consultants LLC (DBA NovaLink Fiber)

Last Updated: January 1, 2026

1. Introduction

APEX Business Consultants LLC, doing business as NovaLink Fiber (“NovaLink,” “we,” “us,” or “our”), respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our internet services, website, and customer portal.

By using NovaLink services, you consent to the data practices described in this Privacy Policy.

This Privacy Policy applies to:

• Internet services provided by NovaLink
• Our website (www.novalinkfiber.com)
• Customer portal and account management tools
• Mobile applications (if applicable)
• Customer support interactions

2. Information We Collect

2.1 Personal Information You Provide

Account Information:
When you sign up for service or create an account, we collect:

• Full name
• Service address (installation location)
• Billing address (if different from service address)
• Phone number(s)
• Email address
• Date of birth (for identity verification)

Payment Information:

• Credit or debit card number, expiration date, CVV
• Bank account and routing number (for ACH payments)
• Billing address
• Payment history and transaction records

Communication Records:

• Customer support tickets and inquiries
• Email correspondence
• Phone call recordings (with notice)
• Chat transcripts
• Feedback and survey responses

Optional Information:

• Marketing preferences
• Referral source (how you heard about us)
• Emergency contact information

2.2 Information Automatically Collected

Network Usage Data:
When you use our internet service, we automatically collect:

• IP addresses assigned to your connection
• Bandwidth consumption (upload/download volumes)
• Connection session times and duration
• Network performance metrics (latency, packet loss, jitter)
• Service tier and plan details
• Equipment identifiers (ONT serial number, router MAC address)

Website and Portal Usage:
When you visit our website or customer portal:

• IP address and device identifiers
• Browser type and version
• Operating system
• Pages viewed and time spent
• Referring website
• Clickstream data
• Cookies and similar tracking technologies (see Section 5)

Location Information:

• Service address (precise location where service is installed)
• General geographic location derived from IP address
• We do not track your physical location via GPS or mobile device

2.3 Information from Third Parties

We may receive information about you from:

Credit Bureaus:

• Credit reports and scores (with your consent, for service approval)
• Identity verification data

Marketing Partners:

• Lead generation sources
• Referral program participants

Public Records:

• Property ownership information
• Publicly available contact information

Other Service Providers:

• Payment processors (transaction confirmation)
• Customer support platforms (support ticket data)

3. How We Use Your Information

3.1 To Provide and Improve Services

• Service Delivery: Activate, maintain, and deliver internet service to your location
• Account Management: Create and manage your customer account, billing, and service preferences
• Technical Support: Diagnose and resolve technical issues, provide customer support
• Network Operations: Monitor and optimize network performance, capacity planning, and quality assurance
• Equipment Management: Track and manage NovaLink-provided equipment (ONT, router)
• Service Upgrades: Offer plan upgrades or additional services that may benefit you

3.2 Billing and Payments

• Invoicing: Generate monthly invoices and billing statements
• Payment Processing: Process payments via your chosen method
• Collections: Pursue collection of past-due accounts
• Fraud Prevention: Detect and prevent payment fraud and unauthorized account access

3.3 Legal and Security

• Compliance: Comply with applicable laws, regulations, and regulatory requirements (FCC, state public utility commissions)
• Law Enforcement: Respond to lawful requests from law enforcement, courts, or government agencies
• Security: Detect, prevent, and investigate security threats, network abuse, and violations of our Acceptable Use Policy
• Rights Protection: Enforce our Terms of Service and Acceptable Use Policy; protect our rights and property
• Emergency Situations: Prevent imminent harm to persons or property

3.4 Marketing and Communications

• Service Communications: Send service-related notices, outage alerts, maintenance notifications, and policy updates
• Marketing: Send promotional offers, newsletters, and information about new services (with your consent)
• Surveys: Request feedback about your experience with NovaLink
• Referrals: Facilitate referral programs if you choose to participate

You may opt out of marketing communications at any time (see Section 9.1).

3.5 Analytics and Research

• Usage Analytics: Analyze aggregate usage patterns to improve service quality
• Market Research: Understand customer needs and preferences
• Product Development: Develop new services and features
• Performance Metrics: Measure network performance and service quality

We do not sell your browsing data or use deep packet inspection for advertising purposes.

4. How We Share Your Information

NovaLink does not sell, rent, or lease your personal information to third parties for their marketing purposes.

4.1 Service Providers and Contractors

We share information with third-party vendors who perform services on our behalf:

Network and Infrastructure:

• Fiber network construction and maintenance contractors
• Equipment manufacturers and suppliers
• Data center and hosting providers

Business Operations:

• Payment processors and billing platforms
• Customer support software providers
• Cloud storage and IT infrastructure providers
• Email service providers
• Marketing and analytics platforms

Professional Services:

• Legal counsel
• Accounting and tax professionals
• Collections agencies (for delinquent accounts)

These service providers are contractually obligated to:

• Use your information only to provide services to NovaLink
• Protect your information with appropriate security measures
• Not use your information for their own purposes

4.2 Legal and Regulatory Disclosures

We may disclose your information when required or permitted by law:

Law Enforcement and Government:

• In response to subpoenas, court orders, or search warrants
• To comply with legal or regulatory requirements
• To respond to lawful requests from public authorities (national security, law enforcement)

Emergency Situations:

• To prevent imminent harm to life or safety
• To protect against fraud or security threats
• To prevent or investigate violations of law or our policies

Transparency: When legally permitted, we notify customers of legal requests for their information and provide a copy of the request.

4.3 Business Transfers

If NovaLink is involved in a merger, acquisition, asset sale, bankruptcy, or other business transaction:

• Your information may be transferred to the successor entity
• We will provide notice before your information is transferred and becomes subject to a different privacy policy

4.4 Copyright Enforcement

• We may disclose customer information to copyright holders in response to valid DMCA subpoenas
• We forward DMCA takedown notices to customers accused of infringement

4.5 With Your Consent

We may share your information for purposes not described in this Privacy Policy with your explicit consent.

4.6 Aggregate and De-Identified Data

We may share aggregate, anonymized, or de-identified data that cannot reasonably be used to identify you:

• Industry research and benchmarking
• Network performance statistics
• Service area demographic information
• Public reporting and transparency disclosures

5. Cookies and Tracking Technologies

5.1 What Are Cookies?

Cookies are small text files stored on your device when you visit websites. We use cookies and similar technologies (web beacons, pixels, local storage) on our website and customer portal.

5.2 Types of Cookies We Use

Essential Cookies:

• Required for website functionality (login sessions, shopping cart)
• Cannot be disabled without breaking core features

Performance Cookies:

• Collect information about how you use our website (pages visited, errors encountered)
• Help us improve website performance
• Data is aggregated and anonymous

Functional Cookies:

• Remember your preferences (language, region, account settings)
• Provide enhanced features and personalization

Marketing Cookies:

• Track your browsing across websites
• Used to deliver relevant advertising
• May be set by third-party advertising networks

5.3 Third-Party Cookies

Our website may contain cookies from:

• Google Analytics: Website traffic and behavior analysis
• Facebook Pixel: Advertising and conversion tracking
• Payment Processors: Fraud prevention and transaction security

5.4 Cookie Preferences

Managing Cookies:

• Most browsers allow you to refuse cookies or delete existing cookies
• You can adjust cookie settings in your browser preferences
• Disabling essential cookies may prevent website functionality

Opt-Out Links:

• Google Analytics: https://tools.google.com/dlpage/gaoptout
• Network Advertising Initiative: https://optout.networkadvertising.org/
• Digital Advertising Alliance: https://optout.aboutads.info/

Do Not Track:
Our website does not currently respond to Do Not Track (DNT) signals, as there is no industry standard for DNT implementation.

6. Data Security

6.1 Security Measures

We implement industry-standard security measures to protect your information:

Technical Safeguards:

• Encryption of data in transit (TLS/SSL)
• Encryption of sensitive data at rest
• Secure network infrastructure with firewalls and intrusion detection
• Regular security audits and vulnerability assessments
• Multi-factor authentication for employee access to customer data

Administrative Safeguards:

• Employee background checks and confidentiality agreements
• Role-based access controls (employees only access data necessary for their job)
• Regular security awareness training
• Incident response and breach notification procedures

Physical Safeguards:

• Secure data centers with restricted physical access
• Video surveillance and access logging
• Equipment disposal procedures (secure data destruction)

6.2 Payment Security

• PCI DSS Compliance: We comply with Payment Card Industry Data Security Standards
• Tokenization: Credit card numbers are tokenized and not stored in our systems
• Third-Party Processors: Payments are processed through PCI-compliant payment gateways

6.3 Your Responsibility

You are responsible for:

• Maintaining the confidentiality of your account password
• Using strong, unique passwords
• Not sharing your account credentials
• Logging out of shared or public computers
• Promptly notifying us of unauthorized account access

6.4 No Guarantee

While we implement reasonable security measures, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your information. You provide information at your own risk.

7. Data Retention

7.1 How Long We Keep Your Information

Active Accounts:
We retain your information for as long as your account is active and as necessary to provide services.

After Account Closure:

• Billing and Transaction Records: 7 years (tax and accounting requirements)
• Service Usage Data: 1-2 years (network planning and analytics)
• Support Records: 3 years (dispute resolution and service improvement)
• Legal Holds: Indefinitely if subject to litigation, investigation, or legal obligation

Account Deletion:
When you cancel service, we delete or anonymize non-essential personal information within 90 days, unless longer retention is required by law or legitimate business purposes.

7.2 Aggregated Data

De-identified and aggregated data may be retained indefinitely for research, analytics, and business purposes.

8. Your Privacy Rights

8.1 General Rights (All Customers)

Access and Portability:

• Request a copy of the personal information we hold about you
• Receive your information in a structured, commonly used format

Correction:

• Request correction of inaccurate or incomplete information
• Update your account information via the customer portal

Deletion:

• Request deletion of your personal information (subject to legal retention requirements)
• Account closure does not automatically delete all data (see Section 7)

Opt-Out of Marketing:

• Unsubscribe from promotional emails via the unsubscribe link
• Opt out of marketing calls by contacting customer support
• You cannot opt out of service-related communications (billing, outage notices, policy updates)

To Exercise These Rights:

• Email: compliance@novalinkfiber.com
• Mail: APEX Business Consultants LLC, Attn: Privacy Officer, 101-4 Chrissa Dr, Pottsboro, TX 75076
• Customer Portal: Account Settings → Privacy Preferences

8.2 California Residents (CCPA/CPRA Rights)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Right to Know:

• Categories of personal information collected
• Sources from which information is collected
• Business or commercial purposes for collection
• Categories of third parties with whom information is shared
• Specific pieces of personal information we hold about you

Right to Delete:

• Request deletion of personal information collected from you (subject to exceptions)

Right to Opt-Out of Sale:

• NovaLink does not sell your personal information. We do not sell browsing data, usage data, or personal information to data brokers or advertisers.

Right to Non-Discrimination:

• We will not discriminate against you for exercising your CCPA rights

Authorized Agents:

• You may designate an authorized agent to submit requests on your behalf (requires verification)

Verification:
To protect your privacy, we verify your identity before processing requests:

• Account login credentials
• Phone number or email verification
• Additional information to match our records

Response Time:
We respond to verified requests within 45 days (may extend by 45 additional days with notice).

CCPA Contact:
Email: compliance@novalinkfiber.com
Phone: (979) 256-5155

8.3 Other State Privacy Laws

Residents of other states with privacy laws (Virginia, Colorado, Connecticut, Utah, etc.) may have similar rights. Contact compliance@novalinkfiber.com for information about your state-specific rights.

9. Opt-Out and Communication Preferences

9.1 Marketing Communications

Email Marketing:

• Click the “Unsubscribe” link in any promotional email
• Update preferences in your customer portal under Account Settings → Email Preferences
• Email compliance@novalinkfiber.com to opt out

Telemarketing:

• Request removal from our calling list during any call
• Email compliance@novalinkfiber.com with your phone number to opt out
• Register with the National Do Not Call Registry: https://www.donotcall.gov

Text Messages:

• Reply STOP to any marketing text message
• We only send texts to customers who opt in

Direct Mail:

• Email compliance@novalinkfiber.com to remove your address from mailing lists

Note: You cannot opt out of service-related communications, including:

• Billing statements and payment reminders
• Service outage notifications and maintenance alerts
• Terms of Service or policy updates
• Security alerts and account notifications

9.2 Advertising and Behavioral Tracking

Interest-Based Advertising:

• Opt out of personalized ads through industry opt-out tools:
  • Network Advertising Initiative: https://optout.networkadvertising.org/
  • Digital Advertising Alliance: https://optout.aboutads.info/

Social Media Advertising:

• Adjust ad preferences on Facebook, Google, and other platforms directly

10. Children’s Privacy

NovaLink services are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18 without parental consent.

If you believe we have collected information from a child under 18:

• Contact us immediately at compliance@novalinkfiber.com
• We will promptly delete the information upon verification

Parental Control: Parents and guardians are responsible for monitoring their children’s internet use and may use parental control software to restrict access to inappropriate content.

11. Third-Party Links and Services

Our website and services may contain links to third-party websites, applications, or services that we do not control.

We are not responsible for:

• Privacy practices of third-party websites
• Content or security of external sites
• Third-party data collection or tracking

We encourage you to:

• Review the privacy policies of any third-party services you use
• Understand how your information is collected and used by others

Examples of third-party services:

• Social media platforms (Facebook, Twitter)
• Payment processors (credit card gateways)
• Content providers and streaming services accessed via our internet service

12. International Data Transfers

NovaLink operates within the United States. If you access our services from outside the U.S., your information will be transferred to and processed in the United States.

By using our services, you consent to:

• Transfer of your information to the United States
• Processing and storage of your information in accordance with U.S. law
• This Privacy Policy and applicable U.S. privacy laws

The United States may have different data protection laws than your country. We take reasonable steps to protect your information regardless of where it is processed.

13. Changes to This Privacy Policy

NovaLink reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations.

Notification of Changes:

• Material Changes: We will notify you via email and/or prominent notice on our website at least 30 days before changes take effect
• Minor Changes: Posted to our website without advance notice

Effective Date: Changes are effective on the date posted unless otherwise specified

Your Consent:

• Continued use of NovaLink services after changes take effect constitutes acceptance of the updated Privacy Policy
• If you do not agree to changes, you may cancel service in accordance with the Terms of Service

Version History:
We maintain a version history of this Privacy Policy at www.novalinkfiber.com

14. Contact Us

Privacy Questions or Requests:

Privacy Officer:
APEX Business Consultants LLC (DBA NovaLink Fiber)
Attn: Privacy Officer
101-4 Chrissa Dr, Pottsboro, TX 75076

Email: compliance@novalinkfiber.com

Phone: (979) 256-5155

Customer Support:
Email: support@novalinkfiber.com
Phone: (979) 256-5155

Mailing Address:
APEX Business Consultants LLC
101-4 Chrissa Dr, Pottsboro, TX 75076

Website: www.novalinkfiber.com

15. California Privacy Notice (CCPA Summary)

Information We Collect:

Business Purposes for Collection:

• Providing internet services
• Account management and billing
• Customer support
• Network operations and security
• Legal compliance
• Marketing (with consent)

Categories of Third Parties We Share With:

• Service providers and contractors
• Payment processors
• Law enforcement (when legally required)
• Successor entities in business transfers

We Do Not Sell Your Personal Information

Your Rights:

• Right to know what information we collect
• Right to delete your information
• Right to opt out of sales (we do not sell)
• Right to non-discrimination

Contact: compliance@novalinkfiber.com or (979) 256-5155

By using NovaLink services, you acknowledge that you have read and understood this Privacy Policy.

Document Version 1.0 – January 1, 2026