Open Internet, Net Neutrality & Transparency Policy

  1. Purpose

This Open Internet, Net Neutrality & Transparency Policy (the “Policy”) describes the principles, network management practices, service terms, and customer disclosures applicable to the broadband internet access services (“Broadband Services”) offered by Brdy Telecom Limited (“Company,” “we,” “our,” or “us”), acting as a reseller and/or authorised distributor of satellite broadband connectivity.

The purpose of this Policy is to:

  • Promote an open and accessible internet
  • Provide transparency regarding network management practices
  • Explain how internet traffic may be managed to ensure network security, integrity, and reliability
  • Disclose customer rights and responsibilities
  • Comply with applicable open internet, telecommunications, consumer protection, and transparency obligations

This Policy applies to all residential, business, and enterprise broadband internet access services unless otherwise stated in a separate service agreement.

  1. Commitment to an Open Internet

The Company supports the principle that customers should be able to:

  • Access lawful internet content of their choice
  • Use lawful applications, services, and devices of their choice
  • Connect compatible devices that do not harm the network
  • Compete fairly in the provision of internet content, applications, and services

Subject to reasonable network management, legal obligations, technical limitations, and satellite network constraints, the Company does not:

  • Block lawful internet traffic
  • Throttle lawful internet traffic based on content, application, or service category
  • Engage in paid prioritisation arrangements that favour specific internet traffic in exchange for compensation
  • Unreasonably interfere with or disadvantage customers’ ability to access lawful internet content or services

 

  1. Nature of Satellite Broadband Services

Customers acknowledge that satellite broadband services differ from terrestrial fibre, cable, or fixed wireless services due to:

  • Shared satellite network capacity
  • Variable latency characteristics
  • Environmental and atmospheric conditions
  • Orbital and gateway infrastructure constraints
  • Congestion during peak usage periods
  • Capacity allocation policies implemented by the underlying satellite network operator

As a reseller, the Company may rely on third-party satellite operators, upstream carriers, terrestrial transit providers, and infrastructure vendors to deliver Broadband Services.

Accordingly:

  • Service performance may vary by geographic area, weather conditions, network load, satellite beam utilisation, and customer equipment
  • Certain network management practices may be implemented by the underlying satellite operator or upstream providers
  • The Company may not control all aspects of traffic routing, prioritisation, congestion management, or service availability

 

  1. Reasonable Network Management

The Company may implement reasonable network management practices that are appropriate and tailored to achieving legitimate network management purposes.

Reasonable network management may include measures necessary to:

  • Ensure network security and integrity
  • Mitigate cybersecurity threats and malicious traffic
  • Prevent spam, malware, phishing, denial-of-service attacks, or fraud
  • Reduce congestion during periods of extraordinary demand
  • Preserve quality of service for latency-sensitive applications
  • Comply with legal obligations or law enforcement directives
  • Protect customers and network infrastructure
  • Prevent unlawful or prohibited uses

 

Any network management practices are designed to be:

  • Application-agnostic where technically feasible
  • Narrowly tailored
  • Proportionate to the operational need
  • Temporary where appropriate
  • Consistent with industry standards and technical requirements

 

  1. Traffic Management Practices

5.1 Congestion Management

The Company and/or underlying network operators may use congestion management techniques during periods of high network utilisation.

Such measures may include:

  • Temporary reduction of throughput speeds for heavy users during peak periods
  • Dynamic allocation of bandwidth across users within a coverage beam or service cell
  • Traffic shaping or queue management
  • Prioritization of latency-sensitive traffic classes required for network stability
  • Fair access or fair use policies

Congestion management practices are generally:

  • Automated
  • Based on real-time network conditions
  • Applied for the minimum duration necessary
  • Intended to maintain overall network performance and customer experience

5.2 Application-Specific Treatment

The Company does not intentionally block or throttle lawful applications or services.

However, certain applications may perform differently due to:

  • Satellite latency characteristics
  • Encryption overhead
  • Underlying protocol behaviour
  • Peak network utilisation
  • Traffic prioritization performed by upstream providers
  • Customer equipment limitations

Latency-sensitive applications such as online gaming, VPNs, VoIP, telemedicine, or real-time communications may experience varying performance levels inherent to satellite networks.

5.3 Security Filtering

The Company may block, filter, rate-limit, or otherwise restrict traffic that:

  • Contains malware or malicious code
  • Participates in denial-of-service attacks
  • Attempts unauthorised network access
  • Violates applicable laws
  • Threatens network stability or customer security

The Company may also implement:

  • IP reputation filtering
  • Spam filtering
  • DNS security protections
  • Abuse mitigation systems
  • Automated anomaly detection

 

  1. No Paid Prioritisation

Except where required for specialised services, emergency communications, public safety obligations, or lawful operational purposes, the Company does not enter into agreements to prioritise internet traffic in exchange for payment or other consideration.

If the Company introduces any form of paid prioritisation in the future, customers will be notified through an updated version of this Policy.

 

  1. Data Usage Policies

7.1 Data Plans and Usage Thresholds

Certain Broadband Service plans may include:

  • Monthly data allowances
  • Priority data thresholds
  • Fair access limits
  • Peak/off-peak usage distinctions
  • Speed tiers

Where applicable, customers exceeding applicable thresholds may experience:

  • Reduced speeds
  • Lower traffic priority during congestion
  • Temporary throughput limitations

Any applicable usage limits or thresholds will be disclosed in service plans, order forms, or customer agreements.

7.2 Excessive Usage

The Company reserves the right to investigate or manage excessive or abnormal usage patterns that:

  • Materially impact shared network resources
  • Degrade service for other users
  • Suggest unauthorised resale or misuse
  • Indicate network abuse or automated traffic generation

Actions may include:

  • Temporary traffic management
  • Service suspension
  • Migration to a more appropriate service plan
  • Enforcement under the Acceptable Use Policy

 

  1. Device Compatibility

Customers may use compatible devices and equipment approved for operation on the applicable satellite network.

The Company may restrict devices that:

  • Cause harmful interference
  • Compromise network integrity
  • Fail certification requirements
  • Violate applicable laws or licensing conditions

Certain services may require Company-approved or satellite-operator-approved equipment.

 

 

  1. Performance Characteristics

9.1 Speeds

Advertised speeds are “up to” maximum expected speeds and are not guaranteed.

Actual speeds may vary due to:

  • Network congestion
  • Signal quality
  • Weather conditions
  • Geographic location
  • Wi‑Fi performance
  • Customer equipment
  • Satellite beam capacity
  • Third-party internet conditions

9.2 Latency

Satellite broadband services inherently involve higher latency than terrestrial fibre or cable networks.

Latency may affect:

  • Real-time gaming
  • Video conferencing
  • Financial trading applications
  • VPN performance
  • Certain cloud-based applications

9.3 Availability

Service availability may be interrupted by:

  • Severe weather
  • Satellite maintenance
  • Gateway outages
  • Solar interference
  • Power disruptions
  • Force majeure events
  • Upstream network failures

The Company does not guarantee uninterrupted or error-free service.

 

  1. Specialised Services

The Company or underlying satellite operator may offer specialised services separate from general broadband internet access services, including:

  • Enterprise networking
  • Emergency communications
  • Public safety services
  • Managed connectivity
  • Voice services
  • Private network solutions

Such services may receive differentiated quality-of-service treatment where technically necessary and legally permitted.

 

  1. Privacy and Data Protection

The Company handles customer information in accordance with its Privacy Policy and applicable data protection laws.

The Company may process network usage information for:

  • Billing
  • Network management
  • Security monitoring
  • Fraud prevention
  • Regulatory compliance
  • Service optimisation

The Company does not inspect the content of customer communications except:

  • As required to operate the network
  • For automated security screening
  • As required by law
  • With customer consent

 

  1. Lawful Content and Copyright Compliance

Customers are responsible for ensuring that their use of Broadband Services complies with applicable laws and regulations.

The Company may:

  • Respond to lawful court orders and government requests
  • Investigate abuse complaints
  • Enforce intellectual property protections
  • Suspend or terminate service for unlawful activity

The Company reserves the right to remove or restrict access where required by applicable law.

 

  1. Customer Support and Complaints

Customers may contact the Company regarding:

  • Service performance concerns
  • Network management questions
  • Open internet complaints
  • Billing inquiries
  • Technical support issues

Contact Information:

Brdy Telecom Limited
77 Camden Street Lower, Dublin, Ireland, DO2 XE80
Info@brdyservice.com
+353 15392734

The Company will investigate complaints in good faith and respond within a commercially reasonable timeframe.

 

  1. Regulatory Compliance

This Policy is intended to support compliance with applicable:

  • Open internet and net neutrality regulations
  • Telecommunications laws
  • Consumer protection laws
  • Data protection and privacy laws
  • Licensing and regulatory obligations

If any provision of this Policy conflicts with applicable law or regulatory requirements, the applicable law or regulation shall control.

 

  1. Policy Updates

The Company may update this Policy from time to time to reflect:

  • Changes in law or regulation
  • Changes in network architecture or service offerings
  • Operational or technical developments
  • Changes imposed by underlying satellite operators

Updated versions will be posted on the Company’s website with a revised effective date.

Continued use of the Broadband Services after publication of updates constitutes acceptance of the revised Policy, where permitted by law.

 

  1. Definitions

“Broadband Internet Access Service”

A mass-market retail service providing the capability to transmit data to and receive data from substantially all internet endpoints.

“Reasonable Network Management”

A network management practice primarily used for and tailored to achieving a legitimate network management purpose, taking into account the particular network architecture and technology of the broadband service.

“Paid Prioritisation”

The management of a broadband provider’s network to directly or indirectly favour some traffic over other traffic in exchange for consideration.

“Throttling”

Intentional impairment or degradation of internet traffic based on content, application, service, or use of a non-harmful device.

“Blocking”

Preventing access to lawful internet content, applications, services, or non-harmful devices.

 

  1. Effective Date

Effective Date: May 2026
Version: 1.0