Annual 47 C.F.R. 64.2009(e) CPNI Certification EB oc!

et 06"#6

Annual 64.2009(e) CPNI Certification for 2013 Date filed: 1/10/2014 Na e of co !an" co#ered $" t%i& certification: Cro'n Point (ele!%one Cor!oration )or 499 )iler ID: *0++14

Na e of &i,nator": -%ana .na!!/0ace" (itle of &i,nator": Pre&ident I1 -%ana .na!!/0ace"1 certif" t%at I a an officer of t%e co !an" na ed a$o#e1 and actin, a& an a,ent of t%e co !an"1 t%at I %a#e !er&onal 2no'led,e t%at t%e co !an" %a& e&ta$li&%ed o!eratin, !rocedure& t%at are ade3uate to en&ure co !liance 'it% t%e Co i&&ion4& CPNI rule&. See 4+ C.).5. 6 64.2001 et seq. Attac%ed to t%i& certification i& an acco !an"in, &tate ent e7!lainin, %o' t%e co !an"4& !rocedure& en&ure t%at t%e co !an" i& in co !liance 'it% t%e re3uire ent& &et fort% in &ection 64.2001 et seq. of t%e Co i&&ion4& rule&. (%e co !an" %a& not ta2en an" action& (!roceedin,& in&tituted or !etition& filed $" a co !an" at eit%er &tate co i&&ion&1 t%e court &"&te 1 or at t%e Co i&&ion a,ain&t data $ro2er&) a,ain&t data $ro2er& in t%e !a&t "ear. Co !anie& u&t re!ort on an" infor ation t%at t%e" %a#e 'it% re&!ect to t%e !roce&&e& !rete7ter& are u&in, to atte !t to acce&& CPNI 1 and '%at &te!& co !anie& are ta2in, to !rotect CPNI. (%e co !an" %a& not recei#ed an" cu&to er co !laint& in t%e !a&t "ear concernin, t%e unaut%ori8ed relea&e of CPNI (nu $er of cu&to er co !laint& a co !an" %a& recei#ed related to unaut%ori8ed acce&& to CPNI1 or unaut%ori8ed di&clo&ure of CPNI1 $ro2en do'n $" cate,or" or co !laint1 e.g.1 in&tance& of i !ro!er acce&& $" e !lo"ee&1 in&tance& of i !ro!er di&clo&ure to indi#idual& not aut%ori8ed to recei#e t%e infor ation1 or in&tance& of i !ro!er acce&& to online infor ation $" indi#idual& not aut%ori8ed to #ie' t%e infor ation). -i,ned 999-%ana .na!!/0ace"999

Crown Point Telephone Corporation STATEMENT OF COMPANY POLICY

When referred to in the guidelines set forth below, "Company," "we," or "us" refers to and includes all employees, associates, and agents of Crown Point Telephone Corporation. Crown Point Telephone Corporation (t%e :Co !an":) %a& a dut" to !rotect t%e confidential1 Cu&to er Pro!rietar" Net'or2 Infor ation (:CPNI:) of our cu&to er&1 ot%er teleco unication& carrier&1 and e3ui! ent anufacturer&. (%erefore1 t%e follo'in, ,uideline& &%all $e follo'ed $" all e !lo"ee& and a,ent& of t%e Co !an":

CPNI i& an" infor ation t%at relate& to t%e 3uantit"1 tec%nical confi,uration1 t"!e1 de&tination1 location1 and a ount of u&e of a teleco unication& &er#ice &u$&cri$ed to $" an" cu&to er of a teleco unication& carrier1 and t%at i& ade a#aila$le to t%e carrier $" t%e cu&to er &olel" $" #irtue of t%e carrier/cu&to er relation&%i!. CPNI al&o include& infor ation contained in t%e $ill& !ertainin, to t%e tele!%one e7c%an,e &er#ice or tele!%one toll &er#ice recei#ed $" a cu&to er of a carrier. ! ! Pro!rietar" infor ation of our cu&to er&1 ot%er teleco e3ui! ent anufacturer& i& !rotected $" )ederal la'. unication& carrier&1 and

CPNI '%ic% t%e Co !an" o$tain& fro anot%er carrier for t%e !ur!o&e of !ro#idin, a !articular teleco unication& &er#ice a" $e u&ed onl" for t%e !ro#i&ion of t%at &er#ice1 and a" not $e u&ed for an" ot%er'i&e unrelated ar2etin, effort&. Indi#iduall" identifia$le CPNI t%at 'e o$tain $" !ro#idin, a teleco unication& &er#ice a" $e u&ed1 di&clo&ed1 or relea&ed only in t%e circu &tance& a& &et fort% in t%e Co !an"4& CPNI ;!eratin, <uideline&.

$%e relea&e of an' CPNI (' &ale& )er&onnel *u&t (e aut%ori+e, (' a &u)er-i&or. $%e Co*)an' ta!e& &eriou&l' t%e )rotection of our cu&to*er&. CPNI/ an, in accor,ance 0it% 47 C.F.R. 64.2009 0ill (e &u(1ect to ,i&ci)linar' re-ie0 for -iolation of t%e )olicie& &et fort% a(o-e. Plea&e contact 'our &u)er-i&or if 'ou %a-e an' 2ue&tion& or re2uire a,,itional infor*ation.

Crown Point Telephone Corporation Operating Guidelines Relating to Customer Proprietary Network Information

I.

Introduction.

These Operating Guidelines relating to Customer Proprietary Network Information (CPNI) are intended to ensure the omplian e !y Crown Point Telephone Corporation (the Company) with the Communi ations " t of #$%&' as amended' and related regulations regarding CPNI that ha(e !een adopted !y the )ederal Communi ations Commission ()CC)* " ordingly' from time to time' these guidelines may hange !ased on hanges in the go(erning law or )CC regulations* CPNI' a ording to federal law' is (a) information that relates to the +uantity' te hni al onfiguration' type' destination' lo ation' and amount of use of a tele ommuni ations ser(i e su!s ri!ed to !y any ustomer of the Company' and that is made a(aila!le to the Company !y the ustomer solely !y (irtue of the Company, ustomer relationship- and (!) information ontained in the !ills pertaining to telephone e. hange ser(i e or telephone toll ser(i e re ei(ed !y a ustomer of the Company* This type of information in ludes personal information su h as/ the telephone num!ers alled !y a ustomer- the length of phone alls- and ser(i es pur hased !y a ustomer' su h as all waiting* Federal law also contemplates data referred to as customer information and subscriber list information. These types of data do not involve personal, individually-identifiable information. Aggregate customer information is data that relates to a group or category of customers from which individual customer identities and characteristics have been removed; subscriber list information is data such as subscriber names, addresses, and telephone numbers. The ompany!s "perating #uidelines address only federal regulations that are applicable to $%&. In a ordan e with federal law' the Company may use' dis lose' or permit a ess to CPNI in its pro(ision of (a) the tele ommuni ations ser(i e from whi h su h information is deri(ed' or (!) ser(i es ne essary to' or used in the pro(ision of that tele ommuni ations ser(i e' in luding the pu!li ation of telephone dire tories*

The Company may o!tain appro(al from the ustomer to a ess and use that ustomer0s CPNI through either Opt,out or Opt,in methods* The Company may' su!1e t to opt,out appro(al or opt,in appro(al' use its ustomer0s indi(idually identifia!le CPNI for the purpose of marketing ommuni ations,related ser(i es to that ustomer* The Company may' su!1e t to opt,out appro(al or opt,in appro(al' dis lose its ustomer0s indi(idually identifia!le CPNI' for the purpose of marketing ommuni ations,related ser(i es to that ustomer' to its agents and its affiliates that pro(ide ommuni ations,related ser(i es* The Company may also permit su h persons or entities to o!tain a ess to su h CPNI for su h purposes* 2. ept for use and dis losure of CPNI that is permitted without ustomer appro(al under 3e tion II*C' !elow' or that is des ri!ed in this paragraph' or as otherwise pro(ided in se tion 444 of the Communi ations " t of #$%&' as amended' the Company may only use' dis lose' or permit a ess to its ustomer0s indi(idually identifia!le CPNI su!1e t to opt,in appro(al* The Opt,in and Opt,out methods are des ri!ed !elow in 3e tions I5*6 and I5*2* II. Limitations on Company se of CPNI.

It is the general poli y of the Company to not use CPNI* If' howe(er' CPNI is used' then the use of CPNI !y the Company will !e only in a ordan e with the following guidelines*

!.

"cope of se

The Company may use' dis lose' or permit a ess to CPNI for the purpose of pro(iding or marketing ser(i e offerings among the ategories of ser(i e ( i.e.' lo al' intere. hange' and C783) to whi h our ustomer already su!s ri!es without ustomer appro(al* If a ustomer su!s ri!es to more than one ategory of ser(i e offered !y our Company' then the Company may share CPNI among our affiliated entities that pro(ide a ser(i e offering to the ustomer* If a ustomer does not su!s ri!e to more than one offering of our Company' then the Company will not share that ustomer0s CPNI with its affiliates' e. ept in a ordan e with the Opt,out and Opt,in pro edures des ri!ed !elow (3e tions I5*6 and I5*2' !elow)* #. Permitted and Non$Permitted se of CPNI %y the Company

The Company will not use' dis lose' or permit a ess to CPNI to market to a ustomer ser(i e offerings that are within a ategory of ser(i e to whi h the su!s ri!er does not already su!s ri!e from our Company' unless the Company has o!tained the ustomer0s appro(al to do so* The Company may use CPNI without ustomer onsent only in a ordan e with 3e tion II*C' !elow* The Company does not use' dis lose or permit a ess to CPNI to identify or tra k ustomers that all ompeting ser(i e pro(iders* )or e.ample' ustomer ser(i e representati(es and other Company personnel may not use lo al ser(i e CPNI to tra k all ustomers that all lo al ser(i e ompetitors* C. se of CPNI without Customer !ppro&al

The Company may use' dis lose' or permit a ess to CPNI' without ustomer appro(al' only as des ri!ed !elow* If the Company pro(ides Commer ial 7o!ile 8adio 3er(i e (C783)' then the Company may use' dis lose' or permit a ess to CPNI deri(ed from its pro(ision of C783' and may do so without ustomer appro(al for the pro(ision of Customer Premises 2+uipment (CP2) and information ser(i e(s)* 3imilarly' the Company may use' dis lose or permit a ess to CPNI deri(ed from its pro(ision of lo al e. hange ser(i e and may do so without ustomer appro(al for the pro(ision of CP2 and all answering' (oi e mail or messaging' (oi e storage and retrie(al ser(i es' fa. store and forward' and proto ol on(ersion* )inally' if the Company pro(ides intere. hange ser(i es (typi ally referred to as long distan e ser(i e)' the Company may use' dis lose or permit a ess to CPNI deri(ed from its pro(ision of intere. hange ser(i e and may do so without ustomer appro(al for the pro(ision of CP2 and all answering' (oi e mail or messaging' (oi e storage and retrie(al ser(i es' fa. store and forward' and proto ol on(ersion* The Company may use' dis lose' or permit a ess to CPNI' without ustomer appro(al' in its pro(ision of inside wiring installation' maintenan e' and repair ser(i es*

9here appli a!le' the Company may use' dis lose' or permit a ess to the CPNI of its C783 ustomers for the purpose of ondu ting resear h on the health effe ts of C783* The Company may use CPNI' without ustomer appro(al' to market ser(i es formerly known as ad1un t,to,!asi ser(i es' su h as' !ut not limited to' speed dialing' omputer,pro(ided dire tory assistan e' all monitoring' all tra ing' all !lo king' all return' repeat dialing' all tra king' all waiting' aller I*6*' all forwarding' and ertain Centre. features* The Company may use' dis lose' or permit a ess to CPNI to prote t the rights or property of the Company' or to prote t users of those ser(i es and other arriers from fraudulent' a!usi(e' or unlawful use of' or su!s ription to' su h ser(i es* III. !. !ppro&al Re'uired for se of CPNI. General Policies Regarding Customer !ppro&als to se CPNI

The Company may o!tain a ustomer0s appro(al to use CPNI through written' oral or ele troni methods* If the Company relies upon a ustomer0s oral appro(al' then the Company will !ear the !urden of demonstrating that su h appro(al was gi(en in omplian e with appli a!le )CC rules* The ustomer0s appro(al or disappro(al to use' dis lose' or permit a ess to that ustomer:s CPNI shall remain in effe t until the ustomer re(okes or limits su h appro(al or disappro(al* The Company will maintain re ords of appro(al' whether oral' written or ele troni ' for at least one year* #. se of CPNI (here Customer !ppro&al is Recei&ed

The Company may use either Opt,out or Opt,In appro(al pro esses as pro(ided for in appli a!le )CC regulations in order to use a ustomer0s CPNI* These appro(al pro esses are des ri!ed in 3e tions I5*6 and I5*2' !elow' 9here appro(al for the use of CPNI is re ei(ed !y the Company from the ustomer' the Company may use a ustomer:s indi(idually identifia!le CPNI for the purpose of marketing ommuni ations,related ser(i es to that ustomer* ;ikewise' where this appro(al is re ei(ed' the Company may also dis lose a ustomer:s indi(idually identifia!le CPNI for the purpose of marketing ommuni ations,related ser(i es to that ustomer' to its agents' and to its affiliates that pro(ide ommuni ations,related ser(i es* )urther' where appro(al has !een re ei(ed !y the ustomer of the use !y the Company of his<her CPNI' the Company may also permit su h persons or entities to o!tain a ess to su h CPNI for su h purposes* 2. ept for use and dis losure of CPNI that is permitted without ustomer appro(al as des ri!ed in 3e tion II' a!o(e' or (ia an Opt,in or Opt,out authori=ation des ri!ed in 3e tions I5*6* and I5*2' !elow' the Company may only use' dis lose' or permit a ess to its ustomers0 indi(idually identifia!le CPNI su!1e t to Opt,in appro(al* I). !. Notice Re'uired for se of CPNI. General Re'uirement

The Company shall pro(ide notifi ation to the ustomer of the ustomer:s right to restri t use of' dis losure of' and a ess to that ustomer:s CPNI prior to any soli itation for ustomer appro(al*

The Company will maintain re ords of notifi ation' whether oral' written or ele troni ' for at least one year* #. Indi&idual Notice nder Certain Circumstances

The Company shall pro(ide indi(idual noti e to ustomers when soli iting appro(al to use' dis lose' or permit a ess to ustomers: CPNI* C. *lements that shall %e Included in any Customer Notice +Opt In and Opt Out,

The ustomer notifi ation shall pro(ide suffi ient information to ena!le the ustomer to make an informed de ision as to whether to permit the Company to use' dis lose' or permit a ess to' the ustomer:s CPNI* The Company0s notifi ation will omply with the following/ #* The notifi ation shall state that the ustomer has a right' and the Company has a duty' under federal law' to prote t the onfidentiality of CPNI* The notifi ation shall spe ify the types of information that onstitute CPNI and the spe ifi entities that will re ei(e the CPNI' des ri!e the purposes for whi h CPNI will !e used' and inform the ustomer of his or her right to disappro(e those uses' and deny or withdraw a ess to CPNI at any time* The notifi ation shall ad(ise the ustomer of the pre ise steps the ustomer must take in order to grant or deny a ess to CPNI' and must state learly that a denial of appro(al will not affe t the pro(ision of any ser(i es to whi h the ustomer su!s ri!es* >owe(er' the Company may pro(ide a !rief statement' in lear and neutral language' des ri!ing onse+uen es dire tly resulting from the la k of a ess to CPNI' i.e., that the Company may !e una!le to market to the ustomer produ ts and ser(i es tailored to the ustomer:s needs* The notifi ation shall !e omprehensi!le and shall not !e misleading* If written notifi ation is pro(ided' then the noti e shall !e learly legi!le' use suffi iently large type' and !e pla ed in an area so as to !e readily apparent to a ustomer* If any portion of a notifi ation is translated into another language' then all portions of the notifi ation shall !e translated into that language* The Company may state in the notifi ation that the ustomer:s appro(al to use CPNI may enhan e the Company0s a!ility to offer produ ts and ser(i es tailored to the ustomer:s needs* The Company also may state in the notifi ation that it may !e ompelled to dis lose CPNI to any person upon affirmati(e written re+uest !y the ustomer* The Company shall not in lude in the notifi ation any statement attempting to en ourage a ustomer to free=e third,party a ess to CPNI* The notifi ation shall state that any appro(al or denial of appro(al for the use of CPNI outside of the ser(i e to whi h the ustomer already su!s ri!es from the Company is (alid until the ustomer affirmati(ely re(okes or limits su h appro(al or denial*

4*

%*

&* ?*

@*

A*

B*

$*

#C*

The Company0s soli itation for appro(al must !e pro.imate to the notifi ation of a ustomer:s CPNI rights*

-.

Opt$out !ppro&al

Opt,out appro(al is a method for o!taining ustomer onsent to use' dis lose' or permit a ess to the ustomer:s CPNI* Dnder this appro(al method' a ustomer is deemed to ha(e onsented to the use' dis losure' or a ess to the ustomer:s CPNI if the ustomer has failed to o!1e t to the Company0s use of the ustomer0s CPNI after the ustomer is pro(ided appropriate notifi ation of the Company:s re+uest for onsent that is pro(ided in a manner onsistent with the appli a!le federal rules and these Operating Guidelines* The Company may pro(ide a ustomer notifi ation to o!tain her<his Opt,out appro(al through ele troni or written methods* 2. ept as pro(ided in 3e tion I5*)' the Company will pro(ide notifi ation to o!tain opt,out appro(al through ele troni or written methods' !ut not !y oral ommuni ation* The ontents of any su h notifi ation shall omply with the standards des ri!ed in 3e tion I5*C' a!o(e* The Company may use Opt,out appro(al to o!tain a ustomer0s onsent to share CPNI among the Company0s affiliates* 9here the Company ele ts to use the Opt,out appro(al pro ess' the Company shall wait %C,days (or in its dis retion a longer period of time) after gi(ing ustomers su h noti e and an opportunity to Opt,out !efore assuming ustomer appro(al to use' dis lose' or permit a ess to CPNI* In all e(ents' the Company shall notify ustomers as to the appli a!le waiting period for a response !efore appro(al is assumed* If the Company uses an ele troni form of notifi ation' then the waiting period shall !egin to run from the date on whi h the notifi ation was sent If the Company sends notifi ation !y mail' then the waiting period shall !egin to run on the third day following the date that the notifi ation was mailed* If the Company uses Opt,out notifi ation' then the Company will pro(ide noti es to its ustomers e(ery two years* If the Company uses e,mail to pro(ide Opt,out noti es' then it will omply with the following federal re+uirements' in addition to the re+uirements generally appli a!le to notifi ation/ #* The Company will o!tain e.press' (erifia!le' prior appro(al from onsumers to send noti es (ia e,mail regarding their ser(i e in general' or CPNI in parti ularThe Company will allow ustomers to reply dire tly to e,mails ontaining CPNI noti es in order to Opt,outIf an Opt,out e,mail noti e is returned to the Company as undeli(era!le' then it will !e sent to the ustomer in another form !efore the Company will onsider the ustomer to ha(e re ei(ed noti eThe Company will ensure that the su!1e t line of e,mail messages ontaining CPNI noti es will identify learly and a urately the su!1e t matter of the e,mailand

4*

%*

&*

?*

The Company will make a(aila!le to e(ery ustomer a method to Opt,out that is of no additional ost to the ustomer and that is a(aila!le 4& hours a day' se(en days a week* The Company may satisfy this re+uirement through a om!ination of methods' so long as all ustomers ha(e the a!ility to Opt,out at no ost and are a!le to effe tuate that hoi e whene(er they hoose*

*.

Opt$in !ppro&al

Opt,in appro(al is a method for o!taining ustomer onsent to use' dis lose' or permit a ess to the ustomer:s CPNI* This appro(al method re+uires that the Company o!tain from the ustomer affirmati(e' e.press onsent allowing the re+uested CPNI usage' dis losure' or a ess after the ustomer is pro(ided appropriate notifi ation of the Company0s re+uest onsistent with appli a!le )ederal regulations as refle ted in these Operating Guidelines* The Company may pro(ide notifi ation to o!tain Opt,in appro(al through oral' written' or ele troni methods* The ontents of any su h notifi ation must omply with the standards of 3e tion I5*C' a!o(e* .. One$Time se of CPNI

The Company may use oral noti e to o!tain limited' one,time use of CPNI for in!ound and out!ound ustomer telephone onta ts for the duration of the all' regardless of whether the Company uses Opt,out or Opt,in appro(al !ased on the nature of the onta t* The ontents of any su h notifi ation must omply with the re+uirements of 3e tion I5*C' a!o(e' e. ept that the Company may omit any of the following noti e pro(isions if not rele(ant to the limited use for whi h the Company seeks CPNI/ #* The Company need not ad(ise ustomers that if they ha(e opted,out pre(iously' no a tion is needed to maintain the Opt,out ele tionIf the Company0s limited CPNI usage will not result in use !y' or dis losure to' an affiliate or third party' then the Company need not ad(ise ustomers that the Company may share their CPNI with the Company0s affiliates or third parties and need not name those entities' The Company need not dis lose the means !y whi h a ustomer an deny or withdraw future a ess to CPNI' !ut the Company must then e.plain to ustomers that the s ope of the appro(al the Company seeks is limited to one, time use- and If the Company ommuni ates learly that the ustomer an deny a ess to his CPNI for the all' then the Company may omit dis losure of the pre ise steps a ustomer must take in order to grant or deny a ess to CPNI*

4*

%*

&*

). !.

Company "afeguards for se of CPNI. !ppro&al "ystem

The Company shall implement a system !y whi h the status of a ustomer:s CPNI appro(al an !e learly esta!lished prior to the use of that ustomer0s CPNI* #. Training

The Company shall train its personnel as to when they are and are not authori=ed to use CPNI' and the Company shall ha(e an e.press dis iplinary pro ess in pla e for non, omplian e with the Company0s safeguards for use of CPNI* C. CPNI Coordinator

The Company shall appoint a CPNI Coordinator who will super(ise implementation and adheren e to these Operating Guidelines* -. Records

The Company shall maintain a re ord' ele troni ally or in some other manner' of its own and its affiliates: sales and marketing ampaigns that use its ustomers: CPNI* The Company shall maintain a re ord of all instan es where CPNI was dis losed or pro(ided to third parties' or where third parties were allowed a ess to CPNI* This re ord shall in lude a des ription of ea h ampaign' the spe ifi CPNI that was used in the ampaign' and what produ ts and ser(i es were offered as a part of the ampaign* The Company shall retain the re ord for a minimum of one year* *. "uper&ision of Compliance

The Company shall esta!lish a super(isory re(iew pro ess regarding its omplian e with federal regulations regarding out!ound marketing situations and maintain re ords of its omplian e for at least one year* 3ales personnel shall o!tain super(isory appro(al of any proposed out!ound marketing re+uest for ustomer appro(al* .. Compliance Certification

"n offi er' as an agent of the Company' shall sign a omplian e ertifi ate on an annual !asis stating that the offi er has personal knowledge that the Company has esta!lished operating pro edures that are ade+uate to ensure omplian e with federal CPNI regulations* The Company shall in lude with the ertifi ation a statement e.plaining how the Company0s operating pro edures ensure that it is or is not in omplian e with the rules in this su!part* "dditionally' the Company shall in lude with its ertifi ation an e.planation of any a tions taken against data !rokers and a summary of all ustomer omplaints re ei(ed in the past year on erning the unauthori=ed release of CPNI* The Company shall make this filing annually with the 2nfor ement Eureau of the )CC on or !efore 7ar h # in 2E 6o ket No* C@F%@' for data pertaining to the pre(ious alendar year* G. Notice of Non$Compliance

The Company shall pro(ide to the )CC written noti e within fi(e !usiness days of any instan e where the Opt,out me hanisms do not work properly' to su h a degree that onsumers: ina!ility to Opt,out is more than an anomaly* The noti e shall !e in the form of a letter' and will in lude the Company0s name' a des ription of the Opt,out me hanism(s) used' the pro!lem(s) e.perien ed' the remedy proposed and when the Company will<did implement it' whether the rele(ant state ommission(s) has !een notified and whether it has taken any a tion' a opy of the noti e pro(ided to ustomers' and onta t information* The Company shall pro(ide su h noti e e(en if the Company offers other methods !y whi h onsumers may Opt,out' and only one of those methods was affe ted* )I. Company "afeguards on the -isclosure of CPNI

!.

"afeguarding CPNI

The Company shall take reasona!le measures to dis o(er and prote t against attempts to gain unauthori=ed a ess to CPNI* The Company shall properly authenti ate a ustomer prior to dis losing CPNI !ased on ustomer,initiated telephone onta t' online a ount a ess' or an in, store (isit* #* Telephone a ess to CPNI

The Company may only dis lose all detail information o(er the telephone' !ased on ustomer,initiated telephone onta t' if the ustomer first pro(ides the arrier with a password' as des ri!ed in paragraph 5I*E' !elow' that is not prompted !y the arrier asking for readily a(aila!le !iographi al information' or a ount information* If the ustomer does not pro(ide a password' the Company may only dis lose all detail information !y sending it to the ustomer:s address of re ord' or !y alling the ustomer at the telephone num!er of re ord* If the ustomer is a!le to pro(ide all detail information to the Company during a ustomer,initiated all without the Company:s assistan e' then the Company may dis uss the all detail information pro(ided !y the ustomer* 4* In,store a ess to CPNI

The Company may dis lose CPNI to a ustomer who' at the Company:s retail lo ation' first presents to the Company or its agent a (alid photo I6 mat hing the ustomer:s a ount information* #. *sta%lishment of a Password and #ack$up !uthentication /ethods for Lost or .orgotten Passwords

To esta!lish a password' the Company shall authenti ate the ustomer without the use of readily a(aila!le !iographi al information' or a ount information* The Company may reate a !a k,up ustomer authenti ation method in the e(ent of a lost or forgotten password' !ut the Company0s !a k,up ustomer authenti ation method shall not prompt the ustomer for readily a(aila!le !iographi al information' or a ount information* If a ustomer annot pro(ide the orre t password or the orre t response for the !a k,up ustomer authenti ation method' the ustomer must esta!lish a new password as des ri!ed in this paragraph* C. Notification of account changes

The Company shall notify ustomers immediately whene(er a password' ustomer response to a !a k,up means of authenti ation for lost or forgotten passwords' online a ount' or address of re ord is reated or hanged* This notifi ation is not re+uired when the ustomer initiates ser(i e' in luding the sele tion of a password at ser(i e initiation* This notifi ation may !e through a Company,originated (oi email or te.t message to the telephone num!er of re ord' or !y mail to the address of re ord' and must not re(eal the hanged information or !e sent to the new a ount information* -. #usiness customer e0emption

The Company may !ind itself ontra tually to authenti ation regimes other than those des ri!ed in this 3e tion 5I for ser(i es it pro(ides to its !usiness ustomers that ha(e !oth a dedi ated a ount representati(e and a ontra t that spe ifi ally addresses the Company0s prote tion of CPNI*

*.

-efinitions

The following definitions of ertain terms used in this 3e tion 5I shall go(ern the implementation and interpretation of the re+uirements of this 3e tion 5I* !ccount information " ount information shall mean that information that is spe ifi ally onne ted to the ustomer0s ser(i e relationship with the arrier' in luding su h things as an a ount num!er or any omponent thereof' the telephone num!er asso iated with the a ount' or the !ill0s amount* !ddress of record "n address of re ord' whether postal or ele troni ' shall mean an address that the Company has asso iated with the ustomer0s a ount for at least %C days* Call detail information Call detail information shall mean any information that pertains to the transmission of spe ifi telephone alls' in luding' for out!ound alls' the num!er alled' and the time' lo ation' or duration of any all and' for in!ound alls' the num!er from whi h the all was pla ed' and the time' lo ation' or duration of any all* Readily a&aila%le %iographical information 8eadily a(aila!le !iographi al information shall mean information drawn from the ustomer0s life history and in ludes su h things as the ustomer0s so ial se urity num!er' or the last four digits of that num!er- mother0s maiden name- home address- or date of !irth* Telephone num%er of record " telephone num!er of re ord shall mean the telephone num!er asso iated with the underlying ser(i e' not the telephone num!er supplied as a ustomer0s onta t information* )alid photo I" (alid photo I6 shall mean a go(ernment,issued means of personal identifi ation with a photograph su h as a dri(er0s li ense' passport' or ompara!le I6 that is not e.pired* )II. Notification of CPNI "ecurity #reaches !. Notification to Law *nforcement

The Company shall notify law enfor ement of a !rea h of its ustomers: CPNI as pro(ided in this 3e tion 5II* The Company shall not notify its ustomers or dis lose the !rea h pu!li ly' whether (oluntarily or under state or lo al law or these rules' until it has ompleted the pro ess of notifying law enfor ement pursuant to 3e tion 5II*"*

"s soon as pra ti a!le' and in no e(ent later than se(en (A) !usiness days' after reasona!le determination of the !rea h' the Company shall ele troni ally notify the Dnited 3tates 3e ret 3er(i e (D333) and the )ederal Eureau of In(estigation ()EI) through a entral reporting fa ility* The internet link to the reporting fa ility that shall !e used !y the Company shall !e that maintained !y the )CC at http'((www.fcc.gov(eb(cpni. Notwithstanding any state law to the ontrary' the Company shall not notify ustomers or dis lose the !rea h to the pu!li until A full !usiness days ha(e passed after notifi ation to the D333 and the )EI e. ept if the Company !elie(es that there is an e.traordinarily urgent need to notify any lass of affe ted ustomers sooner than the se(en (A) !usiness days pro(ided for in 3e tion 5II*"' in order to a(oid immediate and irrepara!le harm' the Company shall so indi ate in its notifi ation and may pro eed to immediately notify its affe ted ustomers only after onsultation with the rele(ant in(estigating agen y* The Company shall ooperate with the rele(ant in(estigating agen y:s re+uest to minimi=e any ad(erse effe ts of su h ustomer notifi ation* If the rele(ant in(estigating agen y determines that pu!li dis losure or noti e to ustomers would impede or ompromise an ongoing or potential riminal in(estigation or national se urity' su h agen y may dire t the Company not to so dis lose or notify for an initial period of up to %C days* 3u h period may !e e.tended !y the agen y as reasona!ly ne essary in the 1udgment of the agen y* If su h dire tion is gi(en' the agen y shall notify the Company when it appears that pu!li dis losure or noti e to affe ted ustomers will no longer impede or ompromise a riminal in(estigation or national se urity* The agen y shall pro(ide in writing its initial dire tion to the Company' any su!se+uent e.tension' and any notifi ation that noti e will no longer impede or ompromise a riminal in(estigation or national se urity and su h writings shall !e ontemporaneously logged on the same reporting fa ility that ontains re ords of notifi ations filed !y the Company* #. Customer Notification

"fter the Company has ompleted the pro ess of notifying law enfor ement pursuant to 3e tion 5II*"' the Company shall notify its ustomers of a !rea h of those ustomers: CPNI* C. Recordkeeping

The Company shall maintain a re ord' ele troni ally or in some other manner' of any !rea hes dis o(ered' notifi ations made to the D333 and the )EI pursuant to 3e tion 5II*"' and notifi ations made to ustomers pursuant to 3e tion 5II*E* The re ord shall in lude' if a(aila!le' dates of dis o(ery and notifi ation' a detailed des ription of the CPNI that was the su!1e t of the !rea h' and the ir umstan es of the !rea h* The Company shall retain the re ord for a minimum of 4 years* -. -efinitions

"s used in this se tion' a !rea h has o urred when a person' without authori=ation or e. eeding authori=ation' has intentionally gained a ess to' used' or dis losed CPNI*

GGG