VoIP Dialing is committed to maintaining the privacy of its customers. VoIP Dialing is obliged to provide Customer with protections to certain information about how Customer uses its Services. However, that information can help us customize and improve Services VoIP Dialing offers to Customer.
In this section, VoIP Dialing describes what information VoIP Dialing protects and how it is protected.
As a customer of VoIP Dialing Services, Customer has the right, and VoIP Dialing has a duty, under federal law, to protect the confidentiality of certain types of Services, including: (1) information about the quantity, technical configuration, type, destination, location, and amount of Customer’s use of its Services, and (2) information contained on Customer’s telephone bill concerning the Services Customer receives. That information, when matched to Customer’s name, address, and telephone number is known as "Customer Proprietary Network Information," or "CPNI" for short. Examples of CPNI include information typically available from telephone-related details on Customer’s monthly bill, technical information, type of Service, current telephone charges, long distance and local Service billing records, directory assistance charges, usage data and calling patterns.
From time to time, VoIP Dialing would like to use the CPNI information it has on file to provide Customer with information about VoIP Dialing’ communications-related products and Services or special promotions. VoIP Dialing’ use of CPNI may also enhance its ability to offer products and Services tailored to Customer’s specific needs. Accordingly, VoIP Dialing would like Customer’s approval so that VoIP Dialing may use this CPNI to let Customer know about communications-related Services other than those to which Customer currently subscribes that VoIP Dialing believes may be of interest to Customer. IF CUSTOMER APPROVES, CUSTOMER DOES NOT HAVE TO TAKE ANY ACTION; CUSTOMER’S SIGNATURE ON THE SERVICE AGREEMENT SIGNIFIES CUSTOMER’S CONSENT THAT VoIP Dialing MAY USE AND DISCLOSE CPNI AS DESCRIBED HEREIN. However, Customer does have the right to restrict VoIP Dialing’ use of Customer’s CPNI. CUSTOMER MAY DENY OR WITHDRAW VoIP Dialing' RIGHT TO USE CUSTOMER’S CPNI AT ANY TIME BY CALLING 855-834-2546. If Customer denies or restricts its approval for VoIP Dialing to use Customer’s CPNI, Customer will suffer no effect, now or in the future, on how VoIP Dialing provides any Services to which Customer subscribes. Any denial or restriction of Customer’s approval remains valid until Customer’s Services are discontinued or Customer affirmatively revokes or limits such approval or denial. In some instances, VoIP Dialing will want to share Customer’s CPNI with its independent contractors and joint venture partners in order to provide Customer with information about VoIP Dialing’ communications-related products and Services or special promotions. Prior to sharing Customer’s CPNI with its independent contractors or joint venture partners, VoIP Dialing will obtain written permission from Customer to do so.
Federal privacy rules require VoIP Dialing to authenticate the identity of its customer prior to disclosing CPNI. Customers calling VoIP Dialing can discuss their Services and billings with a VoIP Dialing representative once that representative has verified the caller's identity. There are three methods by which VoIP Dialing will conduct Customer authentication:
Passwords and/or PINs may not be any portion of the Customer's social security number, mother's maiden name, amount or telephone number associated with the Customer's account or any pet name. In the event the Customer fails to remember their password and/or PIN, VoIP Dialing will ask the Customer a series of questions known only to the Customer and VoIP Dialing in order to authenticate the Customer. In such an instance, the Customer will then establish a new password/PIN associated with their account.
VoIP Dialing may disclose CPNI in the following circumstances:
VoIP Dialing uses numerous methods to protect Customer’s CPNI. This includes software enhancements that identify whether Customer has approved use of its CPNI. Further, all VoIP Dialing employees are trained on the how CPNI is to be protected and when it may or may not be disclosed. All marketing campaigns are reviewed by a VoIP Dialing supervisory committee to ensure that all such campaigns comply with applicable CPNI rules.
VoIP Dialing maintains records of its own and its joint venture partners and/or independent contractors (if applicable) sales and marketing campaigns that utilize Customer CPNI. Included in this, is a description of the specific CPNI that was used in such sales or marketing campaigns. VoIP Dialing also keeps records of all instances in which CPNI is disclosed to third parties or where third parties were allowed access to Customer CPNI.
VoIP Dialing will not release CPNI during Customer-initiated telephone contact without first authenticating the caller's identity in the manner set-forth herein. Violation of this CPNI policy by any VoIP Dialing employee will result in disciplinary action against that employee as set-forth in VoIP Dialing’ Employee Manual.
In the event VoIP Dialing experiences a privacy breach and CPNI is disclosed to unauthorized persons, federal rules require VoIP Dialing to report such breaches to law enforcement. Specifically, VoIP Dialing will notify law enforcement no later than seven (7) business days after a reasonable determination that such breach has occurred by sending electronic notification through a central reporting facility to the United States Secret Service and the FBI. A link to the reporting facility can be found at: www.fcc.gov/eb/cpni. VoIP Dialing cannot inform Customer of the CPNI breach until at least seven (7) days after notification has been sent to law enforcement, unless the law enforcement agent tells the carrier to postpone disclosure pending investigation. Additionally, VoIP Dialing is required to maintain records of any discovered breaches, the date that VoIP Dialing discovered the breach, the date carriers notified law enforcement and copies of the notifications to law enforcement, a detailed description of the CPNI breach, including the circumstances of the breach, and law enforcement's response (if any) to the reported breach. VoIP Dialing will retain these records for a period of not less than two (2) years.
If VoIP Dialing changes this CPNI Policy, VoIP Dialing will post those changes on www.voipdialing.com/cpni or in other places VoIP Dialing deems appropriate, so that Customer can be aware of what information VoIP Dialing collects, how VoIP Dialing uses it, and under what circumstances, if any, VoIP Dialing disclose it. If Customer decides to continue receiving its Services after VoIP Dialing makes any changes to this the CPNI Policy, Customer shall be deemed to have given express consent to the changes in the revised policy.