Customer Proprietary Network Information

Eastern Telephone & Technologies, Inc. (“Eastern”) is dedicated and committed to protecting the privacy of our customers. As a customer of Eastern services, our Customer has the right, and Eastern 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 Eastern services, and (2) information contained on Customer’s telephone bill concerning the services our Customers receive. That information, when matched to a 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, types of Service, current telephone charges, local Service billing records, directory assistance charges, usage data, and calling patterns.

APPROVAL

From time to time, Eastern will use the CPNI information it has on file to provide Customer with information about Eastern’s communications-related products and services or special promotions. Eastern’s use of CPNI may also enhance its ability to offer products and services tailored to Customer’s specific needs. Eastern may use this CPNI to let Customer know about communications-related services other than those to which Customer currently subscribes that Eastern believes may be of interest to Customer. Customer’s signature on a service agreement or sales order signifies Customer’s consent that Eastern may use and disclose CPNI as described herein.
However, Customer does have the right to restrict Eastern’s use of Customer’s CPNI. Customer may deny or withdraw Eastern’s right to use customer’s CPNI at any time by advising Eastern by calling 606-432-0043. If Customer denies or restricts its approval for Eastern to use Customer’s CPNI, Customer will suffer no effect, now or in the future, on how Eastern 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, Eastern will want to share Customer’s CPNI with its independent contractors and joint venture partners in order to provide Customer with information about Eastern’s communications-related products and services or special promotions.

CUSTOMER AUTHENTICATION

Federal privacy rules require Eastern to authenticate the identity of its Customer prior to disclosing CPNI. Customers calling Eastern can discuss their services and billings with an Eastern representative once that representative has verified the caller’s identity. There are three methods by which Eastern will conduct Customer authentication:

  1. By having the Customer provide a pre-established password and/or PIN;
  2. By calling the Customer back at the telephone number associated with the services purchased; or
  3. By mailing the requested documents to the Customer’s address or email address of record.

In the event the Customer fails to remember their password and/or PIN, Eastern may ask the Customer a series of questions known only to the Customer and Eastern in order to authenticate the Customer.

NOTIFICATIONS OF CERTAIN ACCOUNT CHANGES

Eastern will notify Customer of certain account changes. For example, after an account has been established, when a Customer’s address (whether postal or e-mail) changes or is added to an account, Eastern will notify Customer. These notifications may be sent to a postal or e-mail address, or by telephone, voicemail or text message.

YOU DO NOT HAVE TO TAKE ANY ACTION UNLESS YOU DENY PERMISSION

You need to respond only if you wish to deny permission to use your information in Eastern marketing plans. Please contact Eastern at 606-432-0043 if you would like to deny or restrict permission for Eastern’s use of your CPNI.

DISCLOSURE OF CPNI

Eastern may disclose CPNI without asking for Customer’s authorization in any of the following circumstances:

  • When disclosure is required by law or court order.
  • To protect the rights and property of Eastern or to protect Customer and other carriers from fraudulent, abusive, or unlawful use of services.
  • For directory listings.
  • To provide Eastern services to the Customer, including assisting Customer with troubles associated with its services.
  • To bill the Customer for services.
  • When Customer has approved use of their CPNI for Eastern, or Eastern’s partners, affiliates, or independent contractors.

PROTECTING CPNI

Eastern uses numerous methods to protect Customer’s CPNI. Eastern employees are trained on how CPNI is to be protected and when it may or may not be disclosed.

Eastern maintains records of its own and its joint venture partners and/or independent contractors (if applicable) sales and marketing campaigns that may utilize Customer CPNI. Eastern also keeps records of instances in which CPNI is disclosed to third parties or where third parties were allowed access to Customer CPNI.

Eastern will not release CPNI during Customer-initiated telephone contact without first authenticating the caller’s identity.

BREACH OF CPNI PRIVACY

In the event Eastern experiences a privacy breach and CPNI is disclosed to unauthorized persons, federal rules require Eastern to report such breaches to law enforcement. Specifically, Eastern 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. Eastern 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, Eastern is required to maintain records of any discovered breaches, the date that Eastern 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. Eastern will retain these records for a period of not less than two (2) years.

NOTIFICATION OF CHANGES TO THIS POLICY

If Eastern changes this CPNI Policy, Eastern will post those changes on www.ettky.com/terms-conditions-policies or in other places Eastern deems appropriate, so that Customer can be aware of what information Eastern collects, how Eastern uses it, and under what circumstances, if any, Eastern disclose it. If Customer decides to continue receiving its services after Eastern makes any changes to this CPNI Policy, Customer shall be deemed to have given express consent to the changes in the revised policy.