Operating Procedure: CNPI Privacy Policy

This privacy policy is to prevent unauthorized disclosure of Customer Proprietary Network Information (CPNI).
See Exhibit A for definitions.

Training Program
All new employees are trained in the type of information that is considered CPNI when they begin. The training
program is as follows:
Within the first 30 days of employment a one-on-one will be scheduled with the new employee and the
VP of Sales & Marketing. The two will review the CPNI Privacy Policy, FCC Guidelines, and discuss any
additional questions the employee may have regarding the policy. The employee will be provided with
written documentation about the rule for his/her records.
During the first February team meeting when all staff are present, the VP of Sales & Marketing will review
the policy and provide any updates as mandated by the FCC for the calendar year.
Each employee will have a written copy of the CPNI privacy policy in his/her employee procedures
manual. An electronic copy will be filed on the company share under FCC Guidelines/Process
Management/CPNI.

Access Authentication
A CPNI Registration Form is completed by the customers primary contact during the contract phase prior to
service installation. See Exhibit B for an example. A copy of the completed CPNI Registration Form will be filed
electronically in the customer folder on the company share. Passwords will be saved in the Business Partner
Master Data card under the General Tab in the Password field.

In order for a customer to retrieve CPNI each employee must first verify the account number and password on
the account. If the customer cannot accurately verify that information, please forward the customer to the VP
of Sales & Marketing for account access authentication.

In the event the customer fails to remember their password, we will ask the customer a series of questions know
only by the customer in order to authenticate themselves. Once validated, the customer will then need to
create a new password to associate with their account. If the customer requires an account password to be
changed we will confirm via email to the primary contact on the account.

Disciplinary Action
Employees are not allowed to distribute CPNI or subscriber lists to anyone outside of the organization and all
documented CPNI is for internal business use only.

Any employee found to have knowingly distributed CPNI will be subject to disciplinary review that will include a
formal written notice to be filled by the VP of Sales & Marketing submitted to the Director of Human Resources.
Discipline will be based upon existing employee disciplinary process as defined by the Employee Handbook.

Breach of Information
If you suspect an attempt for an unknown party to try to gain unauthorized access to CPNI, notify VP of Sales &
Marketing immediately with the date and time of the call and any additional information retrieved during the
call (i.e., callers name, information they were requesting, number that called in from).

If there is a breach or unauthorized access you must report to the VP of Sales & Marketing immediately. This is
time sensitive and you have 7 days to respond via the FCC website

Clear Voice Telecom, Inc. Operating Procedure: Privacy Policy

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 Pursuant to section 64.2011 of the Commission's rules (47 C.F.R. 64.2011), a telecommunications carrier
or interconnected VOIP provider that determines that a person, without authorization or exceeding
authorization, has intentionally gained access to, used, or disclosed CPNI is required to electronically
notify the United States Secret Service and the Federal Bureau of Investigation through a central
reporting facility. That facility is available at https://www.cpnireporting.gov

After a breach the customer primary contact must be notified and an impromptu meeting should be held with
2 business days to discuss how the breach happened and what process must be changed. Any changes in
process will be added to the Privacy Policy as an amendment, dated when has been accepted.

Data Brokers
It is not our policy to engage with data brokers.

Marketing Practices
It is never the practice of Clear Voice Telecom to disclose customer network information to third party or
independent contractors. If a third party is to have access to any customer proprietary information that will be
required to sign a non-disclosure agreement. See as Exhibit C.

It is also not the practice of Clear Voice Telecom to marketing products and services to customers other than
for services they are currently purchasing.

Customer Service Practices

We may from time to time, send out service announcements to subscribers based upon CPNI. For example, we
may send you an e-mail announcement about a maintenance period, a change in operating policies, or new
features of our service. Customers may not opt out of these service-related communications.

Compliance Coordinator
The VP of Sales & Marketing will be the CPNI Compliance coordinator.

Exceptions
If we send out general marketing information or promotions to all of our customers based without customer
specific target then CPNI rules do not apply. Only customers name, address, email address, and phone number
can be used.

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 Exhibit A: CNPI Privacy Policy
Definitions
Customer proprietary network information
The term customer proprietary network information means
information that relates to the quantity, technical configuration, type, destination, location, and
amount of use of a telecommunications service subscribed to by any customer of a
telecommunications carrier, and that is made available to the carrier by the customer solely by
virtue of the carrier-customer relationship; and
information contained in the bills pertaining to telephone exchange service or telephone toll
service received by a customer of a carrier; except that such term does not include subscriber
list information.
Aggregate information
The term aggregate customer information means collective data that relates to a group or category of
services or customers, from which individual customer identities and characteristics have been removed.
Subscriber list information
The term subscriber list information means any information
identifying the listed names of subscribers of a carrier and such subscribers telephone numbers,
addresses, or primary advertising classifications (as such classifications are assigned at the time of the
establishment of such service), or any combination of such listed names, numbers, addresses, or
classifications; and
that the carrier or an affiliate has published, caused to be published, or accepted for publication in any
directory format.
Public safety answering point
The term public safety answering point means a facility that has been designated to receive emergency calls
and route them to emergency service personnel.
Emergency services
The term emergency services means 911 emergency services and emergency notification services.
Emergency notification services
The term emergency notification services means services that notify the public of an emergency.
Emergency support services
The term emergency support services means information or data base management services used in support
of emergency services.

Clear Voice Telecom, Inc. Operating Procedure: Privacy Policy

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 Exhibit B: CNPI Privacy Policy

Clear Voice Telecom, Inc. Operating Procedure: Privacy Policy

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 Exhibit C: CNPI Privacy Policy
CONFIDENTIALITY AND NON-DISCLOSURE AGREEMENT

The Agreement contained herein is made effective as of the ____ day of ___________________
and is made for the benefit of Clear Voice Telecom, Inc., located at 10259 W. Emerald Street, Suite 100, Boise, ID 83704 (CVT) and
____________________________________________
located at ____________________________________________________________________.

For valuable consideration, receipt, and sufficiency of which are hereby acknowledged, the Parties represent, warrant and agree as
follows:

1. THE PARTIES acknowledge and agree that they may be furnished with confidential and proprietary information (Confidential
Information) regarding the business and internal working of the respective companies, including but not limited to, information
relating to the companys financial data and statements, customers and prospective customers, suppliers, research, technical
knowledge, know-how, trade secrets, and all products, memoranda, notes, letters, and other documents which contain or reflect
such information. THE PARTIES further acknowledge that the Confidential Information is a valuable asset to each respective
party. Therefore, THE PARTIES agree 1) to maintain the Confidential Information only in the course of identifying opportunities
to do business with each other. THE PARTIES further agree that it will return all Confidential Information (and all copies thereof)
to the other Party within five (5) days of the other Partys written request.
2. THE PARTIES will use the Confidential Information solely for the purpose of assessing the feasibility of doing business together.
THE PARTIES further agree not to disclose Confidential Information to any third party without the prior expressed written
consent of the other Party.
3. THE PARTIES recognize that the foregoing agreement is of special and unique nature that any breach thereof may cause
irreparable injury to the non-breaching Party which cannot be estimated, determined or adequately compensated and which
may cause the non-breaching Party to lose its competitive edge and goodwill. Therefore, if either of the PARTIES breach this
Agreement in any respect, the on-breaching Party shall be entitled, without any showing of in any respect, the non-breaching
Party shall be entitled, without any showing of actual damages sustained, to immediate restraining orders, injunctions and
other such relief as it may deem necessary to compel the breaching Party to comply with this Agreement.
4. THE PARTIES agree that nothing in this Agreement constitutes a business commitment on the part of either SP or
______________, other than to comply with the other provisions of this Agreement, including but not limited to maintaining the
confidentiality of the Confidential Information.
5. This Agreement contains the entire understanding of THE PARTIES relating to the subject matter hereof. Any representation,
promise or condition not contained herein shall not be binding on either party. Any amendments or modifications to this
Agreement must be in writing and signed by an authorized representative of each party.
6. This Agreement shall be binding upon and inure to the benefit of the parties hereto and their respective successors. This
Agreement, and the rights and obligations hereunder, shall not be assignable or delegable, and any attempt at assignment or
delegation thereof is void.
7. This Agreement shall be controlled by the construed in accordance with the laws of the state of Idaho, without giving effect to
its conflict of laws provisions. The parties agree to submit to the personal jurisdiction of the courts of the state of Idaho.
8. The provisions of this Agreement are severable and the unenforceability of any provision of the Agreement shall not affect the
enforceability of any other provision hereof.
9. In the event that either party is required to retain legal counsel in connection with this Agreement, the prevailing party shall be
entitled to recover its reasonable attorneys fees and other costs for defending such matter.

Executed on the ________ day of _____________________, 2016

Clear Voice Telecom, Inc.

Signed: _______________________ Signed: _______________________

Name: ________________________ Name: ________________________

Title: _________________________ Title: _________________________

Date: _________________________ Date: _________________________

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