Customer Proprietary Network Information Policy
eSquared is committed to maintaining the privacy of its customers. eSquared 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 eSquared offers to Customer.
In this section, eSquared describes what information eSquared protects and how it is protected.
As a customer of eSquared Services, Customer has the right, and eSquared 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, eSquared would like to use the CPNI information it has on file to provide Customer with information about eSquared’s communications-related products and Services or special promotions. eSquared’s use of CPNI may also enhance its ability to offer products and Services tailored to Customer’s specific needs. Accordingly, eSquared would like Customer’s approval so that eSquared may use this CPNI to let Customer know about communications-related Services other than those to which Customer currently subscribes that eSquared 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 ESQUARED MAY USE AND DISCLOSE CPNI AS DESCRIBED HEREIN.
However, Customer does have the right to restrict eSquared’s use of Customer’s CPNI. CUSTOMER MAY DENY OR WITHDRAW ESQUARED’S RIGHT TO USE CUSTOMER’S CPNI AT ANY TIME BY CALLING 877-371-3222 or emailing firstname.lastname@example.org. If Customer denies or restricts its approval for eSquared to use Customer’s CPNI, Customer will suffer no effect, now or in the future, on how eSquared 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, eSquared will want to share Customer’s CPNI with its independent contractors and joint venture partners in order to provide Customer with information about eSquared’s communications-related products and Services or special promotions. Prior to sharing Customer’s CPNI with its independent contractors or joint venture partners, eSquared will obtain written permission from Customer to do so.
Federal privacy rules require eSquared to authenticate the identity of its customer prior to disclosing CPNI. Customers calling eSquared can discuss their Services and billings with an eSquared representative once that representative has verified the caller’s identity. There are three methods by which eSquared 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 of record.
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, eSquared will ask the Customer a series of questions known only to the Customer and eSquared in order to authenticate the Customer. In such an instance, the Customer will then establish a new password/PIN associated with their account.
NOTIFICATIONS OF CERTAIN ACCOUNT CHANGES
eSquared will be notifying Customer of certain account changes. For example, whenever an online account is created or changed, or a password or other form of authentication (such as a “secret question and answer”) is created or changed, eSquared will notify the account holder. Additionally, after an account has been established, when a Customer’s address (whether postal or e-mail) changes or is added to an account, eSquared will send a notification. These notifications may be sent to a postal or e-mail address, or by telephone, voicemail or text message.
DISCLOSURE OF CPNI
eSquared may disclose CPNI in the following circumstances:
- When the Customer has approved use of its CPNI for eSquared or eSquared and its joint venture partners and independent contractors (as the case may be) sales or marketing purposes.
- When disclosure is required by law or court order.
- To protect the rights and property of eSquared or to protect Customer and other carriers from fraudulent, abusive, or unlawful use of Services.
- When a carrier requests to know whether Customer has a preferred interexchange carrier (PIC) freeze on its account.
- For directory listing Services.
- To provide the Services to the Customer, including assisting Customer with troubles associated with its Services.
- To bill the Customer for Services.
eSquared uses numerous methods to protect Customer’s CPNI. This includes software enhancements that identify whether Customer has approved use of its CPNI. Further, all eSquared 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 eSquared supervisory committee to ensure that all such campaigns comply with applicable CPNI rules.
eSquared 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. eSquared also keeps records of all instances in which CPNI is disclosed to third parties or where third parties were allowed access to Customer CPNI.
eSquared 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 eSquared employee will result in disciplinary action against that employee as set-forth in eSquared’s Employee Manual.
BREACH OF CPNI PRIVACY
In the event eSquared experiences a privacy breach and CPNI is disclosed to unauthorized persons, federal rules require eSquared to report such breaches to law enforcement. Specifically, eSquared 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. eSquared 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, eSquared is required to maintain records of any discovered breaches, the date that eSquared 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. eSquared will retain these records for a period of not less than two (2) years.
NOTIFICATION OF CHANGES TO THIS POLICY
If eSquared changes this CPNI Policy, eSquared will post provide written notice to Customer so that Customer can be aware of what information eSquared collects, how eSquared uses it, and under what circumstances, if any, eSquared disclose it. If Customer decides to continue receiving its Services after eSquared makes any changes to this the CPNI Policy, Customer shall be deemed to have given express consent to the changes in the revised policy.