VoiceCentral is committed to maintaining the privacy of its customers. VoiceCentral 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 VoiceCentral offers to Customer.
In this section, VoiceCentral describes what information VoiceCentral protects and how it is protected.
CPNI PROTECTIONS
As a customer of VoiceCentral Services, Customer has the right, and VoiceCentral 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.
APPROVAL
From time to time, VoiceCentral would like to use the CPNI information it has on file to provide Customer with information about VoiceCentral’s communications-related products and Services or special promotions. VoiceCentral’s use of CPNI may also enhance its ability to offer products and Services tailored to Customer’s specific needs. Accordingly, VoiceCentral would like Customer’s approval so that VoiceCentral may use this CPNI to let Customer know about communications-related Services other than those to which Customer currently subscribes that VoiceCentral 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 VOICECENTRAL MAY USE AND DISCLOSE CPNI AS DESCRIBED HEREIN.
However, Customer does have the right to restrict VoiceCentral’s use of Customer’s CPNI. CUSTOMER MAY DENY OR WITHDRAW VOICECENTRAL’S RIGHT TO USE CUSTOMER’S CPNI AT ANY TIME BY CALLING 908-851-0444. If Customer denies or restricts its approval for VoiceCentral to use Customer’s CPNI, Customer will suffer no effect, now or in the future, on how VoiceCentral 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, VoiceCentral will want to share Customer’s CPNI with its independent contractors and joint venture partners in order to provide Customer with information about VoiceCentral’s communications-related products and Services or special promotions. Prior to sharing Customer’s CPNI with its independent contractors or joint venture partners, VoiceCentral will obtain written permission from Customer to do so.
CUSTOMER AUTHENTICATION
Federal privacy rules require VoiceCentral to authenticate the identity of its customer prior to disclosing CPNI. Customers calling VoiceCentral can discuss their Services and billings with a VoiceCentral representative once that representative has verified the caller’s identity. There are three methods by which VoiceCentral 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, VoiceCentral will ask the Customer a series of questions known only to the Customer and VoiceCentral 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
VoiceCentral 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, VoiceCentral 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, VoiceCentral 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
VoiceCentral may disclose CPNI in the following circumstances:
PROTECTING CPNI
VoiceCentral uses numerous methods to protect Customer’s CPNI. This includes software enhancements that identify whether Customer has approved use of its CPNI. Further, all VoiceCentral 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 VoiceCentral supervisory committee to ensure that all such campaigns comply with applicable CPNI rules.
VoiceCentral 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. VoiceCentral also keeps records of all instances in which CPNI is disclosed to third parties or where third parties were allowed access to Customer CPNI.
VoiceCentral 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 VoiceCentral employee will result in disciplinary action against that employee as set-forth in VoiceCentral’s Employee Manual.
BREACH OF CPNI PRIVACY
In the event VoiceCentral experiences a privacy breach and CPNI is disclosed to unauthorized persons, federal rules require VoiceCentral to report such breaches to law enforcement. Specifically, VoiceCentral 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. VoiceCentral 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, VoiceCentral is required to maintain records of any discovered breaches, the date that VoiceCentral 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. VoiceCentral will retain these records for a period of not less than two (2) years.
NOTIFICATION OF CHANGES TO THIS POLICY
If VoiceCentral changes this CPNI Policy, VoiceCentral will post those changes on https://www.voicecentral.com or in other places VoiceCentral deems appropriate, so that Customer can be aware of what information VoiceCentral collects, how VoiceCentral uses it, and under what circumstances, if any, VoiceCentral disclose it. If Customer decides to continue receiving its Services after VoiceCentral makes any changes to this the CPNI Policy, Customer shall be deemed to have given express consent to the changes in the revised policy.