Customer Proprietary Network Information (CPNI) Policy

Introduction

In accordance with Section 222 of the Communications Act and the Federal Communications Commission’s ("FCC") CPNI Rules (47 C.F.R. § 64.2001, et seq.), OnAir Telecom ("OnAir Telecom" or the "Company") has established the policies and procedures outlined below for collecting, accessing, using, and storing Customer Proprietary Network Information ("CPNI"). OnAir Telecom provides telecommunications services to retail customers. Because OnAir Telecom may collect, access, use, or store CPNI when providing these services, the Company undertakes the steps outlined in this Policy Statement to protect CPNI from unauthorized access or misuse.

Definition of CPNI

Under federal law, CPNI is certain customer information obtained by a telecommunications provider during the course of providing telecommunications and related services (including interconnected VoIP) to a customer. This includes information relating 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.

Examples of CPNI include information typically available from telephone-related details on a monthly bill, such as the types of services purchased by a customer, numbers called, duration of calls, directory assistance charges, and calling patterns. CPNI does not include names, addresses, and telephone numbers of customers, because that information is considered subscriber list information under applicable law.

Use of CPNI

It is the policy of OnAir Telecom not to use CPNI for any activity other than as permitted by applicable law. Any disclosure of CPNI to other parties (such as affiliates, vendors, and agents) occurs only if it is necessary to conduct a legitimate business activity related to the services already provided by OnAir Telecom to the customer. If OnAir Telecom is not required by law to disclose CPNI, or if the intended use is not otherwise permitted under FCC rules, the Company will first obtain the customer’s consent prior to using or sharing CPNI.

OnAir Telecom follows industry-standard practices to prevent unauthorized access to CPNI by a person other than the subscriber or the Company. However, OnAir Telecom cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose personally identifiable information.

CPNI Notification

OnAir Telecom notifies customers immediately of any account changes, including address of record, authentication, online account, and password-related changes.

Employee Training Policies

All employees of OnAir Telecom are trained as to when they are, and are not, authorized to use CPNI. Specifically, OnAir Telecom prohibits its personnel from releasing CPNI based upon a customer-initiated telephone call except under the following three (3) circumstances:

• When the customer has pre-established a password and confirms that password when contacting OnAir Telecom about CPNI-related matters;
• When the information requested by the customer is to be sent to the customer’s address of record; or
• When OnAir Telecom calls the customer’s telephone number of record and discusses the information with the party initially identified by the customer when service was initiated.

Disclosure to Business Customers

OnAir Telecom may negotiate alternative authentication and CPNI procedures for services that the Company provides to business customers that have a dedicated account representative and a contract that specifically addresses the protection of the business customer’s CPNI.

Disciplinary Procedures

OnAir Telecom has informed its employees and agents that it considers compliance with the Communications Act and FCC rules regarding the use, disclosure, and access to CPNI to be very important. Violation by company employees or agents of such CPNI requirements will lead to disciplinary action (including remedial training, reprimands, unfavorable performance reviews, probation, and/or termination), depending upon the circumstances of the violation — including its severity, whether it was a first-time or repeat violation, whether appropriate guidance was sought or received from a supervisor, and the extent to which the violation was or was not deliberate or malicious.

Use of CPNI in Sales and Marketing Campaigns

OnAir Telecom does not use CPNI in its marketing campaigns. However, if OnAir Telecom does use CPNI in marketing campaigns, the Company will maintain a record of all sales and marketing campaigns that use CPNI. The record will include a description of each campaign, the specific CPNI that was used in the campaign, and what products and services were offered as part of the campaign.

OnAir Telecom will also implement a system to obtain prior approval and informed consent from its customers in accordance with the Commission’s CPNI rules. This system will allow the status of a customer’s CPNI approval to be clearly established prior to the use of CPNI. Prior to commencing a sales or marketing campaign that utilizes CPNI, OnAir Telecom will establish the status of a customer’s CPNI approval according to the following procedure:

• Prior to any solicitation for customer approval, OnAir Telecom will notify customers of their right to restrict the use of, disclosure of, and access to their CPNI.
• OnAir Telecom will use opt-in approval for any instance in which the Company must obtain customer approval prior to using, disclosing, or permitting access to CPNI.
• A customer’s approval or disapproval remains in effect until the customer affirmatively revokes or limits such approval or disapproval.
• Records of approvals are maintained for at least two years.

FCC Notification

OnAir Telecom is prepared to provide written notice within five (5) business days to the FCC of any instance where the opt-in mechanisms do not work properly, or to such a degree that consumers’ inability to opt in is more than an anomaly.

Third Party Use of CPNI

To safeguard CPNI, prior to allowing joint venturers or independent contractors access to customers’ individually identifiable CPNI, OnAir Telecom will require all such third parties to enter into a confidentiality agreement that ensures compliance with this Policy, and OnAir Telecom will also obtain opt-in consent from a customer prior to disclosing the information to such third parties. In addition, OnAir Telecom requires all outside agents to acknowledge and certify that they may only use CPNI for the purpose for which that information has been provided. OnAir Telecom requires express written authorization from the customer prior to dispensing CPNI to new carriers, except as otherwise required by law.

OnAir Telecom does not market or sell CPNI information to any third party.

Law Enforcement Notification of Unauthorized Disclosure

If an unauthorized disclosure of CPNI occurs, OnAir Telecom shall provide notification of the breach within seven (7) days to the United States Secret Service ("USSS") and the Federal Bureau of Investigation ("FBI"). OnAir Telecom shall wait an additional seven (7) days from its government notice prior to notifying the affected customers of the breach. Notwithstanding the above, OnAir Telecom shall not wait the additional seven (7) days to notify its customers if the Company determines there is an immediate risk of irreparable harm to the customers.

OnAir Telecom shall maintain records of discovered breaches for a period of at least two (2) years.

Annual CPNI Certification

Pursuant to FCC regulations, 47 C.F.R. § 64.2009(e), OnAir Telecom will annually submit to the FCC, by March 1st or any subsequently established deadline, a CPNI Certification of Compliance and accompanying Statement regarding the Company’s CPNI policies and operating procedures. These documents certify that OnAir Telecom complied with federal laws and FCC regulations regarding the protection of CPNI throughout the prior calendar year.

Contact Us

For questions about this CPNI Policy, contact us at support@onairtel.com, call 1 866 55 ON AIR (66247), or write to us at 10711 Red Run Blvd, STE 101, Owings Mills, Maryland 21117.