STATEMENT OF COMPLLANCE WITH TI{E FCC'S CUSTOMI]R PROPRIETARY NETWORX |NI'ORMATION (CPNI) RIILES

L Fractel, LLCS' operalirg

procedures ensure that Fractel,

CPNI Rules bccause disclosure of. or pe.mining access without obtairring ihe requisire customer approval, excepi as required by iaw, or the exceptions set fonh in 47 L|.S.C. S222, and Subpan U ol Titl 47 oflhe Codc of Federal Regulation! 47 C.F.R {64.2001 throLrgh $64.201l-

LLC is in compliatice with the FCC's to, our customers' CPNI is notallowed

Fraclel. LLC follows industry-standa.d pmclices to pre!'ent unaulhorized acccss to CPNI b) a person other than the subsc.iber or l.ractel, LLC. Electronic fils and databases containing CPNI are nuintaired on conrputcrs thar lre no1 lccessible from thc lntemet or that are on the Comparry's intranr behind lirewalls lhat are regularly monitored and tested for efiecri"-eness. lo additions, such electronic files and darabases may be accessed only by authorizd Company eDployees who have bee, provided a currently effective srrone lons lD and pass*ord (said password is periodically changed).
However, Fradel, LI.C cannot guarantee that these practices will prevent every una lhorjzed atlempt to access, use, or disclose pl.rsollally iderlifiablc irrformation. Therclore

ifan unauthorized disclosure 1{,erc to occur. l.ractel, LLC shali provide notiiication ofrhe
breach within scven (7) days toahe United States Secrr Swice ('USSS") andthe

Federal Bureau oflnvestigalion ("1'Bl") via a cntral rporting tacility accessed tb.rough a

link maifiaiDed by the !'CC at

flaciel, LLC noiifying the

N

shalL wair an additional sven (7) days from jts govemncnr nolice prior 10 atTectd cusromers

!B!-\ti!!r! !q\!.[
ofthe breach.

lpiri

d.

otwithstanding lhe provisions in subparagraph b above, Fractel, LLC shall not wair the additional scvn (7) days to notify its cuslomers ifFractel,l-l,C dtermines there is an inmediate risk of irreparable harm 10 ils customers. Fractel, LLC shall maintain records ofdiscovered breaches for a period of at least rwo (2)

3.

Fractei, LLC has intemal procedurcs ir placc to educate our employees aboul CPNI and rhe disclosure of CPN I as well as the appropriarc systens ro idenriry (he status ofacusromer CPNI approval before the use ofCPNL All employees are trained as ro when they are, and ar not auihorized lo usc CPNI upon employment. Violation ofthese procedures by Company employees will lead to disciplinary action (including remedial training. reprimands. unfavorable performance reviews, probalion, and teminalion), deperding upor thc circumstances oftlc

violation. a. Specifically, Fractel, LLC prohibits its personnel from.eleasing CPNI bascd upon a customer-initiated telephone call excepi undr the follo*'ing three (3) cicumstances:

i.

When lhe customer lras pre-established a password.

wlrcn the information rcquested by the cusiomer is to be

address ofrecord, or discussee the

sent to the customor's

VleD Fraotl, LLC calls the customer's telephoDe numbqs ofrccord ard infom.liotr vrith fte party initiaUy identified try customI when
service was initiated.

a rgcord ofits own aad its affiliat$' sales aad oa.ketfug carnpaigns rhai lracfel, LLC'S customers' CPM. The record will includ a dscription ofeach campaig.L the lpecific CPNI tlnt was used in the campaign, aad whai products and servicis werc offerd as part ofthe campaign. This information regarding sales snal msrtcting csmpaigns shall be maintsiled

Fractel, LLC maintains

I]se

for

amiri

lm priod oftwo (2) years.