ONS-Telecom, LLC Statement of CPNI Procedures and Compliance Certification for 2014 Coverin Prior !

ear 201" #$ %oc&et 0'-"'

ONS-Telecom, LLC does not use or permit access to CPNI to market any telecommunications or non-telecommunications services. Our marketing efforts do not re uire t!e use of any client-specific information. S!ould "e elect to use CPNI in any future marketing efforts, "e "ill follo" t!e applica#le rules set fort! in $% C&' Su#part (, including, if necessary, t!e institution of operational procedures to ensure t!at notification is provided and customer approval is o#tained #efore CPNI is used or disclosed. )e !ave in place specific processes to safeguard our customers* CPNI from improper use or disclosure #y its employees and attempts #y t!ird parties to gain unaut!ori+ed access to CPNI and call detail information. Customers are contacted at t!e telep!one num#er of record or email address of record to follo" up on information or service in uiries. ONSTelecom !as instituted training procedures and a corresponding disciplinary process to ensure t!at its personnel understand and comply "it! restrictions regarding t!e use and disclosure of, and access to, CPNI. )e do not provide call detail information over t!e telep!one. ,ll customer service personnel are trained not to discuss call detail information unless calling party can identify t!e call detail related to t!eir in uiry. Customers -in#ound callers into our Customer Service Center. are re uired to give t!e call detail information to t!e Customer Service 'epresentatives as "ell as t!eir names prior to providing any assistance or information. )e only disclose t!e information re uested t!at comes directly from t!e #illed information. T!e customer must !ave t!e call detail/#ill "!en calling and must #e t!e name on t!e account. To date, ONS-Telecom !as never disclosed any CPNI to a t!ird party, #ut s!ould t!is occur, records "ill #e maintained in accordance "it! &CC rules. )e !ave instituted aut!entication procedures to safeguard t!e disclosure of CPNI on-line "!ic! do not re uire t!e use of readily availa#le #iograp!ical information or account information as defined #y t!e &CC. )e aut!enticate customers #y providing a uni ue system generated user I0 and pass"ord. Customer on-line access is restricted to one user using t!e service initiation e-mail address of record for communications purposes. ONSTelecom !as esta#lis!ed a #ack up aut!entication met!od for lost or stolen pass"ords t!at does not involve readily availa#le #iograp!ical information or account information. If a pass"ord is lost or forgotten, a system generated ne" (ser I0 and pass"ord is sent electronically to t!e customer e-mail address of record. (nless t!e appropriate pass"ord is provided, "e do not allo" on-line access to t!e client*s data.

ONS-Telecom, LLC Page 1 of 2

)e !ave procedures in place to notify customers "!enever a pass"ord, aut!entication for lost or forgotten pass"ords, online account, or address of record is created or c!anged "it!out revealing t!e c!anged information. )e do not send t!e notification to t!e ne" account information. , voicemail is left "it! t!e p!one num#er of record. )e do not !ave any retail locations and t!erefore do not disclose CPNI in-store. )e !ave not !ad any attempts #y t!ird parties to gain unaut!ori+ed access to client information and t!erefore !ave no records to date of suc! #reac!es. 3o"ever, "e !ave procedures in place to notify la" enforcement in t!e event of a #reac! of customers* CPNI and to ensure t!at customers are not notified of t!e #reac! #efore t!e time period set fort! in t!e &CC*s rules, or, if applica#le, "!en so aut!ori+ed #y la" enforcement. )e !ave not taken any actions against data #rokers in t!e last year. )e !ave not received any customer complaints a#out t!e unaut!ori+ed release of CPNI or t!e unaut!ori+ed disclosure of CPNI in calendar year 2415. )e !ave not developed any information "it! respect to t!e processes prete6ters may use to attempt to access CPNI.

ONS-Telecom, LLC Page 2 of 2