JuJu

Bell LLC

Annual CPNI Certification
47 C.F.R. 64.2009
EB Docket No. 06-36

Annual 64.2009(e) CPNI Certification for 2016 covering the prior calendar year 2015

1. COMPANY NAME: JuJu Bell LLC
2. DATE FILED: February 25, 2016
3. FORM 499 FILER ID: 830182
4. NAME OF SIGNATORY: Paresh Rana
5. TITLE: Principal

Statement explaining CPNI procedures:

JuJu Bell LLC provides retail interconnected VoIP services. Because JuJu Bell LLC may access, use, or store
CPNI when providing these services, the company undertakes the following outlined steps to protect CPNI
from unauthorized access or misuse.

(a) Telecommunications carriers must implement a system by which the status of a customer's
CPNI approval can be clearly established prior to the use of CPNI.

It is the policy of JuJu Bell LLC 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, agents, and subcontractors) occurs
only if it is necessary to conduct a legitimate business activity related to the services already provided by
JuJu Bell LLC to the customer; or new services requested by the customer. If JuJu Bell LLC 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 customers consent prior to using or sharing CPNI.

JuJu Bell LLC prohibits the release of CPNI based upon a customer-initiated telephone call except under
the following circumstances.
When the customer has pre-established a password
When the information requested by the customer is to be sent to the customer's email address on record
When JuJu Bell LLC calls the customer's telephone number on record and discusses the information with
the party initially identified by customer when service was initiated.

Password Authentication Procedures
To establish a password, JuJu Bell LLC authenticates the identity of the customer without the use of readily
available biographical or account information. The client may create a back up customer identification
method in the event a customer misplaces or forgets a password, but such alternative customer
authentication will not depend on readily available biographical or account information. If a customer
cannot provide the correct password or the correct response for the back up customer authentication
method, the customer must establish a new password.

Account Change Notification

JuJu Bell LLC notifies customers immediately of any account changes, including address of record,
authentication, and password related changes.

Disclosure to Business Customers
JuJu Bell LLC may negotiate alternative authentication procedures for services that are provided to
business customers that have a dedicated account representative and a contract that specifically
addresses the protection of CPNI.


(b) Telecommunications carriers must train their personnel as to when they are and are not
authorized to use CPNI, and carriers must have an express disciplinary process in place.

All employees and subcontractors of JuJu Bell LLC are trained as to when they are, and are not, authorized
to use CPNI. Through this training, JuJu Bell LLC has informed its employees, agents, and subcontractors
that it considers compliance with the Communications Act and FCC Rules regarding the use, disclosure,
and access to CPNI to be imperative to their retainment at JuJu Bell LLC.

Third Party Use of CPNI
To safeguard CPNI, prior to allowing joint ventures or independent contractors access to customers
individually identifiable CPNI, JuJu Bell LLC requires all such third parties to enter into a confidentiality
agreement that ensures compliance with this Statement of Policy and JuJu Bell LLC requires all outside
agents to acknowledge and certify that they may only use CPNI for the purpose for which that information
has been provided.

JuJu Bell LLC does not engage in selling, marketing, licensing, or lending CPNI information to third parties.

Violation by company employees, agents, or subcontractors of such CPNI requirements will lead to
disciplinary action (including remedial training, reprimands, unfavorable performance reviews, probation,
and termination), depending upon the circumstances of the violation (including the severity of the
violation, whether the violation 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).


(c) All carriers shall maintain a record, electronically or in some other manner, of their own and
their affiliates' sales and marketing campaigns that use their customers' CPNI. All carriers shall
maintain a record of all instances where CPNI was disclosed or provided to third parties, or where
third parties were allowed access to CPNI. The record must include a description of each campaign,
the specific CPNI that was used in the campaign, and what products and services were offered as a
part of the campaign. Carriers shall retain the record for a minimum of one year.

At this time JuJu Bell LLC does not engage in sales and marketing campaigns. JuJu Bell LLC provides a
boutique personalized VoIP service to businesses and 100% of its clients have and continue to be retained
through word of mouth referrals. If, in the future, JuJu Bell uses CPNI in marketing campaigns, the
company will maintain a record of all sales and marketing campaigns that use the 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.


JuJu Bell LLC will also implement a system to obtain prior approval and informed consent from its
customers in accordance with the CPNI Rules. This system will allow for the status of a customers CPNI
approval to be clearly established prior to the use of CPNI.

Prior to commencement of a sales or marketing campaign that utilizes CPNI, JuJu Bell LLC will establish
the status of a customers CPNI approval. The following sets forth the procedure that will be followed by
the company:
Prior to any solicitation for customer approval, JuJu Bell LLC will notify customers of their right to
restrict the use of, disclosure of, and access to their CPNI.
JuJu Bell LLC 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 customers approval or disapproval remains in effect until the customer revokes or limits such
approval or disapproval.
Records of approvals are maintained for a minimum of one year.
JuJu Bell LLC provides individual notice to customers when soliciting approval to use, disclose, or
permit access to CPNI.
The CPNI notices sent by JuJu Bell LLC comply with FCC Rule 64.2008(c).


(d) Telecommunications carriers must establish a supervisory review process regarding carrier
compliance with the rules in this subpart for outbound marketing situations and maintain records
of carrier compliance for a minimum period of one year. Specifically, sales personnel must obtain
supervisory approval of any proposed outbound marketing request for customer approval.

At this time JuJu Bell LLC does not engage in outbound marketing campaigns or marketing initiatives of
any kind. JuJu Bell LLC provides a boutique personalized VoIP service to businesses and 100% of its
clients have and continue to be retained through word of mouth referrals. In addition, JuJu Bell LLC will
establish a supervisory review process regarding compliance with the CPNI rules for outbound marketing
situations and will maintain compliance records for a minimum of one year in the event that it engages in
outbound marketing situations.


(e) A telecommunications carrier must have an officer, as an agent of the carrier, sign and file with
the Commission a compliance certificate on an annual basis. The officer must state in the
certification that he or she has personal knowledge that the company has established operating
procedures that are adequate to ensure compliance with the rules in this subpart. The carrier
must provide a statement accompanying the certificate explaining how its operating procedures
ensure that it is or is not in compliance with the rules in this subpart. In addition, the carrier must
include an explanation of any actions taken against data brokers and a summary of all customer
complaints received in the past year concerning the unauthorized release of CPNI. This filing must
be made annually with the Enforcement Bureau on or before March 1 in EB Docket No. 06-36, for
data pertaining to the previous calendar year.

Pursuant to FCC regulations, JuJu Bell LLC will annually submit to the FCC, prior to March 1, a CPNI
Certification of Compliance and accompanying Statement regarding the companys CPNI policies and
operating procedures. These documents certify that JuJu Bell LLC complied with federal laws and FCC
regulations regarding the protection of CPNI throughout the prior calendar year.


(f) Carriers must provide written notice within five business days to the Commission of any
instance where the opt-out mechanisms do not work properly, to such a degree that consumers'
inability to opt-out is more than an anomaly.

(1) The notice shall be in the form of a letter, and shall include the carrier's name, a description
of the opt-out mechanism(s) used, the problem(s) experienced, the remedy proposed and
when it will be/was implemented, whether the relevant state commission(s) has been
notified and whether it has taken any action, a copy of the notice provided to customers, and
contact information.

(2) Such notice must be submitted even if the carrier offers other methods by which consumers
may opt-out.


JuJu Bell LLC is prepared to provide written notice within five business days to the FCC of any instance
where the opt-out mechanisms do not work properly or to such a degree that consumers inability to opt-
out is more than an anomaly. The notice shall comply with the above stated constraints.


Customer Complaints
JuJu Bell LLC has not received any customer complaints in the past year concerning the unauthorized
release of or access to CPNI.

Actions Taken Against Data Brokers
JuJu Bell LLC has not taken any actions against data brokers before state commissions, state or federal
courts, or the FCC in the past year. JuJu Bell LLC has no information, other than information that has been
publicly reported, regarding processes that pretexters are using to attempt to access CPNI.