CPNI PROTECTIONS (Customer Proprietary Network Information)
Lucid Communications is dedicated and committed to protecting the privacy of our customers. As a customer of Lucid Communications services, our Customer has the right, and Lucid Communications 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 Lucid Communications services, and (2) information contained on Customer’s telephone bill concerning the services our Customers receive. That information, when matched to a 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, types 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, Lucid Communications will use the CPNI information it has on file to provide Customer with information about Lucid Communications communications-related products and services or special promotions. Lucid Communications use of CPNI may also enhance its ability to offer products and services tailored to Customer’s specific needs. Lucid Communications may use this CPNI to let Customer know about communications-related services other than those to which Customer currently subscribes that Lucid Communications believes may be of interest to Customer. Customer’s signature on a service agreement or sales order signifies Customer’s consent that Lucid Communications may use and disclose CPNI as described herein.
However, Customer does have the right to restrict Lucid Communications use of Customer’s CPNI. Customer may deny or withdraw Lucid Communications right to use customer’s CPNI at any time by advising Lucid Communications via email message to [email protected]. If Customer denies or restricts its approval for Lucid Communications to use Customer’s CPNI, Customer will suffer no effect, now or in the future, on how Lucid Communications 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, Lucid Communications will want to share Customer’s CPNI with its independent contractors and joint venture partners in order to provide Customer with information about Lucid Communications communications-related products and services or special promotions.
CUSTOMER AUTHENTICATION
Federal privacy rules require Lucid Communications to authenticate the identity of its Customer prior to disclosing CPNI. Customers calling Lucid Communications can discuss their services and billings with a Lucid Communications representative once that representative has verified the caller’s identity. There are three methods by which Lucid Communications will conduct Customer authentication:
1. By having the Customer provide a pre-established password and/or PIN;
2. By calling the Customer back at the telephone number associated with the services purchased; or
3. By mailing the requested documents to the Customer’s address or email address of record.
In the event the Customer fails to remember their password and/or PIN, Lucid Communications will ask the Customer a series of questions known only to the Customer and Lucid Communications in order to authenticate the Customer.
NOTIFICATIONS OF CERTAIN ACCOUNT CHANGES
Lucid Communications will notify Customer of certain account changes. For example, after an account has been established, when a Customer’s address (whether postal or e-mail) changes or is added to an account, Lucid Communications will notify Customer. These notifications may be sent to a postal or e-mail address, or by telephone, voicemail or text message.
YOU DO NOT HAVE TO TAKE ANY ACTION UNLESS YOU DENY PERMISSION
You need to respond only if you wish to deny permission to use your information in Lucid Communications marketing plans. Please contact [email protected] if you would like to deny or restrict permission for Lucid Communications use of your CPNI.
DISCLOSURE OF CPNI
Lucid Communications may disclose CPNI without asking for Customer’s authorization in any of the following circumstances:
1. When disclosure is required by law or court order.
2. To protect the rights and property of Lucid Communications or to protect Customer and other carriers from fraudulent, abusive, or unlawful use of services.
3. For directory listings.
4. To provide Lucid Communications services to the Customer, including assisting Customer with troubles associated with its services.
5. To bill the Customer for services.
6. When Customer has approved use of their CPNI for Lucid Communications, or Lucid Communications partners, affiliates, or independent contractors.
PROTECTING CPNI
Lucid Communications uses numerous methods to protect Customer’s CPNI. Lucid Communications employees are trained on how CPNI is to be protected and when it may or may not be disclosed.
Lucid Communications maintains records of its own and its joint venture partners and/or independent contractors (if applicable) sales and marketing campaigns that may utilize Customer CPNI. Lucid Communications also keeps records of instances in which CPNI is disclosed to third parties or where third parties were allowed access to Customer CPNI.
Lucid Communications will not release CPNI during Customer-initiated telephone contact without first authenticating the caller’s identity.
BREACH OF CPNI PRIVACY
In the event Lucid Communications experiences a privacy breach and CPNI is disclosed to unauthorized persons, federal rules require Lucid Communications to report such breaches to law enforcement. Specifically, Lucid Communications 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. Lucid Communications 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, Lucid Communications is required to maintain records of any discovered breaches, the date that Lucid Communications 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. Lucid Communications will retain these records for a period of not less than two (2) years.
NOTIFICATION OF CHANGES TO THIS POLICY
If Lucid Communications changes this CPNI Policy, Lucid Communications will post those changes on www.lucidcommunications.net/legal/cpni-policy or in other places Lucid Communications deems appropriate, so that Customer can be aware of what information Lucid Communications collects, how Lucid Communications uses it, and under what circumstances, if any, Lucid Communications disclose it. If Customer decides to continue receiving its services after Lucid Communications makes any changes to this CPNI Policy, Customer shall be deemed to have given express consent to the changes in the revised policy.
Updated on March 28, 2023