Last Updated: April 10th, 2023.
Customer Proprietary Network Information (CPNI) Policy
1.0.0 Introduction
This Customer Proprietary Network Information (CPNI) Policy explains what CPNI is, how Digital Aid LLC (“Digital Aid”, “we”, “us”, or “our”) collects, uses, and protects CPNI, and the circumstances under which we disclose CPNI. This policy is in compliance with the Federal Communications Commission (FCC) rules and regulations governing the protection of CPNI.
1.1.0 Our Customers Privacy Is Important to Us
At Digital Aid, we firmly believe in the importance of your privacy and are committed to protecting the personal information you entrust to us. We understand that safeguarding your privacy is not only our legal responsibility but also a crucial aspect of building and maintaining trust with our valued customers. Our CPNI Policy is designed to ensure transparency and adherence to the highest standards of privacy protection. We are dedicated to upholding your privacy rights and ensuring that your personal information remains secure and confidential.
2.0.0 What is CPNI
Customer Proprietary Network Information (CPNI) is a type of customer-specific information that telecommunications companies, like Digital Aid, obtain when providing telecommunications services to customers. CPNI includes information such as call details, call location, and billing records. It does not include your name, address, or telephone number.
3.0.0 Federal Law Requires Protection of CPNI
Under Section 222 of the Communications Act of 1934, as amended, and the FCC’s implementing regulations, telecommunications providers like Digital Aid are required to protect the confidentiality of their customers’ CPNI.
4.0.0 Consent to Share Your CPNI
4.1.0 Obtaining Consent
We may only use or share your CPNI with your affirmative, opt-in consent, except as permitted by law. We may seek your consent when you sign up for our services, through written, electronic, or oral communications, or at any other time we deem appropriate.
4.2.0 Revoking Consent
You have the right to revoke your consent to share your CPNI at any time by contacting us at support@digitalaid.org. Your decision to revoke consent will not affect the quality or provision of our services.
5.0.0 How Digital Aid Protects CPNI
We implement a variety of technical, administrative, and physical safeguards to protect your CPNI from unauthorized access, disclosure, or use. These safeguards include secure databases, access controls, encryption, and employee training.
6.0.0 Circumstances Where CPNI Is Disclosed
We may disclose your CPNI under the following circumstances:
6.1.0 With Your Consent
As described in Section 4, we may share your CPNI with your consent.
6.2.0 As Required by Law
We may disclose your CPNI when required by law, such as in response to a subpoena, court order, or law enforcement request.
6.3.0 To Protect Our Rights and Property
We may disclose your CPNI to protect our rights, property, or the safety of our customers or employees.
7.0.0 Notification of Account Changes
Digital Aid will notify you whenever there is a material change to your account information, such as a change in your address, password, or security questions. We may provide these notifications through various channels, including but not limited to email, text messages, in-app notifications, or physical mail. It is important to keep your contact information up-to-date, as it enables us to communicate important account-related changes and helps protect your personal information. You are ultimately responsible for the security of your account and password.
7.1.0 Methods of Communication for Notifications
Digital Aid will use a variety of communication methods to inform you about important updates or changes related to your account or our services. We may contact you through any of the following means:
7.1.1 Email
We will send you notifications to the email address associated with your Digital Aid account.
7.1.2 Text Messages
We may send you text messages, if you have provided us with your mobile phone number, to inform you of important account-related updates.
7.1.3 In-app Notifications
If you use the Digital Aid mobile app, we may send you in-app notifications about account changes or service updates.
7.1.4 Physical Mail
We may send you important information through postal mail to the address associated with your account.
8.0.0 Policy for CPNI Breaches
Digital Aid takes the protection of your CPNI very seriously. In the event of a breach or unauthorized access to your CPNI, we will take immediate steps to mitigate the damage and protect your information. Our policy for handling CPNI breaches includes the following provisions:
8.0.1 Incident Investigations
We will promptly investigate any potential breach or unauthorized access to CPNI to determine the cause and extent of the incident.
8.0.2 Notification to Affected Customers
If we determine that your CPNI has been accessed without authorization, we will notify you as soon as reasonably possible, in accordance with applicable laws and regulations.
8.0.3 Notification to Law Enforcement
In accordance with FCC rules and other applicable laws, we will notify the relevant law enforcement agencies of any CPNI breaches.
8.0.4 Remedial Actions
We will take appropriate actions to address the breach, which may include implementing additional security measures, conducting an internal review of our privacy and security policies, and providing affected customers with information on how to protect themselves from potential harm resulting from the breach.
8.0.5 Continuous Improvement
We will continually assess our policies, procedures, and systems to ensure the ongoing protection of your CPNI and prevent future breaches.
Please note that our commitment to protecting your CPNI extends to all aspects of our business, and we will take all necessary measures to maintain the confidentiality, integrity, and availability of your information.
9.0.0 Contact
If you have any questions or concerns about our CPNI Policy or practices, please contact us at Legal Department, CPNI Officer, legal@digitalaid.org, or (512) 885-8556.
This CPNI Policy is subject to change. We will notify you of any material changes by revising the “Last Updated” date at the top of this policy and, in some cases, we may provide additional notice, such as by adding a statement to our website or sending you an email notification.
10.0.0 Order of Precedence
In the event of any conflict or inconsistency among the provisions of the General Terms & Conditions, this Privacy Policy, the CPNI Policy, and any other policies that may be incorporated by reference in the future, the order of precedence shall be determined and specified in the General Terms & Conditions.
