CUSTOMER PROPRIETARY NETWORK INFORMATION (CPNI) COMPLIANCE POLICY

Intermountain Infrastructure Group, LLC (“IIG”) is committed to maintaining the privacy of its customers’ personal information. This policy serves to explain how IIG is complying with Federal Communications Commission (“FCC”) rules related to the privacy of certain Customer Proprietary Network Information.

What is CPNI?

Customer Proprietary Network Information (CPNI) is information that IIG and other telecommunications carriers obtain when providing telecommunications services to you. CPNI includes the types of telecommunications services you currently purchase, how you use them, and the billing information related to those services, including items such as the types of telecommunications services that you have purchased and your calling details (if applicable). Your telephone number, name and address are not considered CPNI.

Use and Disclosure of CPNI.

IIG personnel are trained that CPNI may be used only in the provision of the telecommunications service from which such information is derived or services necessary to, or used in, the provision of such telecommunications service. IIG personnel may also use CPNI to initiate, render, bill and collect for the telecommunications services provided to the customer. Lastly, IIG personnel may use, disclose, or permit access to CPNI for the purpose of providing or marketing service offerings among the categories of service to which the customer already subscribes without customer approval.

IIG does not provide customers with web access to customer records. If it elects to do so in the future, it will follow the applicable FCC rules, including the implementation of authentication procedures that do not require the use of readily available biographical or account information and customer notification of changes.

The information we obtain from you is generally necessary for us to provide your services and design new services for your future use. For example, we need to know your name, address and the services you buy from us to properly provide and bill for those services. When you call us, our representatives pull up your records and may refer to your bill and other information we have to answer questions you may have or recommend how we can best serve you.  We will also use CPNI to bill for services you purchase.

We may also use information in our records to protect our customers, employees or property – for instance, to investigate fraud, harassment or other types of unlawful service activities involving IIG or other carriers that we do business with. In some cases, it may be necessary to provide this information to the government or third parties who make a lawful demand for it (i.e., emergency services, law enforcement assistance, etc.).

IIG does not market, share or otherwise sell CPNI information to any third party. IIG does not currently engage in targeted sales and marketing campaigns of any sort and, therefore, does not use or disclose our customers’ CPNI in connection with marketing efforts.

Unless we receive permission from you, we do not release your account information. We may provide account information to collection agencies when customers do not pay their bills. We restrict the use that can be made of this information to collection activities only for the charges that have been billed.

Security

We have information systems that collect and store customer information separately from our own business records. These systems have different types of security as appropriate for the information stored. IIG has established procedures and trained all employees having access to customer data to identify what constitutes CPI, to identify uses of CPNI not requiring customer authorization, and to identify prohibited uses of CPNI.

Federal privacy rules require IIG to authenticate the identity of its customer prior to disclosing CPNI.

Changes to this Policy

IIG reserves the right to change this CPNI Policy at any time. Any changes to the CPNI Policy will be posted to our website at www.intermountainig.com/legal/cpni-policy.