as Rating Services Telesen & Sles Tat Services tions irene Solu "242 Range February 10, 2017 Via US ECFS Marlene H. Dorteh, Secretary Federal Communications Commission 445 12" Street S.W. Washington, D.C. 20554 RE: APXnet. Form 499 Filer ID: 829310 Annual Customer Proprietary Network Information Compliance Certification; EB Docket No. 06-36 Dear Ms, Dortch, Enclosed for filing is the Annual Customer Proprietary Network Information (“CPNI”) Compliance Certification; EB Docket No. 06-36, filed on behalf of APXnet, Please do not hesitate to contact me at 407-260-1011 or mark@ecsilongwood.com if you have any questions or concerns. Thank you for your assistance in processing this filing. Tut I | ] KI Mark G. Lammert, CPA Tax Preparer for APXnet ce: APXnet file: APXnet ~PUC - FCCSTATEMENT OF POLICY IN TREATMENT OF CUSTOMER PROPRIETARY NETWORK INFORMATION CASTOMER PROPRIETARY NETWORK INFORMATION Iris \PXnet (hereatter referred to as “APNnet") poliey not wo use CPNE tor any hey than permitted by law. Any disclosure of CPNI to other paties (stich as alllions endors. and agents) occurs only if it is necessury to conduct setivity related to the services already provided by the company’ to the customer, Ifthe Company is not required by law to disclose the CPNI or ifthe intended use docs not fl ssithin one of the carve outs. the Company will first obiain the customer's consent prior to using CPNI imate business APXnat follows industry-standard practices preven unauthorized access wo CPNI by fenon other that the subscriber or APXnet. However, APXnet cannot guarantee tae these practices will prevent every unauthorized attempt to aceess. use. or diel personally identifiable information. theretiore: \- Ian unauthorized disclosure were to occur. APXnet shall provide notifivation of the breach within seven (7) days to the United States Seeret Service (*USSS") aad the Federal Bureau of Invest Bo APXnet shall wait an additional seven (7) days trom its government notice prior to notitying the affected customers of the breach, (Notwithstanding the provisions in subparagraph BE above, APNnet shall not watt the additional seven (7) days to notify its customers if APNnet determines there re san immediate risk o irreparable harm to the customers, PD. APSnet shall maintain records of discovered breaches tr perio! fat least ter (2) years, Ml employees will be trained as to when the with the Company and are. and are not, authorized to use CPNT ly thet upon employ mer \Specitically. APNnet shall prohibit its personnel fran releasing CPNI based upon 4 customer-initated telephone call exeept under the following three ea) circumstances: 1 When the customer has pre-established a password. 2 When the information requested by the customer is to be semt to the customer's address of record. or * When APXnet calls the customer's telephone number ot revond and ied by customer liseusses the information with the purty initially ider when service was initiated,Ho APNnet may ae CPNE for the tallonsing purposes © Lovinitiate, render, maint Hand collect for sets ives 1. repair, b * To protect its property rights: or w protect its subscribers or other carriers from fraudulent, abusive . or the unlawful use of, or subscription te, such * To provide inbound telemarketin the customer during a customer initiated call and with the customer's informed consent * Lo market additional services tv customers that are within the same categories af service to which the customer already subscribes: al or auluinistrative services to # Fomarket services formerly known as aaljunet-to-basie serv ives: and + To market additional services to customers with the reecipt of informed consent Via the use ef opt-in or opt-out. as applicable rior to allow ing aecess to Customers’ individually identifiable CPE to APXnets joint ‘enlurcrs or independent contractors, APNnet will require. im onder to safeguard that internation, their entry into both contidentiality agreements that ensure compliance with this Statement and shall obisin opt-in consent from a eustomer prior to dlisclosin ‘information, In addition, APXnet requires all outside Dealers and A acknowledge and certify that they may only use CPNI for the purpose tor which that information has been provided. Apart requires express written authorization ftom the customer prior to dispensing CPNT wo new carriers, except as otherwise required by law APXnet does not market. sh fe oF otherwise sell CPNI information to any third party APXnct maintains @ record of its own and its affiliates" sales andl mi that use APNnets” customers’ CPNI. The record will include a desetiptio sampaign. the specitie CPNT that was used inthe campaign, servives were offered as part of the campaign campaigns of each nl What-produets and A Prior commencement of a sales or marketing campaign that utilizes CPN APXnict establishes the status of a customer's CPNT approval, The following sets forth the procedure followed by APXnet Prior to any: solicitation for customer approval, APXnet will notiti customers of their right to restrict the use a, disclosure of, and aecess. tv their CPNL © APXnet will use opt-in approval for any instar obtain customer approval prior to using. diselosin CPNL © XV customer's approval or disapproval remains in effect « revokes or limits such approval or disapproval. ee in which APNnet mast© Records of approvals are maint * APNnet provides inividual notice to customers wien soliciting ess 10 CPN oF APNnet’s CPNT notices comply with FOC rule 64.2008 (er ned Tor at Least one sear to use, disclose, © the conter APAnet has implemented a syste nfirmed consent trom its customers prior to the use of CPNI for marketing purposes. This systems allows tor the status oa customer's CPNL approval tw he clearly established prior to the use of CPN to obtain approval and WPNnct has supervisory review process re outbound marketing situations and ill m Specitically. APD outbound market; Counsel of APNnet urdin i compliance with the CPNT rules tor ain compliance records for at least one seat *s" sales personnel will obtain express approval of any proposed Fequest for customer approval of the use of CPNI by ‘The Cieneral APXnet notifies customers immediately of any account changes, inelulin record, authentication, onting account and password related changes adress at APXnet may negotiate alternative authentication procedures Provides to business customers that have a dedicated accom womtract that specifically addresses. APXinets’ proteetion of CPN vives that APXnet representative and a WPXnet is prepared to provide written notice within tive business dys to the FCC ofans instance where the optin mechanisms de not work properly to such a degree that consumer's inability to opt-in iy more than anANNUM 47 CERES: 04.2009 (6) CPNECERTIFIC VEION FOR 2017 EB Docker 06 Date Filed: January 28, 2017 Name of Company: APNnet Form 199 Filer ID: @24310 Name of Signatory: Heidi Burns Wood Hitle of Signatory: Vice President & COO {Heidi Bums Wood. certity that Lam an officer of the company named abvive. an acting as an of the company. that {have personal knovlexlse that the company hits established ting procedures that are adequate t» ensure compliance with the Commissions CPNI rules See 47 CHR, 64.2001 et seq. tached to this certification isan accompanying statement explaining how the companys Procedures ensure that the company is in compliance with the requirements set forth in cection 64.2001 ct. sey. of the Commissions rules {he company has not taken ay actions (proceedings instituted or petitions fled by a company an cither state commissions, the court system. or at the Commission against data brokers) sy rokers in the past sear. he steps the company has taken ta protect CPNT include apt rst its CPM practices and procedures and conducting new trainin with the FCC'S modified CPN rules wed 10 ensure compliance The company the tunauith ceeived any customer complaints in the past year concernin;