Customer Proprietary Network Information (CPNI)

Customer Notification Regarding Customer Proprietary Network Information (CPNI)

Garden Valley Technologies (GVT) is committed to maintaining the privacy of its customers. In addition to protecting your personal information as outlined in GVT’s Privacy Policy, GVT employs a number of comprehensive safeguards to protect the privacy of your personal telephone records and information about how you use your services under federal law.

This document serves to explain how Garden Valley Technologies is complying with Federal Communications Commission (“FCC”) rules related to the privacy of customer information and your role as our customer in assuring that your CPNI information is well protected. 

What is Customer Proprietary Network Information (CPNI)?

CPNI is simply defined as a customer’s individual information that relates to the quantity, technical configuration, type, destination, location and amount of use of your telecommunications service, including the information contained in your bill. That information when matched to your name, address and telephone number is known as “Customer Proprietary Network Information” or “CPNI” for short. CPNI does not include however your published directory information or any information that is already in the public domain, such as your name, address, published telephone number or aggregate information or data that is not specific to a single customer.

Examples of CPNI include information about which services you purchase, the amount of your long distance bill or call detail information. These examples are the kind of information that Garden Valley Technologies possesses because we need that information to serve you.

How do we comply?

Garden Valley Technologies has established procedures and trained all employees having access to the customer data to identify what constitutes CPNI data consistent with the definition of CPNI under the Section 64.2003(g) and Section 222(f)(1) of the Communications Act of 1934 as amended (47 U.S.C. 222(f)(1)), to identify uses of CPNI not requiring customer authorization under Section 64.2007 and to identify prohibited uses of CPNI.

Federal privacy rules require GVT to authenticate the identity of its customer prior to disclosing CPNI.  Customers calling GVT’s customer service center can discuss their services and billings with a GVT representative once that representative had verified the caller’s identity. 

GVT currently uses the following methods to authenticate customers:

• Username + Password – customers that wish to create and later access their GVT account online may do so by providing their own e-mail address, which will be used by our system as unique username and creating confidential password. .
• Security Questions / Answers – customers pick a security question from a preset list (i.e. “In what city was your first job?”) and then provide GVT with the answer (i.e. “Mountain View”).  These questions/answers are entered by customer on-line and stored in our system for later retrieval.  Security questions are currently used by GVT as authentication methods for resetting customers’ passwords and for call-in identity verification.

Permitted Use of CPNI by Garden Valley Technologies Without Your Permission

Garden Valley Technologies may disclose CPNI in the following circumstances:

• When the Customer has approved the use of their CPNI
• When disclosure is required by law or court order (i.e. emergency services, law enforcement assistance, etc.)
• To protect the rights and property of Intermedia or to protect Customers and other carriers from fraudulent, abusive or unlawful use of services
• To provide the services to the Customer, including assisting Customer with troubleshooting and provisioning of the purchased services (for this purpose we may release CPNI data to our partners who resell our services and bill their own customers)
• To bill the Customer for services

Approval or Opt-Out for Marketing Communication

Garden Valley Technologies does not provide CPNI to other parties for marketing and thus, at this time, has not used the Opt-Out notifications for this purpose. Prior to any planned CPNI disclosure to outside parties, GVT will initiate the Opt-Out notifications.

From time to time however, GVT would like to use the CPNI information it has on file to provide you with information about GVT’s communications-related products and services or special promotions.  GVT’s use of CPNI may also enhance its ability to offer products and services tailored to your specific needs.  Accordingly, GVT would like your approval so we may use CPNI to let you know about communications-related services other than those to which you currently subscribe and which we believe may be of interest to you.   

IF YOU APPROVE, YOU DO NOT HAVE TO TAKE ANY ACTION.

You need to respond only if you wish to deny permission to use your information in our marketing plans.  Please contact cpni@gvtel.com or call 888-483-2491 if you would like to deny or restrict our use of your CPNI. Please provide your name, telephone number, and a message that you want to opt out.

Any denial or restriction of your approval remains valid until your services are discontinued or you affirmatively revoke or limit such approval or denial.

Please note your denial of use of your CPNI by GVT will not affect the provisioning of any services you subscribe to.

Breach of CPNI Privacy

In the event Garden Valley Technologies discovers an unauthorized use of customer’s CPNI, federal rules require GVT to report such breaches to law enforcement.  Specifically, GVT will notify law enforcement no later than seven (7) business days after a reasonable determination that such breach has occurred. Additionally, GVT is required to maintain records of any discovered breaches. Such documentation would include: the date GVT discovered the breach, the date law enforcement has been notified 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.  GVT will retain these records for a period of not less than two (2) years.

Notification of Changes to this Policy

Garden Valley Technologies reserves the right to change this CPNI policy at any time.