CPNI Policy

TCI is committed to maintaining the privacy of its customers. In addition to protecting your personal information as outlined in TCI's Privacy Policy, we are obliged to give additional protections to certain information about how you use your services. However, that information can help us customize and improve services we offer you.

In this section, we describe what information we protect and how we protect it.

CPNI PROTECTIONS

As a customer of our services, you have the right, and TCI has a duty, under federal law, to protect the confidentiality of certain types of services. Customer proprietary network information (CPNI) is information related to the quantity, technical configuration, type, destination, location, and the amount of telecommunications a customer uses that TCI has access to by virtue of the customer-provider relationship. CPNI does not include the Customer name, address and telephone number, aggregate information or data that is not specific to a single customer, customer premises equipment and Internet access services.

CPNI does not include things like customer name, address, or telephone number; Unless TCI obtains your approval, TCI may not use this CPNI to market products and services to you other than for services you currently purchase.

APPROVAL

From time to time, TCI would like to use the CPNI information it has on file to provide you with information about TCI's communications-related products and services or special promotions. TCI's use of CPNI may also enhance its ability to offer products and services tailored to your specific needs. Accordingly, TCI would like your approval so that TCI may use this CPNI to let you know about communications-related services other than those to which Customer currently subscribes that TCI believes may be of interest to Customer. IF YOU APPROVE, YOU DO NOT HAVE TO TAKE ANY ACTION.

However, you do have the right to restrict our use of your CPNI. YOU MAY DENY OR WITHDRAW TCI'S RIGHT TO USE YOUR CPNI AT ANY TIME BY CALLING 1-231-796-2548. If you deny or restrict your approval for TCI to use your CPNI, you will suffer no effect, now or in the future, on how TCI provides any services to which you subscribe. Any denial or restriction of your approval remains valid until your services are discontinued or you affirmatively revoke or limit such approval or denial.

In some instances, TCI will want to share your CPNI with its independent contractors and joint venture partners in order to provide you with information about TCI's communications-related products and services or special promotions. Prior to sharing your CPNI with its independent contractors or joint venture partners, TCI will obtain written permission from you to do so.

CUSTOMER AUTHENTICATION

Federal privacy rules require TCI to authenticate the identity of its customer prior to disclosing CPNI. Customers calling TCI's customer service center can discuss their services and billings with a TCI representative once that representative has verified the caller's identity. There are three methods by which TCI 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 of record.


Passwords and/or PINs may not be any portion of the Customer's social security number, mother's maiden name, amount or telephone number associated with the Customer's account or any pet name. In the event the Customer fails to remember their password and/or PIN, TCI will ask the Customer a series of questions known only to the Customer and TCI in order to authenticate the Customer. In such an instance, the Customer will then establish a new password/PIN associated with their account.

NOTIFICATIONS OF CERTAIN ACCOUNT CHANGES

TCI will be notifying customers of certain account changes. For example, whenever an online account is created or changed, or a password or other form of authentication (such as a secret question and answer) is created or changed, TCI will notify the account holder. Additionally, after an account has been established, when a customer's address (whether postal or e-mail) changes or is added to an account, TCI will send a notification. These notifications may be sent to a postal or e-mail address, or by telephone, voicemail or text message.

DISCLOSURE OF CPNI

TCI may disclose CPNI in the following circumstances:

PROTECTING CPNI

TCI uses numerous methods to protect your CPNI. This includes software enhancements that identify whether a Customer has approved use of its CPNI. Further, all TCI employees are trained on how CPNI is to be protected and when it may or may not be disclosed. All marketing campaigns are reviewed by a TCI supervisory committee to ensure that all such campaigns comply with applicable CPNI rules.

TCI and its joint venture partners and/or independent contractors maintain records of its own (if applicable) for sales and marketing campaigns that utilize Customer CPNI. Included in this is a description of the specific CPNI that was used in such sales or marketing campaigns. TCI also keeps records of all instances in which CPNI is disclosed to third parties or where third parties were allowed access to Customer CPNI.

TCI will not release CPNI during customer-initiated telephone contact without first authenticating the Customer’s identity in the manner set forth herein. Violation of this CPNI policy by any TCI employee will result in disciplinary action against that employee as set forth in TCI’s Employee Manual.

BREACH OF CPNI PRIVACY

In the event TCI experiences a privacy breach and CPNI is disclosed to unauthorized persons, federal rules require TCI to report such breaches to law enforcement. Specifically, TCI 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: http://www.fcc.gov/eb/cpni. TCI cannot inform its Customers 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, TCI is required to maintain records of any discovered breaches, the date that TCI 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. TCI will retain these records for a period of not less than two (2) years.

NOTIFICATION OF CHANGES TO THIS POLICY

If we change this CPNI Policy, we will post those changes on http://www.tucker-usa.com/legal/cpni.html or in other places we deem appropriate, so that you can be aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If you decide to continue receiving your services after we make any changes to this the CPNI Policy, you shall be deemed to have given express consent to the changes in the revised policy.