1. What CPNI includes
CPNI includes information about the quantity, technical configuration, type, destination, location, and amount of use of a subscriber's telecommunications service — for example, calling and called numbers, call durations, and similar service-related information that Dials collects in providing the Service.
2. Permitted uses
Dials uses CPNI to provide, secure, and bill for the Service, to detect and prevent fraud, and to comply with legal obligations. Dials does not use CPNI for marketing outside the categories permitted by 47 C.F.R. § 64.2005 without the consent required by the rule.
3. Authentication
Dials applies multi-factor authentication on accounts and requires re-authentication before disclosing CPNI in response to a subscriber inquiry. Telephone-channel CPNI requests are not honored absent a verified online session, a verified password, or a delivery to the address of record. Account changes that affect CPNI generate a notification to all addresses of record, as required by the rule.
4. Disclosure
Dials does not disclose CPNI to third parties except (a) as authorized by the subscriber, (b) to carriers and downstream providers as necessary to provide the Service, (c) to comply with lawful process described in our Law Enforcement Guidelines, or (d) as otherwise permitted by law.
5. Customer obligations
Customers who themselves are carriers, or who handle CPNI on behalf of carriers, must comply with 47 C.F.R. Part 64, Subpart U. Customers must train relevant personnel, maintain a written CPNI operating procedure, and submit any required annual certification to the FCC.
6. Breach notification
In the event of a CPNI breach, Dials notifies the U.S. Secret Service and the Federal Bureau of Investigation through the FCC's online portal not later than seven (7) business days after reasonable determination of the breach. Dials notifies affected customers in accordance with the rule's timing requirements and as soon as is consistent with law-enforcement needs.
7. Recordkeeping
Dials maintains records of breaches, customer disclosures, and any consent obtained for at least two (2) years, as required by 47 C.F.R. § 64.2009.
Questions about this document? Write to legal@dials.com. For data subject requests, see our privacy rights workflow.