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COLUMBUS NETWORKS TELECOMMUNICATIONS SERVICES USA, INC.

STATEMENT OF CPNI OPERATING PROCEDURES


Columbus Networks Telecommunications Services USA, Inc. (CN Services USA) has established
policies and procedures to comply with the Federal Communications Commission (FCC) rules regarding
the use, disclosure, and access to customer proprietary network information (CPNI) in accordance with
64.2001 et seq. of the FCCs rules, 47 C.F.R. 64.2001 et seq. This statement is a summary of CN Services
USA policies and procedures designed to safeguard CPNI.
CN Services USA has substantial processes and control for both physical security and access to
data. Its customers will be provided services under contracts with express confidentiality provisions,
verification methods to confirm the identity of customers authorized persons to receive the customers
CPNI. Business customers will have dedicated account representatives with access to customer data. CN
Services USA maintains and utilizes CPNI for the limited purposes of initiating, rendering billing and
collecting of its services, and may use CPNI, if necessary, to protect its property rights. CN Services USA
does not and will not use any CPNI for any marketing purposes, nor will CN Services USA disclose CPNI or
permit access to such CPNI to any third parties other than as necessary to provide service. Given that CN
Services USA does not permit the use of CPNI for any marketing purposes whatsoever, it does not collect
opt-in or opt-out authorizations from customers for such use.
CN Services USA has implemented measures to discover and to protect against unauthorized
attempts to access CPNI. CN Services USA has also implemented measure to discover and to protect
against unauthorized attempts to access CPNI. In addition, CN Services USA has implemented procedures
pursuant to which it will track breaches of CPNI, and it will notify the applicable law enforcement
authorities if such were ever to occur. CN Services USA will notify its customers of the security breach, if
permitted, and will notify of the breaches and notifications for a two-year period thereafter. CN Services
USA has implemented procedures that conform with the relevant FCC rules to inform customers when
their address changes. CN Services USA will track customer complaints regarding CPNI. CN Services USA
has trained and will continue training its employees as to when they are and are not permitted to use,
permitted access to, or permitted to disclose CPNI. CN Services USA has instituted a disciplinary process
in place to address any noncompliance with its policies, including policies regarding CPNI, which includes
the potential for termination. CN Services USA will track CPNI disclosures made to respond to subpoenas
and other information requests from law enforcement authorities from time to time.
CN Services USA has implemented procedures whereby it will not provide CPNI without proper
customer authentication on inbound telephone calls. CN Services USA does not collect, use or maintain
call detail information from its U.S. customers and does not provide online account access for any
customers.
CN Services USA will submit an annual CPNI certification to the FCC from an officer with personal
knowledge of the policies and procedures that it has implemented to safeguard CPNI.