Lumos is committed to respecting and protecting the privacy of our customers. We have strict policies governing access by employees and others to customer communications and information. We access customer account records for authorized business purposes only. We educate our employees about their obligation to safeguard customer information and communications, and we hold them accountable for their actions. In short, privacy is a priority for Lumos in all aspects of our business.
SECTION I. GENERAL PRIVACY PRINCIPLES
1. Lumos uses individual customer information for business purposes only.
Lumos obtains and uses customer information that helps us to provide our customers with quality telecommunications services. In addition to supporting the direct provision of service, this information may be used to protect customers, employees and property against fraud, theft or abuse and to maintain good customer relations. Access to databases containing customer information is limited to employees who need that information to perform their jobs. These employees are required to follow strict rules when handling customer information, and are subject to disciplinary action if they fail to abide by the rules.
2. Lumos gives customers opportunities to control access by others to customer information.
Lumos is committed to providing customers with opportunities to control how Lumos uses customer information about them. For example, customers may inform us of which telephone listings they want to include in our directories and in directory assistance and may also choose to have a non-published number, or a non-listed number. Customers can express a preference for Lumos not to call them for sales purposes. Customers may opt out of our direct mailings and other marketing programs.
Lumos uses aggregated customer information internally for planning purposes – so that we can, for example, develop, test and market new products and services that meet the needs of our customers.
3. Lumos enables customers to control how Lumos discloses individual information about them to other persons or entities, except as required by law or to protect the safety of customers, employees or property.
Lumos shares individual customer information with persons or entities outside the company only for business purposes and only pursuant to an agreement that strictly limits the use and disclosure of such information.
We are required to provide directory publishers with subscriber listing information – name, address and phone number, and for yellow page advertisers, primary advertising classification – for purposes of publishing and delivering directories. In addition, under certain circumstances, we may share customer information with emergency response personnel or with law enforcement to prevent and investigate fraud or other unlawful use of communications services.
4. Lumos strives to ensure that the information we obtain and use about customers is accurate.
Lumos is committed to ensuring that the information we obtain and use about customers is accurate. To that end, we strive to verify that our customer records are correct. Customers who find an error in their Lumos bills are encouraged to notify Lumos. Lumos’ service representatives are trained to answer customer questions about, and to give customers reasonable access to, the information we have about them. Our service representatives will also provide explanations of how such information is used and how to correct any inaccuracies if they occur.
In addition to reviewing their bills, customers can access their customer information by contacting Lumos customer service. However, Lumos will only provide customer information after properly authenticating the identity of the requesting “customer” in accordance with applicable law and industry best practices. In this way, Lumos can maximize the ability of its customers to review their customer information for accuracy while minimizing the risk that this information is fraudulently obtained by a third party. Lumos service representatives can explain how customers may be authenticated to obtain access to their own customer information.
5. All Lumos employees are responsible for safeguarding individual customer communications and information.
SECTION II. FCC’s “CUSTOMER PROPRIETARY NETWORK INFORMATION” RULES
In addition to Lumos’ own efforts to respect and protect the privacy of customer specific information, we comply with the Federal Communications Commission’s rules for protecting “Customer Proprietary Network Information” (CPNI).
1. Definition of “Customer Proprietary Network Information.”
The term “customer proprietary network information” is defined by federal statute to mean: (i) information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscribed to by any customer of a telecommunications carrier, and that is made available to the carrier by the customer solely by virtue of the carrier-customer relationship; and (ii) information contained in the bills pertaining to telephone exchange service or telephone toll service received by a customer of a carrier.
2. Use of Customer Proprietary Network Information.
Under federal law, you have the right to, and we have the duty to protect, the confidentiality of your CPNI. However, we may use CPNI without your consent, in a manner consistent with applicable law, to: (i) initiate, render, bill, and collect for our services; (ii) market services among the categories of service to which you already subscribe; (iii) provide inside wiring installation, maintenance, and repair services; (iv) provide maintenance and technical support for our services; (v) protect our rights and property, and protect users of our services and other carriers from fraudulent, abusive, or unlawful use of, or subscription to, these services; and (vi) provide any inbound telemarketing, referral, or administrative services for the duration of a customer-initiated call.
Further, after providing you with the required notice and opportunity to “opt out” we may use your CPNI, in a manner consistent with applicable law, to market additional communications-related services to you.
3. Disclosure of CPNI outside Lumos.
Lumos releases customer information if disclosure is required by law, or necessary to protect the safety of customers, employees or property. For example:
When you dial 911, information about your location may be transmitted automatically to a public safety agency.
Certain information about your long distance calls may be transmitted to your long distance company for billing purposes.
We will disclose information as necessary to comply with law enforcement statutes, such as to comply with valid subpoenas, warrants and court orders.
We may, where permitted by law, share CPNI with third parties where necessary to provide the services to which you subscribe, to protect our rights or property, and to protect users of our services and other carriers from fraudulent, abusive or unlawful use of services.
4. Authentication to prevent unauthorized access to CPNI.
Lumos is committed to ensuring that only properly authorized individuals are able to access CPNI for legitimate purposes. This includes ensuring that any request by a “customer” to access CPNI is valid and properly authenticated, in accordance with applicable law and industry best practices.
If a “customer” calls us to access “call detail records” (which include the number called, the number from which a call was placed, and the time, location, or duration of any call), we will not release those records unless (i) during the call, the customer provides a pre-established password; (ii) the information is sent to the customer’s address of record; or (iii) after the call, we call the customer’s telephone number of record to provide the requested information. If a “customer” attempts to access CPNI through our website, we will only provide such access if the customer has first established a password and back-up authentication mechanism for the relevant account, in a manner that does not rely on readily-available biographical or account information. If a “customer” attempts to access CPNI by visiting a retail location in person, we will only provide such access if the “customer” presents valid photo identification matching the name of record on the account.
5. Notice of unauthorized access to CPNI.
If Lumos becomes aware that your CPNI has been accessed without proper authority, we will take swift action to fully document and address such unauthorized access and provide you with notice. In particular, we will (i) notify law enforcement (including the United States Secret Service and the Federal Bureau of Investigation) within seven business days; and (ii) notify you and any other affected customers promptly thereafter, unless earlier notification is necessary to avoid immediate and irreparable harm, or we are instructed by law enforcement personnel to refrain from providing such notice.
SECTION III. LUMOS’ “DO NOT CALL” LIST
Any Lumos customer can express a preference not to be called by us for sales and marketing purposes, and Lumos will respect such preference. A customer that does not wish to receive sales and marketing calls from Lumos may ask to be placed on our company-specific “Do Not Call” list. We will note the customer’s request immediately, although it may take up to 30 days for the customer’s telephone number to be removed from any active lists or sales programs that are currently underway.
Residential customers remain on our “Do Not Call” list for five years, and a business customer will remain on our “Do Not Call” list for one year. At the end of those time periods, customers can renew “Do Not Call” status. If a customer’s telephone number changes, the customer must give us updated information in order for the “Do Not Call” status to remain in effect.
Notwithstanding the fact that a customer’s telephone number is on our “Do Not Call” list, Lumos may contact the customer with respect to billing, and other service-related matters.