STATEMENT OF COMPLIANCE The operating procedures of Runestone Telephone Association ensure compliance with the FCCs CPNI Rules.

Such procedures are as follows: Use of CPNI in Marketing ur compan! does not use CPNI in an! of its mar"eting efforts# and does not permit the use of# or access to# customer CPNI $! our affiliates or an! third parties. %e use# disclose or permit access to CPNI onl! for the purposes permitted under &' (.S.C. Sections )))*c+*,+ and *d+. ur compan! ma"es limited# one-time use of CPNI to mar"et our communication-related ser.ices onl! in compliance with FCC Rule /&.)001. 2efore *$ut pro3imate to+ soliciting customer consent for the use of CPNI to mar"et either *a+ our *or our affiliates+ communication-related ser.ices4 or *$+ third-parties communication-related ser.ices# we gi.e each customer notice of his or her right to restrict use and disclosure of# and access to# his or her CPNI# in compliance with FCC Rule /&.)001. ur compan! maintains a record of these notifications for at least one !ear. ur compan! has implemented a s!stem $! which the status of a customers CPNI appro.al can $e clearl! esta$lished prior to the use of CPNI. 5ach customers record contains a designation identif!ing whether or not we ha.e o$tained# through the processes permitted $! the FCCs rules# the customers appro.al to use# disclose or permit access to his or her CPNI. ur compan! accesses and uses a customers CPNI to mar"et our own *or our affiliates+ communicationrelated ser.ices *outside a customers current relationship+ onl! after the customers pt- ut consent has $een o$tained in compliance with FCC Rule /&.)001# and which consent has not $een re.o"ed $! the customer. 5.er! two !ears our compan! *a+ pro.ides notice of customers rights to restrict use and disclosure of# and access to# their CPNI# in compliance with FCC Rule /&.)001# and *$+ solicits pt ut consent for the use of the customer CPNI# in compliance with FCC Rule /&.)001# to each customer who has gi.en pt ut consent. ur compan! permits access to and use of a customers CPNI $! third parties in order to mar"et their communication-related ser.ices onl! after the customers pt-In consent has $een o$tained in compliance with FCC Rule /&.)001# and which consent has not $een re.o"ed $! the customer. ur compan! has a super.isor! re.iew process regarding our compliance with the FCCs CPNI rules for an! out$ound mar"eting efforts. %e re6uire sales personnel to o$tain super.isor! appro.al of an! proposed out$ound mar"eting re6uest for customer appro.al. CPNI Safeguards ur compan! has designated a compliance officer to maintain and secure the compan!s CPNI records and to super.ise training of all compan! emplo!ees. ur compan! trains its personnel as to when the! are# and are not# authori7ed to use or disclose CPNI# and we ha.e an e3press disciplinar! process in place if the rules are .iolated. ur compan! authenticates the identit! of a customer prior to disclosing CPNI $ased on a customer-initiated telephone contact# online account access# or in-store .isit. ur compan! discloses call detail information *C8I+ in a customer-initiated call onl!: after the customer pro.ides a pre-esta$lished password4 or# at the customers re6uest# $! sending the C8I to the customers address of record4 or $! calling $ac" the customer at his or her telephone num$er of record.
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ur compan! esta$lishes passwords with customers in order to authenticate customers. Neither passwords nor the $ac"up method for authentication rel! on customers readil! a.aila$le $iographical information. ur compan! has esta$lished password protection for customers online accounts. ur compan! includes terms specif!ing the confidentialit! and use of CPNI in its contracts with $usiness customers that are ser.ed $! a dedicated account representati.e. ur compan! notifies a customer immediatel! of changes in: a customers password# a customers response to $ac"-up means of authentication# online account# or address of record. CPNI Recordkeeping and Reporting ur compan! maintains a record of our own and our affiliates sales and mar"eting campaigns that use customer CPNI. %e also maintain a record of all instances where CPNI was disclosed or pro.ided to third parties# or where third parties were allowed access to CPNI. %e maintain these records for at least one !ear. ur compan! maintains records of our compliance with the FCCs CPNI Rules for use of CPNI in out$ound mar"eting efforts# for at least one !ear. ur compan! is prepared to pro.ide the FCC with written notice# within fi.e $usiness da!s of an! instance where the <opt out= mechanisms do not wor" properl!. ur compan! is prepared to notif! the (.S. Secret Ser.ice and F2I within se.en $usiness da!s after the occurrence of an intentional# unauthori7ed *or e3ceeding authori7ation+# access to# use of# or disclosure of CPNI. %e ma! also notif! the customer of such $reach# after consulting with the in.estigator! agenc!*ies+# if we $elie.e there is an e3traordinaril! urgent need to notif! a customer *or class of customers+ in order to a.oid immediate or irrepara$le harm. %e will notif! the customer of the $reach after ' $usiness da!s following notification to the F2I and Secret Ser.ice# if such agencies ha.e not re6uested that we postpone disclosure to the customer. ur compan! will maintain records of an! disco.ered $reaches# notices to the Secret Ser.ice and F2I# and their responses# for at least two !ears.

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