DocuSign Envelope ID: B5225994-193F-4F0E-9366-D5E0E89BC824

Annual 47 C.F.R. 64.2009(e) CPNI Certification

EB Docket 06-36

Annual 64.2009(e) CPNI Certification for 2015 covering the prior calendar year 2014
1.

Date filed: February 28, 2015

2.

Name of company covered by this certification: ALCALLER, INC.

3.

Form 499 Filer ID: 828123

4.

Name of signatory: Lionel Maza

5.

Title of signatory: Vice-president, Compliance Officer

6.

Certification:

I, Lionel Maza, certify that I am an officer of the Company named above, and acting
as an agent of the Company, that I have personal knowledge that the Company has
established operating procedures that are adequate to ensure compliance with the
Commissions CPNI rules. See 47 C.F.R. 64.2001 et seq.
Attached to this certification is an accompanying statement explaining how the
Companys procedures ensure that the Company is in compliance with the requirements
(including those mandating the adoption of CPNI procedures, training, recordkeeping, and
supervisory review) set forth in section 64.2001 et seq. of the Commissions rules.
The Company has not taken any actions (i.e., proceedings instituted or petitions filed
by a company at either state commissions, the court system, or at the Commission against
data brokers) against data brokers in the past year.
The Company has not received customer complaints in the past year concerning the
unauthorized release of CPNI.
The Company represents and warrants that the above certification is consistent with
47 C.F.R. 1.17 which requires truthful and accurate statements to the Commission. The
Company also acknowledges that false statements and misrepresentations to the Commission
are punishable under Title 18 of the U.S. Code and may subject it to enforcement action.

Signed: _____________________________
Attachment:

Accompanying Statement Explaining CPNI Procedures

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ALCALLER, INC. STATEMENT OF CUSTOMER PROPRIETARY NETWORK INFORMATION
(CPNI) COMPLIANCE PROCEDURES
Alcaller, Inc. is an Interconnected Voice over Internet Protocol (VOIP) provider that has
established and implemented the following internal policies and procedures that ensure
compliance with the requirements of Section 222 of the Communications Act of 1934, as
amended, and the Federal Communications Commission's rules governing Customer
Proprietary Network Information ("CPNI"), codified at 47 C.F.R. 64.201 et seq. pertaining to
the use, disclosure and access. The responsibility for Alcaller, Inc. policies and procedures
that protect CPNI and guards against its misuse resides with the company's Compliance
Officer, who has reviewed Section 222 of the Communications Act and the FCC's CPNI Rules
(47 C.F.R. 64.201 et seq.) and is familiar with their requirements.
The following operating procedures ensure that Alcaller, Inc. is in compliance with the FCC's
CPNI Rules:
1. Alcaller, Inc. does not make available to any affiliated or unaffiliated entity information
that meets the definition of CPNI set forth at 47 U.S.C. 222(h)(l ), except when required to
do so by law. Furthermore, the Company recognizances the rule that CPNI includes
information that is personal and individually identifiable and that privacy concerns have led
Congress and the FCC to impose restrictions upon its use and disclosure, and upon the
provision of access to it by individuals or entities inside and outside the Company.
2. Alcaller, Inc. has designated a CPNI Compliance Officer who is responsible for: (1)
Communicating with the Companys attorneys and/or consultants regarding CPNI
responsibilities, requirements and restrictions; (2) supervising the training of Company
employees and agents who use or have access to CPNI; (3) supervising the use, disclosure,
distribution or access to the Companys CPNI by independent contractors and joint venture
partners; (4) maintaining records regarding the use of CPNI in marketing campaigns; and (5)
receiving, reviewing and resolving questions or issues regarding use, disclosure, distribution
or provision of access to CPNI.
In addition to the specific matters required to be reviewed and approved by the Companys
CPNI Compliance Officer, Company employees, agents, independent contractors and joint
venture partners are strongly encouraged to bring any and all other questions, issues or
uncertainties regarding the use, disclosure, or access to CPNI to the attention of the
Companys CPNI Compliance Officer for appropriate investigation, review and guidance.
3. Alcaller, Inc. uses the CPNI only for purposes permitted by the FCC rules. It doesnt use,
disclose or permit access to CPNI to provide or market offered services for the categories
that the customer has not already subscribe.

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4. Alcaller, Inc. has practices and procedures that govern the disclosure of
CPNI:
a. Alcaller, Inc. does not disclose or release CPNI upon a customer's telephone request.
b. Alcaller, Inc. does not disclose or release CPNI through online access over the
internet, except to the accounts owner via an online portal that requires a username
and password that is managed by the account owner.
c. Alcaller, Inc. does not have any retail locations where a customer can obtain CPNI.
d. With respect to telephone inquiries by customers concerning specific CPNI related
issues, Alcaller, Inc. requires the customer to provide sufficient specific information
about the call in question to confirm the customer's identity. If customer was able to
authenticate its identity then, the CPNI information requested will be sent to the
customers address of record, or Company calls the telephone number of record and
discusses the requested information.
e. Alcaller, Inc. automatically notifies customers (at the customer's original telephone
number, address or other information on file capable of receiving notification) in case
any changes are made to the customer's primary account information.
f. Alcaller, Inc. will notify the U.S. Secret Service (USSS) and the FBI in the event of a
breach of the CPNI rules and will provide the required notice to affected customers of
any such breach. Such notification would be as soon as practicable and in no event
more than seven (7) days after reasonable determination of the breach. The
notification to the customer will be seven business days after the notification to the
law enforcement agencies. Nevertheless, if the company believes that an irreparable
harm could be made to the customer, then the Company will proceed, after
consultations with the law enforcement agencies, with the immediate notification.
The company will maintain a record, electronically or in some other manner, of any
breaches discovered, notifications made to the USSS and the FBI, and notifications
made to customers. The record includes, if available, dates of discovery and
notification, a detailed description of the CPNI that was the subject of the breach,
and the circumstances of the breach. The records will be retained for a minimum of 2
years.

4. Alcaller, Inc. provides training to all relevant employees on the company's practices and
procedures that protect CPNI and its misuse.
5. Alcaller, Inc. maintains appropriate electronic records that allow its employees,
independent contractors and joint venture partners to clearly establish the status of each
customers Opt-out or Opt-In approvals (if any) prior to use of the customers CPNI. These
records include: (i) the date(s) of any and all of the customers deemed Opt-out approvals

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and/or Opt-in approvals, together with the dates of any modifications or revocations of
such approvals; and (ii) the type(s) of CPNI use, access, disclosure or distribution approved
by the customer.
6. The customer can grant or deny access to CPNI. Alcaller, Inc. advises its customers of the
precise steps the customer must take in order to grant or deny access to CPNI.
7. The Compliance Officer most be notify in the event that any access, accuracy or security
problems are encounter with respect to customers records at the moment of and out-bound
marketing campaign. Any employee, independent contractor or joint venture is responsible
for notifying the Compliance Officer of any inaccuracy.
The Compliance officer will determine whether, new, additional or extended approvals are
necessary and if Opt-Out CPNI Notice or Opt-In CPNI Notice must be used with respect
to various proposed out-bound marketing activities. Such notice will comply with FCC rules.
8. It is a violation of Alcallers, Inc. policies to disclose CPNI outside of Alcaller, Inc. Any
employee that is found to have violated this policy will be subject to disciplinary action up
to and including termination.
9. Access to CPNI at Alcaller, Inc. is restricted to a limited number of employees and
controlled through the use of active security and other measures, including the use of
special passwords that are assigned on a limited basis and technological measures that
prohibit the electronic reproduction or distribution of CPNI. Encryption and other security
practices are utilized when CPNI is transmitted electronically.
10. Strict controls are in place involving responses to law enforcement agencies that serve
Alcaller, Inc. with valid legal demands, such as court ordered subpoena, for CPNI. Alcaller,
Inc. will not supply CPNI to any law enforcement agency that does not produce a valid legal
demand.
11. Alcaller, Inc. will provide written notice within five business days to the Commission of
any instance where the opt-out mechanisms do not work properly, to such a degree that
consumers' inability to opt-out is more than an anomaly. Such notice must be submitted
even if Alcaller, Inc. offers other methods by which consumers may opt-out.
12. Alcaller, Inc. has established a supervisory review process regarding its compliance with
the rules for outbound marketing situations and maintains records of companys
compliance for a minimum period of one year. Specifically, sales personnel must obtain
supervisory approval of any proposed outbound marketing request for customer approval.
13. Alcaller, Inc. maintains a record of its sales and marketing campaigns that use
customers CPNI. These records reflect a description of the campaigns, the specific CPNI
used in the campaign and what products or services were offered as part of the campaign.
These records are retained for a minimum of one year.