Cpni Policy

Callistrox LLC — CPNI Privacy Notice

 

Last Updated: July 10, 2026

Consistent with Section 222 of the Communications Act and the FCC’s CPNI rules (47 C.F.R. § 64.2001 et seq.), Callistrox LLC (“Callistrox”) has adopted the policies below governing the collection, access, use, and storage of Customer Proprietary Network Information (“CPNI”) in connection with the telecommunications and interconnected VoIP services it provides.

Definition of CPNI

 

CPNI is information a telecommunications provider obtains about a customer’s use of telecommunications services — including the quantity, technical configuration, type, destination, location, and amount of use of the service. Typical examples include numbers called, call duration, calling patterns, and directory-assistance charges appearing on a monthly statement. CPNI does not include customer names, addresses, or phone numbers, which are treated as subscriber list information under applicable law.

Use of CPNI

 

Callistrox does not use CPNI for any purpose beyond what applicable law permits. CPNI is disclosed to affiliates, vendors, or agents only where necessary to carry out a legitimate business activity tied to services already provided to the customer. Where disclosure is not legally required and not otherwise permitted under FCC rules, Callistrox obtains customer consent before using or sharing CPNI. Callistrox follows industry-standard safeguards to prevent unauthorized access to CPNI, though no method can guarantee prevention of every unauthorized attempt.

Customer Notification of Account Changes

 

Callistrox notifies customers promptly of changes to address of record, authentication credentials, online account settings, or passwords.

Employee Training

 

Callistrox personnel are trained on when CPNI access is, and is not, authorized. Personnel may not release CPNI in response to a customer-initiated call except where:

• The customer has a pre-established password and provides it when contacting Callistrox about CPNI matters;
• The requested information is sent to the customer’s address of record; or
• Callistrox calls the customer’s number of record and speaks with the individual originally identified when service began.

Business Customers

 

Callistrox may establish alternative authentication and CPNI-handling procedures for business customers with a dedicated account representative and a contract addressing CPNI protection.

Disciplinary Procedures

 

Callistrox treats compliance with the Communications Act and FCC CPNI rules as a serious obligation. Violations by employees or agents may result in disciplinary action — including retraining, reprimand, negative performance review, probation, or termination — depending on severity, whether it is a repeat violation, whether guidance was sought, and whether the violation appears deliberate.

CPNI in Sales and Marketing

 

Callistrox does not currently use CPNI in marketing campaigns. If it does so in the future, Callistrox will maintain records of each campaign describing the CPNI used and the products or services offered, and will implement a system for obtaining and tracking prior opt-in customer approval consistent with FCC rules, including:

• Notifying customers of their right to restrict use, disclosure of, and access to CPNI before requesting approval;
• Using opt-in consent wherever approval is required before using, disclosing, or granting access to CPNI;
• Treating a customer’s approval or disapproval as effective until affirmatively changed by the customer;
• Retaining approval records for at least two years;
• Providing individualized notice when soliciting CPNI approval, consistent with FCC Rule 64.2008(c), retained for at least one year; and
• Maintaining a supervisory review process for outbound marketing involving CPNI, with records retained for at least one year consistent with FCC Rule 64.2009(d).

FCC Notification

 

If Callistrox’s opt-in mechanisms fail to work properly to a degree beyond an isolated anomaly, Callistrox will provide written notice to the FCC within five (5) business days of discovering the issue.

Third-Party Access to CPNI

 

Before granting joint venture partners or independent contractors access to individually identifiable CPNI, Callistrox requires a confidentiality agreement ensuring compliance with this policy and obtains opt-in customer consent for such disclosure. Outside agents must certify that CPNI will be used only for the purpose for which it was provided. Express written customer authorization is required before CPNI is provided to a new carrier, except where otherwise required by law. Callistrox does not sell or market CPNI to third parties.

Breach Notification

 

If an unauthorized disclosure of CPNI occurs, Callistrox will notify the United States Secret Service and the FBI within seven (7) days of discovery, and will wait an additional seven (7) days after government notification before notifying affected customers — unless Callistrox determines there is an immediate risk of irreparable harm, in which case customer notice will not be delayed. Records of any breach are retained for at least two (2) years.

Annual CPNI Certification

 

Consistent with 47 C.F.R. § 64.2009(e), Callistrox will submit an annual CPNI Certification of Compliance to the FCC by March 1st (or any later deadline the FCC establishes), certifying compliance with federal CPNI requirements for the preceding calendar year.

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Callistrox LLC Address: 1001 S. Main St. #7752, Kalispell, MT 59901, United States Phone: (406) 316-4343 | Email: support@callistrox.com | Web: https://callistrox.com/