Annual 47 C.F.R. S: 64.2009(e) CPNI Certification Template EB Docket 06-36 Annual 64.2009(¢) CPNI Certification for 2011 covering the prior calendar year 2010 1. Date filed: March 1, 2011 2. Name of company(s) covered by this certification: All American Telecom, LLC 3. Form 499 Filer ID: 827960 4, Name of signatory: Paul T. Watson 5, Title of signatory: Secretary 6. Centification: |, Paul T, Watson, certify that I am an officer of the company named above, and acting as an agent of the company, that I have persona! knowledge that the company has established operating procedures that are adequate to ensure compliance with the Commission's CPNI rules. See 47 C.F.R. S: 64.2001 et seq Attached to this certification is an accompanying statement explaining how the company's procedures ensure that the company is in compliance withthe requirements (including those mandating the adoption of CPNI procedures, training, recordkeeping, and supervisory review) set forth in section 64,2001 et seq. of the Commission’s rules. ‘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 sulject it to enforcement action Remainder of this page left intentionally blanka Paul Waist, Secrclafy Signed Attachments: Accompanying Statement explaining CPNI procedures (“Attachment A”) Subscribed and sworn to by Paul Watson before me on the 1* day of March, 2011 who is personally known to me. DeAgetre M. Gainer NOTARY PUBLIC Notary public, State oe 5) ty a {STATE OF FLORIDA ‘Comm 00870898 My commission expires __ 3 |. Pole GAT expires 3/14/2014Attachment A Annual Customer Proprietary Network Information (CPND) Procedural Statement of All American Telecom, LLC (2) All American Telecom, LLC (the “Company”) has implemented a system by which the status of a customer's CPNI approval can be clearly established prior to the use of CPNI. Each call center representative (phone, email, or chat) asks five security questions to verify the account prior to releasing information. Each representative is trained to ask the questions, listed on the sales form/script, when a sales/eustomer service eall is received by the call center. Additionally, the privacy policy on the back of the Lifeline form addresses our CPNI position with the subseriber. ‘The Company will not disclose, transfer, sell or otherwise communicate CPNI to any third party other than the Company's subsidiaries and affiliates, and each of (i) their employees or (ii) vendors and contractors operating under confidentiality agreements and subject to the privacy policy. By signing the Lifeline form the customer is expressly opting-in (consenting) to permit the Company to disclose your CPNI to companies that perform marketing services for us ot to other partners who with which we have joint marketing agreements, such as to offer you additional product or services. If the customer desires to-opt-out they must notify the Company in writing to withdraw this consent. The company may release CPNI if required to do so by law, ‘or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright Law) or respond to a court order, subpoena, or search warrant (Mandatory Disclosures”), (b) The company has implemented personnel training as to when personnel are or are not authorized to use CPNI including an express disciplinary process, The Telecom Service Center (“TSC”), the inbound call center for the company, trains each representative to only discuss account information with the account holder o authorized user(s) on the account, In-depth training occurs with each representative upon hiring in the first two weeks before they begin taking live calls, Additionally, ifthe call is not validated using the security questions by the representative then the Quality Assurance Department is alerted and the representative will be subject to disciplinary action up to and including termination of employment. (©) The company maintains records for atleast one year of sales and marketing campaigns ofits own, its agents, affiliates, joint venture partners and any independent contractors, that use its Such records include a description of each campaign, the specific CPNI that ‘was used in the campaign and what products and services were offered as a part of the campaign, All records including CPNI for each campaign are housed and maintained in STRATA, a media buying software created for the sales and marketing industry. customers’ CPN. (@) Outbound marketing efforts are handled by TSC and the supervisory review process and the training are the same as above described.(©) The company has not taken any actions against any individual ot entity that unlawfully obtains, uses, discloses or sells CPNI nor has the company received any customer complaints in the past year conceming the unauthorized release of CPNI. (©) Currently, the company’s opt-out mechanism in place is submission or non-submission of the Company’s Lifeline form or receipt of a letter from the customer stating they elect to opt-out of sharing their CPNI, ‘The privaey policy on the back of the Lifeline form in the Opt-In Election section defines the policy and if the subscriber would like to Opt-Out, they simply do not sign the Lifeline form or remit in writing their option. Customers are also instructed to contact customer service for any questions or clarifications in regards to CPNI