CoreDial, LLC Employee CPNI Training

1. CoreDial, LLC EmployeeCPNI Training May 30, 2013 DRAFT A

2. Introduction The FCC requires companies providing telecommunications services, Internet access services, voice messaging services and/or interconnected VoIP services: • To obtain customer approval prior to using, disclosing or permitting access to customer proprietary network information (CPNI), and • Follow procedures for obtaining customer approval. This training will provide CoreDial’s employees and contractors with an overview of the Company’s CPNI policy and CPNI Verification Process. A separate CPNI training handout will be provided to each employee and contractor.

3. Key Definitions

4. Examples of CPNI Personal Information • User Name • Passwords • Name • Address • Phone Numbers Any and All Call Activity Current and/or Past Features and Services such as: • Call Forwarding • Voicemail • Call Waiting • Long Distance • Service Plans • Any services with monthly recurring charges • Any services with non-recurring charges • Any included services, service bundles or packages

5. Customer Rights and Protections Customer CPNI Rights include: • Limit, restrict or prohibit the use of, disclosure of or access to their individual CPNI. • CoreDial has a legal obligation to abide by each customer’s CPNI decision. • CoreDial is required to keep records of each customer’s CPNI decision. • CoreDial has a legal duty to utilize reasonable measures to protect CPNI from unauthorized access or disclosure. • With limited legal exception CoreDial cannot use, disclose or permit access to a customer’s CPNI without approval from the customer.

6. CoreDial’s CPNI Policy CoreDial has established the following procedures to ensure compliance with the FCC’s CPNI Rules and Regulations. All CoreDial employees and contractors are required to adhere to the following CPNI procedures. Failure to do so may be grounds for termination from CoreDial and/or further legal action.

7. CoreDial CPNI Verification ProcessInbound Callers Any inbound caller to any CoreDial department or employee that requests access to CPNI must first be validated: • Authenticate the caller using the Portal’s PIN System • Log into the Portal • Select the customer’s PBX • On the customer’s “PBX Info” screen enter the PIN that the customer gives you in the “PBX PIN:” field and click the “Validate PIN” button. • If the PIN is successfully validated you may provide the customer’s CPNI to the caller. • If the PIN is not valid, you may validate the customer using the alternate method #2 below. No CPNI may be be provided until the caller is validated.

8. CoreDial CPNI Verification ProcessInbound Callers • Authenticate by calling the customer back with any number that is registered to that customer’s PBX • Log into the Portal • Select the customer’s PBX • On the customer’s “Phone Numbers” screen , a list of phone numbers will appear. Ask the caller to suggest a number to be called. DO NOT PROVIDE the caller with any number from the list. • If the number the caller provided is on the “Phone Numbers” screen, hang up and call the customer back using that phone number. The caller is now validated and may be provided CPNI No CPNI may be be provided until the caller is validated.

9. CoreDial CPNI Verification ProcessPortal Users • All portal users must log into the portal using their CoreDial supplied user name and password. • Lost passwords are not to be recovered using the “Forgot Password?” option. • If the user cannot use the portal’s automated password recovery utility the user must call CoreDial and be validated as an Inbound Caller. No CPNI may be be provided until the caller is validated.

10. CoreDial CPNI Verification ProcessEmail Users Email users do not have the ability to gain access to or change CPNI No CPNI may be be provided until the caller is validated.

11. CPNI Verification Process Any employee or contractor having questions or concerns about CoreDial’s CPNI policy or verification process should be directed to their supervisor. Customer’s may contact CoreDial via: CoreDial Customer Care Department 215-297-4400, Option 2