CPNI Policy

Last Updated: June 30, 2025

STAR-TECH IT SOLUTIONS INC. and its affiliates (“Service Provider”) are committed to protecting the privacy of our customers and their End Users (collectively, “Users”). This Customer Proprietary Network Information (“CPNI”) Policy, incorporated into the Service Agreement (including any Order or Letter of Authorization (LOA)), outlines additional protections for certain information about how you use our VoIP services powered by the SkySwitch platform, as required by the Federal Communications Commission (FCC) under 47 CFR § 64.2003 et seq. This policy supplements the Service Provider Privacy Policy at https://startechitsolutions.com/privacy-policy.

CPNI Protections

CPNI includes information about the quantity, technical configuration, type, destination, location, and usage of the telecommunications or VoIP Services we provide to you, as well as related billing information, when matched with your name, address, or telephone number. Examples include:

• Call records (e.g., phone numbers called or received, call duration, frequency).

• Service type and technical configuration (e.g., VoIP settings, SIP traffic).

• Billing records (e.g., long-distance charges, directory assistance charges).

• Location data associated with E911 services.

CPNI does not include your name, address, telephone number, aggregate or non-individualized data, customer premises equipment, or Internet access services.

Service Provider will not use or disclose your CPNI for purposes other than providing Services, billing, or as permitted below, without your consent, as required by FCC regulations.

Approval for CPNI Use

Service Provider may use your CPNI to market related telecommunications or VoIP services (e.g., new features, promotions) or share it with our affiliates, agents, or underlying service providers (e.g., SkySwitch or its carriers) for such purposes, only with your express consent. You may grant, deny, or withdraw consent at any time by:

• Contacting us at ar@startechitsolutions.com.

• Updating your preferences via the Account Manager (e.g., SkySwitch Dashmanager).

• Calling us at 801-654-1185.

Denying or restricting CPNI use for marketing will not affect the quality or delivery of Services, now or in the future. Your consent or denial remains valid until your Services are terminated or you update your preference.

Disclosure of CPNI

Service Provider may disclose CPNI in the following circumstances:

• With your express consent, as described above.

• To provide Services, including troubleshooting, technical support, or E911 compliance.

• For billing and invoicing purposes.

• For directory listing services, unless you opt for an unlisted number.

• To verify whether you have a preferred interexchange carrier (PIC) freeze.

• To protect Service Provider’s rights or property, or those of Users or service providers, from fraudulent, abusive, or unlawful use of Services.

• When required by law, such as in response to court orders, subpoenas, warrants, or regulatory requirements (e.g., FCC E911 reporting).

• To emergency services (e.g., 911 centers) to protect individuals or the public from immediate threats of serious harm.

When sharing CPNI with vendors, partners, or underlying providers (e.g., SkySwitch or its carriers), we ensure they are bound by confidentiality obligations to protect your information and use it only for authorized purposes.

Client Authentication

To protect your CPNI, Service Provider requires authentication before disclosing account or billing information or providing technical support. You must designate authorized contacts who may access your account or CPNI. To update the authorized contacts list, submit a request on company letterhead via fax or email to support@startechitsolutions.com.

For phone inquiries to our 24-hour support center, we authenticate callers using one of the following methods:

• Confirming a pre-established password or PIN (not derived from your Social Security number, mother’s maiden name, pet name, or account telephone number).

• Calling back the telephone number associated with your account.

• Mailing requested documents to your address of record.

If you forget your password or PIN, we will ask verification questions known only to you and Service Provider. You will then be required to establish a new password or PIN. Calls to report out-of-service conditions (e.g., to open a trouble ticket) do not require authentication.

You are responsible for maintaining an up-to-date authorized contacts list. Service Provider is not liable for missed notifications due to outdated contact information.

Your Rights

You have the right to:

• Access and review your CPNI, subject to authentication.

• Correct inaccurate CPNI.

• Opt out of CPNI use for marketing purposes without affecting Service quality.

• Be notified of any unauthorized access to your CPNI, as required by law.

To exercise these rights, contact us at ar@startechitsolutions.com.

Notification of Changes

Changes to this CPNI Policy will be posted at https://startechitsolutions.com/cpni-policy and effective thirty (30) days after posting. Continued use of Services after this period constitutes acceptance of the revised policy. If a change materially affects your rights, you may object within ten (10) days by contacting us, and we will work to resolve your concerns.

Contacting Us

For questions about this CPNI Policy or your rights, contact us at:

• General Inquiries: mail@startechitsolutions.com

• Support: support@startechitsolutions.com

• Billing: ar@startechitsolutions.com

• Mailing Address: STAR-TECH IT SOLUTIONS INC., 1050 S 400 E, Centerville, UT 84014

• Phone: 801-654-1185