Legal Stuff

Customer Proprietary Network Information Policy -01.01.2025v1.8

Bridger Systems, LLC. is committed to protecting the privacy of its customers. We must follow specific rules and regulations regarding how we use and protect our customers proprietary network information “CPNI”. CPNI data is information that is related to how you use our services, usage behavior, technical information, call records, and information on your bills pertaining to subscribed services that match your address or phone numbers. Specific examples of CPNI protected data are billing and payment details, technical designs and solutions you use, local, national, international usages, any types of behavior or pattern usages, consumption amounts, data, directory assistance charges, or emergency access. We may not use, share, sell or market products and services to you from information protected by CPNI.

Information that is not considered protected by the laws and regulations of CPNI include publicly available information or information you may share with the public. These types of information include Customer Name or DBAs, street address, advertised phone numbers, collectively reported and anonymized aggregated information not specific to you as our customer. Total Network Utilization, Collective throughput, and other key metrics we use to measure the quality of our services are not considered CPNI data.

We are prohibited from soliciting new services which you do not already subscribe and own, but we may use your CPNI information to provide you with savings or services expansion if your usages are in excess of our 95^th percentile and fair use policies in order to allow you an opportunity to become in compliance with our terms and conditions for serviceability when subscribing to our services.

Opt-Out Rights

You can opt-out of our use of this data for those purposes by denying approval or withdrawing our rights to use the information by sending an email to mycpni@bridger.systems. This would prohibit us from using this information. Those who opt-out will be responsible for any/all charges, overages or penalties related to our Terms and Conditions, Fair Use, or 95^th percentile policies. You cannot be penalized for denying access to this information, it is your right as the customer and revoking authorization does not alter your services or agreement for services. Any revocation of use will remain in effect until express consent is provided by sending an email to mycpni@bridger.systems and grant us permission to use it or as required by law. Lastly, you may provide partial, or limited rights to use specific information for specific purposes by sending the approved scope and limits of use to mycpni@bridger.systems.

Customer Authentication and Accessibility

Due to the current federal privacy rules, we are required to authenticate your identity as a named account holder prior to surrendering or providing any information protected by CPNI rules and regulations. Customers may authenticate when calling our offices or support team using one or more of the following methods.

1. A password saved on file, one time password sent via SMS to the number on record for a customer on record, a single use password emailed to the user of record, or account holder.

2. Contact back – For customers who do not have a password on file, or does not know the password, can request or we may require calling back to the number on record for the person of record, but may also include sending a one time password, email or a password mailed to the address, phone number or email on file for the account holder or person of record for the account.

3. In person at one of our official offices open to the public with a valid, non-expired photo ID, passport, drivers license, or other form of Identification issued by a state or federal agency and recognized as an acceptable means of proving identity.

4. We may also authenticate a customer using key details from invoices, notices, or other key details that only the authorized account holder or person of record would know. For this method we will additionally leverage our voice analysis tools to detect and process your speech via an in-house speech engine that does not store the audio of your calls. It does however store key indicators that are arbitrary for any other use, and how we train our algorithm using a point and trait detector that creates a profile of a callers voice using 230 different speech indicators to detect human vs. synthesized voice and allow matching of current vs, previous callers being the same. This system is proprietary, information regarding the methodology, traces, matching markers and indices are considered company secrets. For this reason, we do not store audio.

In the event of a breach, or theft of CPNI data. We will report as required law. We maintain Cyber Security and Ransom Insurance which may delay notification of a loss or theft of CPNI data event. This includes at the recommendations of investigators or other regulatory bodies.

We reserve the right to deny a change to an account, or release information in the event a customer cannot provide information to prove their identity. We do this to protect you, and we are prohibited from restricting access to your account and services, except where a person’s identity cannot be confirmed.

In the event this document, or the CPNI rules/laws have changed, we may update this policy which is available on request, by visiting our website, your customer user portal or upon request.

If you have questions, or to raise comments, concerns or log complaints regarding our CPNI Policies, reach out at privacy@bridger.systems

We will disclose CPNI in the following circumstances:

• When a customer has authorized us to share CPNI protected data with others.
• Where required by law

We may disclose CPNI protected data under the following circumstances:

• To protect our network, Intellectual properties, or financial interest from abuse, fraud, or illegal use of our services.
• When a carrier requests to know whether a customer has a preferred interexchange carrier (PIC) freeze on their account.
• For directory listing services.
• To provide customers with our services such as delivering them, or when troubleshooting issues.
• To bill the customer for services.

Protecting CPNI

We store all customer information including CPNI protected data in accordance with industry conventions and further secured by being encrypted at rest, with controlled access in datastores following best practices for FIPS and CJIS compliance, access is allowed to necessary resources only and we track access history to ensure the safety of all data we store, including CPNI protected data. Staff working with customers or who have a need to access information that is CPNI protected, are trained on how the data may be used, transmitted, and stored.

Marketing

Our CEO, approves all marketing materials, and ensures that CPNI data is not considered, consumed or used for marketing purposes.

Breach of CPNI Privacy

In the event, we experience a privacy breach and CPNI is disclosed to unauthorized persons, in certain circumstances federal rules require us to report such breaches to law enforcement and/or regulatory authorities. We will inform our customers of a CPNI breach as and when required under applicable rules. Additionally, we maintain records of any discovered breaches in accordance with federal rules and will retain these records for not less than two (2) years.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy. If we make material changes to how we manage our clients information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified near the title of the document. We are not required to notify of changes and it is the responsibility of customers to periodically review and understand the policies in place, where Bridger Systems is required to notify clients, it will be via email or via blog post, so a working email associated with your registered and authorized users is your responsibility.

If you have questions, or to provide comments, raise concerns or log complaints regarding our CPNI Policies:

 reach out at privacy@bridger.systems

Call us: Houston - +17137668001 or Austin +15126908001

Bridger Systems may not interfere with a legal, correctly signed, and approved "Port Out Request to another carrier, even if the account is still under contract. Porting to another provider does not release you from your contract. For accounts late or behind on payments, we reserve the right to deny services, charge late fees, or reconnect fees associated with managing and restoring access to services. For accounts routinely delinquent we reserve the right to put a First and Last Months deposit on the account.

• Any month paid late does not count towards the term of the agreement. Example: If you pay January late and have 22 months left of an agreement your term is still 22 months.
• Routinely delinquent and disconnected or abandoned accounts may be sold to collections at our sole discretion.
• Accounts 2 or more months past due are considered delinquent and will have service disrupted until the balance is paid, which will include the late fees, service restoration, and a deposit equal to two months of billing. If there are costs associated with delinquent accounts, those costs will be billed through, and service will not be restored until all balances are settled.
• We allow one late payment per customer per year without penalty. Subsequent late payments will have late fees levied against them when the payment becomes five business days past due. The initial late fee is 5%, and the following months will receive additional late fees equal to 5% until 50% of the original balance is past due, at which point it will be sold to collections, and we will release all numbers back into the number pool.
• Our General Payment Terms are NET15, we prefer ACH or if you are a Chase business customer, we are in bill pay. For any payment method that incurs processing fees, such as when using a Visa or certain club cards, you will pay for the Authorize.net payment gateway fee, which is currently 2.7 percent or 3.6 for American Express. If using any payment method that would go through Stripe, the processing fee associated with the chosen payment method.
• We offer a no-fee payment method when using cryptocurrency, and we accept Bitcoin, Ethereum, and most altcoins. Contact us for the wallet details.
• We accept checks and cash (please do not mail cash) and do not charge for inbound wires.
• If your balances are settled at any point and a surplus remains, we may issue it as a credit to your account or issue it as a check. We will issue a check for any amount greater than $250.00
• If you return merchandise without an approved RMA, you will be responsible for all shipping costs, as well as any restocking fees. Due to hygiene or safety concerns, some items may not be returned for an RMA.

We are required to charge federal excise taxes and 911 taxes along with certain recovery fees. Any federal tax, 911 tax, or recovery fees will be mandatory, and we do not mark them up, cram your bill, or levy any fees disguised as taxes, etc... We are phone guys who built a phone carrier because we are wanting to shake up the old guard, rock the boat and make some changes.

It is for this reason we are investing heavily into WebRTC, Direct Peering, and other technologies. We do not want to tax you any more than you want to be taxed. Unfortunately these things are necessary at this time and everyone gets charged them (yes, even schools, churches, everybody).

100% of hardware, software, and subscription services, along with 50% of the installation costs, are due on acceptance of work.

An invoice will be issued, and once the initial payment has been received, we will order per the agreement schedule.

Upon completion of the work, we will issue an invoice for the remaining 50% of the installation costs, as well as any add-on items, out-of-scope work, shipping charges, and taxes.

Support services will be prorated and billed upon completion of project work. Support services are offered only on +12-month terms and will auto-renew if we are not notified within 45 days of the term date. Once licensing has been ordered and applied, all licensing will become your responsibility. If support ceases or is terminated once renewals have been used, the remaining months of the term + 60 days will be due. We purchase licensing, calling, and other requirements for your solution ahead of each month's payments and sometimes up front for multiple years. Due to the cost of onboarding and terms of 3rd party solutions, we may have to pay fees to terminate that option, which will become your responsibility. Some licensing is nontransferrable; early termination forfeits these services and options if we cannot transfer them.

Our carrier services are offered on an initial +36 month term. We typically purchase all three years of licensing and other subscribed features the second month after onboarding services. Due to this, early termination is on a buy out term.

These are our general billing terms, see the MSA and project agreement for your specific terms as they may be altered or require different conditions.

As a carrier, we must follow the rules, laws, and mandates on the books for all federal regulations and rulings from the FCC and other governing bodies. The following is our commitment to you, the customer, and to the laws which we must follow.

• All calls to or from our network must contain valid caller ID data. We must reject any call not containing valid information in the correct format.
• We must comply with lawful intercept requests accompanied by a warrant. We will not answer lawful intercept requests not accompanied by a warrant.
• We must comply with all TRACED requests and cooperate with involved parties.
• Any call labeled as SPAM will be rejected unless a client requests those calls be sent on. We make no guarantees these calls will be completed if marked as spam as they enter our network and are authorized to send to you.
• Every location using voice services on our network must have a registered E911 location and number registered with the local PSAP. We pass through GEO data to allow the requirements for "Reporting within Meters." Any call with invalid, incomplete E911 data will land in the national call center, and we will pass through all charges associated with these calls.
• We are required to verify your business for "Know Your Customer" as part of our TRACED compliance. Customers opting for our CallerVeritas are eligible to purchase a Full chain certificate for the highest level of trust.
• All SMS traffic and customers using SMS must register for a 10DLC campaign.
• We will reject calls sent from DNO numbers and to DNC opt-in numbers. We are not required to notify you of such events.

We employ advanced tools, Industry tools, AI detection, and anomalous pattern detection tools. However, these tools are not bulletproof. If you opt for our white glove, turn-up, and test offering then you will be less likely to be hacked, become a victim to toll fraud, and be a member of our $0 dollars billed in toll charges club. Any customer who declines the service, is 100% responsible for toll charges made from their system.

we do not charge for our white glove service. If you have an enterprise NGFW with an active security suite and current firmware, and we do not have to open the solution or the world to your system, you will be in a much better security position. We do this for you, and we want to ensure you are safe and sound not a sitting duck with a target on your back.

We have clients who like to haggle, there are vendors who like to write 3 proposals - The Crap one, the Good One and The Expensive one. They don't care which you buy, but they expect you to accept the middle. If you accept the top shelf, that is just icing on the cake.

We recommend the right one, we lead with our best foot, and best pricing. if our offer is too expensive, we may revisit expectations and reevaluate potential options based on the revised understanding. Otherwise if the price needs to come down, the question should become "What can come out". We have the best rate in the industry and we are not working for free, or giving away our time because time is the most precious thing we have and we do not see you beating down any doors looking to work for free. So either lead by example or lead from the bench, it doesn't change much for us. If you feel compelled to haggle, we welcome you to use our haggle calculator.

How the Haggle Promo works (and this is good for any project or scope of work, and you are free to use it any time you like, and as many times as you like.

1. Take your proposals final amount.
2. Multiply it by .25
3. Add that amount to the total, and take that new total, multiply it by .15 and that sum is your Haggle Discount

Example Ticket value is $10,019 to determine discount follow these steps.

Take the final ticket amount multiply by .25. This is the initaial sum. Now take the summed amout, multiply it by .15 and the value is with your discount applied.