Customer Proprietary Network

Information

Compliance Manual and Operating Procedures

PosTrack Technologies, Inc.
Table of Contents
I. DEFINITIONS ............................................................................................................3
II. STATEMENT OF CORPORATE POLICY .............................................................................4
III. USE OF CPNI IN GENERAL ........................................................................................5
IV. GUIDELINES FOR USE OF CPNI...................................................................................5
V. OBTAINING CUSTOMER APPROVAL FOR USE OF CPNI ........................................................6
VI. NOTICES REQUIRED FOR USE OF CPNI .........................................................................7
VII. COMPANY SAFEGUARDS AND RECORDKEEPING REQUIREMENTS. ......................................... 10
APPENDIX 1 .............................................................................................................. 13
APPENDIX 2 .............................................................................................................. 15
APPENDIX 3 .............................................................................................................. 16

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I. DEFINITIONS
Affiliate: A person that (directly or indirectly) owns or controls, is owned or controlled by, or is
under common ownership or control with, another person. The term "own" means to own an
equity interest (or the equivalent thereof) of more than 10 percent.

Carrier: See Telecommunications Carrier.

CMRS: Commercial Mobile Radio Service.

Communications-Related Services: Telecommunications service or interconnection voip

Services, information services typically provided by telecommunications carriers, and services
related to the provision or maintenance of customer premises equipment.

Company: PosTrack Technologies, Inc. or (PosTrack)

Customer: A person or entity to which a telecommunications carrier is currently providing

service.

Customer Proprietary Network Information (CPNI): Information that relates to the quantity,
technical configuration, type, destination, location, and amount of use of a telecommunications
service or interconnected voip service subscribed to by any customer of a telecommunications
carrier, and that is made available to the carrier by the customer solely by virtue of the carrier-
customer relationship; and Information contained in the bills pertaining to telephone exchange
service or telephone toll service received by a customer of a carrier. CPNI does not include
subscriber list information.

Customer Premises Equipment: Equipment employed on the premises of a person (other than
a carrier) to originate, route, or terminate telecommunications.

FCC: Federal Communications Commission.

Information Service: The offering of a capability for generating, acquiring, storing,

transforming, processing, retrieving, utilizing, or making available information via
telecommunications, and includes electronic publishing, but does not include any use of any
such capability for the management, control, or operation of a telecommunications system or
the management of a telecommunications service or interconnected voip service. Information
Services Typically Provided by Telecommunications

Carriers: Information services that telecommunications carriers typically provide, such as

Internet access or voice mail services. The term does not include retail consumer services
provided using Internet websites (such as travel reservation services or mortgage lending
services), whether or not such services might otherwise be considered to be information
services.

Local Exchange Carrier: Any person engaged in the provision of telephone exchange service or
exchange access. Such term does not include a person insofar as such person is engaged in the

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provision of a commercial mobile service (except to the extent that the FCC determines that
such service should be included in the definition of the term).

Opt-In Approval: A method for obtaining customer consent to use, disclose, or permit access to
the customer's CPNI. This approval method requires that the carrier obtain the customer's
affirmative, express consent allowing the requested CPNI usage, disclosure, or access after the
customer is provided appropriate notification of the carrier's request.

Opt-Out Approval: A method for obtaining customer consent to use, disclose, or permit access
to the customer's CPNI. Under this approval method, a customer is deemed to have consented
to the use, disclosure, or access to the customer's CPNI if the customer has failed to object
thereto within the prescribed waiting period, after the customer is provided appropriate
notification of the carrier's request for consent.

Subscriber List Information: Any information (1) identifying the listed names of a carrier's
subscribers and the subscribers' telephone numbers, addresses, or primary advertising
classifications (as such classifications are assigned at the time of the establishment of such
service), or any combination of such listed names, numbers, addresses, or classifications; and
(2) that the carrier or an affiliate has published, caused to be published, or accepted for
publication in any directory format.

Telecommunications Carrier: Any provider of telecommunications service, except that such

term does not include aggregators of telecommunications service (as defined in 47 USC 226)

Telecommunications service: The offering of telecommunications for a fee directly to the public,
or to such classes of users as to be effectively available directly to the public, regardless of the
facilities used.

Interconnected VoIp Service: The offering of a service that (1) enables real-time, two-way voice
communications; (2) requires a broadband connection from user’s location; (3) requires internet
protocol-compatible customer premise equipment (CPE); and (4) permits users generally to
receive calls that originate on the public switched telephone network and terminate calls to the
public switched telephone network (as defined in 47 C.F.R. 9.3).

II. STATEMENT OF CORPORATE POLICY

The policy of PosTrack is to comply with the letter and spirit of all laws of the United States,
including those pertaining to CPNI contained in § 222 of the Telecommunications Act of 1996,
as amended, 47 USC 222, and the FCC's regulations, 47 CFR 64.2001-.2009. The Company's
policy is to rely on the involvement of high-level management to ensure that no use of CPNI is
made until a full review of applicable law has occurred.

The FCC's regulations, 47 CFR 64.2009, require the Company to implement a system to clearly
establish the status of a customer's CPNI approval prior to the use of CPNI, and to train its
personnel as to when they are, and are not, authorized to use CPNI, and to have an express

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disciplinary process in place. This Manual constitutes the Company's policies and procedures
related to CPNI.

All employees are required to follow the policies and procedures specified in this Manual. Any
questions regarding compliance with applicable law and this Manual should be referred to
Donald Heidrich, CEO (815) 768-2065 or Tony Brncich, SR VP of Telecom (815) 768-
2069.

Any violation of, or departure from, the policies and procedures in this Manual shall be reported
immediately to one or both of the above individuals.

III. USE OF CPNI IN GENERAL

Except as otherwise described in this Manual, when the Company receives or obtains CPNI by
virtue of its provision of a telecommunications service or interconnected voip service, it can only
use, disclose, or permit access to individually identifiable CPNI in its provision of:

1. The telecommunications service or interconnected voip service from which the

information is derived; or

2. Services necessary to, or used in, the provision of the telecommunications service or
interconnected voip service, including the publishing of directories.

IV. GUIDELINES FOR USE OF CPNI

A. The Company may not use, disclose, or permit access to CPNI to market service
offerings to a customer that are within a category of service to which the customer does
not already subscribe from the Company, unless the Company has customer approval to
do so (except that no customer approval is necessary in the situations described in
IV.D.)

B. The Company cannot use, disclose or permit access to CPNI to identify or track
customers that call competing service providers. Thus, the Company may not use local
service CPNI to track all customers that call its local service competitors.

C. The Company may use, disclose, or permit access to CPNI for the purpose of providing
or marketing service offerings among the categories of service (i.e., local,
interexchange, and CMRS) to which the customer already subscribes from the Company,
without customer approval.

1. If the Company provides different categories of service, and a customer subscribes

to more than one category of service offered by the Company, the Company may
share CPNI among its affiliated entities that provide a service offering to the
customer, without customer approval.

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 2. If the Company provides different categories of service, but a customer does not
subscribe to more than one offering by the carrier, the carrier is not permitted to
share CPNI with its affiliates, except with the customer's approval as discussed in V.,
below.

D. The Company may use, disclose, or permit access to CPNI, without customer approval,
as described below:

1. To provide inside wiring installation, maintenance, and repair services.

2. CMRS providers may use, disclose, or permit access to CPNI for the purpose of
conducting research on the health effects of CMRS.

3. To market services formerly known as adjunct-to-basic services, such as, but not
limited to, speed dialing, computer-provided directory assistance, call monitoring,
call tracing, call locking, call return, repeat dialing, call tracking, call waiting, caller
I.D., call forwarding, and Centrex features.

4. For the provision of customer premises equipment and call answering, voice mail or
messaging, voice storage and retrieval services, fax store and forward, and protocol
conversion.

5. To protect the rights or property of the carrier, or to protect users of those services
and other carriers from fraudulent, abusive, or unlawful use of, or subscription to,
such services.

6. Initiate, render, bill and collect for telecommunications service or interconnected

voip services.

7. Provide call location information concerning the user of a commercial mobile service
in emergency situations.

V. OBTAINING CUSTOMER APPROVAL FOR USE OF CPNI

A. Soliciting Customer Approval.
The Company may obtain approval through written, oral or electronic methods;

1. If the Company relies on oral approval, it bears the burden of demonstrating that
such approval has been given in compliance with the FCC's regulations.

2. A customer's approval or disapproval to use, disclose, or permit access to CPNI must

remain in effect until the customer revokes or limits such approval or disapproval.

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 3. The Company must maintain records of approval, whether oral, written or electronic,
for at least one year.

B. Use of Opt-Out and Opt-In Approval Processes.

1. The Company may utilize the Opt-out or Opt-in method to obtain approval to use its
customer's individually identifiable CPNI for the purpose of marketing
communications-related services to that customer.

2. The Company may also utilize the Opt-out or Opt-in method to obtain approval to
disclose its customer's individually identifiable CPNI, for the purpose of marketing
communications-related services to that customer, to its agents, to its affiliates that
provide communications-related services, and to its joint venture partners and
independent contractors.

3. If the Company discloses or provides access to CPNI to a joint venture partner or

independent contractor, in addition to obtaining customer approval, it must enter
into confidentiality agreements with such contractors or partners. The confidentiality
agreement must:

i. Require that the independent contractor or joint venture partner use the CPNI
only for the purpose of marketing or providing the communications-related
services for which the Company has provided the CPNI;
ii. Disallow the independent contractor or joint venture partner from using,
allowing access to, or disclosing the CPNI to any other party, unless required
to make such disclosure under force of law; and
iii. Require that the independent contractor or joint venture partner have
appropriate protections in place to ensure the ongoing confidentiality of
consumers' CPNI.

VI. NOTICES REQUIRED FOR USE OF CPNI

A. Mandatory Notices Regarding Solicitation

1. Prior to soliciting any customer approval to use, disclose, or permit access to

customers' CPNI, the Company must notify the customer of the customer's right to
restrict use of, disclosure of, and access to, the customer's CPNI.

2. The Company must maintain records of the notification, whether oral, written or
electronic, for at least one year.

3. Content of Notice: Customer notification must provide sufficient information to

enable the customer to make an informed decision whether to permit a carrier to
use, disclose, or permit access to, the customer's CPNI. The notification must:

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 i. State that the customer has a right, and the Company has a duty, under
federal law, to protect the confidentiality of CPNI.
ii. Specify the types of information that constitute CPNI and the specific entities
that will receive the CPNI, describe the purposes for which CPNI will be used,
and inform the customer of the right to disapprove those uses, and deny or
withdraw access to CPNI at any time.
iii. Advise the customer of the precise steps the customer must take in order to
grant or deny access to CPNI, and must clearly state that a denial of approval
will not affect the provision of any services to which the customer subscribes.
However, the Company may provide a brief statement, in clear and neutral
language, describing consequences directly resulting from the lack of access
to CPNI.
iv. Be comprehensible and not misleading.
v. State that any approval or denial of approval for the use of CPNI outside of
the service to which the customer already subscribes from that carrier is valid
until the customer affirmatively revokes or limits such approval or denial.

4. If written notification is provided, the notice must be clearly legible, use sufficiently
large type, and be placed in an area so as to be readily apparent to a customer.

5. If any portion of a notification is translated into another language, then all portions
of the notification must be translated into that language.

6. The Company may state in the notification that the customer's approval to use CPNI
may enhance the carrier's ability to offer products and services tailored to the
customer's needs. The Company also may state in the notification that it may be
compelled to disclose CPNI to any person upon affirmative written request by the
customer.

7. A carrier may not include in the notification any statement attempting to encourage
a customer to freeze third-party access to CPNI.

8. The Company's solicitation for approval must be proximate to the notification of a

customer's CPNI rights.

B. Opt-Out Notice Requirements

The Company must provide notification to obtain Opt-out approval through electronic or
written methods, but not by oral communication (except for one-time use of CPNI, as
discussed in VI.E., below). The contents of any such notification must comply with the
requirements of VI.A.3., above.

1. The Company must wait a 30-day minimum period of time after giving customers
notice and an opportunity to opt-out before assuming customer approval to use,

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 disclose, or permit access to CPNI. The Company may, in its discretion, provide for a
longer period. The Company must notify customers as to the applicable waiting
period for a response before approval is assumed.

i. In the case of an electronic form of notification, the waiting period begins to

run from the date on which the notification was sent.
ii. In the case of notification by mail, the waiting period begins to run on the
third day following the date that the notification was mailed.

2. If the Company uses the Opt-out mechanism, it must provide notices to its
customers every two years.

3. Use of E-mail: If the Company uses e-mail to provide Opt-out notices, it must
comply with the following additional requirements:

i. The Company must have express, verifiable, prior approval from consumers to
send notices via e-mail regarding their service in general, or CPNI in
particular;
ii. Customers must be able to reply directly to e-mails containing CPNI notices in
order to opt-out.
iii. Opt-out e-mail notices that are returned to the Company as undeliverable
must be sent to the customer in another form before the Company may
consider the customer to have received notice; and
iv. The subject line of the e-mail must clearly and accurately identify the subject
matter of the e-mail.
v. The Company must make available to every customer a method to opt-out
that is of no additional cost to the customer and that is available 24 hours a
day, seven days a week. The Company may satisfy this requirement through a
combination of methods, so long as all customers have the ability to opt-out
at no cost and are able to effectuate that choice whenever they choose.

C. Opt-In Notice Requirements

The Company may provide notification to obtain Opt-in approval through oral, written,
or electronic methods. The contents of any such notification must comply with the
requirements described in §VI.A.3., above.

D. Notice Requirements Specific to One-Time Use of CPNI

1. The Company may use oral notice to obtain limited, onetime use of CPNI for inbound
and outbound customer telephone contacts for the duration of the call, regardless of
whether carriers use Opt-out or Opt-in approval based on the nature of the contact.

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 2. The contents of any such notification must comply with the requirements of VI.A.3.,
except that the Company may omit any of the following if not relevant to the limited
use for which the carrier seeks CPNI:

i. The Company need not advise customers that if they have opted-out
previously, no action is needed to maintain the Opt-out election.
ii. The Company need not advise customers that it may share CPNI with its
affiliate(s) or third parties and need not name those entities, if the limited
CPNI usage will not result in use by, or disclosure to, an affiliate or third
party.
iii. Carriers need not disclose the means by which a customer can deny or
withdraw future access to CPNI, so long as carriers explain to customers
that the scope of the approval the carrier seeks is limited to one-time use.
iv. Carriers may omit disclosure of the precise steps a customer must take in
order to grant or deny access to CPNI, as long as the carrier clearly
communicates that the customer can deny access to his CPNI for the call.

F. Except for use and disclosure of CPNI that is permitted without customer approval as
discussed above, and except for the purpose of marketing communications-related
services to a customer, the Company may only use, disclose, or permit access to a
customer’s individually identifiable CPNI subject to opt-in approval.

VII. COMPANY SAFEGUARDS AND RECORDKEEPING REQUIREMENTS.

A. Management Safeguards

1. Training of Company personnel will include review of this Manual by all new
employees and all existing employees who have not previously done so.

2. The Company will provide additional training on an as-needed basis.

3. Company personnel will make no decisions regarding CPNI without first consulting
one of the following individuals:

Donald Heidrich

Tony Brncich

The Company's personnel must obtain supervisory approval from a person listed
above regarding any proposed use of CPNI.

4. In deciding whether the contemplated use of the CPNI is proper, the individual(s)
listed in the previous paragraph will consult this manual, applicable FCC regulations
or Compliance Guide, and, if necessary, legal counsel.

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 5. The person(s) listed in VII.A.3. above will personally oversee the use of approval
methods and notice requirements for compliance with all legal requirements.

6. The person(s) listed in VII.A.3. above will also ensure that the Company enters into
confidentiality agreements, as necessary, with any joint venture partners or
independent contractors to whom it discloses or provides access to CPNI.

7. Any improper use of CPNI will result in disciplinary action in accordance with
established Company disciplinary policies. Any improper use shall be treated as a
serious offense, and may result in suspension or termination of employment in
appropriate cases. Any company personnel making improper use of CPNI will
undergo additional training to ensure future compliance.

8. The Company will provide written notice within five business days to the FCC of any
instance where the Opt-out mechanisms do not work properly, to such a degree that
consumers' inability to opt-out is more than an anomaly.

i. The notice will be in the form of a letter, and will include the Company's
name, a description of the Opt-out mechanism(s) used, the problem(s)
experienced, the remedy proposed and when it will be/was implemented,
whether the relevant state commission(s) has been notified and whether it
has taken any action, a copy of the notice provided to customers, and
contact information.
ii. The Company must submit the notice even if the Company offers other
methods by which consumers may opt-out.

9. On an annual basis, a corporate officer of the Company will sign a compliance

certificate (Appendix 1) stating that the officer has personal knowledge that the
company has established operating procedures that are adequate to ensure
compliance with the FCC's rules.

10. The Company will review these procedures on a continuing basis to ensure
compliance with all FCC regulations, and will revise these procedures as needed to
reflect any subsequent revisions to the applicable Rules and Regulations addressing
CPNI.

B. Recordkeeping

1. The Company will maintain records of its own sales and marketing campaigns that
use CPNI in files clearly identified as such. These records include a description of
each campaign, the specific CPNI that was used in the campaign, and the products
and services that were offered as a part of the campaign. The Company will
maintain these records in its offices for a minimum of one year.

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 2. The Company will maintain records of its affiliates' sales and marketing campaigns
that use CPNI in files clearly identified as such. These records will include a
description of each campaign, the specific CPNI that was used in the campaign, and
the products and services that were offered as a part of the campaign. The
Company will maintain these records in its offices for a minimum of one year.

3. The Company will maintain records of all instances where it disclose or provides
CPNI to third parties, or where third parties are allowed access to CPNI, in files
clearly identified as such. These records will include a description of each campaign,
the specific CPNI that was used in the campaign, and the products and services that
were offered as a part of the campaign. The Company maintains these records in its
offices for a minimum of one year.

4. The Company's policy is to maintain records of customer approval for use of CPNI,
as well as notices required by the FCC's regulations, for a minimum of one year. The
Company maintains records of customer approval and disapproval for use of CPNI in
a readily-available location that is consulted on an as-needed basis.

5. The Company will maintain separate files in which it will retain any court orders
respecting CPNI.

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 APPENDIX 1

CERTIFICATE OF COMPLIANCE WITH PROTECTION

OF CUSTOMER PROPRIETARY NETWORK INFORMATION RULES

Roderick D. Hill, CFO signs this Certificate of Compliance in accordance with § 222 of the
Telecommunications Act of 1996, as amended, 47 USC 222, and 47 CFR 64.2009, on behalf of
PosTrack Technologies, Inc. (Company) . This Certificate of Compliance addresses the
requirement of 47 CFR 64.2009 that the Company provide both a Certificate of Compliance and
a "statement accompanying the certificate" to explain how its operating procedures ensure
compliance with 47 CFR 64.2001- .2009.

On behalf of the Company, I certify as follows:

1. I am the CFO of the Company. My business address is 150 North Scott Street,
Joliet, IL 60432.

2. I have personal knowledge of the facts stated in this Certificate of Compliance. I am

responsible for overseeing compliance with the Federal Communications Commission's
(FCC) rules relating to customer proprietary network information (CPNI)

3. The Company has established a system by which the status of a customer's approval for
use of CPNI, as defined in 47 USC 222(h) (1), can be clearly established prior to the use
of CPNI. The Company relies on the involvement of its high-level management to ensure
that no use of CPNI is made until a full review of applicable law has occurred.

4. The Company trains its personnel regarding when they are authorized to use CPNI, as
well as when they are not authorized to use CPNI. However, Company personnel make
no decisions regarding CPNI without first consulting with Donald Heidrich, CEO or
Tony Brncich, the Company's SVP of Telecom. The Company has an express
disciplinary process in place for personnel who make unauthorized use of CPNI.

5. The Company's policy is to maintain records of its own sales and marketing campaigns
that use CPNI. The Company likewise maintains records of its affiliates' sales and
marketing campaigns that use CPNI. The Company also maintains records of all
instances where CPNI was disclosed or provided to third parties, or where third parties
were allowed access to CPNI. These records include a description of each campaign, the
specific CPNI that was used in the campaign, and the products and services that were
offered as a part of the campaign. The Company maintains these records in its offices
for a minimum of one year.

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 6. The Company has a supervisory review process regarding compliance with the FCC's
rules relating to protection of CPNI for outbound marketing situations. The purpose of
this supervisory review process is to ensure compliance with all rules prior to using CPNI
for a purpose for which customer approval is required. Company personnel, prior to
making any use of CPNI, must first consult with Donald or Tony regarding the
lawfulness of using the CPNI in the manner contemplated. In deciding whether the
contemplated use of the CPNI is proper, either Donald or Tony will consult one or more
of the following: the Company's own compliance manual, the applicable FCC
regulations, the FCC's Compliance Guide, and, if necessary, legal counsel. The
Company's sales personnel must obtain supervisory approval from either Donald
Heidrich or Tony Brncich regarding any proposed use of CPNI.

8. Further, both Donald and Tony personally oversee the use of Opt-in, Opt-out, or any
other approval requirements, or notice requirements (such as notification to the
customer of the right to restrict use of, disclosure of, and access to CPNI), contained in
the FCC's regulations. They also review all notices required by the FCC regulations for
compliance therewith.

9. Donald and Tony also ensure that the Company enters into confidentiality agreements,
as necessary, with any joint venture partners or independent contractors to whom it
discloses or provides access to CPNI.

10. The Company's policy is to maintain records of customer approval for use of CPNI, as
well as notices required by the FCC's regulations, for a minimum of one year. The
Company maintains records of customer approval and disapproval for use of CPNI in a
readily-available location that is consulted on an as-needed basis.

CERTIFIED THIS DATE BY:

___________________________

CFO

PosTrack Technologies, Inc.

Date: ___________________________

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 APPENDIX 2

Employee Verification

Employee Name:___________________________

Date:______________

I have reviewed the Company's Customer Proprietary Network Information Compliance Manual
and Operating Procedures and agree to comply with the procedures set forth therein.

________________________________________________

Employee Signature

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 APPENDIX 3

SAMPLE OPT-OUT NOTICE Date:____________

PosTrack Technologies, Inc. (Company) utilizes Customer Proprietary Network Information

(CPNI) when providing telecommunications products and services to its customers. CPNI is
defined as information relating to the quality, technical configuration, destination and amount of
use of telecommunications service or interconnected voip services, including information that
may appear on a customer’s bill. Information published in the telephone directory is not CPNI.

Under Federal law, telephone companies have a duty to protect this information. As a customer,
you have the right at any time to restrict the use of CPNI for marketing purposes. This is
considered an "Opt-Out" approach. Your approval to use CPNI may enhance the Company's
ability to offer products and services tailored to your needs.

The Company proposes to use your CPNI to [Specified is: (1) the information that will be used,
(2) the specific entities that will receive the CPNI, (3) the purposes for which CPNI will be used]

If you wish to opt-out, you should take the following steps: [Opt-out procedure list.]

Your decision to opt-out will not affect the provision of any services to which you subscribe. The
company does not and will not sell or offer such information to any third party, except as
permitted under Federal Communications Commission regulations. Once you opt-out, you will
remain on this list until your request otherwise.

If the Company does not receive an opt-out from you prior to the expiration of the 30-day
period following the Company's sending of this notice to you, it will assume that you approve of
its proposed use of your CPNI.

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