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TOWER CLOUD, INC. STATEMENT OF CPNI USAGE POLICY AND PROCEDURES Tower Cloud, Inc.

("Tower Cloud" or "Company") is a facilities-based "carrier's carrier" that specializes in pro idin! hi!h-capacity point-to-point special access replacement ser ices to cellular telephone companies. The ser ices that Tower Cloud pro ides are used to establish connecti ity between a cellular telephone pro ider's pointof-presence and its cell sites in a !i en mar"et. Tower Cloud#s primary customer base consists of lar!e and ery sophisticated wholesale customers. The Company pro ides its ser ices on a retail basis to a ery limited number of end-user customers. The Company does not pro ide its ser ices on a retail basis to the public. Tower Cloud does not use C$%I for mar"etin! purposes. %or does it disclose or permit access to C$%I to third parties for mar"etin! purposes. Tower Cloud does not collect call data records or similar usa!e information for the traffic that transits its facilities. In fact, because Tower Cloud is a carrier's carrier, it does not ha e access to information about indi idual end users in a way that would permit it to use C$%I for mar"etin! purposes. Conse&uently, the re&uirements contained in the 'CC's C$%I rules relatin! to the process for obtainin! customer consent for the use of C$%I for mar"etin! purposes are not applicable to Tower Cloud. In the e ent Tower Cloud should chan!e its capabilities and policies re!ardin! C$%I in the future, it will ensure that the appropriate procedures are in place for obtainin! customer consent and for maintainin! the re&uired record"eepin! and super isory re iew. Tower Cloud has not e(perienced any "nown breaches of C$%I to date. )owe er, Tower Cloud is aware of its obli!ation to report any breaches to law enforcement a!encies ia the breach reportin! facility located at https*++www.cpnireportin!.!o +. Tower Cloud further understands that it may not notify the affected customer for se en days after reportin! the breach. Tower Cloud will retain for two years records relatin! to any disco ered breaches. Tower Cloud ta"es its obli!ations to safe!uard C$%I seriously. Tower Cloud has trained it employees with access to C$%I on the limited purposes for which they are authorized to use C$%I, and on the critical importance of protectin! C$%I from misuse or unauthorized disclosure. It is Tower Cloud's policy that any employee who fails to follow Tower Cloud's policies and procedures with re!ard to C$%I will be sub,ect to disciplinary action.

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