| Effective Date | September 13, 2026 |
| Last Updated | September 13, 2026 |
| Applies To | LaCelle 3 Media LLC Managed Telephony Services |
| Contact Email | techops.telephony@lacelle3.com |
| Contact Phone | +1 (509) 715-3517 |
This Privacy Policy describes how LaCelle 3 Media LLC (“the Company,” “we,” “us,” or “our”) collects, uses, stores, protects, and discloses personal information in connection with our managed telephony services. This policy applies to all clients of the Company’s managed VoIP telephony service and governs all personal information collected during client onboarding, service provisioning, and the ongoing management of your managed phone line.
This Privacy Policy is provided in accordance with Washington state law (RCW 19.255.010) and as a transparency obligation to clients who are asked to submit identity documents as part of our onboarding process under proposed Federal Communications Commission Know Your Customer requirements (FCC 26-27, CG Docket Nos. 17-59 & 02-278).
This Privacy Policy should be read together with the Company’s Customer Proprietary Network Information (CPNI) Policy, which addresses additional privacy obligations specific to call data under federal telecommunications law. Both policies apply to clients of the Company’s managed telephony service.
Section 1 – Information We Collect
We collect the following categories of personal information in connection with our managed telephony services.
1.1 Identity and Contact Information
– Full legal name
– Business name (if applicable)
– Primary email address
– Primary contact phone number
– Billing address
– Primary place of use address (used for E911 registration and Washington state tax sourcing)
1.2 Goverment-Issued Identification
– Government-issued ID type (driver’s license, state ID, or passport)
– Issuing state or country of the government-issued ID
– Identity verification result and Stripe Verification ID (from Stripe Identity, our third-party verification service)
– Last four digits of Social Security Number (collected by Stripe Identity during verification. It is not retained by the Company in plain text, and is stored in a secure, encrypted storage area.)
Identity verification is conducted through Stripe Identity, operated by Stripe, Inc. The Company retains the verification outcome, ID type, issuing jurisdiction, Stripe Verification ID, and the last four digits of Social Security Number. Sensitive document data is processed and held by Stripe under their compliance infrastructure. See Section 4 for details on how this information is stored and retained.
1.3 Telecommunications Service Information
– Dedicated DID (Direct Inward Dialing) telephone number(s) assigned to your account
– Call forwarding number designated by you
– Voicemail-to-email delivery address
– Caller ID Name (CNAM) configuration
– E911 registered service address
– Call detail records (CDRs), including call destination numbers, call duration, call direction (inbound/outbound), and timestamp
– Voicemail recordings (if voicemail is enabled on your line)
– Call recordings (if call recording is elected as an optional add-on service)
– Call transcriptions and voicemail transcriptions (if transcription services are elected)
– Phone Service Balance and usage data
– Elected optional add-on services and configuration
1.4 Billing and Financial Information
– Invoice records including amounts charged, payment due dates, and payment history
– Wave Accounting customer record and transaction history
– Phone Service Balance top-up history
The Company does not collect or store payment card numbers, bank account numbers, or other financial account credentials. Payments are processed through Wave Accounting’s payment processing infrastructure.
1.5 Account Management Records
– LC3M Client ID (unique 6-digit identifier assigned at onboarding)
– Signed Service Agreement, Service Order, E911 Disclosure, and CPNI Policy acknowledgement
– Support ticket history through the LC3M Telephony Service Desk (Jira)
– Account change requests and modification history
– Identity verification records and re-verification history
Section 2 – Why We Collect This Information
We collect personal information only for the purposes described below. We do not collect personal information beyond what is necessary for these purposes.
| Category | Purpose |
| Identity and contact information | Service provisioning, client account creation, billing, E911 registration, support communications, Washington state tax reporting |
| Government-issued identification | Identity verification before service provisioning as required under proposed FCC KYC requirements (FCC 26-27); fraud prevention; compliance with applicable law enforcement and regulatory requests |
| Telecommunications service information | Configuring and managing your managed phone line, voicemail, call routing, E911 service, and elected add-on features; billing for usage-based services; compliance with FCC E911, 988, CPNI, and Robocall Mitigation obligations |
| Call detail records | Billing for usage-based charges; compliance with FCC CPNI regulations (47 U.S. Code § 222); response to traceback requests under the TRACED Act; fraud detection and prevention |
| Call and voicemail recordings | Delivery to the client; storage in the VoIP.ms client portal for client access; optional call transcription if elected |
| Billing information | Invoicing, payment tracking, Washington state B&O tax and sales tax reporting, accounting records |
| Account management records | Ongoing service management, support ticket tracking, service agreement compliance, identity verification history for re-verification purposes |
Section 3 – How We Use Your Information
We use the personal information we collect for the following purposes:
3.1 Service Delivery
We use your identity and contact information, telecommunications service configuration, and billing information to provision your managed phone line, configure your call flow, activate E911 service, manage your Phone Service Balance, and deliver the services described in your Service Agreement.
3.2 Compliance with Legal and Regulatory Obligations
We use your personal information to comply with applicable federal and state law, including:
– FCC E911 obligations under 47 CFR § 9.10; your E911 registered address is provided to our upstream carrier (VoIP.ms) for PSAP routing
– FCC CPNI obligations under 47 U.S. Code § 222 and 47 CFR §§ 64.2001-64.2011; your call detail records are governed by the Company’s CPNI Policy
– FCC Know Your Customer requirements under 47 CFR § 64.1200(n)(4) and proposed FCC 26-27; your identity verification records are retained for compliance purposes
– FCC Robocall Mitigation Database obligations; identity and usage information supports our traceback response obligations under the TRACED Act
– Washington state E911 and 988 excise tax reporting to the Washington State Department of Revenue
– Washington state B&O tax and retail sales tax reporting to the Washington State Department of Revenue
– Washington state data breach notification obligations under RCW 19.255.010
3.3 Billing and Accounting
We use your contact information and usage data to generate monthly invoices, track payment history, calculate applicable Washington state taxes and excise fees, and maintain accounting records.
3.4 Security and Fraud Prevention
We use your identity verification records, call detail records, and usage patterns to detect and prevent unauthorized use of your managed line, to identify potential robocall or fraud activity, and to respond to traceback requests from the Industry Traceback Group (ITG) and FCC enforcement proceedings.
3.5 Communications and Support
We use your email address and phone number to respond to support requests, send service notifications, issue invoices, and communicate changes to your service or this Privacy Policy.
3.6 Marketing (CPNI – Opt-Out Available)
We may use your Customer Proprietary Network Information (CPNI), specifically, information about the telecommunications services you subscribe to, to inform you about communications-related products and services similar to those you currently receive from the Company. You have the right to opt out of this use of your CPNI at any time. See Section 6 for how to exercise this right. We do not use your CPNi to market services unrelated to telecommunications, and we do not sell your CPNI to third parties for any purpose.
Section 4 – How We Store and Protect Your Information
4.1 Storage Systems
Your personal information is stored across the following systems:
| Information Type | Storage System |
| Client account records, onboarding documents, signed agreements | Microsoft 365 and SharePoint enterprise systems with security controls. |
| Identity verification records, KYC compliance data | Stripe Identity (Stripe, Inc.) for verification processing and sensitive document data. Microsoft SharePoint systems for verification results and metadata. Azure encrypted storage systems for government ID documents when required by FCC final rules. |
| Support ticket history, service request records | Jira Service Desk Server, hosted on LaCelle 3 Media LLC’s infrastructure behind Cloudflare tunnel protection. |
| Billing records, invoice history | Wave Accounting, operated by Wave Financial Inc. |
| Call detail records, voicemail, call routing configuration | VoIP.ms reseller portal, operated by 9171-5573 QUEBEC INC., hosted in Canada with US network operations. Governed by VoIP.ms’ own data retention and security policies. |
4.2 Security Measures
The Company implements the following measures to protect your personal information:
– Access controls: sensitive identity and KYC records are accessible only to Hayden LaCelle, LLC Executor / Owner, LaCelle 3 Media LLC. No other personnel have access to sensitive client identity data.
– Encrypted storage: government-issued ID documents are stored in encrypted Azure HSM (hardware security module)-backed storage with audit logging of every access event, soft delete, and with purge protection enabled.
– Authentication: Microsoft 365 accounts are protected by multi-factor authentication. Jira and VoIP.ms portal access require authenticated login.
– Transport security: all client-facing communications and portal access use TLS encryption in transit.
– Third-party security: identity verification is conducted through Stripe Identity, which maintains its own security certifications and compliance infrastructure for sensitive document data.
Section 5 – How Long We Retain Your Information
We retain personal information for the periods described below. After the applicable retention period, information is deleted or destroyed in accordance with our data retention procedures.
| Information Type | Retention Period |
| Government-issued ID documents and KYC verification records | Minimum four (4) years following termination of the service relationship, consistent with the proposed FCC KYC requirements (FCC 26-27) and the statute of limitations under 47 U.S. Code §§ 227(b)(4)(E)(ii) and (e)(5)(A)(iv). Records are deleted promptly upon expiration of the retention period. |
| Call detail records (CDRs) | Per VoIP.ms data retention policies, as the upstream carrier that maintains CDR infrastructure. CDRs accessible through the VoIP.ms client portal are subject to VoIP.ms’ own retention schedule. |
| CPNI and telecommunications compliance records | Minimum two (2) years from the date of the record, consistent with FCC CPNI regulations (47 CFR § 64.2009). |
| Billing records and invoice history | Seven (7) years from the date of the record, consistent with standard accounting practice and Washington state tax record requirements. |
| Signed service agreements and onboarding documents | Duration of the service relationship plus seven (7) years following termination. |
| Support ticket history | Support ticket history is kept indefinitely. |
| Voicemail and call recordings | Per VoIP.ms portal retention policies. Recordings stored in the VoIP.ms client portal are subject to VoIP.ms’s own retention schedule. The Company does not independently archive voicemail or call recordings. |
Section 6 – Who Has Access to Your Information
6.1 Within LaCelle 3 Media LLC
LaCelle 3 Media LLC is a sole-operator company. Access to client personal information, including all sensitive identity and KYC records, is limited exclusively to Hayden LaCelle, LLC Executor / Owner. No other individuals, employees, or contractors have access to your personal information.
6.2 Third-Party Service Providers
The Company shares personal information with the following third-party service providers as necessary to deliver the managed telephony service. Each provider is listed with the information they receive and the purpose of sharing:
| Provider | Information Received | Purpose |
| Stripe Identity (Stripe, Inc.) | Name, email, phone, government-issued ID document, SSN last four digits, selfie | Identity verification before upstream provisioning. Stripe holds sensitive document data under their compliance infrastructure. |
| VoIP.ms (9171-5573 QUEBEC INC.) | DID number(s), E911 registered address, call routing configuration, call detail records, voicemail data, Phone Service Balance | Upstream carrier for call origination, termination, E911 PSAP routing, 988 routing, voicemail, and STIR/SHAKEN authentication. |
| Wave Accounting (Wave Financial Inc.) | Name, business name, email, billing address, invoice amounts | Billing, invoicing, and accounting records. |
| Microsoft Corporation | Account records, signed agreements, client registry data, support tickets (email copies from Jira Service Desk Server.) | Infrastructure – Microsoft 365/SharePoint for document storage; Azure for encrypted ID document storage. |
6.3 Law Enforcement and Regulatory Agencies
The Company may disclose your personal information to law enforcement agencies, the Federal Communications Commission (FCC), the Universal Service Administrative Company (USAC), the Washington State Department of Revenue, the Washington State Attorney General, or other regulatory agencies in the following circumstances:
– In response to a valid subpoena, court order, or law enforcement request accompanied by appropriate legal process
– In response to a traceback request from the Industry Traceback Group (ITG) under the TRACED Act and FCC robocall mitigation obligations
– In connection with FCC enforcement proceedings related to robocalling, CPNI violations, or other telecommunications regulatory matters
– As required by Washington state law, including data breach notification obligations under RCW 19.255.010
– As required for USAC Form 499-A and 499-Q filings and USF contribution obligations
The Company will notify you of any law enforcement request for your personal information where legally permitted to do so.
6.4 What We Do Not Do
– We do not sell your personal information to any third party for any purpose
– We do not share your CPNI with unaffiliated third parties for their own marketing purposes
– We do not share your personal information with data brokers or advertising networks
– We do not use your personal information for purposes unrelated to the provision and management of your telephony service
Section 7 – Your Privacy Rights
7.1 Right to Access
You have the right to request access to the personal information the Company holds about you. To request access, contact us at techops.telephony@lacelle3.com with the subject line “Privacy Policy Information Access Request.” We will respond as soon as possible and provide you with a copy of the personal information we hold about you, subject to the verification of your identity.
7.2 Right to Correction
You have the right to request correction of inaccurate or incomplete personal information we hold about you. To request a correction, submit an Update account contact information request through the Telephony Service Desk portal at https://servicedesk.lacelle3.com/servicedesk/customer/portal/5/create/139, or contact us at techops.telephony@lacelle3.com. Identity verification may be required before corrections are made to sensitive account information.
7.3 Right to Deletion
You have the right to request deletion of your personal information. However, deletion is subject to the following limitations:
– Government-issued ID documents and KYC verification records are subject to a mandatory four-year retention period under proposed FCC KYC requirements and cannot be deleted before the retention period expires
– Call detail records, CPNI, and compliance records are subject to FCC and Washington state regulatory retention requirements and cannot be deleted before the applicable retention period expires
– Billing records are subject to standard accounting retention requirements and cannot be deleted before seven years from the date of the record
– Records subject to active law enforcement requests or regulatory proceedings cannot be deleted until those proceedings are resolved
Where deletion is not subject to a regulatory retention obligation, we will delete your personal information within a reasonable time following a valid deletion request and verification of your identity. To submit a deletion request, contact us at techops.telephony@lacelle3.com with the subject line “Privacy Policy Information Deletion Request.”
7.4 Right to Opt Out of CPNI Marketing Use
You have the right to restrict the Company’s use of your Customer Proprietary Network Information (CPNI) for marketing purposes at any time. Opting out does not affect the services you currently receive. To opt out, contact us at techops.telephony@lacelle3.com or submit a General Telephony Support request through the Telephony Service Desk portal. Your opt-out will remain in effect until you affirmatively revoke it.
See the Company’s CPNI Policy for complete information about your rights regarding call data and telecommunications-specific privacy obligations.
7.5 Right to Privacy Inquiries
You have the right to ask questions, raise concerns, or request additional information about the Company’s privacy practices at any time. Contact us at:
LaCelle 3 Media LLC – Telephony Service Desk
techops.telephony@lacelle3.com
+1 (509) 715-3517
https://servicedesk.lacelle3.com/servicedesk/customer/portal/5
Section 8 – Data Breach Notification
8.1 Washington State Breach Notification (RCW 19.255.010)
In the event that the Company discovers or reasonably determines that a breach of the security of our systems has occurred resulting in the unauthorized acquisition of your personal information, the Company will:
– Notify you of the breach no later than thirty (30) days after the breach was discovered, provided that notification is not delayed at the direction of a law enforcement agency investigating the breach
– Include in the notification: the name and contact information of the Company; a list of the types of personal information that were or are reasonably believed to have been subject to the breach; a time frame of exposure, including the date of the breach and the date of discovery; and, where applicable, the toll-free telephone numbers and addresses of the major credit reporting agencies if the breach exposed personal information that could give rise to identity theft
– If the breach affects more than five hundred (500) Washington state residents: notify the Washington State Attorney General within thirty (30) days of discovering the breach, including the number of Washington state consumers affected, the types of personal information involved, the time frame of exposure, a summary of steps taken to contain the breach, and a sample copy of the breach notification
Notification is not required if the breach is not reasonably likely to subject you to a risk of harm, or if the personal information involved was secured through encryption or other methods rendering it unreadable to an unauthorized person, provided the encryption key or other means to decipher the information was not also acquired.
8.2 FCC CPNI Breach Notification (47 CFR § 64.2011)
In the event of unauthorized disclosure of Customer Proprietary Network Information (CPNI), the Company will:
– Notify the United States Secret Service and the Federal Bureau of Investigation electronically through the FCC’s central reporting facility at cpnireporting.gov no later than seven (7) business days after a reasonable determination that a CPNI breach has occurred
– Notify affected clients of the CPNI breach after the mandatory seven (7) business day law enforcement notification period has elapsed, unless law enforcement instructs the Company to postpone notification pending investigation
– Maintain records of any discovered CPNI breaches for a minimum of two (2) years
8.3 Breach Recordkeeping
Following any data breach, the Company will retain the following records for a minimum of two (2) years:
– The date the breach was discovered
– The date law enforcement was notified (if applicable)
– Copies of all notifications sent to affected clients
– A description of the breach and its circumstances
– Any law enforcement response received
Section 9 – Relationship to CPNI Policy
This Privacy Policy and the Company’s Customer Proprietary Network Information (CPNI) Policy work together to govern how the Company handles information about you and your telecommunications service.
The CPNI Policy specifically governs Customer Proprietary Network Information as defined under federal telecommunications law (47 U.S.C. § 222) – information about the quantity, technical configuration, type, destination, location, and amount of your use of telecommunications services. The CPNI Policy describes your rights to restrict the use of your CPNI, how the Company protects it, and how CPNI-specific breach notification obligations work under FCC rules.
This Privacy Policy is broader and covers all personal information collected by the Company, including identity information, billing information, and KYC records that are not CPNI. Both policies apply to clients of the Company’s managed telephony service, and both must be read together for a complete understanding of the Company’s privacy practices.
The CPNI Policy is incorporated by reference into the Company’s Managed Telephony Services Agreement and is available from the Telephony Service Desk upon request.
Section 10 – Children’s Privacy
The Company’s managed telephony service is intended for adult business clients and is not directed at individuals under the age of eighteen (18). The Company does not knowingly collect personal information from individuals under eighteen (18). If you believe that a minor’s personal information has been submitted to the Company in error, please contact us at techops.telephony@lacelle3.com and we will take appropriate steps to delete the information.
Section 11 – Changes to This Privacy Policy
The Company reserves the right to modify this Privacy Policy at any time. Material changes will be communicated to active clients via email to their address of record at least thirty (30) days before the change takes effect, where practicable. The effective date at the top of this document will be updated upon any revision.
Continued use of the Company’s managed telephony service following notice of material changes constitutes acceptance of the updated Privacy Policy. If you do not accept the updated Privacy Policy, you may cancel your service in accordance with the Managed Telephony Services Agreement.
The current version of this Privacy Policy is always available at https://tel.lacelle3.com/privacy.
Section 12 – Contact Information and Privacy Inquiries
For any questions, concerns, correction requests, deletion requests, access requests, or CPNI opt-out requests related to this Privacy Policy or the Company’s privacy practices, contact:
| Company | LaCelle 3 Media LLC |
| Privacy Contact | Hayden LaCelle, LLC Executor / Owner |
| techops.telephony@lacelle3.com | |
| Phone | +1 (509) 715-3517 |
| Support Portal | https://servicedesk.lacelle3.com/servicedesk/customer/portal/5 |
| Privacy Policy URL | https://tel.lacelle3.com/privacy |
| Mailing Address for Legal and Correspondence Inquiries | Northwest Registered Agent LLC C/O LaCelle 3 Media LLC 522 W Riverside Ave, Ste N Spokane, WA 99201, United States |