Office of the CEO 
 
 
August 3, 2022 
 
VIA EMAIL: Jessica.Rosenworcel@fcc.gov 
 
The Honorable Jessica Rosenworcel 
Chairwoman 
Federal Communications Commission 
45 L Street, N.E. 
Washington, D.C. 20554  

Dear Chairwoman Rosenworcel, 
 
We are in receipt of your letter of inquiry dated July 19, 2022, wherein you ask about our 
policies around geolocation data.  
 
As an innovator in the mobile industry, Red Pocket champions customer choice and privacy. We 
appreciate your shining a light on the important and timely topic of customer geolocation data 
collection and sharing by internet service providers.  
 
Red Pocket, as a mobile virtual network operator, does not collect geolocation data such as A-
GPS from our customers. We therefore do not collect or retain geolocation data.  Nor do we 
share geolocation with or sell it to any third party.  
 
However, we note that the billing records (also known as call detail records, or CDRs) that we 
receive from our underlying network operators may show a given subscriber's cellular market 
or metropolitan statistical area at the time that a particular call, text, or data event occurred.  
 
Such generalized data provides no insight into a customer's precise geolocation, and is 
generally not considered to be “geolocation data” in the telecommunications industry.   
 
This more generalized location information contained in call detail records is stored securely by 
us.  

 
We only share such information with outside parties under the following circumstances in 
compliance with our company policy and obligation to protect Customer Proprietary Network 
Information (CPNI):  
 
   1. To the end user customer of the service, upon proper authentication, so that the 
      customer may review the billing and usage information associated with her or his 
      account with us.   
   2. To appropriate legal authorities upon receipt of a court order, subpoena, or similar 
      warrant that compels our disclosure under the law.  
 
We trust that our response answers any questions that you may have at this time regarding our 
practices and policies around geolocation data. We would be happy to discuss this response 
further at your request.  
 
                                    Sincerely,  


                                                                
                                    Joshua Gordon