Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

• CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Fortyseven Ventures, NSW Australia.

  For the purposes of the GDPR, the Company is the Data Controller.

• Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• Country refers to: New South Wales, Australia

• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

• GDPR refers to EU General Data Protection Regulation.

• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual.

  For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

  For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

  We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.

• Service refers to the Website.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered Data Processors.

• Third-Party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Website refers to Callout, accessible from https://callout.to.

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

  Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Voice Calls and AI Conversations

Callout is an AI-powered intake service used by Australian trade and service businesses. When you call or chat a phone number or website powered by Callout, an AI assistant answers on behalf of that business, captures your enquiry, and passes the details on to the business so they can follow up with you.

Where you are the caller, your information is collected so that the trade or service business you contacted can respond to your enquiry. That business decides how to follow up with you. In handling your information, we act as a service provider to that business.

What we capture during a call or chat may include your name, phone number, address, a description of the job or enquiry, and any photos or attachments you choose to share. For voice calls, we also capture an audio recording and a transcript of the conversation.

Call recordings are treated as personal information. We do not extract voiceprints, create biometric templates, or use your voice for identity verification.

If you ask whether you are speaking to a person or an AI, our AI will tell you honestly that it is an AI assistant.

AI Models and How We Use Your Data

We use AI to transcribe voice calls, summarise conversations, and triage enquiries for the trade or service business you contacted.

We do not use your conversations, call recordings, or transcripts to train AI models. Some of our AI service providers may use aggregated and de-identified data to improve their underlying services in ways that do not identify you or your customers.

Summaries, transcripts, and triage classifications produced by AI may contain errors. They are intended as a starting point for the business that received your enquiry, and should not be relied on as authoritative records or as the sole basis for safety-critical, legal, or pricing decisions.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Account Sign-In

Callout currently supports email-based sign in. If we add additional sign-in methods, this Privacy Policy will be updated.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies We use include beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

Where required by law, we use non-essential cookies (such as analytics, advertising, and remarketing cookies) only with Your consent. You can withdraw or change Your consent at any time using Our cookie preferences tool (if available) or through Your browser/device settings. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

We use both Session and Persistent Cookies for the purposes set out below:

• Essential / Session Cookies

  Type: Session and persistent cookies.

  Administered by: Us.

  Purpose: Set by our authentication system to keep you signed in to the dashboard and to enable core features of the Service. Without these the Service cannot be provided.

• Analytics Cookies

  Type: Persistent cookies.

  Administered by: Third parties.

  Purpose: Set by our analytics providers on the marketing site to measure aggregate traffic and improve the Service. These are anonymous and are not used for advertising.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of Our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To manage Your requests: To attend and manage Your requests to Us.

• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your Personal Data with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions.
• With other users: If Our Service offers public areas, when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures, and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

Retention of Your Personal Data

We retain personal information only for as long as necessary for the purposes set out in this Privacy Policy and as required by law. We apply different retention periods to different categories of data:

• Account profile, settings, and login records. Retained for the life of your account.

• Callout records, transcripts, contact details, and messages. Retained for the life of your account. They are the lead history you signed up for.

• Call audio recordings. Stored by our AI service provider for up to 12 months, then deleted. Copies stored by us are retained while your account is active.

• Financial and transaction records. Invoices and billing history are retained for seven (7) years to comply with Australian Taxation Office record-keeping requirements.

• Marketing email subscribers. Retained until you unsubscribe, or up to 24 months from your last engagement, whichever comes first.

• Account data after cancellation. Deleted on request via hello@callout.to. Otherwise retained in case you reactivate. We are building self-serve account deletion and will update this section when it ships.

We may retain information beyond these periods where required by law, to establish or defend legal claims, for fraud prevention, or in encrypted backups that are not restored except where necessary for security, disaster recovery, or legal compliance.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to, and maintained on, computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and supplementary measures where appropriate. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

• Umami

  Their Privacy Policy can be viewed at https://umami.is/privacy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

• Loops

  Their Privacy Policy can be viewed at https://loops.so/privacy

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

• Stripe

  Their Privacy Policy can be viewed at https://stripe.com/us/privacy

Usage, Performance and Miscellaneous

We may use third-party Service Providers to maintain and improve our Service.

• Google Places

  Google Places is a service that returns information about places using HTTP requests. It is operated by Google.

  Google Places service may collect information from You and from Your Device for security purposes.

  The information gathered by Google Places is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

AI Service Providers

We use third-party AI service providers to operate the AI assistant, transcribe voice calls, and generate summaries. Conversation data is transmitted to and processed by these providers in the United States. As described above, these providers may use aggregated and de-identified data to improve their underlying services in ways that do not identify you or your customers.

Telephony Provider

We use a third-party telephony provider to deliver voice calls to and from Callout phone numbers. Call metadata, including phone numbers, timestamps, and call duration, is transmitted to this provider and processed in the United States.

Australian Privacy Act Compliance

Callout is operated by Fortyseven Ventures in New South Wales, Australia. We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), including:

• APP 1: open and transparent management of personal information.
• APP 3: collection of solicited personal information.
• APP 5: notification of collection.
• APP 6: use and disclosure of personal information.
• APP 8: cross-border disclosure.
• APP 11: security and destruction of personal information.

Cross-border disclosure. Personal information is processed in countries including Australia and the United States by our cloud hosting, AI, and telephony providers. We take reasonable steps to ensure that overseas recipients handle personal information in line with the APPs.

Notifiable Data Breaches. If a notifiable data breach occurs we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme.

Complaints. If you have a privacy concern, please contact us at hello@callout.to first. You may also lodge a complaint with the OAIC at oaic.gov.au.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

International Transfer of Personal Data

We may transfer, store, and process Personal Data in countries other than the country in which You are located, including countries outside the European Economic Area ("EEA") and the United Kingdom ("UK"), where data protection laws may differ.

Where we transfer Personal Data outside the EEA/UK to a country that has not been recognized as providing an adequate level of protection, We rely on appropriate safeguards, such as:

• The European Commission's Standard Contractual Clauses ("SCCs") and/or the UK International Data Transfer Agreement ("IDTA") or the UK Addendum to the SCCs (as applicable)
• Supplementary measures where appropriate, such as encryption in transit and at rest, access controls, data minimisation, and vendor security reviews.

We transfer Personal Data internationally only as needed to provide the Service and to work with our Service Providers (for example, hosting, analytics, email delivery). You may contact Us using the details in the "Contact Us" section of Our Privacy Policy to request further information about the safeguards We use for international transfers, including copies of relevant contractual protections (redacted where necessary).

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your Account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request restriction of processing. You have the right to ask Us to restrict processing of Your Personal Data in certain circumstances (for example, while We verify accuracy or consider an objection).
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible. We generally respond within one month, and may extend by two further months where necessary, in accordance with applicable law.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA/CPRA Privacy Notice (California Privacy Rights)

Callout is an Australian service operated from New South Wales. The following section applies if you are a California resident interacting with our marketing website.

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which We may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Information would only be collected if You provided such personal information directly to Us.

• Category A: Identifiers.

  Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

  Collected: Yes.

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

  Examples: A name, signature, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

  Some personal information included in this category may overlap with other categories.

  Collected: Yes.

• Category C: Protected classification characteristics under California or federal law.

  Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

  Collected: No.

• Category D: Commercial information.

  Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  Collected: Yes.

• Category E: Biometric information.

  Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

  Collected: No.

• Category F: Internet or other similar network activity.

  Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

  Collected: Yes.

• Category G: Geolocation data.

  Examples: Approximate physical location, physical location or movements.

  Collected: No.

• Category H: Sensory data.

  Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

  Collected: No.

• Category I: Professional or employment-related information.

  Examples: Current or past job history or performance evaluations.

  Collected: No.

• Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

  Examples: education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

  Collected: No.

• Category K: Inferences drawn from other personal information.

  Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  Collected: No.

• Category L: Sensitive personal information.

  Examples: Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.

  Collected: No.

Under CCPA/CPRA, Personal Information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA/CPRA's scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
• Indirectly from You. For example, from observing Your activity on our Service.
• Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
• From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:

• To operate our Service and provide You with Our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
• Other purposes consistent with the context in which the information was collected, or as otherwise disclosed to You at the time of collection.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Information" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose Personal Information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sharing of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Third-party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not "sell" or "share" information as most people would commonly understand these terms, meaning We do not, and will not, disclose Your Personal Information in direct exchange for money or some other form of payment.

We allow Our Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a "sale" under CCPA/CPRA. For example, when We promote Our Service, We use Service Providers that market Our Service online, measure the marketing efforts, identify users that are interested in Our Service, etc. This is done by placing tracking technologies on our website such as cookies, tags, pixels, or similar, and by placing these technologies, online identifiers and online behavior information is shared with such vendors, including for "cross-context behavioral advertising". Under the CCPA, these practices are defined as "sharing" or "selling" Personal Information.

We may disclose or may have disclosed in the last twelve (12) months the following categories in a manner that may be considered a "sale" or "sharing" as defined in CCPA/CPRA:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Retention of Personal Information

We retain California residents' Personal Information for as long as reasonably necessary to achieve the purposes described in this Privacy Policy (including the purposes disclosed in this CCPA/CPRA notice), taking into account: (i) how long we need the information to provide and maintain the Service and Your Account; (ii) whether You have requested deletion (subject to applicable exceptions); (iii) Our legal, tax, accounting, and regulatory obligations; (iv) security, fraud prevention, and abuse monitoring needs; and (v) the time periods needed to resolve disputes and enforce Our agreements.

Specific retention periods for major data categories are described in the "Retention of Your Personal Information" section of Our Privacy Policy, and We may retain certain information longer where required or permitted by law (for example, to comply with recordkeeping obligations or to establish, exercise, or defend legal claims).

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the Personal Information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from the parent or guardian of a Consumer less than 16 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 16 has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
• The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
  • The categories of personal information We collected about You
  • The categories of sources for the personal information We collected about You
  • Our business or commercial purposes for collecting or selling that personal information
  • The categories of third parties with whom We share that personal information
  • The specific pieces of personal information We collected about You
  • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
    • The categories of personal information categories sold
    • The categories of personal information categories disclosed
• The right to say no to the sale or sharing of Personal Information (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the "Do Not Sell or Share My Personal Information" section or contact Us.
• The right to correct Personal Information. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.
• The right to limit use and disclosure of sensitive Personal Information. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Us.
• The right to delete Personal Information. You have the right to request the deletion of Your Personal Information under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
  • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

Please see the "Do Not Sell or Share My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

• By email: hello@callout.to

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Information or an authorized representative
• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

• Verify Your identity or authority to make the request
• And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell or Share My Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

You have the right to opt-out of the "sale" of Your personal information. Once We receive and confirm a verifiable consumer request from You, We will stop "selling" Your Personal Information. To exercise Your right to opt-out, please contact Us or follow the below instructions.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If You wish to opt out of the use of Your Personal Information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, You may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

If applicable, click "Privacy Preferences", "Update Privacy Preferences" or "Do Not Sell or Share My Personal Information" buttons listed on the Service to review Your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access the Service.

Additionally, You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA's opt-out platform http://www.youronlinechoices.com/
• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt-out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by Your browser, You will need to opt out again.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the "Use of Your Personal Information" section or contact us.

To submit a request to limit the use or disclosure of sensitive personal information, please contact Us using the methods listed in the "Contact Us" section of Our Privacy Policy.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your Account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: hello@callout.to