PRIVACY POLICY

Introduction

This Privacy Policy ("Policy") describes how LinkedPhone LLC ("LinkedPhone," "we," "us," or "our") collects, uses, discloses, and protects information when you ("you," "Customer," or "your") access or use our products, websites, software applications, mobile applications, application programming interfaces, and the cloud-based communications services we provide, including voice calling, SMS and MMS messaging, voicemail, auto attendant, call routing, AI-assisted features, and related functionality (collectively, the "Service"). This Policy is incorporated into and forms a part of the LinkedPhone Terms of Service ("Terms"). Capitalized terms used but not defined in this Policy have the meanings given to them in the Terms.

This Policy applies whether you access the Service as a paying Customer, an authorized user under a Customer’s account, a visitor to our website, or as a third party who communicates with a Customer by calling or messaging a LinkedPhone-provisioned number. References to "Customer," "you," and "your" throughout this Policy refer to the reader in the capacity in which the reader is interacting with the Service.

By accessing or using the Service, you acknowledge that you have read this Policy and understand how we collect, use, and disclose information. Your use of the Service is also subject to our Acceptable Use Policy. If you do not agree with this Policy, do not access or use the Service.

Scope and Our Role

When you create a LinkedPhone account, we act as a controller of your account information and other personal information we collect directly from you. LinkedPhone may be a Controller when processing personal information for security, fraud prevention, and product improvement.

When a Customer uses the Service to communicate with the Customer’s own clients, employees, contacts, or other third parties (including by placing calls, sending messages, recording conversations, or generating transcripts), the Customer controls those communications and is the controller of the personal information involved. In those cases, LinkedPhone acts as a processor or service provider and processes that information on behalf of the Customer and in accordance with the Customer’s instructions and our agreement with the Customer. If you are a third party whose information has been provided to LinkedPhone by a Customer, please direct privacy requests to that Customer in the first instance.

Information We Collect

The categories and examples of personal information we collect, and have collected over the past twelve months, are as follows.

Information You Provide Directly

• Account and contact information: name, email address, phone number, business name, business address, job title, number of employees, and password or other authentication credentials.

• Billing and payment information: billing address, payment card type, the last four digits of your payment card, and other payment-related identifiers. Full payment card numbers and security codes are collected and stored by our third-party payment processor and are not retained on LinkedPhone’s systems.

• Business verification information: for A2P 10DLC Brand and Campaign registration and other compliance purposes, we collect business registration details, your employer identification number (EIN) (or, where applicable, the equivalent business identifier in your jurisdiction), your website URL, your opt-in workflow URL, sample messages, contact and authorization information, and use-case descriptions required by The Campaign Registry, by wireless carriers, and by Bandwidth Inc. and any other connectivity or messaging provider LinkedPhone uses for messaging services.

• Phone number porting information: when you port an existing number to or from LinkedPhone, we collect the information that carriers require to process the port request, including account numbers with your prior carrier and a Letter of Authorization.

• Communications with us: information you submit when you contact customer support, respond to surveys, provide feedback, or complete forms on our website.

Information We Collect Automatically When You Use the Service

• Call detail records: originating and terminating phone numbers, call duration, date and time stamps, call direction, call disposition (answered, missed, voicemail), and the route or device used to handle a call.

• Message detail records: originating and terminating phone numbers, time stamps, message type (SMS, MMS), and message status.

• Communication content and metadata: voicemail recordings, call recordings, voicemail and call transcriptions, MMS attachments, and SMS message content.

• Device and session information: IP address, device identifiers, operating system, browser type and version, mobile network information, application version, log data, crash reports, and performance metrics.

• Location information: approximate location derived from IP address.

• Cookie and similar technology data: see the section titled Cookies and Similar Technologies.

Information We Receive from Third Parties

• Telecom carriers and infrastructure providers provide us with delivery receipts, routing information, and number-status data necessary to provide the Service.

• Payment processors provide us with confirmation of payment and limited tokenized payment information.

• Integration partners provide us with information when you authorize an integration (for example, CRM, email, calendar, or messaging integrations). The scope of that information is determined by the permissions you grant.

• Analytics, advertising, and marketing providers provide us with information about how visitors find and interact with our website.

• Authorized resellers and referral partners may provide us with information when they refer or onboard you to the Service.

Sensitive Information

We do not intentionally collect categories of information that are designated as "sensitive" under U.S. state privacy laws (such as government identifiers, precise geolocation, racial or ethnic origin, religious beliefs, sexual orientation, biometric identifiers, or health information) unless you affirmatively provide such information to us through a free-text field, a customer support communication, or a recorded or transcribed conversation. We ask that you not transmit such information through the Service unless necessary, and we do not use such information for advertising or profiling.

How We Use Personal Information

We use personal information for the following purposes.

Providing the Service

• Provisioning and managing your account, business phone numbers, and devices.

• Routing, completing, and recording voice calls and messages.

• Delivering voicemail, transcription, auto-attendant, IVR, call queue, ticket management, and related features.

• Authenticating users, including multi-factor authentication.

• Providing customer support and responding to your requests.

• Managing billing, processing payments, and collecting amounts owed.

Improving and Securing the Service

• Monitoring service quality, reliability, and performance.

• Diagnosing and resolving technical issues.

• Conducting research, testing, and product development.

• Preventing, detecting, and investigating fraud, abuse, and violations of our Terms of Service and Acceptable Use Policy.

• Protecting the rights, property, and safety of LinkedPhone, our users, and the public.

Communicating with You

• Sending service-related announcements, including changes to the Service, security alerts, billing notices, and required legal communications. These communications are not promotional and you cannot opt out of them while you maintain an account.

• Sending marketing communications about LinkedPhone products, features, and offers when you have provided the necessary consent or where otherwise permitted by law. You can opt out of marketing communications at any time using the unsubscribe link in our emails or by contacting us as set forth in the section titled Contact Us.

AI and Automated Features

LinkedPhone offers features that use artificial intelligence and machine learning, including voicemail transcription, call transcription, call summarization, call handling, scheduling, and AI Automation features. When you use these features, the underlying audio, text, or metadata is processed to produce the requested output.

To provide AI-assisted features, we may transmit the audio, text, or metadata you submit to third-party model providers that perform inference on our behalf. These providers process your content solely to generate the requested output, are bound by written agreements that prohibit them from using your content to train their general-purpose models, and do not retain your content for longer than necessary to provide the output, except for limited retention required for abuse monitoring, security, or compliance with their own legal obligations under our agreements with them. The categories of providers with whom we share personal information, including these model providers, are described in the section titled How We Disclose Personal Information.

Unless you affirmatively opt in, we do not use the content of your calls, messages, voicemails, or transcripts to train generalized AI or machine learning models. Where you opt in to contribute data for model improvement, you may withdraw that consent at any time, in which case future data will not be used for that purpose. Data previously used in aggregated or de-identified model training cannot practically be reversed out of a trained model, and we will explain this clearly at the point of opt-in.

LinkedPhone does not engage in solely automated decision-making that produces legal or similarly significant effects concerning you.

Legal and Compliance Purposes

• Complying with applicable law, legal process, court orders, subpoenas, and lawful requests from public authorities.

• Cooperating with law enforcement.

• Establishing, exercising, or defending legal claims.

• Enforcing our agreements, policies, and rights.

Aggregated and De-Identified Data

We may create aggregated, anonymized, or de-identified information from personal information and use that information for any lawful business purpose, including analytics, benchmarking, product improvement, and marketing. We commit to maintain such information in de-identified form and not to attempt to re-identify it, except as permitted by law to assess whether the de-identification process is working.

SMS, MMS, and A2P Messaging

LinkedPhone delivers SMS and MMS messaging using third-party carriers and aggregators. The following terms reflect carrier, CTIA, and Federal Communications Commission requirements.

Consent

You may not use the Service to send messages to recipients who have not consented to receive messages from you. Consent must be obtained in a manner that complies with the Telephone Consumer Protection Act (TCPA) and the rules of the Federal Communications Commission, and in some cases must be express written consent. You are responsible for maintaining records of consent.

Campaign Registration and Carrier Vetting

To send SMS or MMS messages using the Service, your business (the "Brand") and each of your messaging use cases (each, a "Campaign") must be registered with The Campaign Registry, the industry registry that supports Application-to-Person 10-Digit Long Code ("A2P 10DLC") messaging on U.S. wireless networks. Direct registration with The Campaign Registry is generally not available to individual Brands; registration is performed through a registered Campaign Service Provider. LinkedPhone is a registered Campaign Service Provider with The Campaign Registry and submits your Brand and Campaign information to The Campaign Registry, and to participating wireless carriers, on your behalf. LinkedPhone delivers SMS and MMS traffic to wireless carriers through one or more underlying connectivity providers, principally Bandwidth Inc. ("Bandwidth"). LinkedPhone has used and may continue to use other connectivity providers and messaging aggregators from time to time, and may change providers, route traffic across multiple providers, or add additional providers without notice to you.

Registration requires information about your business, your messaging use case, sample message content, your opt-in workflow, contact and authorization information, and other information that The Campaign Registry, wireless carriers, and our connectivity providers use to vet senders and assign messaging throughput. You authorize LinkedPhone to submit this information to The Campaign Registry and to provide it to participating wireless carriers and to the connectivity providers and messaging aggregators LinkedPhone uses (including Bandwidth), in each case for the purpose of registering, maintaining, vetting, and enforcing your Brand and Campaign.

You are responsible for the accuracy of the information you provide for registration and for keeping it current. If your registered information becomes inaccurate, if your messaging use case changes, or if your Brand or Campaign is rejected, suspended, or down-rated by The Campaign Registry, a wireless carrier, or an underlying connectivity provider, your ability to send messages may be limited, delayed, or terminated, and registration, vetting, and carrier-imposed fees may be passed through to you. If a Campaign is suspended, an underlying connectivity provider involved in the delivery of your messages may disassociate the telephone numbers previously assigned to that Campaign, which will cause your messaging traffic to be unregistered until you complete a new Campaign registration. Toll-free and short-code messaging are subject to separate verification processes administered by carriers and our connectivity providers, which are governed by the same principles.

LinkedPhone may decline to register or maintain a Brand or Campaign that, in our reasonable judgment, presents a regulatory, carrier, or reputational risk. Decisions by The Campaign Registry, wireless carriers, and our underlying connectivity providers about whether and how to deliver your messages are outside LinkedPhone's control, and LinkedPhone is not liable for those decisions.

Identification and Opt-Out

Initial messages to any recipient must identify the sender and must include opt-out instructions using standard keywords (STOP, UNSUBSCRIBE, CANCEL, END, QUIT). When a recipient sends an opt-out keyword, you must promptly cease sending messages to that recipient, except for a single confirmation that the opt-out has been processed.

Prohibited Content

The categories of content that may not be sent via the Service, including (without limitation) prohibited financial, controlled substance, gambling, adult, and hate-speech content, are set forth in our Acceptable Use Policy and the policies of our upstream carriers, which we incorporate by reference.

LinkedPhone Communications to You

By providing your wireless number, you consent to receive transactional and account-related messages from LinkedPhone, which may be sent using automated technology. Standard message and data rates may apply. You may opt out of LinkedPhone’s non-essential text messages by replying STOP. Opting out of service-related notifications may not be possible while you maintain an active account.

Call Recording and Transcription

LinkedPhone offers features that allow you to record and transcribe calls. You are solely responsible for compliance with all applicable laws governing the recording and transcription of communications, including federal law, state and provincial wiretap and eavesdropping laws (which vary in their notice and consent requirements), and the laws of any jurisdiction in which any party to the communication is located. Several U.S. states require the consent of all parties to a recorded call.

It is your responsibility to (a) configure the Service in a manner that produces the disclosures and obtains the consents required by applicable law, (b) provide notice to call participants, and (c) keep records of consent where required. LinkedPhone disclaims responsibility for your compliance with these laws and you agree to indemnify LinkedPhone in connection with your recording and transcription activities to the extent permitted by our Terms of Service.

Automated transcription is provided as a convenience and may contain errors. You are responsible for verifying the accuracy of any transcription before relying on it.

How We Disclose Personal Information

We disclose personal information only as described below. We do not sell personal information for monetary consideration.

Service Providers and Processors

We disclose personal information to vendors that perform services on our behalf and under written contracts requiring them to use that information only as instructed. These categories include:

• Telecommunications carriers and messaging aggregators, which route voice calls and SMS and MMS messages and provide network connectivity for A2P 10DLC messaging. Bandwidth Inc. currently serves as our principal underlying connectivity provider for messaging and as an upstream provider for certain telephony and number services. LinkedPhone is itself the registered Campaign Service Provider that submits Brand and Campaign registrations to The Campaign Registry. LinkedPhone has used and may use other connectivity providers and aggregators from time to time.

• Cloud hosting and infrastructure providers, which host our application, databases, and storage.

• Artificial intelligence and machine learning providers, which perform inference on audio, text, and metadata to power voicemail transcription, call transcription, call summarization, AI Automation, and similar features.

• Payment processors, which receive and process payment card information and other payment-related data.

• Billing, invoicing, tax automation, and revenue operations providers, which support pricing, invoicing, tax determination, and collections.

• Customer support, ticketing, and helpdesk platforms, which we use to receive, route, and resolve Customer inquiries.

• Identity, authentication, and access management providers, which help authenticate users and protect accounts from unauthorized access.

• Security, fraud prevention, abuse detection, and compliance providers, which help us protect the Service and Customers and meet our regulatory obligations.

• Analytics, product improvement, and performance monitoring providers, which help us understand how the Service is used and improve quality and reliability.

• Email and notification delivery providers, which transmit transactional and other communications on our behalf.

• Marketing, advertising, and customer relationship management providers, which help us market the Service and manage our relationships with prospective and current Customers.

• Professional services providers, including legal counsel, auditors, accountants, and consultants, who require access to limited personal information to provide their services to LinkedPhone.

Integrations You Authorize

When you connect a LinkedPhone account to a third-party service (for example, a CRM, helpdesk, calendar, or messaging platform), you authorize LinkedPhone to transmit information to that third party. The third party’s handling of that information is governed by its own privacy policy, which we encourage you to review. We are not responsible for the third party’s practices.

Account Administrators and Other Users

If you use the Service under a Customer account that is held by your employer or another organization, the account administrator has access to information about your use of the Service, including, among others, call detail records, message detail records, and any content you elect to record or store. Other users within the same Customer account may have access depending on the roles and permissions configured by the administrator.

Legal Process and Protection of Rights

We may disclose personal information when we believe in good faith that disclosure is required to (a) comply with a lawful subpoena, court order, warrant, or other legal process, (b) cooperate with law enforcement or other government authorities, (c) enforce our Terms of Service or other agreements, (d) protect the rights, property, or safety of LinkedPhone, our users, or others, or (e) respond to claims or potential claims. Where permitted by law, we will provide notice to the affected user before responding to a request.

Corporate Transactions

If LinkedPhone is involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, or sale of business assets, personal information may be transferred or disclosed in connection with the transaction. We will provide notice as required by applicable law.

With Your Direction or Consent

We may disclose personal information to other parties when you direct us to do so or otherwise consent.

De-Identified and Aggregated Information

We may share de-identified or aggregated information that does not reasonably identify any individual for any lawful purpose.

International Data Transfers

LinkedPhone is based in the United States and our Service is hosted in the United States. If you access the Service from outside the United States, your information will be transferred to, stored in, and processed in the United States and other jurisdictions where we or our service providers operate. Privacy and data protection laws in those jurisdictions may differ from those in your jurisdiction.

Where applicable law (including the GDPR or UK GDPR) requires a transfer mechanism for international transfers of personal data, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or another lawful mechanism.

Cookies and Similar Technologies

We and our service providers use cookies, pixel tags, web beacons, software development kits (SDKs), local storage, and similar technologies (collectively, "Cookies") on our website and within our applications. We use these technologies to:

Enable essential functions such as login and account security.

Remember your preferences and settings.

Measure and analyze usage of our website and Service.

Support marketing campaigns and measure their effectiveness.

You can manage Cookies through your browser settings. Disabling some Cookies may impair functionality of the Service.

Our Service may not respond to "Do Not Track" browser signals. We honor the Global Privacy Control (GPC) signal as an opt-out of "sale" and "sharing" of personal information for residents of jurisdictions where the GPC is legally recognized.

Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure. These safeguards include encryption of data in transit, access controls, logging, and security training for personnel. No system is perfectly secure, however, and we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your account credentials, for restricting access to your devices, and for the activities that occur under your account. Notify us promptly at support@linkedphone.com if you suspect unauthorized access to your account.

Data Retention

We retain personal information for as long as necessary to provide the Service, to comply with our legal obligations (including telecommunications recordkeeping obligations), to resolve disputes, and to enforce our agreements. Retention of Customer Data following cancellation or termination of your account is described in the section titled Customer Data and Privacy in our Terms of Service.

Specific retention defaults applicable to common categories of information are as follows:

• Account information: retained for the duration of your account and for a reasonable period after termination to address billing, support, and legal matters.

• Call detail records and message detail records: retained for the period required by applicable telecommunications law and our operational needs.

• Call recordings, voicemails, and transcripts: retained for the period required by applicable telecommunications law and our operational needs.

• Billing records: retained for the period required by applicable tax and accounting law.

Following account termination, we delete or de-identify personal information within a reasonable period, subject to legal obligations that may require longer retention. To request deletion sooner, see the section titled Your Privacy Rights.

If your account is suspended, terminated, or delinquent, we may release the associated phone number(s) back into available inventory after a reasonable hold period, in which case the numbers may be reassigned to other users.

Children’s Privacy

The Service is intended for use by individuals who are at least 18 years of age. We do not knowingly collect personal information from individuals under the age of 18, and the Service is not directed to children. If we learn that we have collected personal information from a child under 18, we will delete it. If you believe a child has provided personal information to us, please contact us at support@linkedphone.com.

Your Privacy Rights

Rights Available to U.S. State Residents

Depending on the state in which you reside (which currently includes California, Virginia, Colorado, Connecticut, Utah, Texas, and several others that have adopted comprehensive privacy laws), you may have the following rights with respect to personal information that LinkedPhone processes as a controller:

• Right to know and access: to request confirmation of whether we process personal information about you and to obtain a copy of that information.

• Right to correct: to request correction of inaccurate personal information.

• Right to delete: to request deletion of personal information, subject to legal exceptions.

• Right to portability: to receive a copy of certain personal information in a portable, machine-readable format.

• Right to opt out of "sale" or "sharing": to direct us not to "sell" or "share" your personal information as those terms are defined under applicable law. We do not sell personal information for monetary consideration. To the extent any of our practices constitute "sharing" under the California Consumer Privacy Act (such as the use of online advertising cookies), you may opt out as described below.

• Right to opt out of targeted advertising and certain profiling.

• Right to limit use of sensitive personal information.

• Right against retaliation for exercising any of these rights.

To exercise these rights, submit a request through our Contact Us page or by emailing support@linkedphone.com. We will verify your request using information already in our possession before responding. If we cannot verify your identity, we may decline to act on the request.

If we deny your request, you have the right to appeal that decision by contacting support@linkedphone.com with the subject line "Privacy Appeal." We will respond to appeals within the time required by applicable law.

You may use an authorized agent to submit a request on your behalf. We will require written documentation of the agent’s authority and may require you to verify your identity directly.

If LinkedPhone processes personal information about you on behalf of a Customer (that is, where LinkedPhone is acting as a service provider or processor), please direct your request to that Customer.

Rights of Residents of the European Economic Area, the United Kingdom, and Switzerland

The Service is offered in the United States and Canada and is not directed to the European Economic Area, the United Kingdom, or Switzerland. To the extent the European Union or United Kingdom General Data Protection Regulation applies to our processing of your personal data, and if you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the rights of access, rectification, erasure, restriction of processing, data portability, objection to processing, and the right not to be subject to a decision based solely on automated processing.

Where we process personal data based on consent, you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

You have the right to lodge a complaint with the data protection supervisory authority in your country of residence.

Our legal bases for processing personal data include (a) performance of a contract with you, (b) compliance with a legal obligation, (c) our legitimate interests (including providing, securing, and improving the Service, marketing, and preventing fraud), and (d) your consent where applicable.

Nevada Residents

Nevada residents may submit a verified request to direct us not to sell certain personal information by contacting support@linkedphone.com. We do not sell personal information as defined under Nevada Revised Statutes Chapter 603A.

Notice of Financial Incentive

To the extent we offer any program that may be considered a "financial incentive" under California law (such as a referral program with rewards), we will provide a separate notice of financial incentive describing the material terms and your right to withdraw.

Third-Party Services and Links

The Service may interoperate with, or contain links to, third-party websites, applications, and services that we do not control. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third party before providing personal information to it.

LinkedPhone applications may be distributed through the Apple App Store and Google Play. Your download and use of those applications is also subject to the terms and privacy practices of Apple Inc. and Google LLC, respectively.

Changes to This Policy

We may update this Policy from time to time. The "Effective Date" at the top of this Policy indicates when it was last revised. If we make material changes, we will provide notice through the Service, website, by email, or by other means to the address associated with your account, or by other reasonable means. Your continued use of the Service after the effective date of a revised Policy constitutes acceptance of the changes.

Contact Us

Questions, comments, or requests regarding this Policy may be directed to: support@linkedphone.com