Privacy Policy

Last Updated: June 1, 2019
Effective Date: June 1, 2019

Thanks for using CCPA Toll Free. Our goal is to enable organizations to comply as easily as possible with the California Consumer Privacy Act’s requirement to offer a toll-free number to consumers. As a legal compliance service, we respect and protect your privacy and security and are committed to following best practices to support this principle.
We – meaning Privacy Toll Free, LLC doing business as CCPA Toll Free (also, “CCPA Toll Free,” “our” or “us”) – prepared this Privacy Policy to help you understand our practices regarding the collection, use, and disclosure of information we collect from you through CCPA Toll Free’s web and mobile applications, our websites that link to this Privacy Policy, and any other services we provide to our customers (collectively, “Services”).
By accessing or using the Services, you agree to this Privacy Policy and our Terms of Service.

What Information We Collect

The information we collect from you depends on how you use the Services and what information you choose to provide or make available to us. We collect information from you when you:

Customer Information

Information related to the creation of accounts or that otherwise identifies you as a customer or end user of CCPA Toll Free is what we call “Customer Information.” Customer Information may include certain “personally identifiable information” or “PII,” such as your name, email address, postal address and phone number. It also may include payment information, such as payment method, credit card information, and any contact information (such as name and postal address) associated with payment billing information. If you are an end user using the Services through an account created on your behalf by a CCPA Toll Free customer (such as an employer), we may collect and process Customer Information about you on behalf of the CCPA Toll Free customer with whom we associate your use of the Services.

When you create an account with CCPA Toll Free, we may collect certain Customer Information directly from you or, if you create your account using a third-party service (such as Google or a single sign-on service such as Okta), we may collect Customer Information about you from the third-party service (such as your username or user ID associated with that third-party service). By choosing to create an account using a third-party service, you authorize us to collect Customer Information necessary to authenticate your account with the third-party service provider.

Certain aspects of the Services may allow you to link or integrate third-party products and services to enable certain features and functionalities with the Services. For example, you can connect your Amazon S3 account so as to store consumer voicemails in your Amazon cloud storage. If you choose to use these features or functionalities, you may be asked to create an account with a third-party service provider or link your existing account with that service provider (and, by doing so, agree to the privacy policy and/or terms and conditions of that third-party). You may also be asked to authorize CCPA Toll Free to collect information from the third-party service provider on your behalf. We will then collect information (such as your username or user ID associated with that third-party service) from you and/or that third-party service provider as necessary to enable the Services to upload your data and content to that third-party service provider. Once the authentication is complete, we have the ability to access information you or we made available in the applicable location or that was otherwise collected by the third-party service in accordance with the privacy practices of that third-party service. We may collect and associate that information and data with your CCPA Toll Free account, and we will only use it to enable the integration of the Services with the third-party service provider and to perform actions requested or initiated by you, or that are reasonably necessary to carry out instructions provided by you.

Content

CCPA Toll Free allows you and your consumers to upload to the Services information, data and content such as outgoing and income voicemail messages, compliance notes about your CCPA compliance and other materials. We call anything you upload through the Services “Content.” You control the Content, and our collection, use, and disclosure practices with respect to Content are separate from those with respect to other sorts of information we collect, including Customer Information. As explained in detail above, we may also upload Content automatically with your authorization to third-party service providers (such as Amazon cloud storage).

Use of Content

Notwithstanding anything else in this Privacy Policy to the contrary, we will not use or access your Content except in the following cases: for providing the Services to you; where you (or, if you are an end user, the CCPA Toll Free customer through which you have an account) explicitly approve access (e.g., during a customer support inquiry); where compelled to do so in response to lawful requests by law enforcement or government regulators; where necessary to ensure the stability and security of the Services and our systems (e.g., where we have reason to believe specific Content is degrading server stability); and where necessary to protect the rights, privacy, safety, or property of you, us, or others. We may also analyze metadata related to Content (such as total number of records, file size, API volume, access logs, etc.).

Information Collected Automatically Through Your Use of the Services

We collect information about how you use the Services and your actions on the Services, including IP addresses, what software and hardware you use (such as browser types, operating systems, ISPs, platform type, device type, mobile device identifiers such as make and model, mobile carrier), pages or features of CCPA Toll Free used and associated dates and time stamps, search terms, links you click, whether you open messages sent to your account, and other statistics related to your usage of the Services. We may also use tools, including third-party tools, to collect analytics data. Some of this information is collected through the use of “cookies” and other tracking technologies, such as web beacons and similar technologies (“tracking technologies”). We may also work with third party partners to employ tracking technologies.

If you would prefer not to accept cookies or otherwise wish to disable our use of tracking technologies, please see “Managing Your Information,” below. Please note that doing so may negatively impact your experience using the Services, as some features may not work properly.

Location Information

In some cases, we may collect limited location information. For example, we may use Google Analytics convert your IP address into a rough geolocation to understand in what areas our users are located and to improve and personalize CCPA Toll Free (for example, to display time data in the correct local time).

Aggregated and Anonymized Information

We may collect information by aggregating and anonymizing other information. The aggregation and anonymization process prevents the information from being reassociated or identified with any one customer account, user, or individual. We may use aggregated and anonymized information for a wide variety of statistical, analytical and marketing purposes.

How We Use the Information We Collect

We use the information we collect for a variety of purposes, and how we use it depends on what we collect and what features of the Services you use. These purposes may include:

Personally Identifiable Information

Specifically, we may use personally identifiable information (including those contained within the Customer Information or otherwise collected by us) for the above purposes, but only to the extent necessary for the purposes for which you have provided us with the information, to respond to inquiries or requests (including requests for customer support or technical assistance), to otherwise perform our obligations or act consistently with our Terms of Service, to respond to law enforcement or other governmental or legal authorities, and to otherwise use the information consistent with your instructions to us (both explicit, such as when you contact us directly with a request, and implied, such as when you engage us to provide you with the Services). If you wish to change these instructions, either by request, by correcting, amending, or deleting information we may have collected about you, or by opting out of certain data collection practices, please see “Managing Your Information” below.

How We Share Information

We may disclose the information we collect in the following cases:

How We Secure Your Information

We implement appropriate technical and organizational measures to protect the information we collect and store. Note that no security measures are 100% foolproof, and as no network or system (including ours) can be guaranteed to be 100% secure against destruction, loss, alteration, unauthorized disclosure of, or access to information we collect and store. If you believe your information may not be secure for any reason, please contact us immediately at privacy@CCPATollFree.com.

Managing Your Information

You have choices to access information we collect about you and about how we use or disclose that information. This section details those choices, including how you can exercise rights with respect to your information (including personally identifiable information), how you can opt out of collection and use of certain types of information for certain purposes (such as marketing), and how you can use your browser or third-party tools to disable certain collection methods (such as cookies or tracking technologies).

You may access, correct, amend, or delete Content by accessing it within the Services. You control all Content you upload. Content you delete (including Content containing personal information) may be retained in archived or backup copies in order to enable you to use certain features like compliance logging. For instructions on how to permanently delete Content from your CCPA Toll Free account, contact us at privacy@CCPATollFree.com. Please note that permanent deletion of Content through this process will impair or disable those features with respect to that Content.

You may access, correct, amend, or delete Customer Information we have about you by logging into your account and using the applicable site features. If you wish to cancel your account and delete all of your Customer Information, email us at support@CCPATollFree.com. We will then delete your Customer Information within 30 days.

Our general data retention policy is to keep all of your Customer Information that you do not delete for as long as you maintain your account with us, and we will delete your Customer Information within 30 days after you close your account or if you do not convert to a paid subscriber at the end of your free trial period. However, as consumer voicemails represent larger file sizes, we reserve the right to delete them if they are more than 180 days old in the case of small and medium business accounts, or more than 365 days old in the case of enterprise accounts. All customers may preserve consumer voicemails indefinitely by using the download feature in the dashboard, and enterprise customers can automatically back them up using our Amazon S3 integration.

Notwithstanding anything else in this privacy policy to the contrary, (1) we may retain information in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law and (2) we retain certain Customer Information in our log files for 90 days from the date it is created to assist us with technical troubleshooting, provided that log files will never contain audio content or your compliance notes.

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new CCPA Toll Free features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of our using your information for these purposes, follow the opt-out instructions by clicking “Unsubscribe” (or similar opt-out language) in those communications. You can also contact us at privacy@CCPATollFree.com to opt out.

Cookies, Tracking Technologies and Do Not Track – How to Opt Out

If you prefer not to accept cookies or otherwise wish to disable our use of tracking technologies, most browsers and mobile devices allow you to change your settings so as to notify you when you receive cookies or other tracking technologies are being used, and to choose whether or not to accept/allow it. Most browsers also allow you to disable or delete existing cookies or to automatically reject future cookies. Disabling cookies may limit your ability to use the Services.

Certain tracking technologies we use are related to advertising networks, and through those technologies we may share certain information such as IP addresses. No directly identifying personal information is shared with these advertising networks, but please note that the information we share with those advertising networks might be combined with other information about you that those networks may have collected from other sources. To learn more about advertising networks and how to opt out of sharing information with them, please click here and here. If you’re in the EU, you can find additional information about your choices with respect to advertising networks and online behavioral advertising by clicking here.

CCPA Toll Free does not support Do Not Track. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit here.

If you have any questions about how we or our third-party service providers use cookies or other tracking technologies that aren’t answered in this Privacy Policy, please contact us at privacy@CCPATollFree.com.

International Transfers (including Transfers Outside of the European Union)

We process and store information on servers located in the United States, and we may store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. By using the Services, you consent to the transfer of information (including Customer Information, Content, and personally identifiable information) to locations that may be outside of your country of residence, including to the United States. You acknowledge and agree that, as a condition of providing any Content, you can legally transfer it to the United States and any other country.

With respect to transfers of information out of the European Union (EU), we may process some personally identifiable information pursuant to data processing agreements that include the EU Standard Contractual Clauses. To learn more about our data processing agreements, please contact us at privacy@CCPATollFree.com.

Information from Children

CCPA Toll Free is not directed to children under the age of 13 and we do not knowingly collect personally identifiable information from children under the age of 13. If we learn that we have collected personally identifiable information of a child under the age 13, we will take reasonable steps to delete such information from our files as soon as is practicable. Please contact us at privacy@CCPATollFree.com if you believe we have any information from or about a child under the age of 13.

California Consumer Privacy Act Disclosures

The California Consumer Privacy Act, or CCPA, requires businesses subject to this law to provide consumers residing in California with certain rights regarding their personal information.

At this time, we do not sell your personal information, so no opt-out or opt-in choices apply. For more information, visit www.ccpatollfree.com/donotsell.

Here’s a summary of rights for California consumers under the CCPA:

  1. The categories of personal information we have collected about you.
    1. We collect customary “web log” data about the device you use to access our services, such as which browser you use, your device platform (e.g., iPhone vs. Windows PC), your screen resolution and your device language setting.
    2. We collect registration data when you create an account on our site, such as your name, company name, email address and password.
    3. We collect payment data when you purchase our services, such as your credit card number and billing address.  
    4. We collect service usage data, such as which services features you and your consumers interacting with our services access, how often you and they access them and at what time you and they access them.
    5. We collect the content you transmit to our services, including your compliance notes and the outgoing greetings your consumers hear when they call our toll-free number and enter one of your service codes.
    6. We collect the content your consumers transmit to us when they interact with our services, including the voicemails they leave for you.
    7. We collect marketing data such as your email address when you sign up for our mailing list.
    8. For more information, see above under the caption, “What Information We Collect.”
  2. The categories of sources from which we collect personal information.
    1. We collect personal information from you actively when you enter it into our services (e.g., by typing in your name).
    2. We collect personal information passively when you access our services, to the extent your web browser provides this information to our servers (e.g., your operating system, and screen resolution) and also based on your service usage (e.g., when and from what IP address you log on to our services).  
    3. We collect personal information when your consumers interact with our services by calling our toll-free number and leaving a message.
    4. For more information, see above under the caption, “What Information We Collect.”
  3. Our business or commercial purpose for collecting or selling personal information.
    1. We collect your personal information to promote our services, to provide them, to support them and to develop them.
    2. For more information, see above under the caption, “How We use the Information We Collect.”
    3. We do not sell your personal information to third parties.
  4. The categories of personal information that we disclosed about you for a business purpose.
    1. We rely on vendors to operate our infrastructure, and for each category of personal information that collect (i.e. web log data, registration data, payment data, service usage data, your content, your consumers’ content and marketing data), we disclose it to one or more of our third-party vendors for a business purpose, including to develop, market, provide and support our services.
    2. For more information, see above under the caption, “How we Share Information.”
  5. The categories of third parties with whom we share personal information.
    1. We share your personal information with our vendors in order to achieve our business purposes described above. Our vendors include Amazon, Google, Twilio, NameCheap, Heroku, EasyWP, MailChimp, PaperTail
  6. The specific pieces of personal information we collected about you.
    1. Please email us at  privacy@ccpatollfree.com or call us toll free at 1-866-I-OPT-OUT and enter Service Code 1 to request this information. Before we can respond to your request, we’ll need to verify your identity.  
  7. The categories of personal information that we sold about you, and the categories of third parties we sold it to, including list by category of personal information for each third party to which we sold personal information.
    1. We do not sell your personal information, so there is nothing for us to disclose to you based on your right to know this information.

Because we operate our services consistently for all customers, we have disclosed to everyone as part of our privacy policy most of the information the CCPA entitles you to receive, so there is no need for you to submit a request for that information unless it is a request for the specific pieces of personal information that we collected about you as described in 6 above.

Changes to Privacy Policy

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, revise the Privacy Policy from time to time. If a revision is material, as determined solely by us, we will notify you, for example via email. The current version will always be posted to our Privacy Policy page.

If you have any questions about this Privacy Policy, or wish to exercise any of your privacy rights, please contact us at privacy@CCPATollFree.com.