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.
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:
- Create or register an account, and when you administer your account
- Input information or data into any of our Services, or post or upload Content to our Services
- Submit questions, requests, other communications to us via forms, email, or other communication media
- Contact us for customer support or technical support
- Visit any of our websites or download any of our apps
- Participate in any promotions, demonstrations, contests, surveys, or other marketing events
- Interact with other CCPA Toll Free users and guests on our community forums
- Integrate third-party products and services with your CCPA Toll Free account
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.
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
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.
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:
- Providing the Services to you;
- Responding to requests or inquiries from you;
- Providing customer support or technical assistance;
- Contacting you to provide product updates and information about the products you have requested or purchased;
- Marketing CCPA Toll Free products, services and features that you may be interested in, and monitoring the performance of our advertisements and marketing efforts;
- Creating or administering your account, including identifying you with your account or the account of a CCPA Toll Free customer;
- Billing you;
- Deriving market insights, ways to improve the Services, and other business analysis or research purposes;
- Customizing existing and future product offerings and other aspects of the Services to you and other users;
- Securing the Services and our systems, and protecting your information and data;
- Sharing with third parties for the purposes discussed in “How we share information,” below; and
- Any legitimate business purpose, provided that the information is aggregated and anonymized.
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:
- You asked us to, or otherwise gave your specific consent (for example, by posting Content to user forums, you consent to our sharing that Content with other CCPA Toll Free users);
- With vendors we engage to provide you with aspects of the Services, such as data storage, hosting, and payment processing;
- With third-party service providers who enable certain features or functionalities of the Services that you’ve requested (for example, by integrating the Services with your Amazon S3 account for voicemail storage);
- With vendors we engage to help us gain insights and analytics into how the Services are used and how they might be improved (for example, we may use third-party data enrichment services to match Customer Information or other personally identifiable information we collect with publicly available database information in order to communicate more effectively with you);
- As necessary to comply with applicable law, including governmental requests, law enforcement requests, and otherwise to protect the rights, privacy, safety, or property of you, us, or others;
- As necessary in the event of a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, financing, or other disposition of all or any portion of CCPA Toll Free business, assets, or equity; and
- With others for any legitimate business purpose, provided the information is aggregated and anonymized.
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.
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.
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:
- Your Right to Opt Out. You have the right to tell businesses that do sell your personal information to third parties (i.e. not us) not to sell it at any time. Businesses that sell your personal information to third parties must also ensure that the third parties do not resell it unless the business notified you explicitly and provided you with a chance to opt out of resales. These opt-out rights apply to businesses that do not know your age, or know you are older than 16.
- Your Right to Opt In. If a business has actual knowledge that you are between ages 13 and 16 (e.g., based information the business collects), businesses cannot sell or allow resales of your personal information without your affirmative authorization. If a business has actual knowledge that you are younger than 13, it may not sell or allow resales of your personal information without your parent or guardian’s affirmative authorization. This is your right to opt in.
- Your Right to Disclosures. You have the right to know:
- The categories of personal information we have collected about you.
- 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.
- We collect registration data when you create an account on our site, such as your name, company name, email address and password.
- We collect payment data when you purchase our services, such as your credit card number and billing address.
- 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.
- 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.
- We collect the content your consumers transmit to us when they interact with our services, including the voicemails they leave for you.
- We collect marketing data such as your email address when you sign up for our mailing list.
- For more information, see above under the caption, “What Information We Collect.”
- The categories of sources from which we collect personal information.
- We collect personal information from you actively when you enter it into our services (e.g., by typing in your name).
- 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).
- We collect personal information when your consumers interact with our services by calling our toll-free number and leaving a message.
- For more information, see above under the caption, “What Information We Collect.”
- Our business or commercial purpose for collecting or selling personal information.
- We collect your personal information to promote our services, to provide them, to support them and to develop them.
- For more information, see above under the caption, “How We use the Information We Collect.”
- We do not sell your personal information to third parties.
- The categories of personal information that we disclosed about you for a business purpose.
- 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.
- For more information, see above under the caption, “How we Share Information.”
- The categories of third parties with whom we share personal information.
- 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
- The specific pieces of personal information we collected about you.
- 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.
- 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.
- Your Right to Data Deletion. You have the right to request that we delete any personal information about you that we have collected. Before we delete any information, we’ll need to verify your identity. If we delete your information, we’ll also instruct our vendors (aka service providers) to delete it. The CCPA does not obligate us to delete information under all circumstances, including where we need the information to provide our services to you, to detect security incidents, to identify errors in our services, or to comply with legal obligations. If you request that we delete information, we’ll let you know if we are deleting it or if we are not deleting it based on exemptions provided by the CCPA. You may also delete personal information by using our services dashboard as described above under the caption “Managing Your Information.”
- Your Anti-Discrimination Rights. Businesses may not discriminate against you exercising any of your consumer privacy rights such as by: (1) denying you goods or services; (2) charging you different prices or rates for goods or services, including via discounts or other benefits or penalties; (3) providing you a different level or quality of goods or services or (4) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Businesses may however discriminate where any difference is reasonably related to the value provided to you by your data. We will not discriminate against you in any way for exercising your privacy rights.
- Designated methods for submitting requests.