PRIVACY NOTICE FOR CALIFORNIA CONSUMERS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

Categories of Personal Information	Examples Personal Information Collected within Category	Collected & Specific Data Sets
Category A Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.
Category B Personal Information categories listed in California Customer Records statute (subdivision (e) of Section 1798.80 of California Civil Code)	A name, signature, Social Security number, 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.	Yes A name, address, telephone number, education, employment, employment history, bank account number, credit card number*, or any other financial information. *Note we do not collect or store your full credit card information rather solely 4 digits and expiry date, where the full payment details will be stored solely by the payment processor used by us.
Category C Protected classification characteristics under California or federal law.	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).	No
Category D Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. The transcripts may be analyzed by a team member or by OpenAI which we use to receive a summary and insights of the call. We make sure to use the OpenAI API that does not use the inputs (i.e., transcripts) for learning purposes.	Yes Records of products or services purchased and used or considered and other purchasing or consuming histories or tendencies. In all other cases, we will process Call Records and transcripts subject to our legitimate interest.
Category E Biometric information	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.	No
Category F Internet or other electronic network activity information	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes Information on a consumer's interaction with our Website or advertisement.
Category G Geolocation data	Physical location, approximate location derived from IP address or movements	Yes Approximate location extracted from IP address, and address (where provided by you).
Category H Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	Yes Consumers and prospects calls with our sales or customer support team. In certain cases, we may further transcript the call.
Category I Professional or employment-related information	Current or past job history or performance evaluations.	Yes In the event you are interested in joining our team or apply for a position posted on our Website.
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)).	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.	No
Category K Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No
Category L Sensitive personal information	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.	No

Disclosures Of Personal Information for a Business Purpose

The Company may disclose your Personal Information to a contractor or service provider for a business purpose, subject to entering 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.

The categories of Personal Information the Company discloses (and has disclosed within the last 12 months) are listed in the table below:

 

	Category ***corresponding with the table above	Category of Recipient	Business Purpose
1.	Category A Category B Category D Category F Category G Category H Category I	Cloud computing and storage service providers.	Storage, hosting.
2.	Category A Category B Category D Category F Category G Category H Category I	Operating systems.	Operating the Website and services offered therein (e.g., services’ web-interface). To verify you, your account activity and your information.
3.	Category A Category B Category D Category F Category G Category H Category I	Government entities/Law enforcement.	Subject to a law or official authority requirement.
4.	Category A Category D Category F Category G Category H	Data analysis providers.	Providing analytic data on the use of our Website and services available therein, to maintain the quality of our services, including to improve, upgrade, and enhance our services.   We may further use transcripts of calls made to our customer support to summarize the call, to assist us in improving our customer service and to offer you additional support or offers following the call and based on the call content. The transcripts may be analyzed by a team member or by OpenAI which we use to receive a summary and insights of the call. We make sure to use the OpenAI API that does not use the inputs (i.e., transcripts) for learning purposes.
6.	Category A Category B Category D Category F Category G	Marketing & promotions providers, CRM providers, social networks, advertising networks.	To manage our services, including to help us operate, provide, evaluate, improve, monitor, customize, bill and support our services. To maintain and service Customer account. Marketing which is not cross-contextual, ad delivery.
7.	Category A Category B Category D Category F Category G Category H	Security service providers.	To detect, investigate and report fraud, abuse or illegal use of our Website, products and services or Customer accounts
9.	Category A Category B Category D Category F Category G Category H Category I	Customer support providers.	To provide Customers with support regarding our products and services To maintain and service Customer account, including to process orders and payments
10.	Category A Category B Category D Category F Category G Category H Category I	N2P Group	To manage our services, including to help us operate, provide, evaluate, improve, monitor, customize, bill and support our global services. To maintain and service Customer account. Marketing which is not cross-contextual, ad delivery.

 

Categories of Sources - How We Collect Personal Information

We collect the categories of Personal Information detailed above, in the following ways: 

Directly from the consumer - for example, when you fill out our forms, when you contact us, etc.;

Indirectly from activity on our Website or across the internet- for example, we collect your online identifiers and usage data on our Website automatically using cookies and similar technologies and we receive data related to engagement with our campaigns, for example, when you view or interact with certain content and ads;

Indirectly – for example, we may receive business emails of prospects from marketing tools we use. 

Use Of Personal Information

We may use, or disclose the Personal Information we collect for one or more of the following business purposes:

To fulfill or meet the reason you provided the Personal Information. For example, if you are our Customer we will use your Personal Information to create your account, if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry, as well as for support, review your CV considered for a job position, etc.; 

To detect, investigate and report fraud, abuse or illegal use of our Website and services or Customer accounts;

To manage our Website and services, including to help us operate, provide, evaluate, improve, monitor, customize, bill and support our services. To maintain the quality of our Website services, including to improve, upgrade, and enhance our Website, content and services and our marketing efforts which includes but not limited to, analyze which types of content and promotional campaigns are effective, marketing our services; analyzing your use of the Website, etc.; 

To maintain and service your Customer account, including to process orders and payments, verify you, your account activity and your information; 

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 Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sale or Share of Personal Information

We do not “Sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment.  We may “Share” or “Sell” Personal Information for “interest-based advertising” or “cross-context behavioral advertising.”  The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration.”  In other words, we may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content.  

The categories of Personal Information the Company discloses (and has disclosed within the last 12 months), where such disclosure is defined as “sale” or share” under the CCPA, are listed in the table below:

CATEGORY (CORRESPONDING WITH THE TABLE ABOVE)	CATEGORY RECIPIENT	PURPOSE OF SALE OR SHARE
Category A Category D Category F  Category G	Ad-network and advertising partners.	Sale/Share for cross-context behavioral advertising.

How Long will the Company Retain Your Personal Information.

The Company retains your Personal Information only for as long as is necessary to carry out the purposes described in this CCPA Notice, and we have strict review and retention policies in place to meet these obligations.  This time period may vary depending on the type of Personal Information and the services used, and applicable law, which may require us to maintain information for a set amount of time.  After such time, we will either delete or anonymize your Personal Information.  You cannot be identified from anonymized information retained or used by the Company. 

As noted above, the retention periods are determined, among others, according to the types of Personal Information, and for example:

Customer account information.  We store your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate your service.  

Contact information. If you voluntarily sign up to our newsletter or event, we will collect the information you have provided such as name and email address, and store it for as long as you haven’t requested to unsubscribe, and thereafter, as part of our suppression list, for the applicable statuary limitation period.  

We also retain some of your Personal Information as necessary to comply with our legal obligations, to resolve disputes including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods, to enforce our agreements, to support business operations, and, subject to applicable laws, to continue to develop and improve our services.  For example, we are required under certain applicable tax laws to keep your basic Personal Information (name, address, contact details and transactions) for a minimum of six years after which time it will be destroyed unless required to be kept for other purposes.  Please note that except as required by applicable law, we will not be obligated to retain your Personal Information for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

Children Under the Age of 16. 

Our Website and services are not intended for use by children and we do not knowingly or intentionally collect the Personal Information of a consumer under the age of 16, nor sell or share the Personal Information of a consumer under the age of 16 unless the consumer (if age 13-16) or the consumer’s parent (for consumers under 13) affirmatively authorizes the sale or sharing.  

Amendments

As required under the CCPA, we will update this CCPA Notice every 12 months (if needed). The last revision date will be reflected in the “Last Updated” heading located at the header of the CCPA Notice. 

CALIFORNIA RESIDENTS’ RIGHTS AND HOW YOU MAY EXERCISE THEM.

Your Rights

As a California resident you have certain rights regarding your Personal Information under the CCPA. 

Right to know and access Personal Information collected, and data portability – you have the right to request that the Company disclose the categories of Personal Information collected about you; categories of sources of Personal Information; business or commercial purpose for collecting, selling or sharing your Personal Information; categories of third parties with whom we disclose your Personal Information; and the specific pieces of personal information that we have collected about you. You further have the right to request a copy of Personal Information you provided to us in a portable format.

Right to non-discrimination for exercising your rights under the CCPA - the Company cannot (and does not) deny goods or services, charge you a different price, or provide a different level or quality of goods or services because a consumer exercised any of the consumer’s rights under the CCPA.  However, if you refuse to provide your Personal Information to the Company or ask it to delete or stop selling your Personal Information, and that Personal Information or sale is necessary for the Company to provide you with goods or services, the Company may not be able to complete that transaction. Pursuant to the CCPA, the Company is permitted to charge a consumer a different price or rate, provide a different level of service, offer you promotions, discounts and other deals in exchange for collecting, keeping, or selling your Personal Information, if that difference and the financial incentive offered is reasonably related to the value of your Personal Information. If you ask to delete or stop selling your Personal Information, you may not be able to continue participating in the special deals offered in exchange for Personal Information.

Right to delete – you have the right to request that the Company delete Personal Information that it has collected about you.  There are exceptions to this right and the common reasons why the Company does not have to delete your Personal Information include: where the Company cannot verify your request; if it is reasonably necessary to complete a transaction with you, to provide services or for certain warranty and product recall purposes; if retention of Personal Information is needed to comply with our legal obligations, exercise legal claims or rights, or defend legal claims; if retention of Personal Information is needed for certain business security practices or certain internal uses that are compatible with reasonable consumer expectations or the context in which the information was provided; if information is exempt from the CCPA, and as otherwise provided in the CCPA. 

Right to correct inaccurate Personal Information – you have the right to request that the Company correct any inaccurate Personal Information that it maintains about you.

Right to opt out of “sale” or “sharing” of Personal Information – as detailed above, the Company’s practice of using advertising cookies (used for cross-context behavioral advertising known as “targeting”) in its Website falls under the definition of “Sale” and “Share” under the CCPA.  You have the right to opt-out from cookies using our Cookies Setting tool, where you can further change your preferences at any time. We will also process any opt-out of sale/sharing preference signal that meets the requirements set forth in the CCPA and its regulations.  In addition, you may request that the Company not sell or share your Personal Information should the Company decide in the future to sell or share Personal Information to third parties (as shall be detailed under this CCPA Notice).  To exercise this right please go to https://www.idt.net/ccpa-do-not-sell and complete the form.  

Right to limit use and disclosure of Sensitive Personal Information – the Company does not use your Sensitive Personal Information (as defined in the CCPA) for purposes other than as set forth in the CCPA.  Nonetheless, you have the right to direct the Company to limit its use of your Sensitive Personal Information to that use which is necessary for the Company to perform the services and provide the goods you requested from the Company.  To exercise this right please go to https://www.idt.net/ccpa-do-not-sell and complete the form.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws

How to Exercise Your Rights 

To exercise your rights to know and access your Personal Information collected, sold, shared or disclosed by the Company, or to exercise your right to delete your Personal Information or to correct inaccurate Personal Information, please go to  https://www.idt.net/ccpa-do-not-sell and complete the form.  

To exercise your right to opt out of the sale or sharing of your Personal Information, or to exercise your right to limit the use and disclosure of your Sensitive Personal Information please go to  https://www.idt.net/ccpa-do-not-sell and complete the form. To opt-out from selling or sharing information through our use of cookies, use our Cookies Setting tool. We will also process any opt-out of sale/sharing preference signal that meets the requirements set forth in the CCPA and its regulations.  

In addition, you can exercise your rights by calling the following toll-free number:  +1 866-978-8260.  

Authorized Agents 

“Authorized Agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that, the Company may require that the consumer do the following: provide the authorized agent signed permission to do so or power of attorney; verify their own identity directly with the Company; directly confirm with the Company that they provided the authorized agent permission to submit the request. The Company may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

Verification of Consumer Requests.  

In order to comply with a consumer request, the Company must reasonably verify the requestor.  A record of each request is made as soon as it is received by our data protection team.  The Company will use all reasonable measures to verify the identity of the individual making the request.  We will utilize the requested data to ensure that we can verify the requestor’s identity and where we are unable to do so, we may contact you for further information, or ask you to provide evidence of your identity prior to responding to your request.  This is to protect your data and rights.  If a third party, relative or representative is requesting the data on your behalf, we will verify their authority to act for you and may contact you and them to confirm you and their identity and gain your authorization prior to responding to the request.

Responding to Consumer Requests  

The Company will attempt to confirm receipt of each request by contacting the requestor either at the email or telephone number submitted, through the consumer’s account or by other electronic means.  The Company will attempt to verify each request and if it is able to verify a request will provide a response (if necessary and applicable) within 45 days of the receipt of the request, which time period may be extended by the Company for an additional 45 days.  If a delay is necessary, the Company will contact the requestor within the original 45 days period and provide the reasons for the delay.  The Company may charge a fee or refuse to act on any request that is manifestly unfounded or excessive.  All the Company responses shall be in writing and cover the previous 12 months period unless the consumer requests information beyond the 12 months period (only applies to personal information collected on or after January 1, 2022).  Where possible the response shall be sent through the consumer’s account.  Otherwise, the response shall be sent by mail or electronically.  The Company is not obligated to provide a response to a consumer more than two times in any 12 months period.  The CCPA contains certain exemptions and exceptions to the exercise of some of these rights.  If one or more of those exemptions or exceptions applies to your request, then we may not be able to act upon your request.  Where possible we will inform you of the reasons for not acting upon your request.

Other California Obligations 

Direct marketing requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please go to  https://www.idt.net/ccpa-do-not-sell 

Do Not Track settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us. 

Notice Of Financial Incentive

We do not offer financial incentives to consumers for providing Personal Information.    

FOR MORE INFO.  

For more information on your rights and our obligations under the CCPA please send an email to Privacy@net2phone.com. For California residents with a disability please send an email to ccpa@idt.net for information on how to access this policy in another format.