Privacy Policy

Overview

DialClear LLC, a New Mexico limited liability company ("DialClear," "we," or "us") respects your privacy and is committed to protecting it through compliance with this Privacy Policy ("Privacy Policy"). This Privacy Policy describes the types of Information we may collect from you when you visit the website at https://dialclear.co or use the Services offered there (the "Platform"), including the web portal, the DialClear API, and the DialClear LeadConnector integration, and that you may provide in electronic messages to DialClear. It also describes our practices for collecting, using, maintaining, protecting, and disclosing that Information.

Please read this Privacy Policy to understand our policies and practices regarding your Information and how we will handle it. If you do not agree with our policies and practices, do not use the Platform. By accessing or using the Platform, you agree to this Privacy Policy. DialClear may change this Privacy Policy at any time, at its discretion. Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

This Privacy Policy is subject to and governed by the DialClear Terms of Service ("Terms of Service") available on the Platform. The Services are part of the Platform and are described further in the Terms of Service.

The Types of Information That DialClear Collects About You and How DialClear Collects It

DialClear may collect two types of information from you when you visit the Platform: Personal Information and Non-Personal Information (collectively "Information").

"Personal Information" refers to data by which you may be personally identified, such as name, email address, employer, telephone number, and other information described in this Privacy Policy.

"Non-Personal Information" means data that is about you, but does not identify you specifically.

If you do nothing during your visit to our Platform but browse, read pages, or view content, we will gather and store Information about your visit that does not identify you personally.

We collect Information:

• Directly from you when you provide it to us.
• Through our communications with you.
• From third parties.
• Automatically as you navigate through the Platform.
• Automatically, on an aggregate level, when you utilize our Services.
• Through analytics.

Information You Provide Directly to DialClear. The Information that you provide us directly through the Platform may include:

• Account data you provide when you create an account, such as your name, email address, and, for password-based accounts, a password (stored only in hashed form). You may authenticate with an email and password, via Google sign-in, or through single sign-on from a connected CRM.
• Phone numbers, names, email addresses, and mailing addresses you submit for screening or verification, via the web portal, the API, file upload, or the LeadConnector integration. This is contact data belonging to you or your business ("Customer Contact Data"), and we process it on your behalf to provide the Services.
• Lookup results and lookup history generated from your screening requests, such as DNC registry status, litigator flags, reassigned-number results, contact-verification trust scores, address verification results, and geolocation data.
• Consent records you capture, import, or that are collected from your connected CRM's forms and surveys at your direction, including the contact's phone number, email, name, the consent wording, and timestamps, and call recordings you upload as evidence of verbal consent. Recordings are stored with a cryptographic fingerprint to demonstrate they have not been altered; we do not analyze voices or create biometric identifiers from them.
• Consent dates you supply for Reassigned Numbers Database queries.
• Usage and billing records, including per-lookup records and token balance history used to calculate charges. Payment card details are collected and processed by our payment processor, Stripe: DialClear does not store full payment card numbers.
• Information that you provide when you report a problem with the Platform, or in connection with an inquiry you have. We may ask you for additional Information to resolve the problem.
• Records and copies of your correspondence (including email addresses), if you contact us.

Information Automatically Collected from You. The Information that DialClear may automatically collect and store about you when you visit the Platform may include:

• Your location;
• The Internet Protocol address and domain name used. The Internet Protocol address is a numerical identifier assigned either to your internet service provider or directly to your computer. We use the Internet Protocol address to direct internet traffic to you;
• The type of browser and operating system you used;
• The date and time you visited the Platform;
• The web pages or Services you accessed at the Platform, and API request logs;
• The website you visited prior to coming to the Platform; and
• Cookies and session data. Cookies are small text files that a web server places on a user's computer. We use cookies and similar technologies to keep you signed in and to optimize the Platform for your use. You can remove or reject cookies using your browser or device settings, but in some cases doing so may affect your ability to use our products and Services.

Customer Contact Data. Phone numbers, names, email addresses, and addresses you submit for screening or verification belong to you and the individuals they identify. We process Customer Contact Data solely to perform the screening and verification you request (including checking numbers against Do Not Call registries, known-litigator databases, and the FCC Reassigned Numbers Database, verifying contact identity signals, verifying addresses, and resolving geolocation), to maintain your lookup history and consent records, to provide the re-screening and flag-propagation features, and to spend tokens from your balance for each lookup. We do not use Customer Contact Data for our own marketing, do not sell it, and do not use it to contact the individuals it identifies.

How flag propagation works across accounts. When a number you screen comes back flagged, that screening result may be applied to the same number in other DialClear accounts that already hold it and subscribe to a Shield tier, and screening results from other accounts may likewise be applied to numbers you already hold. Only the provider-derived screening result crosses between accounts — never your Customer Contact Data, and never the identity of the account a result came from. What is written to a contact is exactly what that account's own screening of that number would have written. This happens whether or not you subscribe to a Shield tier; a subscription determines what your account receives, not whether your results contribute.

How DialClear Uses Information It Collects About You and the Purposes for the Collection and Use

We use Information that we collect about you or that you provide to us, including any Personal Information, for the following purposes:

• To provide, operate, and maintain the Platform and Services, including creating and managing your account, authenticating you, performing the screenings you request, and delivering the features you subscribe to.
• To process payments, manage your token balance and purchases, and administer your account, including charging your payment method, issuing invoices, calculating taxes, and preventing payment fraud.
• To maintain your lookup history so you have an auditable record of the screenings you have run.
• To provide customer support and respond to your inquiries, requests, and technical issues.
• To monitor and improve the security, reliability, and performance of the Platform, including detecting and preventing fraud, abuse, and unauthorized access.
• To improve the Platform, develop new features and Services, and conduct research and analytics to better understand how our customers use the Platform.
• To send you transactional, administrative, and service-related communications, such as account notifications, billing notices, security alerts, and updates to these policies.
• To send you marketing communications about DialClear products, features, and offers, where permitted by applicable law and your communication preferences. You may opt out of marketing communications at any time.
• To comply with applicable legal, regulatory, tax, accounting, and reporting obligations, and to respond to lawful requests from government authorities.
• To establish, exercise, or defend legal claims and to enforce these terms.

Platform statistics are compiled into aggregate reports, which help DialClear understand, anticipate, and respond to user needs. This Information helps us create a better overall experience for Platform users.

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and for other purposes described in this Privacy Policy. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information. And in some circumstances we will anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

How DialClear Protects Your Information

We have implemented measures designed to protect your Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the internet is not completely secure. Although we are working to protect your Information, we cannot guarantee the security of your Information either in transmission or when stored. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

When DialClear Shares Your Information

We may disclose your Information:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business, as described further below, including third-party payment facilitators and data providers used to perform the screenings you request.
• To a buyer or other successor (potential or actual) in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of DialClear's assets, including any related due diligence.
• To fulfill the purpose for which you provide it, for example, transmitting phone numbers you submit to our screening data provider to return DNC and litigator results, or syncing screening results back to your LeadConnector account when you connect the integration.
• For any other purpose disclosed by us when you provide the Information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Service.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of DialClear or others.

DialClear does not sell any of your Personal Information.

Updating and Correcting Information

We believe you should have the ability to access and edit the Personal Information that you have provided to us. You may change your account information online at any time by signing in to your account. We encourage you to promptly update your Information if it changes. You may ask to have Information on your account deleted or removed; however, some Information, such as billing records, past transactions, and logs of technical support requests, may not be deleted. In addition, it may be impossible to completely delete your Information without some residual Information due to our backup procedures.

Third-Party Service Providers and Subprocessors

We use third parties to host the Platform, operate Platform features, and perform administrative, analytics, screening, and payment processing services. We may disclose your Information to these companies so they can carry out these services. These companies are bound by contractual obligations to keep Information confidential and to use it only for the purposes for which we disclose it to them. Our current service providers and subprocessors include:

• Google Cloud (including Cloud Run, Google sign-in, the Gmail API for transactional email, and the Geocoding and Time Zone APIs), infrastructure hosting, authentication, service email, and address geolocation.
• Stripe, payment processing, token purchases, and subscription management.
• Blacklist Alliance: DNC registry and known-litigator screening data used to perform phone lookups.
• Twilio, phone line-type, caller-name, and carrier identity-match data used to perform contact verification lookups.
• The FCC Reassigned Numbers Database administrator, receives the phone number and consent date for premium reassigned-number queries you request.
• LeadConnector, only if and when you connect the DialClear LeadConnector integration to your LeadConnector account, in which case contact data, screening results, and (if you use the Consent Vault) form and survey submissions are exchanged between DialClear and LeadConnector at your direction.

We will provide reasonable advance notice of any material change to our subprocessors, except in the case of emergency security or service-continuity changes, where notice will be provided as soon as practicable thereafter.

Information From Children

We do not knowingly collect, use, or disclose Information from individuals under 18. If we learn that we have collected the Personal Information of an individual under 18, we will take steps to delete the information as soon as possible. If you are under 18, do not provide any Information about yourself to DialClear. If you become aware that Information of an individual under 18 years of age has been provided, please contact us at legal@dialclear.co.

Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked to or from the Platform, including the information or content contained therein. Our Privacy Policy does not apply to third-party websites or services.

Do Not Track

Some browsers incorporate a "Do Not Track" ("DNT") feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.

Residents of the European Economic Area ("EEA") and United Kingdom ("UK")

If you are located in the EEA or UK, you may have certain rights with respect to your Personal Information that are described below.

Processing. DialClear may process your Personal Information on one or more of the following legal bases:

• as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide Services, to respond to requests from you, or to provide customer support;
• where we have a legitimate interest, as described in this Privacy Policy (see "How DialClear Uses Information It Collects About You and the Purposes for the Collection and Use");
• as necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
• with your consent.

Your Rights. Subject to applicable law, you may have the right to:

• ask whether we hold Personal Information about you and request copies of such Personal Information and information about how it is processed;
• request that inaccurate Personal Information is corrected;
• request deletion of Personal Information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements;
• ask us to restrict the processing of Personal Information where the processing is inappropriate;
• object to the processing of Personal Information;
• request portability of Personal Information that you have provided to us (which does not include Information derived from the collected Information), where the processing of such Personal Information is based on consent or a contract with you and is carried out by automated means; and
• lodge a complaint with the appropriate data protection authorities.

You can exercise your rights of access, rectification, erasure, restriction, objection, and data portability by contacting us at legal@dialclear.co. We will respond to verifiable requests within one (1) month of receipt.

When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

Cross-Border Data Transfers. DialClear is located in the United States, and your Personal Information will be transferred to and processed in the United States. For transfers of Personal Information from the EEA, the United Kingdom, or Switzerland to the United States, DialClear relies on the European Commission's Standard Contractual Clauses (SCCs), as updated from time to time (typically Module 2 or Module 3, depending on the relationship between the parties), to provide an adequate level of protection. You may request a copy of the applicable SCCs by contacting legal@dialclear.co.

The categories of Personal Information that DialClear collects are identified above. Additional information about how long DialClear will retain your Information and how it shares your Information is found in the sections above.

U.S. State Privacy Rights

Residents of U.S. states with comprehensive consumer privacy laws (including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Tennessee, Delaware, Maryland, Minnesota, New Hampshire, New Jersey, Florida, and others as such laws come into effect) may have the following rights regarding their Personal Information, subject to applicable exceptions:

• The right to know what categories of Personal Information we have collected about them and the sources from which it was collected.
• The right to access the specific pieces of Personal Information we have collected.
• The right to correct inaccurate Personal Information.
• The right to delete Personal Information, subject to applicable exceptions.
• The right to data portability, to receive Personal Information in a structured, commonly used format.
• The right to opt out of the "sale" or "sharing" of Personal Information as those terms are defined under applicable law. DialClear does not sell Personal Information for monetary consideration.
• The right to limit the use and disclosure of sensitive Personal Information.
• The right to non-discrimination for exercising privacy rights.
• The right to opt out of certain forms of automated decision-making and profiling, where applicable.

To exercise any of these rights, contact us at legal@dialclear.co. We will acknowledge your request within ten (10) business days and respond within forty-five (45) days of receiving a verifiable request. Where a request is complex or we receive a high volume of requests, we may extend that period by a further forty-five (45) days and will tell you why before the first period ends. Residents of the EEA and UK are subject to the separate one-month period described above. We will not discriminate against you for exercising any of your rights under applicable privacy law.

California Residents (CCPA / CPRA). In addition to the rights above, California residents may exercise the rights provided under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"). You may submit a request by emailing legal@dialclear.co. Pursuant to California's "Shine the Light" law (Civil Code §1798.83), you may also request information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.

We do not sell or share your Personal Information. DialClear does not sell Personal Information, and does not share it for cross-context behavioral advertising, as those terms are defined by the CCPA/CPRA. We have not done so in the preceding twelve (12) months. Because there is no sale or sharing to opt out of, we do not currently process opt-out preference signals such as Global Privacy Control (GPC); if that ever changes, we will implement signal handling and update this policy before any sale or sharing begins.

Your Choices About Information

We may, from time to time, send you emails regarding new products and Services that we feel may interest you. Only DialClear (or agents working on behalf of DialClear and under confidentiality agreements) will send you these solicitations, and only if you have previously indicated that you wish to receive them.

If you no longer wish to receive marketing or promotional communications from us, click the "unsubscribe" link provided in such communications or send us an email at legal@dialclear.co. You can also sign in to your account and change the applicable communication settings so that you no longer receive such communications.

If you opt out of receiving marketing or promotional emails, we may still send you non-promotional emails, such as emails about your account, billing, or our ongoing business relations.

Please report your concerns about collection or use of Personal Information through the Platform to legal@dialclear.co.

Data Breach Notification

In the event of a confirmed material breach of security that compromises the confidentiality, integrity, or availability of customer Personal Information, DialClear will notify affected customers without undue delay and in no event later than seventy-two (72) hours after DialClear confirms the breach is material. The notification will include the nature of the breach, the categories of data involved, the likely consequences, and the measures taken or proposed to address the breach. DialClear will cooperate with customers' own breach-response and regulatory notification obligations. Where a law enforcement agency determines that notification would impede a criminal investigation, DialClear may delay notification for the period the agency requests, and will notify affected customers as soon as the agency confirms that notification will no longer compromise the investigation.

Sharing with Affiliated Companies

We may share information about material contract breaches (including chargeback abuse, fraud, and repeated terms violations) with our affiliated companies for the purpose of declining future service. This sharing is limited to information necessary for that purpose and is not used for credit, insurance, or employment decisions.

How To Contact Us About This Privacy Policy

To ask questions about this Privacy Policy and our privacy practices, contact us at legal@dialclear.co.

DialClear LLC