Privacy Notice for California Residents

Effective Date: June 25, 2020

This Privacy Notice for California Residents supplements the information contained in Telo USA Inc.'s Opt Out Page and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

I. Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

As a registered data broker with the State of California, we have collected the following categories of personal information within the last twelve (12) months:

Category Examples Collected
A. Identifiers. Name, address, phone number, online identification. Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)).

Name, address, phone number, and education level.

Some personal information included in this category may overlap with other categories.
Yes
C. Protected classification characteristics under California or federal law. Gender and marital status Yes
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No
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
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Yes
G. Geolocation data. Physical location or movements. No
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No
I. Professional or employment-related information. Current occupation, but only if posted by the person on a public social media account Yes
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
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No

As a registered data broker with the State of California, we obtain the categories of personal information listed above from the following categories of sources:

  • the consumer directly;
  • government entities;
  • data analytics providers;
  • operating systems and platforms; and
  • data brokers.
II. Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Website, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • 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 CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information directly collected from you for materially different, unrelated, or incompatible purposes without providing you notice.

As a registered data broker with the State of California, we process personal information on consumers that we do not have a direct relationship with.

III. Sharing Personal Information

We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see www.telo.com/ccpa). When we disclose personal information for a business purpose, we enter 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.

We share your personal information with the following categories of third parties:

  • Service providers.
  • Third Parties (organizations that want to identify nuisance calls, or spam calls, or inactive calls).
  • Third Parties (Customers of Open CNAM and Everyone API products)
  • Data analytics providers.
  • Subsidiaries and affiliates of Telo USA Inc.
A. Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category Examples Collected
Category A: Identifiers. Name, address, phone number, online identification. Yes
Category B: California Customer Records personal information categories.

Name, address, phone number, and education level.

Some personal information included in this category may overlap with other categories.

Yes
Category C: Protected classification characteristics under California or federal law. Gender and marital status Yes
Category D: Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No
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 similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. No
Category G: Geolocation data. Physical location or movements. No
Category H: Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No
Category I: Professional or employment-related information. Current occupation, but only if posted by the person on a public social media account Yes
Category J: Non-public education information. 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

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.
  • Third Parties (organizations that want to identify nuisance calls, or spam calls, or inactive calls).
  • Third Parties (Customers of Open CNAM and Everyone API products)
  • Data analytic providers.
  • Subsidiaries and affiliates of Telo USA Inc.
B. Sales of Personal Information

In the preceding twelve (12) months, Company has sold the following categories of personal information:

Category Examples Collected
Category A: Identifiers. Name, address, phone number, online identification. Yes
Category B: California Customer Records personal information categories.

Name, address, phone number, and education level.

Some personal information included in this category may overlap with other categories.

Yes
Category C: Protected classification characteristics under California or federal law. Gender and marital status Yes
Category D: Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No
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 similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. No
Category G: Geolocation data. Physical location or movements. No
Category H: Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No
Category I: Professional or employment-related information. Current occupation, but only if posted by the person on a public social media account Yes
Category J: Non-public education information. 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

We sell your personal information to the following categories of third parties:

  • Service providers.
  • Data analytics providers.
  • Other businesses.
  • Subsidiaries and affiliates of Telo USA Inc.
  • Third Parties (Customers of Open CNAM and Everyone API products).
  • Third Parties (organizations that want to identify nuisance calls, or spam calls, or inactive calls).
IV. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

A. Access Request Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. To submit an access request, see Section IV.C below (“Submitting a Request”). Once we receive and confirm your verifiable consumer request we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
B. Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. To submit an access request, see Section IV.C below (“Submitting a Request”).Once we receive and confirm your verifiable consumer request, we will delete (and, to the extent they received your personal information from us or collected it on our behalf, we will direct our service providers to delete) your personal information, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
C. Submitting a Request

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Visiting www.telo.com/ccpa and filling out the online form.
  • Emailing us at privacy@telo.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:

  • Providing the information required to fill out the www.telo.com/ccpa
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see www.telo.com/ccpa

D. Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

E. Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. If you are between 13 and 16 years of age, your parent or guardian must affirmatively authorize the opt-in to the sale of your personal information.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing us at privacy@telo.com or by calling 1-888-315-TELO

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at privacy@telo.com or by calling 1-888-315-TELO

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

V. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

VI. Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@telo.com

VII. Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

VIII. Contact Information

If you have any questions or comments about this notice, the ways in which Telo USA Inc. collects and uses your information described here, for OpenCNAM (www.opencnam.com/privacy/), or EveryoneAPI (www.everyoneapi.com/privacy-policy), your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-888-315-8356

Website: telo.com

Email: privacy@telo.com

Postal Address:
Telo USA Inc.
9450 SW Gemini Dr #94386
Beaverton, OR 97008
Attention: California Privacy Requests