California Privacy Notice
This California Privacy Notice supplements our Privacy Policy and applies specifically to California residents. It is provided pursuant to the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively, “CPRA” or “CCPA”), to the extent those laws apply to our operations.
This Notice does not apply to information collected in connection with employment applicants, employees, contractors, or their dependents. It does not apply to information subject to a separate written data processing or business associate agreement between Phonewire and a business customer.
Table of Contents
§ 1 Who This Notice Applies To
1.1 California Residents. This Notice applies to California residents whose personal information is collected by Phonewire, Inc. (“Phonewire,” “we,” “us,” or “our”) in connection with our websites (www.phonewire.com, phonewire.net, www.phonewire.cloud), our telecommunications products and services, and our business operations.
1.2 Business Context. Phonewire sells exclusively to businesses. Most individuals who interact with us do so in a professional or commercial capacity — as employees, agents, or authorized representatives of business customers. Personal information we collect is primarily business contact information and service data generated in the course of our commercial relationships. The CPRA applies to such individuals regardless of the commercial context, and this Notice describes our practices with respect to their personal information.
1.3 Relationship to General Privacy Policy. This Notice supplements our general Privacy Policy. You should review that Policy for complete information about our privacy practices, including our use of AI Tools (§ 2.10 and § 4.10 of the Privacy Policy) and our commercial use of customer relationship content (§ 2.8 and § 4.11). In the event of a conflict between this Notice and the general Privacy Policy with respect to California residents’ rights, this Notice controls.
§ 2 Personal Information We Collect
In the twelve months prior to the effective date of this Notice, and in the ordinary course of our business operations, we have collected the following categories of personal information about California residents:
| CPRA Category | Types of Information We Collect | Collected? | Sold or Shared for Behavioral Advertising? |
|---|---|---|---|
| A. Identifiers | Business name, contact name, mailing address, billing address, business phone number, business email address, IP address, account name, device identifiers, AI chatbot session identifiers | YES | NO |
| B. Personal information under Cal. Civ. Code § 1798.80(e) | Name, address, telephone number. We do not collect payment card numbers, signatures, or education level beyond what is collected in other listed categories. Payment card data is handled exclusively by PCI-compliant third-party processors. | PARTIAL | NO |
| C. Protected classification characteristics | We do not intentionally collect age, gender, race, marital status, or other protected classification characteristics of our business contacts. If such information is incidentally provided, it is not used for any purpose. | NO | NO |
| D. Commercial information | Transaction history, order history, service subscription records, payment type (not full card numbers), and records of work performed at customer locations that may be referenced in case studies, press releases, or marketing materials per our Privacy Policy § 2.8. | YES | NO |
| E. Biometric information | We do not collect fingerprints, faceprints, or voiceprints for identification purposes. Automated voicemail transcription processes audio for text conversion only and does not extract or store biometric voice identifiers. | NO | NO |
| F. Internet or electronic network activity | Website page visits, time on page, browser type, referring URLs, IP address, cookie identifiers (via Google Analytics). AI chatbot session logs, conversation transcripts, and interaction metadata collected when you use our AI-powered website assistant or support tools. See our Privacy Policy §§ 2.4, 2.10, and 7 for details. | YES | NO |
| G. Geolocation data | We do not collect precise geolocation. IP-derived general location (city/region level) may be captured in analytics logs and AI chatbot session logs. | NO (precise); IP-level only | NO |
| H. Audio, electronic, visual, or similar information | Recordings of calls with our team for quality assurance purposes, where notice is provided. Customer voicemail audio stored as part of our voicemail transcription service. AI-generated transcriptions of calls and voicemails. Installation photography and video footage taken at customer job sites for marketing and documentation purposes per our Privacy Policy § 2.8. | YES | NO |
| I. Professional or employment-related information | Employer/business name, job title, professional role — collected as business contact context, not personal employment records. Individual names and titles may appear in case studies, press releases, or interviews per our Privacy Policy § 2.8. | YES | NO |
| J. Education information (non-public, per FERPA) | We do not collect student education records or non-public education information. | NO | NO |
| K. Inferences from personal information | We do not build consumer profiles, propensity models, or behavioral inference datasets about individuals. AI Tools we use may generate operational classifications (e.g., routing a support inquiry to the correct department) but these are operational system functions and do not constitute profiling or inferences about individual preferences, behavior, psychology, or abilities as defined under CPRA. | NO (in the CPRA sense) | NO |
| Sensitive Personal Information | We do not collect Sensitive Personal Information as defined under CPRA, including government identification numbers, precise geolocation, racial or ethnic origin, religious beliefs, union membership, health information, biometric data for identification, sexual orientation, or the content of private communications where we are not the intended recipient. AI Tool conversation content is processed as a service provider function and not retained or used as Sensitive Personal Information. | NO | NO |
The specific personal information we collect about any individual may vary based on their relationship with us — prospective customer, active customer, service contact, or website visitor.
§ 3 How We Use Personal Information
We collect and use personal information for the following business and commercial purposes:
- Providing services and fulfilling orders — provisioning telephone systems, processing transactions, managing accounts, providing technical support
- Business communications — invoicing, service notifications, renewals, support communications
- AI-powered communications and service delivery — operating and improving AI chatbots, automated assistants, voicemail transcription, ticket classification, and AI-assisted billing and support systems as described in our Privacy Policy §§ 2.10 and 4.10. AI Tool providers process data as service providers under written contracts. AI processing does not constitute automated decision-making with legal effects.
- Marketing — communicating with existing and prospective business customers about our products and services. California residents may opt out of marketing communications at any time (see § 5)
- Commercial and promotional use of customer relationship content — using customer business names, logos (subject to our Terms and Conditions), installation photography, job site imagery, project documentation, testimonials, interviews, and related content in commercial videos, YouTube content, social media, radio and podcast advertising, press releases, case studies, customer reference lists, website imagery, and other promotional channels, as described in our Privacy Policy §§ 2.8 and 4.11. California residents who object to these uses may opt out as described in § 5.8 of this Notice.
- Website analytics — understanding how our website is used through Google Analytics to improve content and navigation
- Security and fraud prevention — protecting our systems, networks, and customers from unauthorized access, fraud, and abuse
- Legal compliance — complying with applicable federal and state laws, including FCC telecommunications regulations, tax law, and data protection obligations
- Business operations — accounting, auditing, recordkeeping, and general business administration
We do not use personal information for automated profiling or automated decision-making that produces legal or similarly significant effects on individuals. AI Tool operational use (chatbot routing, transcription, ticket classification) does not constitute automated decision-making in the legal or regulatory sense as it does not produce decisions affecting individuals’ legal rights, credit, employment, financial access, or similar significant interests.
§ 4 Third-Party Disclosure — We Do Not Sell Personal Information
We do not sell personal information. Phonewire does not sell, rent, lease, or transfer personal information to third parties for monetary or other valuable consideration as those terms are used in the CPRA. We do not share personal information for cross-context behavioral advertising as defined under CPRA.
We disclose personal information to third parties only in the following limited circumstances:
| Category of Recipient | Purpose / Categories of Information Disclosed | Sale or Sharing? |
|---|---|---|
| Service providers and processors | Payment processors, SIP carriers, cloud infrastructure providers, CRM software, email platforms, professional advisors — all under written contracts that prohibit them from using data for any purpose other than the contracted service | Service provider disclosure only — NOT a sale |
| AI platform providers | Third-party AI service providers that power our website chatbot, conversational assistants, voicemail transcription, automated ticket classification, and AI-assisted support systems. These providers process data solely to deliver the contracted AI services and are prohibited from using data for their own AI model training or marketing without our express authorization. | Service provider disclosure only — NOT a sale or behavioral ad share |
| Google Analytics | Website usage data (IP address, browsing behavior on our site) is transmitted to Google Analytics for site performance analysis. This is disclosed for analytics purposes, not for advertising. Google processes this data subject to its own Privacy Policy and Data Processing Terms. | Analytics — NOT a sale or behavioral ad share |
| Government and law enforcement | Disclosure in response to lawful subpoenas, court orders, FCC regulatory requirements (including CPNI obligations), or other legal process | Legal obligation — NOT a sale |
| Business transaction parties | In connection with a merger, acquisition, financing, or asset sale, customer information may transfer as part of the transaction, subject to applicable legal requirements | Business transfer — NOT a sale for data monetization |
| Marketing and media recipients | Business names, logos, installation imagery, and work documentation may be shared with marketing agencies, video production companies, advertising platforms, podcast networks, and social media platforms in connection with Marketing Content Uses described in our Privacy Policy § 2.8. This sharing is for promotional purposes under a customer-consented disclosure, not for behavioral advertising or data monetization. | Marketing disclosure under consent — NOT a sale |
We do not disclose personal information to advertisers, social media platforms, political campaigns, political action committees, political parties, consumer goods advertisers, or financial advisory services for their own use. We do not use personal information for cross-context behavioral advertising or targeted advertising purposes.
§ 5 Your California Privacy Rights
To the extent the CPRA applies to our collection of your personal information, California residents have the following rights:
5.1 Right to Know. You have the right to request that we disclose: (a) the categories of personal information we have collected about you; (b) the categories of sources from which we collected it; (c) the business or commercial purpose for collecting it; (d) the categories of third parties to whom we have disclosed it; and (e) the specific pieces of personal information we have collected about you.
5.2 Right to Delete. You have the right to request that we delete personal information we have collected about you, subject to certain exceptions. We may deny a deletion request if retaining the information is necessary for us to: provide a service you have requested; complete a transaction or fulfill a contract; maintain security; comply with a legal obligation; or exercise rights provided by law. For active customers, we cannot delete information necessary to provide contracted services.
5.3 Right to Correct. You have the right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes of its processing.
5.4 Right to Opt-Out of Sale or Sharing. You have the right to direct us not to sell or share your personal information. As stated in § 4, we do not sell personal information and we do not share personal information for cross-context behavioral advertising. Therefore, there is nothing to opt out of with respect to sale or sharing for advertising purposes. If our practices change, we will update this Notice and provide a mechanism to opt out.
5.5 Right to Limit Use of Sensitive Personal Information. You have the right to limit our use of Sensitive Personal Information to certain permitted purposes. As stated in § 2, we do not collect Sensitive Personal Information as defined under CPRA. This right is therefore not applicable to our current practices.
5.6 Right to Non-Discrimination. We will not discriminate against you for exercising any of your CPRA rights. We will not deny you goods or services, charge you different prices, provide a different level of service, or suggest that you will receive a different level of service for exercising your rights under this Notice.
5.7 Right to Data Portability. In connection with a Right to Know request for specific pieces of personal information, you may receive that information in a portable, readily usable format to the extent technically feasible.
5.8 Right to Opt-Out of Marketing Content Uses. California residents have the right to opt out of future use of their personal information — including their name, job title, or identifiable photographs or video likeness — in Phonewire’s Marketing Content Uses as described in our Privacy Policy §§ 2.8 and 4.11. To exercise this right, submit a written request to [email protected] with “Marketing Content Opt-Out — California” in the subject line. Opt-out requests will be honored on a prospective basis. Content already published, broadcast, distributed, or posted prior to our receipt of your request is not subject to removal under this opt-out right, though we will cease new uses upon request. This opt-out does not affect our use of business entity names or logos, which are governed by our Terms and Conditions and trademark license provisions applicable to the business entity, not to any individual.
5.9 AI and Automated Processing. California residents have the right to request information about whether we use automated decision-making technology in a manner that affects them. As stated in § 3, we use AI Tools for operational communications functions (chatbots, transcription, ticket routing) but not for automated decision-making that produces legal or similarly significant effects. If you believe an AI Tool interaction has produced a significant decision affecting you, contact us at [email protected] to request human review.
§ 6 Exercising Your Rights
6.1 How to Submit a Request. California residents may submit a request to exercise any of the rights described in § 5 by:
- Emailing [email protected] with “California Privacy Request” in the subject line
- Calling us at (800) 857-1517
- Writing to: Phonewire, Inc., Attn: Privacy — California Request, 120 S Central Ave Ste 400, Saint Louis, Missouri 63105-1705
6.2 Verification. We are required to verify your identity before fulfilling a request to know, delete, or correct personal information. The verification process will vary depending on the nature of the request and the sensitivity of the information involved. We will ask you to provide information we already have on file about you — for active business customers, this typically means verifying your account credentials or providing information that matches our records. We cannot fulfill a request if we cannot reasonably verify your identity.
6.3 Authorized Agents. You may designate an authorized agent to submit a request on your behalf. To use an authorized agent, you must either: (a) provide the agent with written permission signed by you, and we will require the agent to verify its identity and submit proof of your permission; or (b) provide a valid power of attorney. We may deny a request from an agent who cannot provide adequate verification of their authority.
6.4 Response Timeline. We will acknowledge receipt of your request within ten (10) business days and will respond substantively within forty-five (45) calendar days of receipt. If we need additional time (up to a total of 90 days), we will notify you of the extension and the reason within the initial 45-day period. We provide responses to verifiable requests at no charge, unless a request is excessive, repetitive, or manifestly unfounded.
6.5 Frequency of Requests. You may submit a Right to Know request no more than twice in any twelve-month period.
§ 7 Non-Discrimination
Phonewire will not discriminate against you for exercising any of your rights under the CPRA or this Notice. Specifically, we will not:
- Deny you goods or services
- Charge you different prices or rates, including through the use of discounts or other benefits or by imposing penalties
- Provide you with a different level or quality of goods or services
- Suggest that you will receive a different price, rate, level, or quality of goods or services
However, we may charge a different price or provide a different level of service to the extent that doing so is reasonably related to the value provided by your personal information — for example, if participating in a marketing program or analytics program requires sharing certain data.
§ 8 Changes to This Notice
We may update this California Privacy Notice from time to time to reflect changes in our practices, applicable law, or regulatory guidance — including changes to our use of AI Tools or automated processing technologies, or changes to our commercial use of customer relationship content. When we update this Notice, we will revise the “Last Updated” date. Material changes will be communicated through our website or by other appropriate means. Your continued use of our website or services after any update constitutes acceptance of the updated Notice. We encourage you to review this Notice periodically.
§ 9 Contact Us
For questions about this Notice, to exercise your California privacy rights, or to submit a data or marketing content opt-out request:
California Privacy Requests
Phonewire, Inc.
Attn: Privacy — California Request
120 S Central Ave Ste 400
Saint Louis, Missouri 63105-1705
Email: [email protected]
Subject line: California Privacy Request
Phone: (800) 857-1517
Our general Privacy Policy provides additional information about our practices. For questions about CPNI (telecom-specific data), see § 6 of our Privacy Policy. For Marketing Content opt-out requests, use the subject line “Marketing Content Opt-Out — California.”