California Residents Privacy Notice

Last Updated: December 29, 2022.

This Privacy Notice for California Residents supplements the information contained in Talkatone, LLC’s (“Talkatone,” “we” or “us”) Privacy Policy and applies solely to all visitors, users, and customers who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together and each as may be amended from time to time, the “CCPA”) and any terms defined in the CCPA or the Privacy Policy, as the case may be, have the same meaning when used in this notice.

We collect personal information, as that term is defined in the CCPA, from and about California residents (“CCPA personal information”).  CCPA personal information includes information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household, with certain exceptions for de-identified information, and other specific types of information.

Categories of Information We Collect

Here are the categories of CCPA personal information we collect from or about consumers:

 

Category	Examples (some CCPA personal information included in one category may overlap with other categories)
Identifiers.	A real name, alias, unique personal identifier, online identifier such as an Advertising ID (as defined by the Interactive Advertising Bureau), Internet Protocol (“IP”) address, email address, and account name.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, physical characteristics or description, and telephone number.
Protected classification characteristics under California or federal law, if you choose to provide this information to us.	Age (40 years or older) and sex (gender).
Commercial information	Records of products or services purchased, obtained, or considered.
Internet or other similar network activity.	Information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data.	Physical location or movements.
Sensory data.	Recordings of your voice for the creation of a voicemail greeting; voice recordings of people who leave you a voicemail message.

Use of Personal Information

We may use each of the categories of CCPA personal information listed above for one or more of the business purposes described in our Privacy Policy, or for another purpose that we describe to you when or before collecting your CCPA personal information. We may also disclose your age, IP address and Advertising ID to allow our advertising partners to select the appropriate audience for their advertisements or offers, as further described in our Privacy Policy, subject to your right to opt-out of those sales. We will not collect additional categories of CCPA personal information or use the CCPA personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice and obtaining any legally required consent.

Sharing Personal Information

Disclosures of Personal Information for a Business Purpose

We may disclose any of the categories of CCPA personal information listed above to one or more of our service providers, for the purpose of helping us engage in one or more of the purposes described in our Privacy Policy, or for another purpose that we describe to you when or before collecting your CCPA personal information.

Sales of Personal Information

We may disclose your age, IP address and Advertising ID to allow our advertising partners to select the appropriate audience for their advertisements or offers, as further described in our Privacy Policy, subject to your right to opt-out of such disclosure.

Personal Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate the Services. Please see Section 2.2 (Other Information Collected Automatically) of our Privacy Policy for more information.

Your Rights and Choices

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

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your CCPA personal information since the date that is the later of: January 1, 2022 or the date we first began collecting CCPA personal information about you, unless doing so proves impossible or would involve a disproportionate effort. Once we receive and confirm your verifiable consumer request (see Exercising Your CCPA Rights), we will disclose to you:

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

Deletion Request Rights

You have the right to request that we delete any of your CCPA personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your CCPA Rights), we will delete (and direct our service providers to delete) your CCPA personal information from our records, unless an exception applies.

Correction of Personal Information

You have the right to request that we correct any factual errors in your CCPA personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your CCPA Rights), we will update any factual errors in your CCPA personal information from our records, unless an exception applies.

Sensitive Personal Information

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Once we receive and confirm your verifiable consumer request (see Exercising Your CCPA Rights), we will limit the use or disclosure of your “sensitive personal information,” unless an exception applies.

Exercising Your CCPA Rights

To exercise your CCPA rights described above, please submit a verifiable consumer request to us via e-mail to privacy-talkatone@ooma.com, or through our website or app.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your CCPA personal information. You may also make a verifiable consumer request on behalf of your minor child, if applicable.

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 CCPA personal information or an authorized representative, in particular, we will validate your user name and/or email address from the communication we receive from you via email or through our website or app. In addition, we will also ask you to confirm your state of residence.
• 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 CCPA personal information if we cannot verify your identity or authority to make the request and confirm the CCPA personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to CCPA personal information associated with that specific account.

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

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 period from the date that is the later of: January 1, 2022 or the date we first began collecting CCPA personal information about you, unless doing so proves impossible or would involve disproportionate effort, through the date of our receipt of your verifiable consumer request. 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 CCPA personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance specifically Comma Separated Values (.csv).

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.

Opt-Out and Opt-In Rights for Sales and Sharing of Personal Information

You have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”). We do not sell or share the personal information of consumers we actually know are less than 16 years of age.

Note that you will continue to receive ads when you use Talkatone, even if you have opted out of personal information sales. But the ads you see may be less relevant to you.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

Do Not Sell My Personal Information

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales and/or sharing. However, you may change your mind and opt back into personal information sales and/or sharing at any time by visiting this Internet Web page link: Opt-in

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.

Retention of Your Personal Information

Please see Section 8 (How long do we store your data?) of our Privacy Policy for more information.

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.

Changes to Our Privacy Notice for California Residents

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 provide you with notice on the Website and update the notice’s effective date. Your continued use of our Website and Services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described above and in the Privacy Policy, your choices and rights regarding such use, wish to exercise your rights under California law, or if you have a disability and need this notice in an alternative format, please contact us at: