Privacy Policy

1. Who This Policy Applies To

This Privacy Policy may apply to:

• Visitors to our website;
• Insurance agents, agencies, organizations, publishers, advertisers, media providers, call providers, vendors, and other businesses using Calltivate;
• Individuals who create or manage a Calltivate account;
• Consumers whose calls or information are transmitted through the Calltivate platform; and
• Individuals who communicate with Calltivate regarding sales, support, billing, or other business matters.

Calltivate primarily operates as a business-to-business technology and marketplace platform.

When consumer information is provided to Calltivate by another business, that business may be independently responsible for providing legally required notices and obtaining legally required permissions or consent.

2. Information We Collect

The information we collect or process depends on how you interact with Calltivate.

Account and Business Information

We may collect:

• Name;
• Business or agency name;
• Email address;
• Telephone number;
• Business or mailing address;
• Account identifiers;
• Login and authentication information;
• Account settings and permissions;
• Insurance-license or business-related information where appropriate; and
• Communications with our sales, onboarding, billing, or support teams.

Call and Campaign Information

Because Calltivate facilitates inbound calls, we may collect or process:

• Caller telephone number;
• Agent or recipient telephone number;
• Date and time of calls;
• Call duration;
• Call source;
• Campaign information;
• Publisher or supplier information;
• Routing information;
• Geographic information associated with calls;
• Call status and disposition;
• Call recordings;
• Call transcripts;
• Call summaries;
• Notes;
• Qualification information;
• Consent or source information made available to us; and
• Other information communicated during or associated with a call.

Consumer Information

Consumers may voluntarily provide information during insurance-related conversations, including:

• Name;
• Telephone number;
• Address or general location;
• Age or date of birth;
• Insurance interests;
• Existing coverage information;
• Policy-related information;
• Responses to qualification or eligibility questions; and
• Other information voluntarily communicated during the conversation.

Calltivate may process such information as necessary to provide, secure, monitor, and support the Services.

Payment and Transaction Information

We may collect or process:

• Billing information;
• Payment-method information;
• Account balances;
• Deposits;
• Call purchases;
• Credits;
• Refunds;
• Transaction history;
• Publisher payments or payouts;
• Tax information where required; and
• Related accounting information.

Payments may be processed by third-party payment providers. Calltivate may receive transaction identifiers, tokens, or limited payment information rather than complete payment-card information.

Device and Website Information

We may automatically collect:

• IP address;
• Browser and device type;
• Operating system;
• Pages viewed;
• Dates and times of access;
• Referring website;
• Session activity;
• Cookies and similar technologies;
• Error and security logs; and
• Usage and performance information.

We may derive approximate geographic information from an IP address.

3. Sources of Information

We may receive information:

• Directly from you;
• Through consumer calls;
• From insurance agents and agencies;
• From publishers, advertisers, media providers, and call suppliers;
• From authorized integrations;
• From payment and fraud-prevention providers;
• From telephony and call-routing providers;
• From transcription and artificial-intelligence providers;
• From consent or identity-verification providers;
• Automatically through devices or browsers; and
• From other legally permitted sources.

4. How We Use Information

We may use information to:

• Operate and provide Calltivate;
• Route inbound calls;
• Connect consumers with participating insurance professionals;
• Manage campaigns;
• Determine whether calls meet applicable campaign requirements;
• Calculate call durations and billing thresholds;
• Process payments, deposits, credits, refunds, and payouts;
• Maintain account balances;
• Provide dashboards, analytics, recordings, transcripts, and reporting;
• Provide real-time or post-call assistance;
• Monitor quality;
• Investigate disputes and chargebacks;
• Detect and prevent fraud or misuse;
• Protect Calltivate, our Users, and consumers;
• Provide support;
• Communicate regarding accounts and Services;
• Maintain compliance and consent-related records;
• Enforce agreements and policies;
• Improve and develop the Services;
• Generate aggregated or de-identified analytics;
• Maintain legally required business records;
• Comply with legal obligations; and
• Send marketing communications where permitted by law.

5. Paid Call Routing and Disclosure of Personal Information

Calltivate operates a marketplace and technology platform through which inbound consumer calls may be routed to insurance professionals. Insurance professionals may pay Calltivate for calls or related Services.

Information associated with a consumer call may therefore be disclosed or made available to the insurance professional receiving the call.

This information may include identifiers, telephone numbers, campaign information, call information, qualification information, and information communicated during the call.

Certain privacy laws define a “sale” of personal information broadly and may characterize some transfers made in exchange for monetary or other valuable consideration as a sale even when a company does not sell traditional consumer lists.

Accordingly, Calltivate does not represent that every transfer made through its paid call-routing marketplace falls outside every statutory definition of “sale.”

Where applicable law treats a Calltivate disclosure as a sale, sharing, targeted advertising, or another regulated transfer, Calltivate will provide legally required notices, choices, consent mechanisms, or opt-out rights as applicable.

Calltivate does not knowingly disclose personal information to unrelated third parties solely for their independent marketing purposes except as disclosed and permitted by applicable law.

6. Consumer Health Data and Sensitive Information

Final-expense and other insurance conversations may involve information regarding an individual’s:

• Medical conditions;
• Medical history;
• Diagnoses;
• Medications;
• Symptoms;
• Tobacco or nicotine use;
• Physical condition; or
• Other health-related information.

Depending on applicable law, this information may constitute sensitive personal information or consumer health data.

Because calls may be recorded, transcribed, summarized, or analyzed, health-related information voluntarily communicated during a conversation may be captured through the Services.

Where applicable consumer-health-data laws require additional notice, consent, authorization, access controls, deletion rights, or a separate consumer-health-data privacy policy, Calltivate will process covered information subject to those requirements.

Calltivate will not knowingly sell consumer health data where prohibited by law or where legally required authorization has not been obtained.

Users are independently responsible for complying with applicable insurance, privacy, consumer-health, and data-protection requirements when collecting or processing health-related information through Calltivate.

7. Highly Sensitive Information

Calltivate is not intended to serve as a repository for unnecessary highly sensitive credentials or financial information.

Users should not unnecessarily enter into Calltivate notes, messages, or other platform fields:

• Full Social Security numbers;
• Complete payment-card numbers;
• Bank-account credentials;
• Passwords;
• Authentication codes; or
• Other highly sensitive credentials.

When sensitive information is necessary to complete an insurance application, insurance professionals should use the applicable insurance carrier’s authorized secure application system or another authorized secure method.

Where technically available and appropriate, recording should be paused or discontinued before highly sensitive information is collected when recording that information is unnecessary or prohibited.

Calltivate may use automated or manual measures to redact, restrict, remove, or prevent unnecessary storage of highly sensitive information.

8. Call Recording, Transcription and Monitoring

Calls transmitted through Calltivate may be recorded, monitored, transcribed, summarized, or analyzed.

These activities may be performed for:

• Quality assurance;
• Training;
• Compliance;
• Fraud prevention;
• Dispute resolution;
• Billing verification;
• Call qualification;
• Agent assistance;
• Platform analytics; and
• Service improvement.

Recording or transcription is intended to occur only after any notice or consent required by applicable law has been provided or obtained.

Users must not circumvent, remove, disable, or misrepresent legally required recording disclosures.

Where applicable law requires consent from multiple or all participants, the applicable parties are responsible for ensuring that legally required disclosure and consent procedures are implemented before recording or interception begins.

9. Artificial Intelligence and Automated Processing

Calltivate may use artificial intelligence, machine learning, automated systems, or rules-based technology for features including:

• Transcription;
• Call summaries;
• Real-time agent assistance;
• Suggested responses;
• Objection detection;
• Call categorization;
• Quality review;
• Fraud detection;
• Campaign analysis;
• Call routing;
• Scoring; and
• Platform analytics.

AI-generated information may be inaccurate or incomplete and should not be treated as legal, medical, underwriting, insurance, or other professional advice.

Calltivate does not make insurance underwriting decisions or determine eligibility for insurance coverage unless expressly disclosed as part of a separate service.

10. Information Supplied by Publishers and Other Businesses

Calltivate may receive calls, consumer information, campaign information, advertisements, consent records, and compliance representations from publishers, advertisers, media providers, call suppliers, agencies, and other third parties.

Those parties are responsible for the legality, accuracy, provenance, advertising practices, permissions, and consent associated with information and calls they provide.

Calltivate may conduct compliance reviews, request records, reject traffic, suspend routing, issue credits, or terminate a provider.

Any such review does not relieve the originating party of its independent legal responsibilities.

11. How We Disclose Information

We may disclose information as reasonably necessary to operate the Services to:

Insurance Professionals

Consumer and call information may be transmitted to the insurance professional, agency, or organization receiving a call.

Publishers and Call Providers

Information necessary for routing, campaign management, billing, dispute resolution, fraud detection, or quality review may be disclosed to parties involved in supplying or routing the applicable call.

Service Providers

We may use third-party providers for:

• Cloud infrastructure;
• Telephony;
• Call routing;
• Recording;
• Transcription;
• Artificial intelligence;
• Analytics;
• Payment processing;
• Fraud prevention;
• Customer support;
• Email and SMS;
• Identity or consent verification;
• Software development; and
• Security.

Authorized Integrations

Information may be transmitted to third-party services that a User chooses or authorizes Calltivate to connect with.

Professional Advisors

We may disclose information to attorneys, accountants, auditors, insurers, consultants, and similar professional advisors.

Legal, Security and Compliance Purposes

We may disclose information where reasonably necessary to:

• Comply with applicable law or legal process;
• Respond to governmental requests;
• Investigate fraud or unlawful conduct;
• Protect consumers or Users;
• Protect Calltivate’s rights or property;
• Enforce agreements; or
• Protect the integrity and security of the Services.

Business Transactions

Information may be transferred in connection with a merger, acquisition, financing, restructuring, asset sale, bankruptcy, or similar transaction.

12. Telephone, SMS and Consent Records

Calltivate may maintain available records relating to:

• Consumer consent;
• Call origin;
• Campaign or advertisement source;
• Telephone number;
• Consent timestamps;
• IP address;
• User agent;
• Consent language;
• Opt-in activity;
• Opt-out activity; and
• Other compliance-related information.

Where Calltivate itself initiates marketing calls or text messages requiring consent under applicable law, Calltivate intends to obtain the level of consent legally required for the applicable communication.

Consumers may revoke applicable marketing consent through reasonable methods provided by Calltivate.

Marketing SMS recipients may reply STOP to opt out.

Calltivate may retain suppression records after an opt-out to help prevent unwanted future communications.

Publishers, advertisers, agents, agencies, call suppliers, and other businesses providing or using calls through Calltivate are independently responsible for compliance with applicable TCPA, Do Not Call, telemarketing, advertising, consent, and state-law requirements.

13. Marketing Communications

Where permitted by law and where required consent has been obtained, Calltivate may send information about:

• Services;
• Promotions;
• Platform updates;
• Demonstrations;
• Events; and
• Business opportunities.

Message frequency may vary. Message and data rates may apply.

Consent to receive promotional text messages is not a condition of purchasing Calltivate Services.

Reply STOP to marketing text messages to opt out.

Reply HELP for assistance or contact: support@calltivate.io

Marketing emails may include an unsubscribe mechanism.

We may continue sending non-marketing communications reasonably necessary for account, billing, security, support, or transactional purposes.

Carriers are not liable for delayed or undelivered messages.

We do not sell or share SMS opt-in consent or mobile telephone numbers with third parties for their own marketing purposes.

14. Cookies and Similar Technologies

Calltivate may use cookies, pixels, local storage, analytics tools, and similar technologies to:

• Maintain sessions;
• Remember preferences;
• Analyze website usage;
• Measure advertising;
• Detect fraud;
• Improve security; and
• Improve the Services.

Where required, Calltivate will provide legally required cookie choices.

15. Sale, Sharing and Targeted Advertising

Depending on the circumstances and applicable law, certain transfers involved in Calltivate’s paid call-routing marketplace may constitute a “sale” of personal information.

Consumers may therefore have the right, where applicable, to opt out of qualifying:

• Sales;
• Sharing for cross-context behavioral advertising;
• Targeted advertising; or
• Certain profiling.

Calltivate will honor legally recognized opt-out preference signals, including Global Privacy Control, where required by applicable law and technically applicable to the relevant processing.

An opt-out preference signal does not substitute for affirmative consent where applicable law requires affirmative consent.

16. Data Security

Calltivate uses commercially reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, use, alteration, disclosure, destruction, or loss.

Safeguards may include:

• Access controls;
• Authentication;
• Encryption or secure transmission methods where appropriate;
• Monitoring;
• Vendor controls;
• Security logging; and
• Other measures appropriate to the Services.

No electronic system, telecommunications network, database, or storage method can be guaranteed to be completely secure.

Users are responsible for protecting their passwords, devices, credentials, and account access.

17. Data Retention

We retain information for periods reasonably necessary for purposes including:

• Providing the Services;
• Maintaining transaction and business records;
• Processing payments and payouts;
• Resolving call and billing disputes;
• Preventing and investigating fraud;
• Maintaining compliance and consent records;
• Satisfying legal, tax, insurance, accounting, and regulatory requirements;
• Enforcing agreements; and
• Protecting legal rights.

Retention periods may vary by category of information.

Information subject to litigation, investigation, chargeback, regulatory inquiry, legal hold, or dispute may be retained for longer periods where reasonably necessary.

18. Privacy Rights

Depending on your state of residence and applicable law, you may have rights to:

• Access personal information;
• Confirm whether we process your information;
• Correct inaccurate information;
• Delete certain information;
• Obtain certain information in portable form;
• Obtain information concerning categories of information and recipients;
• Opt out of qualifying sales or sharing;
• Opt out of targeted advertising;
• Opt out of certain profiling;
• Limit certain uses of sensitive information; and
• Exercise applicable rights without unlawful discrimination.

Submit privacy requests to: support@calltivate.io

Use “Privacy Request” as the subject line.

We may reasonably verify your identity before completing a request.

Where legally permitted, an authorized agent may submit a request on your behalf subject to verification.

If Calltivate received your information from another business and that business controls the applicable information, we may refer your request to that business or assist it in responding as appropriate.

Where applicable law requires additional methods for submitting privacy requests, Calltivate will make those methods available.

19. Privacy Appeals

Where applicable state law provides a right to appeal a decision concerning a privacy request, you may submit an appeal to: support@calltivate.io

Use “Privacy Appeal” as the subject line and identify the request being appealed.

20. California Privacy Rights

California residents may have additional rights under the California Consumer Privacy Act, as amended (“CCPA”), subject to applicable thresholds, definitions, and exceptions.

These may include rights to:

• Know;
• Access;
• Correct;
• Delete;
• Obtain portability;
• Obtain information concerning categories of sources and recipients;
• Opt out of qualifying sales or sharing;
• Limit certain uses of sensitive personal information; and
• Exercise rights without unlawful discrimination.

Because certain privacy laws define “sale” broadly, Calltivate does not represent that every paid transfer through its call marketplace falls outside the CCPA definition of sale.

Where Calltivate is subject to the CCPA and a transfer constitutes a sale or sharing, Calltivate will provide applicable rights and disclosures.

21. Other U.S. State Privacy Rights

Residents of Texas and other states with comprehensive privacy laws may have additional rights subject to the scope and applicability of those laws.

Calltivate will provide applicable access, correction, deletion, portability, opt-out, consent, appeal, and other rights where legally required.

22. Consumer Health Data Rights

Certain jurisdictions provide additional protections for consumer health data.

Where such laws apply, consumers may have rights concerning:

• Access;
• Confirmation;
• Withdrawal of consent;
• Deletion;
• Identification of certain third parties or affiliates receiving consumer health data; and
• Other rights established by applicable law.

Where a jurisdiction requires a separate Consumer Health Data Privacy Policy, Calltivate will make that notice separately available as required.

Calltivate will obtain additional consent or authorization before processing or transferring consumer health data where required by applicable law.

23. Children’s Privacy

Calltivate is intended for adults and business Users.

The Services are not directed to children under 18, and Calltivate does not knowingly seek to collect personal information directly from children.

If we learn that information from a child has been collected in violation of applicable law, we may take reasonable steps to remove it.

24. HIPAA and Industry-Specific Information

Calltivate is not a healthcare provider or health insurer and does not represent that the Services constitute a HIPAA-compliant medical-record system.

Whether particular information is governed by HIPAA, the Gramm-Leach-Bliley Act, state insurance privacy laws, consumer-health-data laws, or another industry-specific law depends on the circumstances.

Insurance professionals and other Users are responsible for determining and satisfying requirements applicable to their own activities.

25. Third-Party Websites and Services

Calltivate may link to or integrate with third-party websites, platforms, applications, or services.

Those third parties maintain their own privacy practices.

Calltivate is not responsible for the privacy, security, or content practices of an independent third party after information is transmitted to that third party as authorized or directed.

26. International Users

Calltivate primarily operates in the United States.

Information may be transferred to, stored in, or processed in the United States or other jurisdictions in which Calltivate or its service providers operate.

Where legally required, appropriate mechanisms may be used for international transfers.

27. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our Services, technology, legal requirements, or business practices.

The Last Updated date above identifies when this Policy was most recently revised.

Where applicable law requires additional notice or consent for a material change, we will provide such notice or obtain such consent.

28. Contact Calltivate

For questions concerning this Privacy Policy, privacy requests, or Calltivate’s privacy practices, contact:

Calltivate

Email: support@calltivate.io

Website: calltivate.io

For privacy-rights requests, use “Privacy Request” in the email subject line.