Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy ("Health Policy") supplements the Callbetter LLC Comprehensive Privacy Policy and applies specifically to "Consumer Health Data" as defined by the Washington My Health My Data Act (MHMD), the Maryland Online Data Privacy Act (MODPA), and similar 2026 state laws.

As a business-to-business (B2B) VoIP provider, Callbetter only collects health-related data to the extent it is strictly necessary to provide requested telephony services, such as E911 routing or fulfilling specific service features.

In the preceding 12 months, Callbetter has collected the following categories of data that may be classified as Consumer Health Data:

• Precise Geolocation Data: We collect location information (within a radius of 1,750 to 2,000 feet) from your device. While this is used for call routing and E911, it may be classified as health data if it indicates a visit to a health care facility.
• Health-Related Inferences: We may process metadata (e.g., call logs to healthcare providers) that could allow for inferences regarding your physical or mental health status.

Note: Callbetter does not collect or process biometric data (such as voiceprints or fingerprints) or genetic data.

We collect and use Consumer Health Data strictly for the following purposes:

• Emergency Service Routing: To provide accurate location information to 911 dispatchers and public safety answering points (PSAPs).
• Service Functionality: To fulfill your affirmative requests for telephony services that rely on location metadata for routing or regional compliance.
• Security and Fraud Prevention: To detect and prevent "toll fraud" or unauthorized access to our communications infrastructure.

We collect Consumer Health Data from the following sources:

• Directly from You/Your Device: Automatically via SIP headers and device location services when you utilize our telephony application.
• Service Interaction: Through your engagement with our platform and the metadata generated by your communications.

Callbetter does not sell Consumer Health Data for monetary or other valuable consideration. We share this data only with the following specific categories of recipients:

• Telephony and E911 Carriers: Necessary for call completion and emergency routing.
• Cloud Infrastructure Providers: To host and secure the databases where this metadata is stored.
• Specific Third Parties: In compliance with 2026 laws, a list of specific entity names to whom data was disclosed is available to you upon request by contacting privacy@callbetter.com.

In accordance with 2026 Washington and Maryland mandates, Callbetter does not implement "geofences" within 2,000 feet of any entity providing in-person health care services for the purpose of identifying, tracking, or targeting users based on their health data.

If you are a resident of Washington, Maryland, or another jurisdiction with similar health privacy protections, you may exercise the following rights:

• Right to Access: Request a copy of the specific Consumer Health Data we hold about you (up to two requests annually free of charge).
• Right to Delete: Request the permanent deletion of your health-related metadata, subject to FCC record-retention requirements for CPNI.
• Right to Withdraw Consent: Revoke your authorization for us to process your location data for purposes beyond core service functionality.

To exercise any of these rights, please submit a request via:

• Email: privacy@callbetter.com
• Secure Dashboard: Accessible via your Callbetter Account Settings.

We will respond to your request within 45 days. If we deny your request, you may appeal our decision within 30 days by contacting appeals@callbetter.com.

We maintain administrative, technical, and physical safeguards designed to protect Consumer Health Data. Access to this data is restricted to employees and contractors who are subject to a contractual duty of confidentiality.