Privacy Policy

Callbetter LLC ("Callbetter," "we," "us," or "our"), a Delaware Limited Liability Company, provides an interconnected Voice over Internet Protocol (VoIP) and AI-enhanced Software-as-a-Service (SaaS) platform for business. This policy establishes our 2026 governance framework, designed to satisfy the most stringent requirements of U.S. federal and state law, including the mandates of Maryland (MODPA), Virginia (VTPPA), Connecticut (CTDPA), and Rhode Island (RIDTPPA).

1.1 Business and Professional Use Only

Our Services are strictly for business, commercial, or professional use. They are not intended for personal, family, or household purposes. You represent that you are a business entity or a professional user; accordingly, consumer-specific protections for household use are limited by contract.

1.2 California Jurisdiction Exclusion

Callbetter does not currently conduct business in the State of California, nor do we target our Services to California residents. Our Services are not intended for use within California. Despite this exclusion, we implement the technical defenses described in Section 8 to protect all users and mitigate risks from multi-jurisdictional "tester" litigation (e.g., CIPA/pen-register claims).

1.3 FCC Attestation: Foreign Adversary Control

In compliance with the FCC's January 2026 Report and Order (GN Docket No. 25-166), Callbetter LLC attests that it is not owned by, controlled by, or subject to the jurisdiction or direction of a "foreign adversary" as defined by the U.S. Department of Commerce.

As an interconnected VoIP provider, Callbetter has a federal legal duty to protect your CPNI metadata generated by our telecommunications relationship.

• Authorized Use: We use CPNI only to provide your service, for billing, and to prevent "toll fraud."
• SIP 603+ Transparency: Per the March 25, 2026 FCC mandate, if a carrier blocks your call based on analytics, we will provide you with the SIP 603+ response code, identifying the reason for the block and the specific analytics provider (e.g., Hiya, TNS).
• Marketing Opt-Out: You may restrict our use of CPNI for marketing unrelated features by contacting privacy@callbetter.com.

In the preceding 12 months, we have collected the following categories of information for strictly necessary business purposes:

Right to Specific Third-Party Names: In compliance with 2026 Maryland, Oregon, and Minnesota laws, you have the right to request a list of the specific names of all third parties to whom your personal data has been disclosed.

Callbetter utilizes AI to enhance communications. In accordance with the Colorado AI Act (SB 24-205) and the Connecticut LLM Mandate:

4.1 LLM Training and De-identification

In accordance with the July 1, 2026 Connecticut mandate, Callbetter discloses that it may use de-identified user content (such as call transcripts) to train proprietary Large Language Models (LLMs) to improve transcription accuracy. We do not sell your data to third parties for LLM training. You may opt-out of training use in your Account Settings.

4.2 Algorithmic Discrimination (Duty of Care)

We use reasonable care to avoid algorithmic discrimination. If we use AI to make "consequential decisions" (e.g., fraud-based termination), you have the right to request the logic and parameters used and to request human review of the decision.

4.3 De-identification Commitment

Callbetter publicly commits to maintaining de-identified data in its current form and will not attempt to re-identify it, as required by 2026 Maryland and New Jersey law.

• AI Voice Disclosure: In compliance with FCC/TCPA mandates, you must disclose at the beginning of each call if you are using AI-generated voices.
• Rhode Island 15-Day Rule: We will stop processing your data within 15 days of receiving a consent revocation.
• Virginia 10-Year Rule: Per the 2026 VTPPA, all opt-out/STOP requests for telephony will be honored and recorded for a period of 10 years.

6.1 Geofencing Prohibition

Callbetter does not implement "geofences" (virtual boundaries) within 2,000 feet of any entity providing in-person health care services for the purpose of identifying or tracking users.

6.2 Washington "My Health My Data" (MHMD)

Because our processing of precise location data may be used to infer health-related insights, we maintain a standalone Consumer Health Data Privacy Policy accessible at callbetter.com/health-privacy in accordance with Washington law.

Callbetter does not sell your personal information. Data is disclosed to partners (carriers, payment processors, hosts) only as necessary to make our application work. These partners are contractually bound to 2026 standards, which strictly prohibit:

• Using your data for their own benefit or to train their own AI models.
• Combining your information with data from other sources.

To protect against 2026 "Broken Banner" and "Trap and Trace" claims:

• Script Blockade: We attest that our consent management system physically prevents non-essential scripts (pixels, replay software) from loading until affirmative clickwrap consent is given.
• GPC Response: We display a visible "Opt-Out Request Honored" indicator upon detection of a Global Privacy Control signal.

Regardless of residency, Callbetter provides:

• Authorized Agents: We honor requests submitted by automated privacy apps/agents once identity and authority are verified.
• Minnesota "Outcome" Right: The right to request an explanation of actions you could have taken to secure a different result from an automated decision.
• Right to Appeal: If a request is denied, you may appeal to appeals@callbetter.com within 30 days. If the appeal is denied, you may contact your State Attorney General.

• Covered Data: Breach notification now includes unauthorized access to both CPNI and PII (Name, Address, Phone).
• 7-Day Notice: We notify federal law enforcement (FCC, FBI, Secret Service) within 7 business days for breaches affecting 500+ users.

This policy is available via the Settings menu of the Callbetter application and at callbetter.com/privacy.

Callbetter LLC Privacy Office

Email: privacy@callbetter.com

Address: [Insert Address]