Privacy Policy

Version: v1 — Effective: as of the date posted at emberdial.com/legal/privacy. Published by Salire LLC (doing business as EmberDial), a Wyoming limited liability company with its principal place of business at 30 N Gould Street, Suite R, Sheridan, Wyoming 82801 ("EmberDial," "we," "us," or "our"). Capitalized terms not defined here have the meanings given in the EmberDial Master Services Agreement (the "MSA") and the Acceptable Use Policy (the "AUP").

1. Scope and Roles

This Privacy Policy describes how EmberDial collects, uses, discloses, and retains personal information in connection with (a) the EmberDial cloud-based AI-assisted dialer platform (the "Service"), (b) the emberdial.com marketing and documentation websites (the "Sites"), and (c) related business operations such as sales, support, billing, and recruiting.

EmberDial provides the Service to customers (licensed insurance agencies and similar businesses; "Customer" or "Customers"), whose authorized users (licensed insurance agents and their support staff; "Authorized Users") use the Service to place and receive telephone calls to consumers ("called parties").

1.1 Customer Data — EmberDial is a service provider / processor. Personal information that flows through the Service in lead lists, call audio, call transcripts, and related materials (collectively, "Customer Data") is controlled by the relevant Customer. As between EmberDial and the Customer, the Customer is the "business" (under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, the "CCPA") or "controller" (under the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and analogous laws), and EmberDial is the "service provider" or "processor." This Privacy Policy describes our own commitments with respect to Customer Data; the Customer's own privacy notices govern as between the Customer and the called party.

1.2 Business and Site Data — EmberDial is a business / controller. Personal information that EmberDial collects directly from Customers, Authorized Users, Site visitors, prospects, applicants, and other business contacts (collectively, "Business Data") is controlled by EmberDial. EmberDial acts as a "business" or "controller" with respect to Business Data, and the substantive sections of this Privacy Policy apply directly.

2. Information We Collect

2.1 Information you provide to us

• Account and billing information. Customer legal entity name, address, contact name, business email, business telephone, billing address, and payment-method metadata (we do not store full payment card numbers; those are handled by our payment processor).
• Authorized User profile information. Name, business email, role, insurance license details (where provided), in-product preferences, and authentication credentials.
• Customer-uploaded lead lists. Names, telephone numbers, mailing addresses, email addresses, age/date-of-birth (where supplied), lead source, and other contact and demographic fields Customer chooses to include.
• Communications. Support tickets, sales inquiries, feedback, and other messages you send us.

2.2 Information generated by use of the Service

• Call audio. Audio recordings of calls placed or received through the Service. Recording is a material feature of the Service and is enabled by default; Customer is responsible for delivering any required recording disclosure to the called party (MSA §7.2; AUP §3.6).
• Call transcripts and metadata. Automated speech-to-text transcripts of call audio; call disposition; duration; from / to telephone numbers; STIR/SHAKEN attestation; and related metadata.
• AI coaching outputs. Scores, summaries, suggested next actions, and other analytical outputs that the Service generates from transcripts and metadata.
• Usage telemetry. Application events such as page views, click events, feature usage, errors, performance measurements, and device and browser characteristics. We use telemetry to operate, debug, and improve the Service.

2.3 Information collected automatically on the Sites

• Server logs. IP address, user agent, referrer, request paths, and timestamps.
• Cookies and similar technologies. Strictly necessary cookies for session management; optional analytics cookies for aggregated traffic measurement (where used). The Sites do not currently serve third-party advertising and do not use cross-site tracking cookies for advertising purposes.

2.4 Information from third parties

• Upstream carriers and number-reputation providers. Call-delivery status, traceback notices, reputation labels, and similar telephony metadata from upstream carriers (currently Telnyx LLC) and number-reputation providers.
• Service providers. Information from payment processors, identity-verification providers, fraud-detection providers, and similar vendors we engage to run the Service.

3. How We Use Information

We use personal information for the following purposes:

• Provide the Service. Provision accounts; allocate DIDs; place and receive calls; record, transcribe, and store call audio; generate AI coaching outputs; deliver reports and dashboards; deliver support.
• Bill, secure, and operate the Service. Process payments; detect and respond to security incidents, fraud, abuse, and illegal activity; enforce the MSA and AUP; comply with Applicable Law, lawful regulatory or carrier inquiries, and Industry Traceback Group requests.
• Improve the Service. Diagnose and fix defects; measure feature performance; develop new features; train and evaluate machine-learning models in accordance with Section 4.
• Communicate. Send transactional notices (security alerts, billing notices, service notices); respond to inquiries; with appropriate consent or as otherwise permitted by law, send marketing communications about EmberDial products.
• Comply with law and protect rights. Establish or defend legal claims; respond to lawful subpoenas, court orders, regulatory inquiries, and law-enforcement requests; and protect the rights, property, and safety of EmberDial, our Customers, called parties, and others.

4. Aggregated and De-Identified Data; AI Model Training

EmberDial may de-identify and aggregate Customer Data such that it cannot reasonably be used to identify any Customer or natural person ("Aggregated Data"), and may use Aggregated Data for any lawful business purpose, including product analytics, benchmarking, security research, and the training and evaluation of machine-learning models that power the Service's AI coaching and analytical features. We will not publish or share Aggregated Data in a manner that identifies a Customer or a natural person, and we maintain technical and organizational measures designed to prevent re-identification.

EmberDial does not sell or share Customer Data with third-party advertisers and does not use Customer Data for cross-context behavioral advertising or targeted advertising directed at consumers.

5. No Voice Biometrics

EmberDial does not generate, derive, store, or use voice prints, voice templates, or other biometric voice identifiers from call audio, and does not use call audio to identify, authenticate, or profile speakers. EmberDial's AI coaching pipeline operates on speech-to-text transcripts and call metadata only. This commitment is intended to address the carve-out concerns commonly raised under biometric-privacy statutes (including the Illinois Biometric Information Privacy Act, 740 ILCS 14, as amended). If we materially change this posture, we will update this Privacy Policy and the AUP on a prospective basis and provide notice as described in Section 12.

6. How We Share Information

We share personal information only as described in this Section:

• Customer and its Authorized Users. The Customer who originated the Customer Data, and the Authorized Users it has authorized, can access the Customer Data through their EmberDial accounts.
• Service providers and sub-processors. We share information with vendors that perform services on our behalf under written contracts, including:
  • Telephony: Telnyx LLC (upstream carrier and call delivery).
  • Cloud infrastructure: Amazon Web Services (hosting, storage, networking, email-via-SES, and related infrastructure).
  • AI / machine-learning: Speech-to-text and large-language-model providers used to transcribe calls and generate coaching outputs.
  • Payments: The payment processor used to charge subscription Fees.
  • Operational tooling: Analytics, error-tracking, customer-support, and similar tools used to operate the Service.
  A current list of sub-processors is available on request at privacy@emberdial.com.
• Carriers and regulators. We disclose telephony metadata to upstream and downstream carriers, number-reputation providers, the Industry Traceback Group, and applicable regulators as necessary to deliver calls and to respond to lawful traceback and compliance inquiries.
• Business transfers. If EmberDial is involved in a merger, acquisition, reorganization, asset sale, or financing, personal information may be transferred to the counterparty subject to confidentiality protections and this Privacy Policy.
• Legal process and safety. We may disclose personal information to law enforcement, regulators, courts, or other third parties when we believe in good faith that disclosure is required by Applicable Law or necessary to protect rights, property, or safety.
• With consent. Otherwise with the relevant individual's or Customer's consent.

7. Retention

EmberDial retains personal information for as long as necessary to provide the Service, comply with Applicable Law, resolve disputes, and enforce its agreements. The default retention periods for the principal categories of data are:

• Account and registration data — for the duration of the account, plus thirty (30) days following termination unless retention is required by Applicable Law.
• Customer Data (lead and contact records) — for the duration of the Customer's subscription. On termination, exportable for thirty (30) days and then deleted from active systems as described in MSA §9.5.
• Call recordings and transcripts — twenty-four (24) months by default, configurable per Customer and subject to litigation-hold extension on Customer or EmberDial request. After the retention deadline an automated sweeper purges the audio object and verbatim transcript from active systems and writes an append-only audit-log entry.
• Compliance audit log (consent attachments, DNC scrub results, dial-gate events, calling-hours checks, retention-purge events) — five (5) years minimum, exceeding the four-year statute of limitations under the TCPA to support safe-harbor defense.
• Billing and transaction records — seven (7) years, consistent with applicable tax and financial record-keeping requirements.
• Call metadata and usage analytics — for the duration of the subscription in identifiable form; Aggregated Anonymous Data (as defined in MSA §14.2) may be retained indefinitely.
• Identity-verification documents (where collected as part of Customer KYC) — for the duration of the account relationship plus one (1) year following termination, after which the documents are securely destroyed.

When personal information is no longer needed, EmberDial deletes or de-identifies it in the ordinary course. Limited copies may persist in encrypted backup systems for a short additional period and are purged on normal backup-rotation cycles. Customer may request earlier deletion to the extent permitted by Applicable Law and retention obligations.

8. Security

EmberDial maintains commercially reasonable administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of personal information, consistent with industry practice for SaaS providers of similar scale. No security program is perfect; we cannot guarantee absolute security. Customer is responsible for configuring strong passwords, enabling multi-factor authentication where available, and promptly removing access for Authorized Users who no longer need it.

9. Your Rights and Choices

9.1 State privacy law rights

Depending on your state of residence, you may have rights under the CCPA, VCDPA, CPA, CTDPA, UCPA, and similar laws, including the rights to (a) know what personal information is collected about you, (b) access a copy of that information, (c) correct inaccurate information, (d) delete certain information, (e) opt out of the sale or sharing of personal information, (f) opt out of certain types of profiling, and (g) be free from retaliation for exercising these rights.

For personal information that EmberDial holds as a service provider / processor for a Customer (most call-related and lead-related personal information), the Customer is the appropriate point of contact and the controller of that data. EmberDial will assist the Customer in responding to verifiable consumer rights requests as required by MSA §14.6.

For personal information that EmberDial holds as a business / controller (account information, Authorized User profile information, Site analytics, marketing contacts), you may submit a request directly to privacy@emberdial.com. We may need to verify your identity before responding and will respond within the time frame required by Applicable Law.

9.2 Marketing communications

You can opt out of marketing emails at any time by following the unsubscribe link in those emails or by emailing privacy@emberdial.com. Transactional and security communications are not subject to opt-out.

9.3 Cookies

Most browsers let you control cookies through your browser settings. Blocking strictly necessary cookies may affect your ability to use the Sites or the Service.

10. International Users; GDPR Exclusion

EmberDial operates the Service from the United States. The Service is intended for use by United States insurance agencies and the United States consumers they call, and is not directed at users in other countries.

EmberDial does not currently offer the Service to individuals or organizations subject to the European Union General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), the United Kingdom General Data Protection Regulation, or any analogous extra-territorial data-protection regime. If you are a resident of, or located in, the European Economic Area, the United Kingdom, Switzerland, or any other jurisdiction whose data-protection law would purport to apply, please do not use the Service. If we extend the Service to those jurisdictions in the future, we will update this Privacy Policy and implement appropriate data- transfer mechanisms (Standard Contractual Clauses, adequacy decisions, or equivalent) before doing so.

If you access the Service or Sites from outside the United States in violation of the foregoing, you acknowledge that your information will be processed in the United States, which may have different data-protection laws than your country of residence.

11. Children's Privacy

The Service and Sites are intended for business users 18 years of age or older. EmberDial does not knowingly collect personal information from children under 18. If you believe a child under 18 has provided personal information to us, please contact privacy@emberdial.com and we will take reasonable steps to delete it.

12. Changes to This Privacy Policy

EmberDial may update this Privacy Policy from time to time. Material changes will be announced to Customers through email to the administrator-of-record address or by in-product banner at least 30 days before they take effect; non-material changes (typo fixes, clarifying edits) may take effect on posting. Continued use of the Service or Sites after a change takes effect constitutes acceptance of the modified Privacy Policy.

13. Contact Us

Questions, requests, or complaints about this Privacy Policy or EmberDial's privacy practices may be sent to:

Salire LLC (d/b/a EmberDial)
Attn: Privacy
30 N Gould Street, Suite R
Sheridan, WY 82801
Email: privacy@emberdial.com

End of Privacy Policy v1.