Privacy Policy

Effective Date: February 3, 2026

PhoneBurner, Inc. (“PhoneBurner,” “We,” “Us,” or “Our”) is committed to protecting Your privacy. This Privacy Policy explains how We collect, use, disclose, store, and protect Personal Data when You use the PhoneBurner® services, Our website, and applications (collectively, the “System”), or interact with Us.

By accessing or using the System, submitting Personal Data to Us, or interacting with Our website or team, You agree to the practices described in this Privacy Policy. If You do not agree, please do not use the System  or our services or website.

If you have any questions, please contact support@phoneburner.com.

Scope and Application

This Privacy Policy  applies to all Personal Data collected by or on behalf of PhoneBurner, including data collected through:

• Our website (including but not limited to phoneburner.com and all related sites and pages);
• The PhoneBurner® System (including dialing software and ARMOR® Call Protection);
• Coach-Specific AI and other AI-enabled tools and/or machine learning (collectively, “AI Tools”);
• Customer service or sales interactions;
• Mobile applications or integrations;
• Member uploads and Customer interactions.

Because each user account may be controlled by an independent Member, PhoneBurner cannot control how each Member uses or manages the Personal Data they upload into the Systems.

The System is intended for use in the United States and Canada only.

Role of PhoneBurner

With respect to Personal Data relating to Customers that is uploaded to or processed through the System by Members, PhoneBurner acts as a service provider or processor on behalf of the Member, who determines the purposes and means of processing such data. PhoneBurner processes such data only in accordance with the Member’s instructions, this Privacy Policy, and applicable law.

This Privacy Policy should be read together with our Terms of Service and Acceptable Use Policy, which describe additional obligations, restrictions, and enforcement mechanisms related to use of the System and AI-enabled features.‍

Key Terms

An individual or entity who subscribes to the System is referred to as a "Member" of the System. An Individual who is contacted, dialed, or managed by a Member is referred to as a “Customer.” “Users” or “You” include Members, their Customers, and any visitors to Our website.

“Personal Data” means any information that identifies or can be used to identify an individual, directly or indirectly. Personal Data does not include data that is anonymized, aggregated, and/or de-identified.

“Inputs” refer to any data, content, files, prompts, queries, audio, images, or materials You submit to Our AI Tools.

“Outputs” refer to any AI-generated results, responses, or insights generated in response to Your Inputs.

“Aggregated Data” refers to de-identified data that cannot reasonably identify any individual and may be used for analytics, benchmarking, and machine learning.

‍Consent

By using the System, You consent to the collection, use, and disclosure of Your Personal Data as outlined in this Privacy Policy. 

The forms of consent may vary based on the sensitivity of the Personal Data and Your reasonable expectations:

• Implied consent may be used when Personal Data is less sensitive and reasonably expected to be used, for example, when You provide Us with Your phone number or email address, upload contact information to the System in order to make calls to Your Customers, and/or provide Us with phone numbers for monitoring or labeling remediation.
• Explicit consent may be required when We handle more sensitive information or where required by law.

Sensitive information such as biometrics or Protected Health Information (“PHI”) must not be uploaded to the System unless expressly permitted and covered by a valid Business Associate Agreement.

We may collect, use, or disclose Personal Data without Your knowledge or consent where it is required or permitted by law. 

Information We Collect

We may collect the following categories of information.

‍Information You Provide Directly

• Name, email, phone number, EIN, or other business identifiers;
• Account registration details;
• Payment information (processed through PCI-compliant providers; PhoneBurner does not store full credit card details);
• Customer contact lists or other information provided by Members;
• Inputs submitted into AI Tools such as the Coach-Specific AI (prompts, audio, files, SMS content, call recordings, transcripts, etc.);
• Support inquiries and communications;
• Data provided to Us by You through a data export or API  or “probe” integration.

We do not seek to collect sensitive personal information such as private government ID numbers such as Your social security number, precise geolocation, or similar “sensitive personal information” or Personal Health Information (“PHI”) as defined by certain U.S. state laws, and You should not upload such information unless expressly permitted by applicable law and this Policy.

We do not use call audio to identify individuals or to create biometric identifiers, voiceprints, or similar biometric profiles, except where expressly disclosed and permitted by applicable law.

Information Collected Automatically

We may automatically collect:

Usage data, device information, browser type, IP address;

• Call data created through Your activity in the System (such as answered call rates, call durations, call recordings, recorded voicemail);
• Call audio, call recordings, voicemails, and transcripts may be monitored and analyzed, including by AI Tools, in real time or near real time to generate coaching insights, analytics, and recommendations where enabled by a Member and permitted by law. PhoneBurner does not use call audio to identify individuals or to create biometric identifiers, voiceprints, or similar biometric profiles, except where expressly disclosed and permitted by applicable law;
• Interaction logs, dial session information;
• Cookies, tracking pixels, analytics data; and
• System performance metrics and deliverability status.

Information from Third Parties

We may also receive Personal Data from:

• Integrations (CRM, VoIP, email providers, etc.);
• Marketing partners;
• Public sources;
• Affiliates.

 Summary of Personal Data Categories

To help You understand what We collect and why, here is a summary of the main categories of Personal Data We may process:

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‍How and Why We Use Personal Data

PhoneBurner uses Personal Data only as reasonably necessary to:

• Provide and operate the System; 
• Improve, maintain, and secure Our System;
• Monitor and remediate number labeling;
• Register numbers with carriers and their analytics companies and the Free Call Registry;
• Provide analytics and insights driven by AI Tools;
• Respond to requests and inquiries;
• Comply with legal obligations; 
• Prevent fraud, misuse, or security breaches; and
• Support our business operations and marketing.

For Canadian residents, Our legal basis for processing Personal Data includes consent and legitimate business purposes consistent with PIPEDA.

We do not sell Your Personal Data. However, we may share limited Personal Data with advertising and measurement partners to deliver interest-based or cross-context behavioral advertising, including ads displayed on television or connected TV platforms, as defined under applicable U.S. privacy laws. Such sharing does not include sensitive personal information as defined under applicable U.S. privacy laws. Where required by law, Users may opt out through a “Do Not Sell or Share My Personal Information” link or by contacting support@phoneburner.com

PhoneBurner does not use call content, Inputs, or Outputs for purposes unrelated to a Member’s use of the System, except where required by law or where such data has been aggregated, de-identified or anonymized.

6. Use of Artificial Intelligence (AI), Inputs, and Outputs

How We Use AI

When  you use AI Tools: 

• We process and may store the Inputs You provide;
• We process and may store the Outputs generated; and
• We use Inputs and Outputs to deliver the Services, ensure accuracy, maintain continuity, troubleshoot issues, improve quality, and comply with legal obligations.  

Inputs and Outputs may include Personal Data, depending on what You choose to upload or enter.

AI Subprocessors

Certain AI functionality may be powered by third-party AI service providers (“AI Subprocessors”). These may include, without limitation, OpenAI and/or such other AI providers that We may add or replace from time to time. We may also use AWS and similar infrastructure providers that process or log metadata and contextual information.

AI Subprocessors may process or log Inputs, Outputs, and related metadata as necessary to provide their services, maintain security, detect abuse, or comply with applicable laws. PhoneBurner requires all AI Subprocessors to provide privacy and security protection consistent with U.S. and Canadian privacy laws. Some AI Subprocessors may store or process Personal Data in jurisdictions other than Your own. Cross-border transfers are described in Section 11 (Storage and Cross-Border Transfers) below.

These subprocessors will not use Your Personal Data to train their models. 

AI Training, Machine Learning, and Aggregated Data

We do not use identifiable Personal Data to train, retrain, or fine-tune Our AI or machine-learning models without Your explicit consent.

We may use aggregated, de-identified, and/or anonymized data derived from Your use of the System to train, refine, or validate AI and/or machine-learning models.

We do not attempt to re-identify de-identified or anonymized data.

Real-Time Call Analysis and AI Coaching

AI Tools may analyze call audio, call transcripts, and related interaction data in real time or near real time to generate coaching insights, performance analytics, recommendations, or observations during or after live calls, subject to Member configuration and applicable law. Such analysis may occur automatically when AI Tools are enabled by a Member.

Member Controls and Configuration

Certain AI features, retention settings, or data-processing activities may be configurable at the Member account level, subject to product availability and contractual terms. Members are responsible for selecting and enabling features appropriate to their use cases and compliance obligations. PhoneBurner may suspend or limit access to AI Tools where we reasonably believe required notices or consents have not been obtained, consistent with our Acceptable Use Policy.

Automated Decision-Making and Profiling

AI Tools may generate insights about, for example: 

• delivering coaching observations and suggestions during and/or after a call;
• call performance and answer rates;
• number reputation and labeling risk;
• engagement predictions; and/or
• optimization recommendations (e.g., when to dial, which numbers may be more at risk of spam labeling).

AI Tools may perform profiling or analysis to generate recommendations or insights; however, such outputs do not produce legal or similarly significant effects on individuals and do not independently determine eligibility, rights, or obligations.

These AI-generated insights are provided for informational purposes only. AI Outputs may be incomplete, inaccurate, or reflect limitations or biases in underlying data or industry patterns. AI Tools do not replace human judgment, professional training, or independent evaluation, and should not be relied upon as the sole basis for decisions.

Use of AI Tools is also governed by the Terms and Conditions of Service and Acceptable Use Policy, which describe additional compliance obligations, limitations, and restrictions on AI-assisted features.

7. Cookies and Tracking Technologies

We may use cookies, tracking pixels, and similar technologies in order to:

• Authenticate users and maintain sessions;
• Analyze traffic and usage patterns; 
• Support advertising and remarketing (in compliance with applicable laws); 
• Enable advertising and measurement activities, including linking website visits to advertising delivered on television or connected TV platforms, where permitted by law; and
• Improve site and System functionality.

Users may modify cookie preferences via browser settings. Some features may not function properly if cookies are disabled.

We do not sell data collected through cookies to third parties. However, we may share limited Personal Data with advertising and measurement partners to deliver interest-based or cross-context behavioral advertising, including ads displayed on television or connected TV platforms, as defined under applicable U.S. privacy laws.

At this time, PhoneBurner does not respond to browser-initiated “Do Not Track” (DNT) signals.

8. Usage Data and Usage Content

We may collect:

• Call recordings, call audio, and voicemail recordings;
• Dial session history and call logs;
• Interaction logs; and
• User behavior within the platform.

You are solely responsible for obtaining all legally required notices and consents from Customers or call participants before recording or monitoring any communications.

We may inspect or analyze content to:

• Enforce and verify compliance with Our Terms and Conditions of Service (“TOS”);
• Detect and prevent fraud, abuse, and security incidents;
• Improving service quality and user experience;
• Support AI model and/or machine learning refinement (using aggregated and/or anonymized data only);
• Assist in the remediation of Your numbers.

Member Responsibility for Notice and Consent

Members are solely responsible for providing all legally required notices and obtaining all required consents from Customers or call participants for call recording, monitoring, transcription, and AI-assisted analysis, including in jurisdictions requiring two-party or all-party consent. PhoneBurner does not obtain such consent on a Member’s behalf. Additional requirements are described in our Terms of Service and Acceptable Use Policy.

9. How We Disclose Personal Data

We disclose Personal Data only as reasonably necessary to operate the System, comply with the law, or support our business operations. This includes disclosures to:

• Service Providers: such as hosting providers, data storage providers, analytics vendors, AI providers (including OpenAI and/or such other AI or machine-learning service providers we may engage), payment processors, and customer-support platforms that process data on Our behalf;
• Carrier Partners and Reputation Services: including the Free Call Registry, carriers to support telecommunications such as calls and SMS, and carriers and analytics companies to support number registration, labeling remediation, and call-performance optimization;
• Legal and Regulatory Recipients: where required by law, regulation, legal process, or to protect Our rights or the rights of others;
• Aggregated, De-Identified, or Anonymized Data: which does not identify any individual and may be shared for analytics, benchmarking, research, and system, machine-learning, and/or AI improvement.

We do not sell Your Personal Data. However, we may share limited Personal Data with advertising and measurement partners to deliver interest-based or cross-context behavioral advertising, including ads displayed on television or connected TV platforms, as defined under applicable U.S. privacy laws. Such advertising-related sharing may involve online identifiers, device identifiers, IP addresses, or similar pseudonymous identifiers, and does not include sensitive personal information.

10. Sharing Personal Data With Third Parties

The following sections provide more detail on specific categories of disclosure:

Service Providers

We use trusted third-party service providers to help Us deliver and support the System, including hosting, data storage, payment processing, analytics, AI services, and customer support. These providers are only permitted to use Personal Data as necessary to provide services on Our behalf.

‍Carrier Partners and Reputation Services

In order to provide the System, including dialing calls, sending SMS, enhancing call performance, validating number reputation, and remediating number labeling, We may (and You authorize Us to) share necessary information with third-parties including: 

• The Free Call Registry;
• Carriers and analytics companies; and
• Provider registries.

Law Enforcement and Legal Compliance

We may be required by law to disclose Your Personal Data to the government or third parties under certain circumstances. We may (and You authorize us to) disclose information if We, in Our sole discretion, believe it is necessary or appropriate to comply with law, subpoenas, or legal process, or to protect Our rights or the rights of others.

Aggregated and De-Identified or Anonymized Data

We may and You authorize us to share Aggregated Data (including de-identified and/or anonymized data) with Members, Our partners and advertisers. We may also use such data for analytics, benchmarking, research, and system, machine learning and/or AI improvement. This information cannot reasonably be used to identify any individual personally and You may have the right to opt out where required by law. PhoneBurner uses Aggregated Data solely for purposes related to operating, maintaining, improving, and developing the System and its features and does not attempt to re-identify such data.

11. Storage and Cross-Border Transfers

We store Personal Data in the United States The location of storage may depend on Your region, the specific services You use, and Our service providers.

If You are located in Canada, Your Personal Data will be transferred to, stored in, or accessed from the United States. If You use our ARMOR Services in Canada, Your usage data will not be transferred. Such data may be subject to U.S. laws and lawful access by U.S. authorities. By using the System, You consent to these cross-border transfers.

We take steps to ensure that any Personal Data transferred across borders receives a comparable level of protection as required under applicable U.S. and Canadian privacy laws, including through contractual safeguards and oversight of Our subprocessors.‍

12. Retention

We retain Personal Data, including Inputs and Outputs, call recordings, usage logs, and system data, for as long as necessary to:

• Deliver the System;
• Maintain account history;
• Support legal compliance;
• Enforce Our agreements; and
• Perform troubleshooting or service enhancement.

Retention periods vary based on the purpose of processing, the sensitivity of data, and legal obligations. Call data records, Inputs, and Outputs may be retained for the duration of Your account plus a reasonable period thereafter for security, auditing, fraud prevention, and system integrity. Retention periods may vary by feature and may be configurable by Members, subject to legal and operational requirements. You are responsible for retaining Your own telemarketing records as set forth in our Acceptable Use Policy.

When Personal Data is no longer required, We will delete it or aggregate, de-identify and/or anonymize it.‍

13. Security

We use industry-standard security measures to protect Your Personal Data, including SOC2 Type II controls, encryption in transit and/or at rest where appropriate, access controls and least privilege principles, monitoring logging, and auditing, and organizational safeguards, such as policies and training. 

However, please be aware that no data transmission over the Internet or storage system can be guaranteed to be 100% secure. You use the System at Your own risk.

14. Your Data Protection Rights

US State Privacy Rights (CPRA, CO, CT, VA, UT, etc.)

Depending on Your state of residence, You may have some or all of the following rights subject to legal limitations:

• Access: to request a copy of the Personal Data We hold about You;
• Correction: to request that We correct inaccurate Personal Data;
• Deletion: to request that We delete certain Personal Data;
• Portability: to request a portable copy of certain Personal Data;
• Opt out of targeted advertising or cross-context behavioral advertising, including advertising delivered via television or connected TV platforms, where required by applicable law;
• Opt out of profiling or certain automated-decision making: where such processing produces legal or similarly significant effects; and
• Right to Appeal: if We deny Your privacy request, You may have the right to appeal Our decision. Instructions will be provided in Our response. 

Requests can be submitted to support@phoneburner.com. We may need to verify Your identity before fulfilling a request and may decline requests where an exception applies.

‍Right to Opt Out of Sharing for Advertising

Where required by law, You may opt out of the sharing of Your Personal Data for cross-context behavioral advertising. Requests may be submitted to support@phoneburner.com, or through any “Do Not Sell or Share My Personal Information” mechanism made available on Our website.

‍Financial Incentives

PhoneBurner does not offer financial incentives, price differences, discounts, or service-level variations in exchange for the collection, retention, sale, or sharing of Personal Data. If this ever changes, we will provide a detailed description of the program, the categories of data involved, and instructions for how to opt-in or withdraw consent.

‍Canadian Privacy Rights (PIPEDA)

Canadian residents have rights to:

• Access their Personal Data;
• Request correction of inaccurate or incomplete information;
• Withdraw consent to further processing  (subject to legal or contractual restrictions and reasonable notice); and
• Request information about Our use of automated decision-making that may significantly affect them; 
• Request information about PhoneBurner’s policies and practices relating to the management of Personal Data.

If You are a Canadian resident and wish to exercise these rights, please contact support@phoneburner.com.

You may also file a complaint with the Office of the Privacy Commissioner of Canada or the relevant provincial commissioner. More information is available at www.priv.gc.ca.

‍Customers of Member Accounts

If You are a Customer who has been contacted by a Member, the Member is typically the controller of Your Personal Data. You should direct privacy-related  requests to that Member. PhoneBurner will assist Members, as appropriate, in responding to such requests.

Children’s Privacy

The System is intended for business use by adults and is not directed to or intended for individuals under the age of 18. If You are not 18 years old, You are not permitted to access this site or use the System for any reason. We do not knowingly collect or maintain Personal Data from individuals under 18. If we become aware that We have collected such information, We will take steps to delete it. 

Protected Health Information

The System is not designed to store or process Protected Health Information (“PHI”) or individually identifiable information relating to the past, present, or future health status of an individual that is created, collected, or transmitted, or maintained by a HIPAA-covered entity in relation to the provision of healthcare, payment for healthcare services, or use in healthcare operations, unless We have signed a Business Associate Agreement with You.

‍Marketing Communications

We may send You marketing communications from time to time. You may opt out of receiving such marketing communications at any time by following the unsubscribe button or contacting Us at support@phoneburner.com.

15. Business Transitions

In the event We go through a significant business transition, such as a merger, acquisition, or asset sale, Your Personal Data may be transferred as part of that transaction. We will take reasonable steps to ensure that any successor entity continues to protect Your Personal Data in accordance with this Privacy Policy or provides comparable protections. 

16. Notification of Changes

We may update this Privacy Policy from time to time. We will post any changes on Our website and the “Effective Date” at the top will be updated accordingly.

If We make material changes to our Privacy Policy,  We may also notify You via email or through the the System where appropriate and required by law. 

17. Contact Information

If You have any questions or suggestions regarding Our privacy policy, or wish to exercise Your rights regarding Your Personal Data, please contact us at:

PhoneBurner
1968 S. Coast Hwy, Suite 1800
Laguna Beach, CA 92651
888 928 7637
support@phoneburner.com
www.phoneburner.com

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