Last updated: [DATE]
DRAFT — for review by counsel before publication.
This policy explains what [LEGAL ENTITY NAME] collects, why, and what we do with it.
1. What we collect
Information you give us
- Contact and account details: name, company, email, phone, billing and service addresses.
- Enquiries submitted through this website, including what you tell us about your current setup.
- Payment details, processed by our payment provider.
Information generated by using the service
- Call detail records — numbers called, date, time, duration, and routing data.
- Call recordings and voicemail, where you have enabled them.
- Messaging metadata and, where necessary to deliver or troubleshoot, content.
- Registered service addresses, used for emergency call routing.
- Technical logs: IP addresses, device and client versions, connection quality.
2. Customer Proprietary Network Information (CPNI)
Some of what we hold is CPNI — information about the quantity, technical configuration, type, destination, location and amount of your use of our telecommunications service. Federal rules restrict how we use, disclose and permit access to it.
We use CPNI to provide and bill for the service, to protect our network and users, and as otherwise permitted by law. We do not sell it. Disclosure to third parties for marketing requires your approval, and we will seek it separately rather than burying it in this policy.
[Counsel: CPNI carries its own obligations — an annual compliance certification, an authentication procedure before disclosing CPNI over the phone, notification of account changes, and a breach reporting process with defined timing. Those live in an internal procedure, not only in a website policy.]
3. How we use information
- To provide, configure, support and bill for the service.
- To route emergency calls to the correct emergency call centre.
- To detect fraud, toll abuse and network threats.
- To respond to your enquiries.
- To meet legal, regulatory and lawful process obligations.
4. Who we share it with
- Underlying carriers and numbering partners, to originate, terminate and port calls and messages.
- Emergency service providers, when a 911 call is placed.
- Service providers — hosting, payment processing, email delivery — under contract and only as needed.
- Authorities, in response to valid legal process.
We do not sell personal information.
5. Call recording
Where you enable recording, you are the party deciding to record and you are responsible for obtaining any consent the law requires. Recording law varies by state and some require the consent of all parties. We store recordings on your behalf and make them available to you; we do not listen to them except where you ask us to help with a technical fault.
6. Retention
- Call detail records: [PERIOD].
- Recordings and voicemail: [PERIOD], or until you delete them.
- Website enquiries: [PERIOD].
- Billing records: as required by tax and telecom regulation.
7. Security
[Describe honestly what you actually do — encryption in transit, access controls, where data is hosted, who has administrative access. Don’t claim a certification you don’t hold.]
8. Your rights
You may request access to, correction of, or deletion of personal information we hold about you, subject to our legal retention obligations. Contact us at [EMAIL].
9. Changes
We will post changes here and update the date above. Material changes will be notified to account holders.
10. Contact
[LEGAL ENTITY NAME]
[ADDRESS]
[EMAIL] · [PHONE]