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Privacy Policy

Effective PLACEHOLDER: date Version 1.0 — draft
Draft for design purposes — not legal advice
Structure and coverage only. Must be completed and reviewed by privacy counsel, including state-specific rights (CCPA/CPRA and equivalents) and any sector-specific obligations that apply to the verticals operated on the Platform.

1. Scope

This policy covers information we handle as the operator of the CallCenterCampaigns.com Platform. It covers business users — call center partners and campaign owners — and explains our role in relation to consumer data generated by campaigns run through the Platform.

2. Information we collect

From call center partners

  • Company identity: legal name, address, website, business registration details
  • Contact details for named individuals: name, role, business email, phone
  • Operational profile: agent counts, states of operation, verticals, campaign experience, traffic sources, dialer platform, recording and QA capability, operating hours, available capacity
  • Verification records: call notes, documents requested and supplied, verification outcome
  • Performance data: calls, transfers, qualified events, rejections, disputes, QA scores, complaint records
  • Payment details required to remit earnings

From campaign owners

  • Company identity and contact details for named individuals
  • Campaign information: targeting, operations, pricing, compliance materials, tracking configuration
  • Billing and payment information
  • Campaign performance and spend data

Automatically

  • Device, browser and IP information; pages viewed; actions taken in the Platform
  • Audit records of material actions, including actor, timestamp and before/after state

3. How we use information

  • To verify identity, capability and eligibility of participants
  • To score and match centers against campaigns
  • To deliver training, certification, routing and tracking
  • To calculate, validate and administer payouts and billing
  • To detect, investigate and act on fraud, quality and compliance issues
  • To provide account management and support
  • To send operational notifications and, where permitted, relevant campaign opportunities
  • To meet legal, regulatory and audit obligations

4. Legal basis

PLACEHOLDER: counsel to state applicable bases per jurisdiction — contractual necessity, legitimate interests, consent, legal obligation.

5. Sharing

We share information only as necessary to operate the network:

  • With campaign owners — partner identifier, tier, aggregate and per-campaign performance for centers running their campaign. Full center contact detail is shared only where the Platform brokers a direct introduction.
  • With call center partners — campaign requirements, materials and routing needed to perform. Campaign owner identity is disclosed only where the campaign permits it.
  • With service providers — hosting, telephony, payment processing, identity verification, analytics and support tooling, under contract.
  • For legal reasons — where required by law, regulation, subpoena, or to protect rights, safety, or investigate fraud.

We do not sell business or consumer personal information. PLACEHOLDER: confirm and align with state-law definitions of "sale" and "sharing".

6. Consumer data from campaigns

Consumers contacted during a campaign are not our customers. Responsibility for lawful contact, consent capture, disclosure and suppression rests with the call center partner making the contact and the campaign owner whose offer is being presented. The Platform processes consumer records — such as transfer records, dispositions and quality evidence — on behalf of those parties for validation, quality control, fraud detection and dispute resolution.

PLACEHOLDER: counsel to confirm controller/processor characterization for each data flow and to draft the corresponding data processing terms.

7. Call recordings

Most campaigns require call recording. Recording obligations, consent requirements and retention differ by state. Partners are responsible for lawful recording and for the disclosures their agents make. The Platform may access recordings for QA sampling, dispute resolution and fraud investigation.

8. Retention

We retain records for as long as needed to operate the network, resolve disputes, meet audit and legal obligations, and enforce our agreements. PLACEHOLDER: define retention periods per data category.

9. Security

We apply role-based access control with ownership scoping, encryption in transit and at rest, audit logging of material actions, least-privilege internal access, and periodic review. PLACEHOLDER: confirm certifications, sub-processor list and breach notification commitments.

10. Your rights

Depending on where you live, you may have rights to access, correct, delete, port or restrict processing of your personal information, and to appeal a decision. Requests can be made through the contact details below; we will verify your identity before acting. PLACEHOLDER: counsel to enumerate state-specific rights and response deadlines.

11. Cookies & analytics

We use strictly necessary cookies for authentication and security, and — with consent where required — analytics cookies to understand product usage. PLACEHOLDER: cookie table and consent mechanism.

12. Children

The Platform is a business tool and is not directed to anyone under 18.

13. Changes

Material changes will be notified in-platform and by email to account administrators before taking effect.

14. Contact

PLACEHOLDER: privacy contact email, postal address, and — if appointed — data protection officer or state privacy representative.