Privacy Policy

This Privacy Policy is issued by 2FO Holdings, LLC d/b/a Cloned Closer, a Wyoming limited liability company ("Cloned Closer", "we", "us"), 30 N Gould St Ste R, Sheridan, Wyoming 82801. It explains what personal information we collect, why, who we give it to, how long we keep it, and the choices and rights you have. It covers: (a) people who place a telephone call that is connected to a business through our platform ("callers"); (b) people who visit clonedcloser.com or app.clonedcloser.com ("visitors"); and (c) the individuals who use our platform on behalf of the businesses that buy calls ("Buyers") or supply calls ("Publishers"). Section 14 has additional terms for Buyers and Publishers. This policy does not cover the privacy practices of the Publisher whose advertisement you responded to or of the Buyer you spoke with; each is a separate business with its own privacy notice.

In short

• We run a pay-per-call platform. When you call a number advertised by one of our Publishers, the Publisher sends us your telephone number and the details you gave it, we normally play a recorded notice, and we connect you to a business in the field you asked about. We charge that business for the call. Under California law and similar state laws, that is a "sale" of your personal information.
• We do not use your information for advertising, we do not "share" it for cross-context behavioral advertising, and we do not sell it to anyone other than the business we connect you with, our service providers, or as the law requires.
• Calls connected through our platform are recorded. Recordings are kept for the period in Section 8 and are available to the business you spoke with and to us.
• You can tell us not to sell your information and to stop connecting calls from your number at any time: use the "Do Not Sell or Share My Personal Information" link in the footer of every page of our websites, or email admin@clonedcloser.com. We honor Global Privacy Control signals on our websites.
• We do not knowingly collect information from anyone under 18 and do not sell or share the information of anyone we know to be under 16.
• Our platform refuses health, medical, medication or tobacco-use fields from Publishers (they are never stored with your call or passed to a business), and we require the businesses we connect you with not to write any into their notes.

If anything in this summary differs from the sections that follow, the sections control.

1. Who we are and who this policy covers

Cloned Closer operates a technology platform that connects live inbound telephone calls from consumers to independent businesses that pay us for those calls. We are not the business you spoke with, we do not sell the products or services discussed on the call, and we do not decide whether you qualify for anything. This policy applies to callers, visitors, and the individuals behind Buyer and Publisher accounts. It applies in the United States, the only place our platform is offered.

2. Notice at collection

Our Notice at Collection is a short summary of the categories of personal information we collect, the purposes we use them for, whether each category is sold, and how long we keep it. It is linked beside every form on our websites. For the call audio we collect directly, the recorded notice normally played before your call is connected tells you that the call is recorded and may be transcribed, that we will connect you to an independent business and share the information you gave with it, and where to find this policy; the Publisher that collected your information from you gave you its own notice at collection. This policy and the Notice at Collection carry the categories, purposes and retention periods a recorded message cannot; the Notice summarizes Sections 3, 4 and 8 of this policy, and where they differ, this policy controls.

3. What we collect, where it comes from, why, whether we sell it, and how long we keep it

Category names follow California Civil Code section 1798.140(v). We have collected the following categories of personal information in the preceding 12 months (or since our platform launched, if later).

• Identifiers. Your telephone number (from your carrier's caller ID and from the Publisher); your name, email address and postal address (from the Publisher, if you gave them); the Publisher's request, lead and traffic-source identifiers; consent-record references (a TrustedForm certificate URL or Jornaya LeadiD supplied by the Publisher); our own call and reservation identifiers. Purposes: connect your call to a business authorized in your state; record and bill the call; detect duplicate, fraudulent and un-pinged calls; resolve business disputes and Publisher returns; honor your opt-out and do-not-call requests; comply with law. Sold to: the business connected to your call. Disclosed for a business purpose to: our telephony, hosting, database and email providers and, only while the business has AI assist turned on, our speech-recognition and language-model providers; the Publisher that sent the call, for dispute and return resolution. Retained: 24 months after the call, then deleted or de-identified, except the telephone number on our suppression list (kept so we can keep honoring your request) and billing metadata (7 years).
• Characteristics of protected classifications. Age or date of birth, gender and spoken language (from the Publisher). Purposes: eligibility routing; letting the business serve you. Sold to: the business connected to your call. Retained: 24 months.
• Commercial information. The product or service you inquired about; the business's disposition and notes about the call; any sale value the business records (from the Publisher and the business). Purposes: billing; disputes; quality; Publisher payment. Not sold. Disclosed to service providers. Retained: 24 months (notes) and 7 years (billing).
• Household and financial information you gave the Publisher. Household or beneficiary details and income range (from the Publisher). Purposes: eligibility routing; letting the business serve you. Sold to: the business connected to your call. Retained: 24 months.
• Audio, electronic or similar information. The dual-channel recording of your call from the moment the business answers (collected by us). If the business has AI assist on, the call audio is streamed from the business's browser to our speech-recognition provider, which returns a live transcript to that browser; we do not store the transcript. Purposes: verify the call and its duration; resolve disputes and chargebacks; quality, compliance and training; respond to complaints, subpoenas and regulators; fraud prevention. Made available to the business you spoke with and to service providers; excerpts may be provided to the Publisher to resolve a return. Because the business you spoke with can listen to the recording as part of the call it paid for, we treat the recording as sold to that business and to no one else. Retained: 365 days after the call, longer if a dispute, chargeback, complaint or legal hold is open.
• Geolocation. We do not collect precise geolocation. We record the state you told the Publisher or, if none, the state associated with your area code.
• Inferences. The state inferred from your area code when the Publisher did not tell us (generated by us). Purpose: routing to a business authorized in that state. The inferred state is transmitted to the business as part of the call record. Retained: 24 months.
• Internet or other network activity. IP address, browser type, device identifiers, pages requested and timestamps when you visit our websites; opt-out preference signals from your browser. Purposes: security, fraud prevention, operating the sites, honoring your choices. Not sold. Retained: server logs for the short period our hosting providers keep request logs (never more than 90 days); opt-out records for as long as needed to honor them.
• Sensitive personal information. We do not request it. Our platform refuses health, medical, medication and tobacco-use fields from Publishers (they are never stored with your call or passed to a business), and we prohibit the businesses we connect you with from recording health or other sensitive information in notes. A recording may incidentally capture sensitive information you say on a call; we do not use or disclose sensitive personal information to infer characteristics about you or for any purpose other than those permitted by 11 CCR section 7027(m), so we do not offer a separate "Limit the Use of My Sensitive Personal Information" choice. See Section 7.

Categories of sources: Publishers (the businesses whose advertisements you responded to and their call-tracking platforms); telephone carriers (caller ID); you (what you say on a recorded call and what you enter on our forms); the businesses that take your call (dispositions, notes); consent-verification services (references only); our own systems (inferences and call metadata).

We do not "share" personal information for cross-context behavioral advertising and do not use it for targeted advertising or profiling.

4. We sell personal information

When a business answers a call routed through our platform, we transmit to that business the call and the information the Publisher sent with it, and the business pays us for the call. Under the California Consumer Privacy Act and similar laws in Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, that transfer is a "sale" of personal information.

Categories we have sold in the preceding 12 months: identifiers; characteristics of protected classifications (age or date of birth, gender, language); household and financial information you gave the Publisher; commercial information about the product or service you asked about; and the audio recording of your call. Category of third parties we sold them to: the business that received your call, a licensed business or professional in the field you asked about (for example an agency, lender, contractor, law firm or other provider) that has agreed in writing to use your information only to handle your inquiry and not to resell it.

We have not "shared" personal information for cross-context behavioral advertising. We have disclosed the categories in Section 3 for business purposes to the categories of service providers and contractors in Section 15 and, for dispute resolution only, to the Publisher that sent the call.

We do not sell or share the personal information of consumers we have actual knowledge are under 16 years of age. Our Publishers agree not to send us calls from anyone under 18, and if we learn that a caller is under 16 we delete the call's lead information and add the number to our suppression list.

How the chain works and what you were told: the Publisher that collected your information must tell you, at or before collection, that it will be sold to call networks such as Cloned Closer and to the businesses that receive your call, and must give you a way to opt out. We in turn sell it only to the business connected to your call, under a written agreement that prohibits that business from selling or renting it, or from sharing it with anyone other than the provider of the product or service you asked about and its own service providers, and that requires it to delete it when it is no longer needed.

List of specific recipients: if you live in Connecticut, Minnesota or Oregon (or another state that provides this right), you may ask us for the name of each business that received your personal information, and we will provide it. Anyone may ask us for the categories of businesses that received it.

5. Your privacy choices: Do Not Sell or Share My Personal Information

You can direct us not to sell your personal information. Because the only thing we sell is a live call with the information attached to it, opting out also means we stop connecting calls from your telephone number through our platform; treat it as a do-not-connect request as well.

How to opt out (no account, no identity verification, no fee):

• Web form: use the "Do Not Sell or Share My Personal Information" link in the footer of every page of our websites and enter the telephone number(s) you want suppressed. Name and email are optional and are used only to confirm your request.
• Email: admin@clonedcloser.com, stating the telephone number(s) to suppress.
• Mail: the address in Section 20.
• Global Privacy Control or another opt-out preference signal from your browser (Section 6).
• An authorized agent may submit any of these for you (Section 10).

What happens next: we add the number to our suppression list within 15 business days (in practice immediately), after which our platform refuses any Publisher ping and any inbound call from that number and never transmits it to a business again. We notify any business that received your personal information between the time you submitted your request and the time we processed it, direct it to comply with your request and to pass the request on to anyone it disclosed the information to, and we forward your request to the Publisher that sent us your call. We will not ask you to opt back in for at least 12 months, and we keep your telephone number on our suppression list so that your request keeps working; you can withdraw it by contacting us.

What opting out does not do: it does not delete information already sold to a business (use the deletion right in Section 11 and we will forward it); it does not stop the Publisher or the business you already spoke with from contacting you directly (contact them; each has its own privacy notice); and it does not affect calls you place directly to a business outside our platform.

We will not discriminate against you for opting out (Section 18).

6. Opt-out preference signals (Global Privacy Control)

Our websites recognize the Global Privacy Control (GPC) and other opt-out preference signals sent by your browser or extension. When we receive one, we treat it as a valid request to opt out of the sale and sharing of personal information for that browser and any information we can associate with it, without any pop-up, fee or change to your experience. Because we sell only the personal information attached to telephone calls and set no advertising cookies, a browser signal by itself cannot identify your telephone number; to opt out a telephone number, use any method in Section 5, and we will suppress it whether or not your browser sends a signal. If you have previously consented to a sale and later send a signal, we honor the signal. You can turn on GPC in browsers and extensions that support it (see globalprivacycontrol.org). Residents of Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon and Texas may use a recognized universal opt-out mechanism in the same way.

7. Sensitive personal information and consumer health data

We do not ask for, and our platform refuses, Social Security numbers, driver's license or other government identifiers, financial account or card numbers, precise geolocation, biometric identifiers, and health, medical, medication or tobacco-use information from Publishers. We require the businesses we connect you with not to record health, medical or other sensitive information in their notes, and we may remove such notes. A recording may capture sensitive information you volunteer on a call. We use and disclose any sensitive personal information we hold only to perform the service you requested (connecting and recording your call), to prevent fraud and security incidents, to verify the quality of our service and to comply with law, and never to infer characteristics about you. For that reason we do not offer a separate "Limit the Use of My Sensitive Personal Information" choice; you may still delete your information under Section 11. We do not sell sensitive personal data as defined by the laws of Texas, Maryland or any other state.

Consumer health data (Washington, Nevada, Connecticut and similar laws). We do not intentionally collect, share or sell consumer health data. If you are a Washington resident (or your data was collected in Washington), a Nevada resident or a Connecticut resident: (a) we do not accept health information from Publishers; (b) if you nonetheless say something about your health on a recorded call, that recording is retained as described in Section 8; the business you spoke with may listen to it only for the limited purposes its agreement with us allows (handling your inquiry, quality, compliance and dispute resolution), we receive no payment for the recording separate from the call, and we do not sell or share it to anyone else; (c) you have the right to confirm whether we hold consumer health data about you, to withdraw consent, and to have it deleted, by any method in Section 20; and (d) we do not use geofencing.

8. How long we keep personal information

We keep personal information only as long as needed for the purposes in Section 3, then delete or de-identify it. Our standard periods are:

• Call recordings: 365 days from the call, then deleted from our telephony provider and our records. Held longer only while a business dispute, chargeback, consumer complaint, regulator inquiry, subpoena or litigation hold is open, and then deleted when it closes.
• Lead information transmitted with a call (name, contact details, age or date of birth, gender, language, household or financial details, consent-record references) and the business's notes: 24 months from the call, then deleted or de-identified. Criteria: the 12-month period for which we must be able to answer a request to know, plus the period in which business disputes, Publisher returns and consumer complaints about a call are typically raised.
• Call metadata needed for billing and tax records (telephone number, timestamps, duration, charges, and the business and Publisher involved): 7 years, the period required for financial records, after which the telephone number is removed.
• Suppression list (opt-out, do-not-call and blocked numbers): for as long as needed to keep honoring the request; any name, email or note you gave with the request is deleted after 24 months.
• Records of privacy requests and our responses: 24 months, as California regulations require.
• AI assist transcripts and suggestions: none; they exist only in the business's browser during the call. Our speech-recognition and language-model providers retain what they receive for a limited period under our agreements with them (currently no more than 30 days for the language-model provider) and do not use it to train models.
• Website server logs (IP address, browser, pages): the short period our hosting providers keep request logs, never more than 90 days.
• Buyer and Publisher account records, agreements, signature records, wallet ledger, payout statements, tax forms and support tickets: for the life of the account plus 7 years.
• Email one-time sign-in codes: stored hashed and deleted when used or when they expire, minutes after they are sent. A password, for accounts that still use one: stored hashed for the life of the account.

De-identified and aggregated data we derive from any of the above is kept without limit and is not re-identified.

9. Your privacy rights

Depending on where you live, you have some or all of the following rights. We extend the rights below to every U.S. resident regardless of state.

• Right to know and access: to confirm whether we hold personal information about you and to receive the categories we collected, the categories of sources, our purposes, the categories (and, in Connecticut, Minnesota and Oregon, the names) of third parties we sold it to or disclosed it to, and the specific pieces we hold, in a portable, readily usable format. We provide information for the 12 months before your request; you may ask for more if we still hold it.
• Right to delete: to have us delete personal information we collected about you, subject to the exceptions in Section 11.
• Right to correct: to have inaccurate personal information corrected.
• Right to opt out of sale or sharing: Section 5. We do not use personal information for targeted advertising or for profiling that produces legal or similarly significant effects, so there is nothing to opt out of on those grounds.
• Right to limit sensitive personal information: not applicable because of the way we use it (Section 7).
• Right to withdraw consent and to delete consumer health data (Washington, Nevada, Connecticut): Section 7.
• Right to non-discrimination: Section 18.
• Right to appeal: if we decline your request, you may appeal within 60 days by replying to our decision or writing to admin@clonedcloser.com with "Appeal" in the subject line; we will answer in writing within 45 days (60 in some states) and, if we uphold the denial, tell you how to contact your state Attorney General.

How to submit a request: the privacy request form linked from the footer of our websites; email admin@clonedcloser.com; or mail (Section 20). You do not need an account. You may use an authorized agent (Section 10).

What to expect: we confirm receipt within 10 business days and explain how we will verify you; we respond within 45 calendar days of receipt and may take up to 45 more days if reasonably necessary, in which case we will tell you why. Opt-out requests are processed within 15 business days. We will not charge a fee unless requests are manifestly unfounded or excessive, and we need not respond to more than two requests to know from the same person in 12 months. Information you give us to verify a request is used only for that purpose and deleted afterwards.

California "Shine the Light" (Civil Code section 1798.83): we do not disclose personal information to third parties for their own direct-marketing purposes.

10. How we verify your request; authorized agents

We do not verify identity for opt-out requests; we only need the telephone number to suppress. For requests to know, delete or correct, because you do not have an account with us, we verify you by matching what you tell us against what we already hold:

• Categories of information, or deletion or correction of lead details: at least two of the telephone number the call was placed from, your name as given to the Publisher, your ZIP code or state, your email address, and the approximate date of the call.
• Specific pieces of information, including a copy of a recording: at least three of those data points plus a signed declaration under penalty of perjury that you are the person who placed the call, and we may confirm by calling or sending a one-time code to the telephone number on the call. Where we cannot reach that standard we will instead tell you the categories we hold.

We may deny a request we cannot verify and will tell you why. If we cannot verify a deletion request we treat it as an opt-out and suppress the number. We never ask for a government ID, a photograph, a Social Security number or a payment card to verify a request.

Authorized agents: you may use an agent to submit requests. For opt-outs, the agent needs only your signed permission. For other requests we may ask the agent for your signed permission and ask you to confirm the request directly with us or verify your own identity; a valid power of attorney under California Probate Code sections 4121 to 4130 is accepted without further proof. Agents must keep your information secure and use it only for your request.

Recordings: a copy of a recording is provided as an audio file of your side of the call, with the other side removed, and only to the verified caller or their agent.

11. Deleting your information

When we verify a deletion request, we: (1) delete the lead information, business notes and recording(s) associated with your telephone number; (2) direct our service providers to delete them; (3) notify each business that received your information and the Publisher that sent it, asking them to delete it and to pass your request on; and (4) add your telephone number to our suppression list so that we do not collect or sell your information again. We complete this within 45 days. Once we are registered as a data broker in California, we also process deletion requests submitted through the California Privacy Protection Agency's Delete Request and Opt-out Platform (DROP) at least every 45 days, matched to our records by telephone number and email and processed as above without further verification.

What we keep, and why: (a) the telephone number itself, on our suppression list, because deleting it would defeat your request; (b) the minimum call and billing metadata (date, duration, charges, business and Publisher identifiers, and the number in one-way hashed form) for 7 years, to complete the transaction, keep required financial records and defend disputes and chargebacks; (c) a recording while a dispute, chargeback, complaint, regulator inquiry or legal hold about that call is open, deleted when it closes; and (d) information needed to detect security incidents or fraud, or to comply with a legal obligation. These are the exceptions California Civil Code section 1798.105(d) allows. Information already in a business's or Publisher's hands is under their control; we forward your request, and you may also contact them directly.

12. Children

Our platform and websites are for businesses and adults. We do not knowingly collect personal information from anyone under 18, and we do not sell or share the personal information of anyone we know to be under 16 (or under 18 in Maryland and other states that set a higher age). Publishers agree not to send us calls from anyone under 18 and must not run advertising directed to children. If we learn that a caller is a minor, we delete the lead information and recording and add the number to our suppression list. Parents or guardians who believe a child's information reached us can contact us by any method in Section 20 and we will delete it.

13. Cookies and tracking on our websites

Our websites use only cookies and similar storage that are strictly necessary to operate them: a session cookie that keeps you signed in, and browser storage (not a cookie) that remembers your display theme and, for account holders, console preferences such as microphone, speaker, hold music and the transcript panel. These are not used for advertising and are not read by third parties. We do not use advertising cookies, tracking pixels, session-replay tools, third-party chat widgets or cross-site analytics, and no third party collects information about your online activities over time and across different websites through our sites. Payments are entered on our payment processor's own checkout page, which is governed by its privacy notice. Because we do not track visitors across sites, we do not change our behavior in response to "Do Not Track" browser signals, but we do honor Global Privacy Control signals as described in Section 6. If we ever add analytics or other non-essential tools, we will update this policy first and, where required, ask for your consent before they load. Our Cookie Notice, linked from the footer of our websites, has the details.

14. Buyers, Publishers and the people who work for them

If you open a Buyer account, sign a Publisher agreement, or use the platform on behalf of one, we collect: your name and business name; email address, one-time sign-in codes and, for accounts that still use one, a password (stored hashed); IP address, browser and device information; your typed and drawn signature and the record of the agreement version you accepted; your status and presence history, calls handled, dispositions and notes; wallet deposits, charges and refunds (we do not receive your full card number; payments go through our payment processor's hosted checkout); for Publishers, tax forms, payout instructions and API usage; support tickets and messages; and, for anyone who takes calls, your voice on the dual-channel recording of every call. We use this information to operate the platform, authenticate you, route and record calls, bill and pay, resolve disputes and chargebacks, prevent fraud, provide support, enforce our agreements and comply with law. We do not sell or share personal information about Buyers, Publishers or their personnel. We disclose it to the service providers in Section 15, to the Publisher or business on the other side of a call when needed to resolve a dispute, complaint or return, to payment networks in response to a chargeback, and to regulators, carriers and courts as the law requires. Your tax identification number and bank details are used only for payment and tax reporting. Your rights under Section 9 apply to this information; note that we must keep agreement, billing and tax records for the periods in Section 8 even after you close your account.

15. Who else receives personal information

• Service providers and contractors, under written contracts that limit them to providing services to us: telephony and call-recording carriers; cloud hosting and database providers; a payment processor (for Buyer deposits and Publisher payouts); a transactional email provider (sign-in codes and account notices); and, only while a business has AI assist turned on during a call, a speech-recognition provider (receives the live call audio) and a language-model provider (receives recent transcript text, the lead information for the call and campaign materials). Those two providers retain what they receive for a limited period under our agreements (currently no more than 30 days for the language-model provider) and do not use it to train models; we keep no transcript or suggestion text at all.
• Buyers: the business connected to your call receives the call, the lead information and access to the recording, as a sale described in Section 4.
• Publishers: the business that sent your call may receive call details and, to resolve a return or dispute, an excerpt of the recording, for that purpose only.
• Consent-verification services: Publishers may send us a reference to a consent record held by a third-party service; we store the reference and do not send them your information.
• Legal and safety: regulators, licensing bodies, carriers, payment networks, courts and law enforcement when required by law, subpoena or legal process, to enforce our agreements, or to protect the rights, safety or property of any person.
• Corporate transactions: a successor in a merger, acquisition, financing or sale of assets, under this policy.
• Affiliates of 2FO Holdings, LLC, for the purposes in this policy.

We do not disclose personal information to data brokers, advertisers or marketing-list compilers.

16. Security

We protect personal information with administrative, technical and physical safeguards appropriate to its sensitivity, including encryption in transit, database access restricted to our application, audit-logged staff actions, hashed sign-in codes, short-lived credentials for our telephony and AI-assist features, and written security obligations on every service provider and Buyer. No system is perfectly secure and we cannot guarantee that unauthorized access will never occur. If a security incident affects your personal information in a way that the law requires us to report, we will notify you and the relevant authorities without unreasonable delay in the manner state law requires.

17. Automated tools and AI assist

We do not use automated decision-making technology or profiling to make decisions that have legal or similarly significant effects on you, such as decisions about eligibility for, or the terms of, any product or service. Our platform routes your call using rules (the state you are calling about, which businesses are available and authorized there, and operating hours), not a profile of you. Some businesses use an optional AI assist feature that, during the call, streams the audio to our speech-recognition provider and shows the business a live transcript and suggested talking points in its browser; the suggestions are seen only by the business, are not stored by us, are not used to evaluate you, and do not create a voiceprint or other biometric identifier. The business alone decides what to say to you.

18. No discrimination

We will not deny you a service, charge you a different price, provide a different level or quality of service, or suggest that we will, because you exercised any privacy right. We do not offer financial incentives or price or service differences in exchange for personal information.

19. Data broker notice

Because we collect personal information from Publishers rather than from you directly and sell it to the businesses we connect you with, we are a "data broker" as that term is defined by the laws of California, Texas, Oregon, Vermont and, from January 1, 2027, Connecticut. NOTICE: Cloned Closer (2FO Holdings, LLC) is a data broker. We register with each of those states on the schedule its law sets and will list our registration identifiers here as they are issued. You can opt out of the sale of your personal information and ask us to delete it using any method in Section 5 or Section 9, including, once our California registration is in place, through the California Privacy Protection Agency's Delete Request and Opt-out Platform, and you may authorize an agent to do so for you. We collect the categories of personal information listed in Section 3; we do not collect precise geolocation, reproductive health data, login credentials, government identification numbers, citizenship or immigration status, union membership, sexual orientation or gender identity, or biometric data, and we do not knowingly collect information about minors. We do not sell personal information to foreign governments, to the federal government, to law enforcement, or to developers of artificial-intelligence systems.

20. How to contact us and submit requests

• Web: the "Do Not Sell or Share My Personal Information" link (opt out) and the privacy request form (all other requests), both in the footer of every page of our websites.
• Email: admin@clonedcloser.com, which is also our designated address for legal notices and for Nevada opt-out requests.
• Mail: 2FO Holdings, LLC d/b/a Cloned Closer, Attn: Privacy, 30 N Gould St Ste R, Sheridan, Wyoming 82801.

This policy is available in a printable format. If you have a disability and need this policy or a request form in another format, email us and we will provide it. If you believe we have not resolved your concern, you may contact the California Privacy Protection Agency, the California Attorney General, or the Attorney General of your state.

21. Recorded calls

Every call connected through our platform is recorded from the moment the business answers, on separate channels for you and for the business. Before your call is connected you normally hear a recorded notice; a business may run a campaign without it, in which case the business must give the notice itself as its first words, and in every case the business is required to tell you at the start of the call that the call is recorded and to end the call if you object. Cloned Closer makes the recording as the operator of the platform and keeps it for the period in Section 8. The recording can be listened to by the business you spoke with (for its own quality, compliance and dispute purposes and for serving you), by our personnel, under our internal access rules and with any change they make to an account recorded in our audit log, to resolve disputes, complaints, fraud and compliance questions, and, in excerpt, by the Publisher that sent your call to resolve a return. Recordings are not sold to anyone other than the business you spoke with, are not used for advertising, and are not used to create voiceprints. If you do not want to be recorded, hang up when you hear the notice or tell the business at the start of the call and the call will end; if you want an existing recording deleted, use Section 11, and we will delete it unless a dispute or legal hold is open. Businesses that download recordings must secure them and may keep them only as their own legal obligations require. Our Call Recording Notice, linked from the footer of our websites, repeats this in plain language.

22. Changes to this policy

We review this policy at least once every 12 months and whenever our practices or the law change. Each version carries a version identifier and a "last updated" date at the top, and prior versions are available on request. If we make a material change, we will post a notice on our websites for at least 30 days before it takes effect and, for Buyers and Publishers, send notice to the email on the account; we will not use personal information collected under a prior version for a materially different purpose without first giving notice and, where the law requires, obtaining consent.