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Privacy Policy

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Updated August 27, 2025

This Privacy Policy explains privacy practices specific to Dialwave, Inc. (collectively "Dialwave," "we," "us," "our") and provides information on how and why we collect, use, and share personal data and information acquired from our customers, website visitors, and end users of our site and services (collectively "you," "your") through our interaction with you and through our site and services. This Policy also describes your choices regarding use, access, deletion and correction of your personal data.

This Policy is subject to revision at any time, with or without notice. Dialwave may, at its sole discretion, announce significant changes to this Policy. For Dialwave Customers, this Policy is incorporated into and made a part of Customer's Agreement with Dialwave.

1. Introduction

1.1 Our Commitment to Your Privacy

At Dialwave, we are dedicated to upholding the privacy of our customers and website visitors. We acknowledge the critical importance of maintaining the privacy and security of the personal data collected from you via this website and our Services. All data entrusted to us is subject to secure storage protocols and handled with the utmost diligence, in strict adherence to all applicable legal and regulatory frameworks.

1.2 Defining Personal Data

For the purposes of this Privacy Policy, "personal data" is defined as any information that relates to, describes, or could be used to identify an individual, directly or indirectly. This specifically excludes anonymous or de-identified data, which cannot be linked to or identify a natural person.

1.3 Scope of This Privacy Policy

This Privacy Policy applies to personal data collected by Dialwave through our website, dialwave.com, our Services, and other interactions where a direct link to this notice is provided, including digital, paper, and in-person communications. It does not extend to the handling of your personal data if you are an employee, intern, consultant, contractor, or applicant of Dialwave. Furthermore, this notice does not cover information collected by third-party sites, content, or applications that may be linked to or accessible from our websites.

2. Collection of Personal Data

2.1 Categories of Personal Data Collected

Dialwave collects various categories of personal data, which include:

  • Identifiers: This encompasses your full name, address, email, company name, company website, telephone number, caller ID information, unique personal identifier, online identifier, Internet Protocol ("IP") address, and, where mandated by regulatory requirements, proof of address and ID of end users.
  • Account Payment Information: Details such as your credit/debit card details and billing address.
  • Commercial Information: Records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
  • Internet or Similar Network Activity: Information regarding your browsing and search history, interactions with our websites and advertisements, and data about communications delivered via our platform.
  • Metadata: This includes information about communications delivered via our platform, such as source and destination details, IP address, completion status, and time and duration of use.
  • Geolocation Data: When you utilize our products or services, we may collect source and destination information about the communications delivered, as well as real-time location information for emergency services facilitated through Dialwave products.
  • Cookies and Other Technologies: We utilize website cookies and similar technologies (e.g., web beacons, pixels, tags, JavaScript) to distinguish you from other visitors and compile data on website usage. Further details are provided in the "Cookies and Other Tracking Technologies" section.
  • Sensory Data: Your interactions with our sales and customer support teams may be recorded for quality assurance, training, and analysis purposes, subject to your consent if required by applicable law. When using our products or services, this may include text-to-speech/speech-to-text transcriptions, DTMF tones, and media within your voice calls and text messages.
2.2 Methods of Personal Data Collection

We employ diverse methods to collect personal data from and about you, including:

  • Direct Interactions: Data is collected when you directly provide information to us, such as by filling in forms, engaging in chat on our website, accessing or utilizing our websites, opening an account, requesting support, subscribing to newsletters, requesting information or materials (e.g., whitepapers), registering for events or webinars, visiting our booth at trade shows, participating in surveys or evaluations, submitting questions or comments, or corresponding with us via phone, email, video, or other channels.
  • Automated Technologies or Interactions: As you interact with our websites, we may automatically collect technical data regarding your equipment, Browse actions, and patterns. More information can be found in the "Cookies and Other Tracking Technologies" section.
  • Third Parties or Publicly Available Sources: We may receive information about you if you visit other websites employing our cookies, or from third parties including, for example, advertising networks, analytics providers, or through publicly available data, such as social media platforms (e.g., LinkedIn, Facebook) and other websites.
  • Indirectly: We also collect data indirectly as a service provider during the course of delivering voice and messaging communication services.
2.3 Customer Proprietary Network Information (CPNI)

Certain information pertaining to your telecommunications services account with Dialwave, such as details regarding to whom, where, and when you make calls, constitutes Customer Proprietary Network Information (CPNI). CPNI is protected by specific federal laws and regulations and as such we are fully committed to comply with such laws and regulations, both through our website and in all other respects. Without your consent, we will only share or disclose your CPNI for the following permissible purposes:

  • To market to you services or products within the categories of services or products to which you currently subscribe.
  • To initiate, render, bill, and collect for our telecommunications services.
  • To protect you or other carriers from illegal or fraudulent use of, or subscription to, our services, or to safeguard our rights or property.
  • To provide your call location information in certain specified emergency situations.
  • For other legally permissible purposes.

Telecommunications carriers, including Dialwave, are required to take reasonable measures to protect against unauthorized access to CPNI and must properly authenticate a customer before disclosing CPNI based on customer-initiated contact.

2.4 Call Recording

Dialwave operates a telephone system which is capable of recording conversations for the achievement of various proper and lawful purposes, including (i) quality monitoring; (ii) compliance; and (iii) safeguarding purposes. You understand and agree that calls, incoming or outgoing, may be subject to monitoring or recording. Under normal circumstances, a call will not be monitored or recorded unless:

  • It is necessary to investigate a complaint;
  • It provides assurance of Dialwave quality standards and policies;
  • There is a threat to the health and safety of staff and/or visitors and/or customers and/or vendors and/or for the prevention and/or detection of a crime;
  • It is necessary to check compliance with regulatory procedures;
  • It is for safeguarding purposes; or
  • It is for helping to protect employees from abusive or nuisance calls.

When possible, we will inform the caller and callee that the call will be monitored or recorded so that they have the opportunity to discontinue the call.

3. Utilization and Sharing of Personal Data

3.1 How We Utilize Your Personal Data

The personal data we collect may be used for one or more of the following purposes:

  • Service Delivery and Customer Engagement: This includes responding to inquiries about our products and services, investigating and addressing concerns, improving our responses, enabling communication via our platform for customers and end users, billing for services, informing you of new features or expanded coverage, facilitating interaction with our systems and websites, creating and securing your account, processing requests, purchases, transactions, and payments, and remitting taxes, fees, and surcharges to relevant jurisdictions.
  • Personalization and Marketing: We use data to personalize your website experience, deliver relevant content and service information, including targeted offers, marketing communications, and ads through our websites, third-party sites, and email.
  • Operational Integrity and Improvement: This involves maintaining the safety, security, and integrity of our website, services, databases, and other technology assets and business. Data is also used for testing, research, development, and analysis; mitigation of fraud and spam, unlawful or abusive activity, or violations of our Acceptable Use Policy; performing quality control; gauging routing effectiveness and deliverability; and product development, including developing and improving our websites and products and services. Specifically for MMS and SMS messaging, we employ industry-standard content-analysis software that utilizes electronic, algorithmic inspection of originating telephone numbers and/or content for spam blocking (US only).
  • Directory Services: If you have elected to publish your name, address, and telephone number in directories, we may share such information with directory publishers (e.g., white pages, yellow pages) and directory assistance providers.
  • Disclosures at Collection: We may use your data as described to you when collected.
  • Law Enforcement, Security, and Safety: Personal data may be used to respond to law enforcement requests, as required by applicable law, court order, governmental regulations, or other legal processes, particularly where we believe in good faith that disclosure protects your safety or the safety of others, or where necessary to protect a legitimate business interest such as combating fraud that harms our rights.
  • Corporate Transactions: Data may be used to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Dialwave's assets, where personal data held by Dialwave about you is among the assets transferred.

The legal basis for collecting and using personal data depends on the specific data and context of its collection, which may include performance of a contract, legitimate interest, compliance with a legal obligation, or your consent. Dialwave will not use collected personal data for materially different, unrelated, or incompatible purposes without prior notice to you. Non-personal data may be used for any business purpose. To enhance our offerings, we commonly de-identify/anonymize or aggregate your personal data so it can no longer be associated with you, in which case this information may be used indefinitely without further notice.

3.2 How We Share Your Personal Data

We may disclose your personal data to third parties for business purposes, as detailed in the "How We Utilize Your Personal Data" section. Dialwave may share your personal data in the following ways:

  • Service Providers and Affiliates: To companies that perform services on our behalf, solely as necessary for service execution, including other communications providers for routing communications over the Dialwave Network.
  • Marketing and Analytics Partners: To advertising and marketing companies and networks, and to data analytics providers.
  • Legal and Safety Compliance: To other companies and entities to respond to emergencies or exigencies; comply with court orders, laws, and other legal processes, including governmental, public, or regulatory authority requests, and to meet national security or law enforcement requirements. This also includes assisting with identity verification, preventing fraud, and identity theft.
  • Directory Assistance: With your consent, to provide directory assistance services.
  • Explicit Consent and Business Purposes: To fulfill the purpose for which you provide it, for any other purpose disclosed in writing when you provide the personal data, or with your explicit consent.
  • Corporate Reorganization: To facilitate the sale, transfer, merger, divestiture, restructuring, reorganization, or dissolution of all or a portion of our business or assets.
  • Enforcement and Protection of Rights: To enforce our customer Services Agreement, Acceptable Use Policy, and other agreements, and to protect the rights, property, or safety of our business, employees, customers, or others.

4. International Data Transfers and Privacy Frameworks

4.1 Compliance

Dialwave complies with the EU-U.S. Data Privacy Framework ("EU-U.S. DPF") and the UK Extension to the EU-U.S. DPF ("UK Extension"), and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") as set forth by the U.S. Department of Commerce. Dialwave has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles ("EU-U.S. DPF Principles") with regard to the processing of personal data received from the European Union and the United Kingdom (and Gibraltar, if applicable) in reliance on the EU-U.S. DPF and the UK Extension. Dialwave has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles ("Swiss-U.S. DPF Principles", together with the EU-U.S. DPF Principles, the "DPF Principles") with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework ("DPF") Program, and to view our certification, please visit https://www.dataprivacyframework.gov.

The Federal Trade Commission has jurisdiction over Dialwave's compliance with the EU-U.S. DPF and the UK Extension, and the Swiss-U.S. DPF.

4.2 International Data Transfer and Processing

Your personal data may be transferred and processed outside your jurisdiction and in countries that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area ("EEA"). As set forth by the U.S. Department of Commerce, Dialwave is officially certified under the EU-U.S. DPF, the UK Extension, and Swiss-U.S. DPF and relies on these certifications as its primary transfer mechanisms for transfers of personal data from the EU and Switzerland to the U.S. Where neither the EU-U.S. DPF, the UK Extension, nor the Swiss-U.S. DPF apply, and where applicable law requires us to utilize a data transfer mechanism, we rely on adequacy decisions as adopted by the applicable jurisdiction; standard contractual clauses issued by the European Commission or pursuant to established derogations for specific situations.

4.3 Third-Party Data Transfer and Processing

Dialwave may transfer personal data received from the European Economic Area or from the United Kingdom (and Gibraltar, if applicable) to third parties, such as its service providers, in reliance on the DPF. Dialwave maintains contractual agreements with these entities that explicitly restrict their access, use, and disclosure of personal data. These agreements further stipulate that such third parties must uphold a level of data protection equivalent to that mandated by the DPF Principles. Dialwave bears responsibility for ensuring these third parties adhere to these obligations. Should such personal data be processed by these parties in a manner inconsistent with the DPF Principles, Dialwave may be held liable under the Principles, unless Dialwave can demonstrate that it is not responsible for the event leading to the damages incurred.

4.4 Dispute Resolution

In compliance with the EU-U.S. DPF and the UK Extension, and the Swiss-U.S. DPF, Dialwave commits to resolving complaints about our collection or use of your personal data pursuant to the EU-U.S. DPF and the UK Extension, and the Swiss-U.S. DPF. Individuals with inquires or complaints should first contact Dialwave as set forth in the Contact Us section below.

Dialwave has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, JAMS. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit JAMS at https://www.jamsadr.com/DPF-Dispute-Resolution for more information and https://www.jamsadr.com/file-a-dpf-claim to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. Please visit https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for more information.

5. Your Privacy Choices and Control Mechanisms

5.1 Cookies and Other Tracking Technologies

Our websites employ cookies (small files placed on your device) and similar technologies (e.g., web beacons, pixels, tags, JavaScript) to differentiate you from other visitors and gather information about website usage. These technologies, which may be provided by us or authorized third parties, help us deliver a better and more personalized service and improve our websites. We may also use these technologies for behavioral tracking, collecting information about your online activities across different websites or online services over time. Both session-based and persistent cookies are utilized on our websites. Session-based cookies are temporary and disappear when you close your browser; persistent cookies remain on your device after you close your browser.

We also use web beacons on our websites and in email communications. For example, web beacons in marketing emails can notify us when you click a link that directs you to our websites. To unsubscribe from marketing emails, click the "Unsubscribe" link at the bottom of the email. Please note that you cannot opt out of transactional emails related to our products and services. We may disclose information to third parties or allow them to directly collect information using these technologies on our websites, including social media companies, advertising networks, analytics providers (for ad tracking and reporting), and security providers.

5.2 Categories of Cookies and Your Options
  • Strictly Necessary Cookies: These cookies are essential for our websites to function and cannot be disabled in our systems. Examples include session cookies for website transmission, authentication cookies, and security cookies. If you have identified yourself to us, we may place a cookie on your device to uniquely identify you when logged in and to process online transactions. Upon your first visit, a cookie consent banner may prompt you to customize preferences. For EEA users (based on IP address), only strictly necessary cookies will be served unless consent for additional categories is provided.
  • Functional Cookies: These cookies improve website function, performance, and services. They also enable us to analyze website usage to evaluate and enhance your customer experience. For example, some of our websites use Google Analytics, which employs cookies to understand visitor behavior. Learn how Google Analytics collects and processes data at: https://policies.google.com/technologies/partner-sites. Disabling functional cookies may impair certain service functionalities.
  • Targeting Cookies: These cookies, potentially set by our advertising partners through our websites, may be used to build a profile of your interests and display relevant advertisements on other sites. They do not directly store personal data but rely on uniquely identifying your browser and internet device. Examples include cookies used for remarketing or interest-based advertising.
  • Performance Cookies: These cookies allow us to count visits and traffic sources, enabling us to measure and improve our websites' performance and identify popular pages.
5.3 Managing Your Cookie Preferences

Upon your initial visit to our websites, a cookie consent banner may appear, allowing you to customize your cookie preferences. Browser settings also allow you to control cookie usage; instructions can be found in your web browser's help section or at https://allaboutcookies.org. Please note that disabling cookies may limit your use of certain website features.

5.4 Advertising Preferences

Third-party tools are available for opting out of targeted advertising. You can access mechanisms for exercising your ad setting choices by visiting https://youradchoices.com and https://youronlinechoices.eu. Please be aware that these opt-out tools are provided by third parties and are not controlled by us.

6. Data Subject Rights

6.1 Overview of Rights

You have specific rights concerning our processing of your personal data under applicable data protection laws. While these laws may contain limitations or exceptions, the general rights are outlined below. When you request to exercise any of these rights, we may provide more detailed information regarding any applicable exceptions or limitations.

  • Right to Know: You have the right to ascertain whether we process your personal data, including the categories collected, sources, purposes of collection, categories of third parties to whom we disclose data, and the specific pieces of personal data collected about you.
  • Right to Access: You are entitled to request a copy of your personal data and supplementary information.
  • Right to Correction/Rectification: You can request that we correct any inaccurate information or complete incomplete information.
  • Right to Erasure/Deletion: Under certain circumstances and subject to exceptions, you have the right to request the erasure or deletion of your personal data.
  • Right to Restriction of Processing: You have the right to restrict the processing of your personal data under specific circumstances. This may include, depending on applicable law and your jurisdiction, opting out of disclosures to unaffiliated third parties not acting as our agent or service provider, or the use of personal data for a purpose other than its original collection or authorized use.
  • Right to Data Portability: You have the right to receive personal data you have provided to us in a structured, commonly used, and machine-readable format, enabling seamless transmission to another controller. You may also request direct transmission of this data to another controller.
  • Right to Withdrawal of Consent: If our processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing based on consent prior to its withdrawal.
  • Right to Object to Processing: You have the right to object to the processing of your personal data at any time, under certain circumstances.
  • Right to Opt Out of Processing, "Sale," or Sharing for Targeted Advertising: You have the right to opt out of our processing, "sale" (as broadly defined by the California Consumer Privacy Act), or sharing of your personal data for targeted or cross-context behavioral advertising. This means opting out of advertising based on personal data inferred from your activities across different online services we do not operate. As detailed in the "Cookies" section, you can exercise this right by disabling targeting cookies. Note that opting out of targeted advertising does not prevent our ads from appearing on other websites or preclude us from basing advertising on your interactions with us and our websites.
  • Non-Retaliation: You have a right not to receive discriminatory treatment for exercising the rights described herein.
6.2 Exercising Your Rights

To exercise any of the rights outlined above or for questions regarding this Privacy Policy, please contact us at legal@dialwave.com.

6.3 Request Submission

Only you, or a legally authorized representative (including an authorized agent), may submit a verifiable consumer request concerning your personal data. Your request: (1) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative; and (2) describes your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You may only make a request for access or data portability twice within a 12-month period. Our response will explain any reasons for non-compliance, if applicable.

6.4 Information Required for Verification

We may request specific information, such as your first and last name, email address, mailing address, telephone number, or other details, to confirm your identity and ensure your right to access or exercise other rights. This security measure prevents unauthorized disclosure of personal data. We may also contact you for additional information to facilitate our response. Personal data provided for verification and fraud prevention will be used solely for that purpose and deleted as soon as practical after processing your consumer request.

6.5 Fees for Requests

There will be no fee for accessing your personal data or exercising other rights. However, we reserve the right to charge a reasonable fee for requests that are clearly unfounded, repetitive, or excessive, or refuse to comply in such circumstances.

6.6 Response Timing

We aim to respond to all legitimate requests within one month of receipt. Complex or numerous requests may extend this period, in which case we will notify you and provide updates.

7. Data Retention and Security Measures

7.1 Personal Data Retention Policy

We retain your personal data only for as long as reasonably necessary to fulfill the purposes for which it was collected, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. A longer retention period may apply in the event of a complaint or if litigation concerning our relationship with you is reasonably anticipated.

To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the processing purposes, and whether those purposes can be achieved by other means, as well as applicable legal, regulatory, tax, accounting, or other requirements. Upon expiration of applicable retention periods, your personal data will be deleted or anonymized. If technical reasons prevent complete deletion from our systems, appropriate measures will be implemented to prevent further use of such data. To enhance our products and services, we commonly aggregate your personal data (rendering it unassociated with you), allowing indefinite use of this information without further notice.

7.2 Data Security Safeguards

Dialwave employs administrative, technical, and physical measures to safeguard against the accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the personal data we process or use. However, no provider can guarantee absolute security, particularly for services reliant on the public internet or during telecommunications transmissions. You bear sole responsibility for protecting your account password(s), limiting device access, and signing out of websites after sessions. You are responsible for any activity conducted using your credentials or passwords. If you suspect compromise of your password for any of our websites or systems, you must notify us immediately at support@dialwave.com.

8. Additional Important Information

8.1 Linked Third-Party Websites

For your convenience, our websites may contain hyperlinks to other websites ("third-party sites"). We are not responsible for the privacy practices of these third-party sites or any companies we do not own or control. This Privacy Policy does not apply to third-party sites, which may collect additional information beyond what we collect. We do not endorse any third-party sites, their services or products, or any content contained therein. We strongly advise reading the Privacy Policy of each third-party site you visit to understand their data collection and protection practices.

8.2 Children's Privacy

Our websites, products, and services are not intended for children (under 13 in the United States or under 16 in the EEA), and we do not knowingly collect online personal data directly from children. If you are a parent or guardian of a minor child and believe the child has disclosed online personal data to us, please contact us at legal@dialwave.com.

8.3 Contact Us

For any questions regarding this Privacy Policy, please contact us at legal@dialwave.com.

Written correspondence can be sent to:

Dialwave, Inc.
Attn: Legal Dept.
31 West 34th Street
8th Floor
New York, NY 10001 USA

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