PHONE CLOVER - PRIVACY POLICY

Last updated: October 16, 2026

TABLE OF CONTENTS

1. Who We Are and What This Policy Covers
2. Our Two Roles
3. Information We Collect
4. How We Use Information
5. How We Share Information
6. We Do Not Sell or Share Personal Information
7. Call Recordings and AI Notes
8. Cookies and Analytics
9. Text Messages and Email
10. Sensitive Information
11. Data Retention
12. Data Security
13. Your Privacy Rights
14. How to Make a Request
15. Children
16. Changes to This Policy
17. Contact Us

1. WHO WE ARE AND WHAT THIS POLICY COVERS

Phone Clover ("we," "us," "our"), provides an app that adds calling, texting, number management and AI call notes to HighLevel, running on our customers' own Telnyx accounts.

This Policy explains how we collect, use, disclose and protect personal information when you visit phoneclover.com (the "Site"), request early access, install or use the Phone Clover app (the "App"), or contact us. It also covers information about our customers' personnel who use the App. It does not cover our own employees or job applicants.

This Policy is a notice. It does not give anyone's consent to recording or marketing, and it does not expand the limits in our Terms of Service and customer data-processing terms.

We operate from California. Our service providers may process information in other locations, including outside the United States, under the safeguards described in this Policy.

2. OUR TWO ROLES

Our own activities. For the Site, early-access requests, customer accounts, billing, support and security, we decide how personal information is used, and this Policy describes our practices directly.

Processing for our customers. If you called, texted, or were called or texted by a business that uses Phone Clover (a "Contact"), that business decides why your communications and records are processed. We process them only on that business's behalf and instructions, as its service provider. We do not use them for our own advertising, profiling or AI training, and we do not sell or share them.

Please send requests about a business's records to that business. If you contact us instead, we will help identify the business and forward your request within 10 business days.

3. INFORMATION WE COLLECT

These categories describe what we have collected in the past 12 months and collect today. Not every category is about every person.

Under California law, these are the categories of identifiers; customer records information; commercial information; internet or network activity; general geolocation; audio and electronic information; professional information; and sensitive personal information where present (Section 10).

After a business-texting registration is submitted, we keep only the last four digits of the EIN.

Payment information is handled by HighLevel. We do not receive or store payment card numbers.

We do not collect precise geolocation, and we do not create voiceprints or use voice biometrics to identify anyone. We do not buy or rent contact lists.

4. HOW WE USE INFORMATION

We use personal information to:

• provide, configure, operate and support the App, including placing and receiving calls and texts, routing calls, logging activity to HighLevel and showing dashboards;
• connect to and configure your Telnyx account, and submit registrations, number purchases and texting requests you initiate;
• apply the compliance controls you use, such as do-not-disturb checks, opt-out handling, quiet hours and spam screening;
• produce AI Notes when you enable them;
• respond to early-access and support requests, and send you account, setup, security and legal notices;
• send product updates by email to customers, and to early-access applicants who agree to receive them, with an unsubscribe link in every message;
• secure the App, prevent fraud and abuse, and fix errors;
• measure Site usage in aggregate;
• comply with law, enforce our Terms of Service, and establish or defend legal claims; and
• evaluate or complete a merger, acquisition, financing or sale of assets.

Information we process for customers is used only to provide the App to that customer. Communications content is never sent to website analytics.

5. HOW WE SHARE INFORMATION

We disclose personal information only as needed for the purposes in Section 4, to:

• the customer's authorized users, according to their roles in the App;
• HighLevel, which receives the call logs, notes, transcripts, summaries, tags, tasks and Contact information the App writes to the customer's account, and handles subscription billing;
• Telnyx and carriers, which carry calls and texts on the customer's Telnyx account and receive the registration and number requests the customer submits;
• messaging registries, such as The Campaign Registry, which receive business-texting registrations the customer submits;
• our service providers (below), under written contracts that limit their use of the information to serving us;
• professional advisors, such as lawyers, accountants and insurers;
• authorities, when required by law or legal process, or to protect the rights, safety or property of any person; and
• parties to a business transaction, such as a merger or sale of assets, subject to confidentiality and this Policy.

Our service providers (subprocessors):

HighLevel and Telnyx are contracted directly by our customers, and their own privacy policies apply to information in those accounts.

6. WE DO NOT SELL OR SHARE PERSONAL INFORMATION

We do not sell personal information, we do not share it for cross-context behavioral (targeted) advertising, and we have not done so in the past 12 months. We do not disclose personal information to third parties for their own marketing. We do not knowingly sell or share the information of anyone under 16. If this ever changes, we will update this Policy and offer an opt-out before it takes effect.

7. CALL RECORDINGS AND AI NOTES

7.1 Recording is controlled by the customer. Recording is off unless a customer turns it on. Customers can enable a spoken recording announcement and are responsible for giving notice and obtaining every consent the law requires before a call is recorded. If you are a Contact and do not want to be recorded, ask the business for an unrecorded call or hang up when you hear the announcement.

7.2 Storage and access. Recordings are captured through the customer’s Telnyx account and kept in our encrypted storage. Within the App, representatives can access recordings of their own calls, and administrators can access recordings for their subaccount. Playback links generated by the App dashboard expire one hour after generation; recording links provided to HighLevel expire seven days after generation. Anyone possessing a valid playback link can access the recording without a separate login until the link expires or the recording is deleted. Customers are responsible for sharing links only with authorized recipients and for controlling access to copies they download or export.

7.3 AI Notes. When a customer enables AI Notes, eligible recorded calls are processed after the call ends by Cloudflare Workers AI, which runs open-source models on our behalf: OpenAI's Whisper for transcription and Meta's Llama for summaries. OpenAI and Meta do not receive the audio or text. The transcript and summary are written to the Contact's record in the customer's HighLevel account. AI output can be inaccurate and should be reviewed by a person.

7.4 No AI training. We do not use recordings, transcripts, messages or any customer or Contact data to train AI models, and we do not permit Cloudflare to use them to train or improve any model or service. Cloudflare's terms for Workers AI state that it does not use this content for those purposes.

7.5 No automated decisions. AI Notes documents calls. It does not make decisions about anyone's credit, housing, employment, education, insurance or healthcare. Our personnel access recordings or transcripts only to provide support you request, fix errors, prevent abuse or comply with law.

8. COOKIES AND ANALYTICS

8.1 What we use. Cookies are small files stored on your device. We also use similar technologies such as scripts and local storage.

We do not use advertising or retargeting cookies. Analytics is not used inside the App or on call or message data.

8.2 Google Analytics. We use Google Analytics with advertising features and Google Signals turned off, and Google may not use this data for advertising. Learn how Google uses data at policies.google.com/technologies/partner-sites, or opt out with Google's browser add-on at tools.google.com/dlpage/gaoptout.

8.3 Your choices. Accept or reject analytics cookies in our cookie banner, and change your choice anytime using the Cookie Settings link in our footer. You can also block or delete cookies in your browser. We treat a Global Privacy Control signal as a request to turn off analytics and to opt out of any sale or sharing. We do not respond to "Do Not Track" signals, as there is no common standard for them.

9. TEXT MESSAGES AND EMAIL

9.1 Messages customers send. Customers send and receive texts through their own Telnyx numbers using the App, and each customer is responsible for consent and for the content of its messages. The App records opt-out replies such as STOP so the customer can honor them. If you received a text from a business using Phone Clover, reply STOP to that business or contact it directly.

9.2 Mobile information is never shared for marketing. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties, excluding the customer that collected them and the aggregators and providers of the text messaging services.

9.3 Our emails. We email customers and early-access applicants about requests, setup, accounts, security and our terms. Product-update emails include an unsubscribe link and our mailing address. Unsubscribing does not stop account and service emails.

10. SENSITIVE INFORMATION

We collect sensitive information only where needed to provide the App:

• Credentials. Telnyx API keys and HighLevel tokens are stored encrypted and are never displayed in full.
• Registration documents. EINs and the identity or address documents some countries require for a number are used only for that registration or purchase.
• Communications content. Calls and texts are live conversations, and a Contact may volunteer sensitive information. We use it only to provide the App to the business concerned, for security, or as required by law.

We do not use sensitive information to infer characteristics about anyone or for advertising. The App may not be used for protected health information under HIPAA, and we do not sign business associate agreements. Please do not send sensitive information in support messages.

11. DATA RETENTION

We keep personal information only as long as reasonably necessary for the purposes in this Policy:

A customer may ask us to delete its data sooner. We may keep information longer only where the law requires it or to resolve a dispute. Copies in a customer's HighLevel or Telnyx account, or exported by the customer, are controlled by the customer and those providers.

12. DATA SECURITY

We use reasonable administrative, technical and physical safeguards, including encryption in transit and at rest, encrypted storage of credentials, sign-in through HighLevel instead of separate passwords, role-based access and expiring recording links. No system is completely secure.

If a breach affects personal information we hold for a customer, we will notify that customer immediately following discovery. If a breach requires us to notify you directly, we will do so as the law requires, and for California residents within 30 days of discovery.

13. YOUR PRIVACY RIGHTS

Depending on where you live, you may have the right to:

• know and access the personal information we have collected about you, its sources, the purposes for using it, and the categories of recipients;
• delete your personal information, subject to legal exceptions (for example, records we must keep for tax purposes or to honor an opt-out);
• correct inaccurate personal information;
• receive a copy of your information in a portable format;
• opt out of sale, sharing, targeted advertising, profiling or automated decision-making (we do none of these);
• limit the use of sensitive personal information (we use it only as described in Section 10);
• appeal our decision on your request; and
• not be discriminated against for exercising any of these rights.

We offer these rights to all U.S. residents, including customer personnel. California residents may also request information about disclosures to third parties for their direct marketing (California "Shine the Light" law); we make no such disclosures.

14. HOW TO MAKE A REQUEST

Email support@phoneclover.com with the subject line "Privacy Request," and include enough information to identify the account or communication. Do not send passwords, API keys or identity documents by email.

Timing. We confirm receipt within 10 business days and respond within 45 days. If we need up to 45 more days, we will tell you why before the first deadline. Opt-out requests are handled within 15 business days.

Verification and agents. We verify your identity by matching information you provide to our records. Opt-out requests do not require verification. You may use an authorized agent, who must provide your signed permission; we may still confirm directly with you.

Fees. Requests are free unless they are manifestly unfounded or excessive.

Appeals. To appeal a decision, reply to it or email us with the subject line "Privacy Appeal" within 60 days. We will respond within 45 days. If we deny your appeal, you may contact your state attorney general.

Contacts. Requests about a business's records should go to that business first, as explained in Section 2.

15. CHILDREN

The Site and App are for businesses and are not directed to children under 16. We do not knowingly collect personal information from children under 13. If you believe a child has provided us personal information, contact us and we will delete it.

16. CHANGES TO THIS POLICY

We review this Policy at least once a year and update it when our practices change. We will post the new version with a new "Last updated" date and, for material changes, notify customers by email at least 30 days before they take effect. We will not use previously collected information for a materially different purpose without any notice or consent the law requires. Prior versions are available on request.

17. CONTACT US

Phone Clover, 30 N Gould St STE R, Sheridan, WY 82801

Email: support@phoneclover.com

If you have a disability and need this Policy in another format, contact us and we will provide it.