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Privacy Policy

Last updated: July 2026

0. Draft Notice

THIS DOCUMENT IS A DRAFT PENDING REVIEW BY LICENSED LEGAL COUNSEL. It is provided for internal review only and does not constitute legal advice. Terms may change before this policy becomes effective. Certain figures below (data-retention periods and the AI-training stance) are pending final decision and attorney confirmation.

Plain-Language Summary (not a substitute for the full Policy)

This summary is for convenience only. The full Policy below controls if there is any conflict. • Two kinds of people are involved: the trades business that subscribes (our "Customer"), and the callers that business's own customers are — whose calls Kayla answers and records. • We collect account info, payment metadata (never your raw card number — the payment processor handles that), how you use the product, and call data: recordings, transcripts, and caller phone numbers. • Recording: Kayla records calls and plays a verbal disclosure at the start of every call. Whether one-party or all-party (two-party) consent is legally required is the Customer's responsibility for their state and their callers' states — the disclosure may not by itself satisfy your state's consent law (see Section 5). • Who sees your call data: recordings, transcripts, and booking details from a call are made available to the trades business that was called and its authorized staff. If you are a Caller and want your recording accessed or deleted, that usually goes to the business you called (see Section 8); if you don't know who that was, email privacy@tradescallpro.com and we will route your request. • We do not sell your data and do not share it for cross-context behavioral advertising. We do not send your data to providers hosted in China. • AI training: [OWNER DECISION — DEFAULT: we do NOT use identifiable call recordings or transcripts to train general-purpose or third-party AI models. See Section 4.] • You can access, correct, delete, and export your data and exercise CCPA/CPRA and GDPR rights where they apply to you; which rights you have depends on where you live and whether you are a Customer or a Caller (Section 8). • We keep call recordings and other data only as long as needed and delete them after a roughly 90-day window following your account's termination (subject to legal requirements and routine backup cycles); the exact periods are being finalized (Section 7).

1. Who We Are and Scope

This Privacy Policy explains how TradesCallPro LLC ("TradesCallPro," "we," "us," or "our") collects, uses, discloses, and protects personal information in connection with our software-as-a-service AI voice receptionist ("Kayla") and CRM platform for trades businesses (the "Service"). It is a companion to our Terms of Service, and defined terms used here have the meaning given in the Terms unless stated otherwise. Two-sided data model. Our direct customer is the trades business that subscribes to the Service (the "Customer"). When Kayla answers a Customer's inbound calls, the people calling are the Customer's own end-customers ("Callers"). For most personal information about Callers, the Customer determines the purposes and means of processing and is the controller/business, and TradesCallPro acts as the Customer's service provider/processor, processing that information on the Customer's behalf and under our agreement with the Customer. For the Customer's own account and billing information, TradesCallPro is the controller/business. This Policy describes both roles. Where TradesCallPro acts as a service provider/processor for Caller data, a Caller's rights requests are generally directed to, and handled by, the Customer; we assist the Customer as required by law. Kayla identifies the business being called at the start of each call. If a Caller submits a rights request directly to TradesCallPro, we will, where the relevant Customer can be identified, forward the request to that Customer for handling and let the Caller know we have done so.

2. Categories of Personal Information We Collect

We collect the following categories of personal information: Identifiers: name, phone number, email address, business name, billing address, and account credentials. Commercial information: subscription plan, billing history, payment method metadata (payments are processed by our third-party payment processor — we do not store full card numbers or bank-account details), minute balance, and transaction records. Professional and employment-related information: trade type, business address, worker names and phone numbers, worker roles and skills. Audio and voice data (highest sensitivity): inbound and outbound call recordings processed through Kayla, together with transcripts derived from them and Caller phone numbers. A verbal disclosure is provided at the start of every Kayla-handled call. Recordings and transcripts may contain whatever a Caller chooses to say, which can include sensitive personal information; Customers and Callers should avoid stating information that is not needed to handle the call. Geolocation data: location of a Customer's field workers, captured at discrete clock-in/out events and during active jobs (not continuous tracking). [ATTORNEY/ENGINEERING TO CONFIRM the actual precision — device GPS (precise) vs. network/cell-derived (approximate) — the wording here must match reality because precise geolocation is "sensitive personal information" under the CPRA (see Section 8), and the "right to limit" language must be strengthened accordingly if it is precise.] Internet or other electronic network activity: log files, device identifiers, browser type, IP address, and usage events collected to operate and secure the Service. In our primary application databases, IP addresses are stored only as a SHA-256 hash rather than in raw form; an IP address may appear transiently in raw form in security, network, or infrastructure logs used for operational and security purposes. Inferences: job-completion rates, call-handling quality scores, and service preferences derived from the above, used to operate and improve the Service.

3. Sources of Personal Information

We collect personal information from the following sources: • Directly from the Customer, when you sign up, configure your account, add workers, or use the platform. • Automatically, through use of the Service (log data, device identifiers, call events). • From Callers, when Kayla handles inbound calls and captures the information a Caller provides to book a job or leave a message — collected on the Customer's behalf. • From third-party integrations the Customer authorizes, such as QuickBooks Online (accounting sync).

4. How We Use Personal Information (including AI and call data)

We use the personal information we collect to: • Deliver the Service — answering and routing calls, transcribing calls, booking jobs, dispatching workers, and sending notifications. • Operate emergency dispatch and on-call alerts. (Kayla is not a 911 or emergency-response service — see the Terms.) • Process payments through our payment processor and maintain billing records. • Send operational SMS and email notifications about jobs, bookings, and account activity. • Secure, maintain, debug, and improve the Service, including quality assurance and reliability. • Comply with legal and regulatory obligations, and detect, investigate, and prevent fraud or unauthorized use. How call data is processed by AI. To answer and handle a call, call audio and transcripts are processed in real time by third-party AI, speech-to-text, and text-to-speech providers acting as our subprocessors, strictly to deliver the Service for the Customer on whose line the call arrived. This real-time processing to operate the Service is different from using call data to train AI models, which is addressed next. Quality assurance and troubleshooting. To keep the Service working correctly, authorized TradesCallPro personnel and automated systems may review call recordings, transcripts, and logs for debugging, quality assurance, safety, and fraud prevention, under access controls and confidentiality obligations. Such review is limited to operating, securing, and improving the Service and is not model training. [ATTORNEY TO CONFIRM the human-review disclosure is adequate and consistent with the no-training stance.] AI model training [OWNER DECISION — attorney to confirm]. DEFAULT STANCE, pending your final decision: TradesCallPro does NOT use identifiable Customer or Caller call recordings or transcripts to train, fine-tune, or develop general-purpose or third-party AI/ML models, and does not permit its subprocessors to use Customer or Caller data to train their own models. Any use of de-identified or aggregated data that does not identify the Customer, any worker, or any Caller — solely to measure and improve the reliability, accuracy, and safety of the Service — is limited to that purpose. [If you decide to use call data for model training or product-model improvement, this Section MUST be rewritten to say so plainly, the consent/opt-out mechanics must be built, and biometric-voice law (e.g., Illinois BIPA) must be assessed first — see the open-questions doc.] We do not sell your personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA.

5. Call Recording, Consent, and Legal Basis

Kayla records calls for service delivery, quality assurance, and transcription. A verbal recording disclosure is delivered at the start of every Kayla-handled call. Consent is the Customer's responsibility. Under U.S. federal law, one-party consent is generally sufficient for call recording, but many states require all-party (two-party) consent, and the applicable rule can depend on where the Caller is located. AS THE BUSINESS OPERATOR, THE CUSTOMER IS RESPONSIBLE for determining and satisfying the call-recording-consent requirements applicable to the Customer and to the Customer's Callers, as described in the Terms of Service. TradesCallPro provides the verbal disclosure on every call as a standard feature; TradesCallPro does not represent that the disclosure alone satisfies the requirements applicable to any particular Customer or Caller, and Customers should consult their own counsel. Legal bases (GDPR/UK GDPR, where applicable). Where the GDPR or UK GDPR applies to processing for which TradesCallPro is a controller, we rely on: performance of a contract (to provide the Service to the Customer); our legitimate interests (to secure, maintain, and improve the Service and prevent fraud), balanced against individuals' rights; and compliance with legal obligations. Where TradesCallPro processes personal information as a processor on the Customer's behalf, the Customer is responsible for establishing the lawful basis (including any consent) for that processing. [ATTORNEY TO CONFIRM the lawful-basis mapping and whether any processing requires consent rather than legitimate interest.]

6. How We Share Information — Subprocessors and Disclosures

We disclose personal information to the categories of service providers ("subprocessors") below, who process it on our behalf, under written terms, and only as needed to provide the Service to us. The current, canonical subprocessor list is maintained here and referenced by our Terms of Service; it may be updated as providers change. • Cloud infrastructure and database hosting — all data categories, as our primary infrastructure providers. • Telephony and AI voice infrastructure — call audio, transcripts, and Caller phone numbers, to answer and handle calls. • AI model, speech-to-text, and text-to-speech providers — call audio and transcript text, to process calls in real time. • Object storage — call recordings, job photos, and generated documents. • Payment processing — commercial information and payment-method metadata (the processor, not TradesCallPro, handles full card/bank details). • SMS and transactional email — phone numbers, email addresses, and message content for operational notifications. • Mapping/routing — approximate worker location for distance and routing calculations. • Accounting sync (only when enabled by the Customer) — customer names, contact information, and invoice data. • Product analytics and error monitoring — usage events and error context; we configure these tools to minimize or filter direct identifiers before transmission. [ENGINEERING TO VERIFY the identifier-scrub covers all named fields before launch.] Access by the Customer. Call recordings, transcripts, Caller contact details, bookings, and messages generated on a Customer's line are made available to that Customer and its authorized account users and workers, so the Customer can run its business. This is a core function of the Service, not a disclosure to an unrelated third party. No China-hosted providers. TradesCallPro does not send Customer or Caller personal information to subprocessors that store or process that data in the People's Republic of China. [ATTORNEY/ENGINEERING TO VERIFY this holds across the full subprocessor chain, including any sub-subprocessors.] Other disclosures. We may disclose personal information to comply with law, respond to lawful requests and legal process, enforce our agreements, protect the rights, safety, and security of TradesCallPro, our Customers, and others, and in connection with a merger, acquisition, financing, or sale of assets (subject to this Policy). We do not sell personal information and do not share it for cross-context behavioral advertising.

7. Data Retention and Deletion

We keep personal information only as long as needed for the purposes described in this Policy, to provide the Service, and to meet legal, tax, accounting, and dispute-resolution requirements, after which it is deleted or de-identified. Call recordings, transcripts, and CRM records are "Customer Data" as defined in the Terms of Service, and the retention and deletion in this Section are intended to match the Customer Data provisions of the Terms — one consistent clock governs both documents. The following retention periods are PROPOSED DEFAULTS pending your final decision and attorney confirmation [OWNER DECISION — see the open-questions doc]: • Account, CRM, and job data: retained while your account is active and for 90 days after termination, to allow export, after which it is deleted (subject to legal-hold and backup-overwrite caveats below). [Confirm 90 days.] • Call recordings and transcripts: retained while your account is active and for about 90 days after termination to allow export, after which they are deleted (subject to the backup-overwrite and legal-hold caveats below). This matches the account-data window and the Terms of Service. [ATTORNEY TO CONFIRM 90 days is the right retention for voice recordings given breach and biometric-privacy exposure — a shorter period may be advisable.] • Worker GPS location pings: 90 days rolling. [Confirm.] • Payment and billing records: retained as required by applicable financial and tax law. • Analytics and error-monitoring data: retained on a de-identified basis per each provider's standard retention. Deletion on account termination. After your account terminates, Customer Data is deleted in accordance with the Terms of Service and this Policy once the export window ends, except for (a) copies in routine backups, which are overwritten on our normal backup cycle and in any event no later than [OWNER/ENGINEERING TO SET — e.g., 35 days] after the primary deletion, and (b) information we are required by law to retain. You may request earlier deletion by contacting privacy@tradescallpro.com, subject to those exceptions.

8. Your Privacy Rights

Depending on your location and your role (Customer or Caller), you may have the following rights. Because TradesCallPro often processes Caller data as a service provider/processor on the Customer's behalf, a Caller who wants to exercise rights over data captured on a call should generally contact the trades business they called; TradesCallPro will assist that business as required by law. California residents (CCPA / CPRA): • Right to Know / Access — the categories and specific pieces of personal information we collected, the purposes, and the categories of recipients. • Right to Delete — deletion of your personal information, subject to legal exceptions. • Right to Correct — correction of inaccurate personal information. • Right to Opt Out of Sale or Sharing — we do not sell personal information and do not share it for cross-context behavioral advertising, so there is nothing to opt out of; we honor opt-out preference signals where required. • Right to Limit Use of Sensitive Personal Information — to the extent we process sensitive personal information (such as precise geolocation or the contents of communications), you may request that we limit its use to purposes permitted under the CPRA. • Right to Non-Discrimination — we will not discriminate against you for exercising your rights. EU/EEA and UK residents (GDPR / UK GDPR): • Rights of access, rectification, erasure, restriction of processing, data portability, and objection, and the right to lodge a complaint with a supervisory authority. Where processing is based on consent, the right to withdraw consent. How to exercise. Contact privacy@tradescallpro.com. We will acknowledge and respond within the timeframe required by applicable law — generally within 45 days for CCPA/CPRA requests (extendable by a further 45 days with notice) and within one month for GDPR/UK GDPR requests (extendable by two further months for complex requests, with notice). We may need to verify your identity before acting on a request. [ATTORNEY TO CONFIRM the response timelines and verification standard match current statutory requirements.]

9. Security and Breach Notification

We maintain commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, or disclosure, including encryption of sensitive data in transit and, for the data stores we control, at rest, together with access controls and audit logging. No method of transmission or storage is perfectly secure, and we do not warrant that the Service will be free from unauthorized access. If we become aware of a breach of security leading to the unauthorized access, disclosure, loss, or destruction of your personal information, we will notify affected Customers without undue delay and, where feasible, within seventy-two (72) hours of becoming aware, consistent with our Terms of Service, and will provide information reasonably available to us about the incident. This contractual timeline does not waive or replace any shorter or different statutory notification deadline that applies to either party. Where TradesCallPro acts as a processor — including for Caller personal information — we will notify and assist the affected Customer on a timeline intended to enable the Customer to meet its own breach-notification obligations to Callers and regulators.

10. International Data Transfers

TradesCallPro is based in the United States, and personal information we process is stored and processed in the United States and in other countries where our subprocessors operate — but not, as stated in Section 6, in the People's Republic of China. Where personal information is transferred out of the EEA, the UK, or another region with transfer restrictions, we rely on an appropriate transfer mechanism (such as the European Commission's Standard Contractual Clauses and, where applicable, the UK Addendum) or another lawful basis. [ATTORNEY TO CONFIRM the transfer mechanism(s) and whether a transfer impact assessment is required for the Customer base.]

11. Cookies

We use essential cookies and browser storage for authentication and session management (for example, session tokens and a secure httpOnly refresh cookie). We use limited first-party product analytics to understand and improve how the Service is used. We do not use third-party advertising or cross-context behavioral-tracking cookies. [ENGINEERING/ATTORNEY TO CONFIRM whether the analytics tool sets any non-essential cookie or storage before consent, and whether a consent mechanism is required for the Customer/Caller footprint.]

12. SMS / Text Messaging

TradesCallPro sends operational (transactional) SMS messages to account owners and workers — including account and onboarding alerts, job booking and schedule changes, worker clock-in/out alerts, payment and receipt notifications, emergency dispatch alerts, and billing notices. We do not send marketing or promotional text messages. Where the Service sends SMS to a Customer's Callers on the Customer's behalf (for example, booking confirmations), the Customer is responsible for obtaining any legally required consent from the Caller, as described in the Terms of Service. Message frequency varies by account activity. Message and data rates may apply. For operational messages TradesCallPro sends to account owners and workers, you may opt out at any time by replying STOP to any message; reply HELP for help. After opting out, SMS delivery stops for that number, and critical alerts (such as emergency dispatch) are then delivered only via the dashboard and email. Opt-out handling for messages a Customer directs the Service to send to the Customer's own Callers is the Customer's responsibility as the sender. Mobile opt-in data and consent are never sold or shared with third parties for their own marketing. See our TCPA page for further detail.

13. Children's Privacy

The Service is intended for businesses and is not directed to children under the age of 18, and we do not knowingly collect personal information from children. Because Kayla answers inbound calls, a Caller could in principle be a minor; we do not knowingly retain personal information we learn to be that of a child, and a Customer or parent who believes a child's information has been collected should contact privacy@tradescallpro.com so it can be deleted. [ATTORNEY TO CONFIRM whether any child-specific obligations (e.g., COPPA) are implicated by inbound-call handling.]

14. Changes to This Policy

We will notify Customers of material changes to this Privacy Policy by email or in-product notice at least 30 days before they take effect, consistent with our Terms of Service. Non-material changes (such as clarifications or corrections, or routine updates to the subprocessor list in Section 6) may be made without advance notice. Continued use of the Service after the effective date constitutes acceptance of the updated Policy.

15. Contact

For privacy-related questions, requests, or to exercise your rights: TradesCallPro LLC Port Orchard, Washington, USA Email: privacy@tradescallpro.com