This Privacy Policy describes how Ultatel, LLC (“Ultatel,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards Personal Information when you visit our Website at www.ultatel.com or any related sites, mobile applications, sales pages, or marketing portals (collectively, the “Website”), or when you interact with us in connection with sales, marketing, support, or your account.

Ultatel’s services are designed for U.S.-based businesses. Customer Data processed through our services is stored and processed in the United States.

1. Important: Customer Data vs. Personal Information

This Privacy Policy applies to Personal Information we collect from website visitors, prospects, free-trial users, and individuals interacting with Ultatel directly. It does not govern “Customer Data,” which is information transmitted, stored, or processed by Ultatel’s business customers through our voice, video, messaging, contact center, and related services (the “Services”).

Customer Data is processed by Ultatel as a service provider on behalf of the customer, pursuant to the customer’s service agreement with Ultatel (the Master Services Agreement (“MSA”) or the Service Agreement, as applicable) and the Data Processing Agreement (“DPA”). If you are an end user (employee, customer, or contact) of an Ultatel business customer and have questions about how your information is processed through the Services, please direct your inquiry to that business.

2. Information We Collect

We collect the following categories of Personal Information from website visitors, prospects, and account-holders:

2.1 Information you provide

• Contact information: name, business email, business phone, business address.
• Account information: username, account ID, password, role/title, language and communication preferences.
• Billing information: billing name and address, payment card details (processed by our payment processor; see Section 7), tax identification numbers where applicable.
• Commercial information: products and services purchased, evaluated, or expressed interest in; service usage and subscription details.
• Voluntary submissions: form submissions, sales chat conversations, support tickets, survey responses, event registrations, and content you submit through marketing or support channels.

2.2 Information collected automatically

• Device and technical information: IP address, device type, operating system, browser type and version, language, time zone, unique device identifiers.
• Website usage information: pages viewed, links clicked, time spent, referring URL, exit URL, search terms used to reach the Website.
• Cookies and similar technologies: as described in Section 9.
• General geolocation: derived from IP address; we do not collect precise geolocation unless you affirmatively enable it (e.g., for location-based services).

2.3 Information from third parties

• Marketing and analytics partners: information about your interactions with our advertisements, content, and sales outreach.
• Business data providers: enrichment of contact and firmographic information for B2B marketing, where permitted by law.
• Authentication providers: if you sign in using a third-party identity service, the information that service shares (typically a verified email address).
• Referrals: contact information you submit when you refer a colleague or our partners refer you to us.

3. Categories Under California Law

Under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), the following table summarizes the categories of Personal Information we collect about California residents:

We do not sell Personal Information for monetary consideration. We do not knowingly use or disclose sensitive Personal Information beyond the purposes permitted by Cal. Civ. Code § 1798.121.

4. How We Use Personal Information

We use Personal Information for the following purposes:

• To provide, operate, and improve the Website and the Services;
• To respond to inquiries, schedule demos, and provide customer support;
• To process registrations, signups, and payments;
• To send marketing communications about Ultatel’s products and services, where permitted by law and subject to your right to opt out;
• To personalize the Website and your experience;
• To analyze Website performance and conduct market research;
• To detect, prevent, and respond to fraud, abuse, security incidents, and other harmful or unlawful activity;
• To comply with legal obligations and respond to legal process; and
• To enforce our agreements and protect the rights, property, and safety of Ultatel, our customers, and others.

5. How We Share Personal Information

We share Personal Information only as described in this Section.

5.1 Service providers

We share Personal Information with vendors and contractors that perform services on our behalf, including hosting, analytics, marketing automation, payment processing, customer support, and security operations. These service providers are bound by contractual obligations to protect Personal Information and to use it only for the purposes for which we engage them.

5.2 Marketing analytics partners

We use marketing analytics and advertising tools provided by third parties such as Google, Microsoft, LinkedIn, Facebook (Meta), HubSpot, and similar platforms. These tools may set cookies or similar technologies on your device that enable us to measure the effectiveness of our marketing and to deliver advertising about our products on third-party sites. See Section 9 for cookie controls.

5.3 Business transfers

If Ultatel is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of its business or assets, Personal Information may be transferred as part of that transaction, subject to standard confidentiality obligations and applicable law.

5.4 Compliance and legal

We may disclose Personal Information to comply with applicable law, regulation, legal process, or governmental request; to enforce our agreements and policies; to detect, prevent, or address fraud, security, or technical issues; or to protect the rights, property, or safety of Ultatel, our customers, or others.

5.5 With your direction or consent

We share Personal Information with third parties as you direct (for example, when you request a quote that you ask us to share with a partner) or where you have given consent.

5.6 Sub-processors

A list of sub-processors that we use to deliver the Services is maintained at www.ultatel.com/subprocessors. The list is updated as our sub-processor relationships change.

6. Data Retention

We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected, including for legitimate business needs and to comply with legal obligations. The following table provides general retention periods; specific periods may vary based on legal, regulatory, or contractual requirements.

When Personal Information is no longer needed, we delete or de-identify it in accordance with our data retention schedule, except where retention is required by law or to defend legal claims.

7. Data Storage and Security

Personal Information and Customer Data are stored and processed in the United States. We do not transfer Customer Data outside of the United States without the customer’s prior written consent.

We maintain administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, alteration, disclosure, or destruction, consistent with industry-standard security frameworks. These safeguards include access controls, encryption in transit and at rest where appropriate, network security controls, monitoring, and regular security testing. The minimum security measures applicable to Customer Data are described in Annex 2 of the DPA.

Despite these measures, no system is completely secure. We cannot guarantee the absolute security of Personal Information. If you have reason to believe your interaction with us is no longer secure, contact us promptly at security@ultatel.com.

8. International Visitors

Ultatel’s services are intended for businesses located in the United States. Our Website is operated from the United States, and any information you provide will be transferred to and processed in the United States. The data protection laws of the United States may differ from those of your country of residence. By using the Website, you consent to the transfer of your Personal Information to the United States and to its processing in accordance with this Privacy Policy.

9. Cookies and Similar Technologies

We use cookies and similar technologies (such as pixels, web beacons, and SDKs) on the Website to operate the Website, remember your preferences, analyze usage, and support marketing. Cookie types we use include:

• Strictly necessary cookies, required for core Website functionality (cannot be disabled).
• Functional cookies, used to remember your preferences and choices.
• Analytics cookies, used to understand how visitors interact with the Website.
• Marketing cookies, used by us and our partners to deliver and measure advertising.

You can manage cookie preferences through the cookie preference center accessible from the Website footer or through your browser settings. Disabling certain cookies may affect Website functionality. We respond to recognized opt-out signals, including the Global Privacy Control (GPC), where required by applicable law.

10. Your Privacy Rights

10.1 Rights for California residents (CCPA / CPRA)

California residents have the following rights with respect to their Personal Information:

• Right to know: request that we disclose the categories and specific pieces of Personal Information we have collected, the categories of sources, the business or commercial purpose, and the categories of third parties with whom we share Personal Information.
• Right to delete: request that we delete Personal Information we have collected, subject to exceptions.
• Right to correct: request correction of inaccurate Personal Information.
• Right to limit use of sensitive Personal Information.
• Right to opt out of sale or sharing: we do not sell Personal Information for monetary consideration. To the extent any of our advertising activity is considered “sharing” under the CCPA, you may opt out using the “Do Not Sell or Share My Personal Information” link on the Website footer or by submitting GPC.
• Right to non-discrimination: we will not discriminate against you for exercising any of these rights.

10.2 Rights for residents of Virginia, Colorado, Connecticut, Utah, Texas, and other U.S. states

Residents of states with comprehensive consumer privacy laws have similar rights, including the right to access, delete, correct, and (where applicable) opt out of targeted advertising or profiling. We honor these rights consistent with applicable law.

10.3 How to exercise rights

To exercise any of the foregoing rights, please submit a request at www.ultatel.com/privacy-request or contact privacy@ultatel.com. We will verify your identity before responding. We may decline a request if it is not verifiable, is excessive, or falls within an exception under applicable law. You may designate an authorized agent to make a request on your behalf.

If you are an end user of an Ultatel business customer and your request relates to information processed through the Services, please direct your request to that business; we will refer such requests to the applicable customer.

10.4 Appeal of denied requests

If we decline a privacy request, you may appeal that decision by replying to our denial response or by emailing privacy@ultatel.com with the subject line “Privacy Request Appeal.” We will respond to appeals within the time period required by applicable law (typically forty-five (45) to sixty (60) days).

11. Marketing Communications

You may opt out of marketing communications by clicking the unsubscribe link in any marketing email, by adjusting your communication preferences in your account, or by contacting privacy@ultatel.com. Opting out of marketing does not affect transactional or service-related communications, which are necessary to provide the Services.

SMS / mobile communications: by providing a mobile number and opting in to receive text messages from Ultatel, you agree that message and data rates may apply, and message frequency varies. Reply HELP for help, STOP to cancel. We do not share mobile information or SMS opt-in data with third parties or affiliates for marketing purposes.

12. Children’s Privacy

The Website and Services are intended for businesses and adult users. We do not knowingly collect Personal Information from children under thirteen (13) years of age in violation of the Children’s Online Privacy Protection Act (COPPA), and we do not knowingly target the Website to children under sixteen (16) years of age. If you believe we have collected Personal Information from a child in violation of applicable law, contact privacy@ultatel.com and we will take appropriate steps.

13. Third-Party Sites and Services

The Website may link to or integrate with third-party sites, services, and platforms. We are not responsible for the privacy practices of those third parties. Their use of your information is governed by their own privacy policies.

14. Automated Decision-Making

We do not use automated decision-making (including profiling) that produces legal or similarly significant effects on you in connection with the Website.

15. Changes to this Policy

We may update this Privacy Policy from time to time. The “Effective Date” at the top reflects the most recent update. Material changes will be communicated by reasonable means, which may include email (where you have an account), banner notice on the Website, or other prominent disclosure. Continued use of the Website after the effective date of an update constitutes acceptance of the updated Policy.

16. Contact Us

Questions, requests, or complaints about this Privacy Policy or our handling of Personal Information may be sent to:

Ultatel, LLC

Attn: Chief Privacy Officer

13873 Park Center Rd, Suite 450

Herndon, VA 20171

Email: privacy@ultatel.com

Privacy request portal: www.ultatel.com/privacy-request