privateLINE utilizes state-of-the-art private network security and end-to-end encryption to provide private applications, messaging, and Internet calling services (“Services”) to users worldwide (“Members”). Your calls and messages are always encrypted, so they can never be shared or viewed by anyone but yourself and the intended recipients and your data is not transmitted over the public internet, unless in a secure encrypted tunnel (in addition to any application data encryption).
Your privacy is important to us. This privacy notice for privateLINE (“we,” “us,” or “our”), describes how and why we might collect, store, use, or share (“Use”) your information when you use our Services, including when you
- Visit our website at https://privateline.io or any website of ours that links to this privacy notice; or
- Download and use our mobile application, or any other application of ours that links to this privacy notice.
Everyone who uses your Account is covered by this private notice.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@privateline.io
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us. [NOTE: All internal links to come.]
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we use your information.
In what situations and with which types of parties do we share personal information?We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? Your calls and messages are always encrypted, so they can never be shared or viewed by anyone but yourself and the intended recipients and your data is not transmitted over the public internet, unless in a secure encrypted tunnel (in addition to any application data encryption). We also have organizational procedures in place to protect your personal information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights in some US states, Canada and some European countries and certain other countries..
How do you exercise your rights? The easiest way to exercise your rights is by visiting privateline.io/support or by contacting us at privacy@privateline.io. We will consider and act upon any request in accordance with applicable data protection laws. Learn more about how to exercise your rights.
Want to learn more about what we do with any information we collect? Review the privacy notice in full below.
Personal Information Provided by You
We collect personal information that you voluntarily provide to us when you become a Member, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.
Account Information. We do not require a phone number from our Members, but you may register a phone number when you create a privateLINE account if you wish to make your account visible to people you know. Your information is only available to other Members who pay for Services and for whom you specifically approve their connection to you. Phone numbers are not used to provide our Services to you and other privateLINE users. You may optionally add other information to your account, such as a profile name, profile picture or email. This information is end-to-end encrypted.
Sensitive Information. We do not collect or use sensitive information.
Messages. privateLINE cannot decrypt or otherwise access the content of your messages or calls. privateLINE queues end-to-end encrypted messages on its servers for delivery to devices that are temporarily offline (e.g. a phone whose battery has died). Your message history is stored encrypted on our servers until you download it to your own devices.
Contacts. Private Line does not scan your contacts.
Payment Data. We collect data necessary to process your payments, such as your payment instrument number, and the security code associated with your payment instrument. All credit/debit card payment data is stored by Stripe, never by privateLINE. You may find Stripe’s privacy notice link(s) here: www.stripe.com/privacy.
User Support. If you contact privateLINE User Support, any personal data you may share with us is kept only for the purposes of researching the issue and contacting you about your case and will be destroyed 30 days after your case is closed.
Managing your information. You can manage your personal information in Private Line’s applications PL Connect, PL Comms and PL 2FA in Settings within your Account.
Your obligations. Any personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
- Device Data We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Information Required to Operate the Services
Certain technical information is stored on our servers, including randomly generated authentication tokens, keys, push tokens, and other material that is necessary to establish calls and transmit messages. privateLINE limits this additional technical information to the minimum required to operate the Services.
- To facilitate account creation and authentication and otherwise manage user accounts. We use your information so you can create and log in to your account, as well as to keep your account in working order.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see PRIVACY CHOICES AND CONTROLS, below.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
- Payment Processors
We also may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see HOW WE SHARE YOUR PERSONAL INFORMATION above), in the United States, and other countries.
If you are a resident in the European Economic Area (EA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you
- Consent. We may process your information if you have given us permission (i.e.. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh our interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services;
- Analyze how our Services are used so we can improve them to engage and retain users;
- Diagnose problems and/or prevent fraudulent activities; or
- Understand how our users use our products and services so we can improve user experience.
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
- For investigations and fraud detection and prevention;
- For business transactions provided certain conditions are met;
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
- For identifying injured, ill, or deceased persons and communicating with next of kin;
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced; or
- If the information is publicly available and is specified by the regulations.
We will only keep your personal information while you are a Member, plus thirty (30) days after you close your account, unless a longer retention period is required by law.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your calls and messages are always encrypted, so they can never be shared or viewed by anyone but yourself and the intended recipients and your data is not transmitted over the public internet, unless in a secure encrypted tunnel (in addition to any application data encryption). We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information utilizing our Services is at your own risk.
We require the consent of a parent or legal guardian in order for anyone under the age of 16 to create an account. We do not knowingly collect personal information from anyone under the age of 16 without parental consent. We will not contact a child under 16 for marketing purposes without parental consent. However, if we are not aware that a child is using a service purchased by an adult, we may collect the information and treat it as the adult's.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section HOW TO CONTACT US below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section HOW TO CONTACT US below. You will then be removed from the marketing lists. However, we may still communicate with you - for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
- Log in to your account settings or Settings of PL Connect software and update or delete your user account.
- Contact us using the contact information provided or email support@privateline.io.
If you have questions or comments about your privacy rights, you may email us at privacy@privateline.io
If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you have specific rights under the laws of your state regarding access to your personal information.
Categories of personal information we collect
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES* *We collect your phone number and email address only if you voluntarily provide it to us; we collect your account name |
| B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES* *We collect your phone number and email address only if you voluntarily provide it to us; we do not collect other personal information |
| C. Protected classification characteristics under state or federal law | Gender and date of birth. | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | NO |
| G. Geolocation data | Device location | NO |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
| J. Education information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics | NO |
| L. Sensitive personal information | NO |
We will use and retain the collected personal information as needed to provide the Services or for thirty days after you cease being a Member or having an account with us.
- You receive help through our customer support channels;
- You participate in customer surveys or contests; or
- You participate in customer surveys or contests; orWe respond to your inquiries.
How we share your personal information
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about who we disclose personal information to in the section, HOW WE SHARE YOUR PERSONAL INFORMATION.
We may use our personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of our personal information.
We have never sold or shared any personal information to third parties for a business or commercial purpose.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under HOW WE SHARE YOUR PERSONAL INFORMATION.
California Civil Code Section 1798.83, also known as the “Shine The Light” law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines “residents” as:
- every individual who is in the State of California for other than a temporary or transitory purpose; and
- every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your rights with respect to your personal data
- Right to request deletion of the data
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
- Right to request information
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect:
- the purposes for which the collected personal information is used;
- whether we sell or share personal information to third parties
- the categories of personal information that we sold, shared, or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- the business or commercial purpose for collecting, selling, or sharing personal information; and
- the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
- Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
- Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
- Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us.
For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying your identity.
- Other privacy rights:
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, please contact us at privacy@privateline.io. If you have a complaint about how we handle your data, we would like to hear from you.
- Right to be informed whether or not we are processing your personal data;
- Right to access your personal data;
- Right to correct inaccuracies in your personal data;
- Right to request deletion of your personal data;
- Right to obtain a copy of the personal data you previously shared with us; and
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).
To submit a request to exercise these rights described above, please email privacy@privateline.io
If we decline to take action regarding your request and you wish to appeal our decision, please email us at privacy@privateline.io Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. Be sure to keep a recent backup of any important data.
- Right to be informed whether or not we are processing your personal data;
- Right to access your personal data;
- Right to correct inaccuracies in your personal data;
- Right to request deletion of your personal data;
- Right to obtain a copy of the personal data you previously shared with us; and
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).
To submit a request to exercise these rights described above, please email privacy@privateline.io
if we decline to take action regarding your request and you wish to appeal our decision, please email us at privacy@privateline.io. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
- Right to be informed whether or not we are processing your personal data;
- Right to access your personal data;
- Right to request deletion of your personal data;
- Right to obtain a copy of the personal data you previously shared with us; and
- Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data.
To submit a request to exercise these rights described above, please email privacy@privateline.io
Under the Virginia Consumer Data Protection Act (VCDPA):
“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition of “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data:
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
Exercise your rights provided under the Virginia VCDPA
You may contact us by email at privacy@privateline.io
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at privacy@privateline.io Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
In some parts of Europe, such as the European Union, United Kingdom, and Switzerland, and in Canada, you have certain rights under applicable data protection laws.
- The right to be informed: this means we must inform you of how we intend to use your personal data and we do this through the terms of this privacy notice.
- The right of access: this means you have the right to request access to the data we hold about you and we must respond to those requests within one month. You can do this by sending an email to privacy@privateline.io
- The right to rectification: this means that if you believe some of the data we hold is incorrect, you have the right to have it corrected. You can do this by logging into your account with us, or by sending us an email with your request. You can do this by sending an email to privacy@privateline.io
- The right to erasure: this means you can request that the information we hold about you be deleted, and we will comply unless we have a compelling reason not to, in which case you will be informed of the reason. You can do this by sending an email to privacy@privateline.io
- The right to restrict processing: this means you can change your communication preferences or opt-out of certain communications. You can do this by sending an email to privacy@privateline.io
- The right of data portability: this means you can obtain and use the data we hold for your own purposes without explanation. If you wish to request a copy of your information, contact us at privacy@privateline.io
If you are located in the EU or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.
- offer you the products or services that you want;
- respond to or help with your requests;
- manage your account with us; or
- confirm your identity and protect your account.
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section HOW TO REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU.
If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section HOW TO YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU.
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may contact our Data Protection Officer (PO), Russell Hyzen, by email at: privacy@privateline.io
contact us by post at:
Private Line
LLC Russell Hyzen
You have the right to request access to the personal information we collect from you. change that information or delete it. To request to review, update, or delete your personal information, please email privacy@privateline.io
Last updated March 10, 2024