CALLURA PRIVACY POLICY

Effective Date: October 8, 2026
Last Updated: October 20, 2026

INTRODUCTION

Callura Limited Liability Company (“Callura,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and protect information when you visit our websites, including calluravoice.ai and callura.io (the “Website”), respond to our advertisements or lead forms on third-party platforms such as Facebook and Instagram, or use our AI-powered voice communication platform (the “Service”).

This Privacy Policy applies to: (a) visitors to our Website; (b) businesses and individuals who use our Service (“Clients”); and (c) individuals whose information is processed through our Service on behalf of our Clients (“End Users”), such as patients or customers who interact with our AI-powered phone system.

If you called a business that uses Callura and have questions about your personal information, please contact that business directly. Callura processes End User information on behalf of its Clients and is not the primary controller of that information. By accessing our Website or using our Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our Website or Service.

INFORMATION WE COLLECT

2.1 Information You Provide to Us
We collect information that you voluntarily provide to us, including:

Account Information: When you create an account or become a Client, we collect your name, email address, phone number, company name, billing address, and payment information.

Contact Form Submissions: When you submit a contact form, request a demo, or otherwise reach out to us, we collect your name, email address, phone number, company name, and the

content of your message.

Ad Lead Forms and Meeting Requests: When you respond to one of our ads by submitting a lead form on a platform such as Facebook or Instagram, or when you book a meeting with us, we receive the information you provide, such as your name, email address, phone number, practice or company name, city, and role, together with the meeting time you choose.

Communications: When you communicate with us via email, phone, or other channels, we collect the content of those communications.

2.2 Information Collected Through the Service

When our Clients use the Service, we process information on their behalf, including:

Call Data: Phone numbers of callers, call recordings, call transcripts, call duration, and call metadata.

Appointment Information: Names, contact information, appointment dates and times, service types, and related scheduling details.

Health Information: When the Service is used by healthcare providers, we may process limited Protected Health Information (“PHI”) necessary for appointment scheduling, such as reason for visit or provider preferences. The handling of PHI is governed by our Business Associate Agreement with the applicable Client and is subject to HIPAA requirements.

Client Configurations: Scripts, prompts, business rules, and other configurations provided by

Clients for use in the Service.

2.3 Information Collected Automatically

When you visit our Website, we automatically collect certain information, including:

Device Information: Browser type, operating system, device type, and unique device identifiers.

Usage Information: Pages visited, time spent on pages, links clicked, and referring URLs.

Log Data: IP address, access times, and system activity.

2.4 Cookies and Similar Technologies

We use cookies and similar tracking technologies to collect information about your interactions with our Website.
The types of cookies we use include:

Essential Cookies: These cookies are necessary for the Website to function properly and cannot be disabled. They enable core functionality such as session management and security.

Analytics Cookies: These cookies help us understand how visitors interact with our Website by collecting information about pages visited, time on site, and other usage metrics. This information is used to improve our Website and services. This includes Microsoft Clarity, which we use on our blog and landing pages at blog.callura.io (see Section 4.7).

Advertising Cookies and Pixels: We use advertising technologies, including the Meta Pixel, to measure how well our ads work and to show relevant ads on platforms such as Facebook and Instagram. These technologies may collect information such as the pages you visit, the actions you take on our Website, and device and browser information.

You can control cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our Website.

2.1 Information You Provide to Us
We collect information that you voluntarily provide to us, including:

content of your message.

Communications: When you communicate with us via email, phone, or other channels, we collect the content of those communications.

2.2 Information Collected Through the Service

When our Clients use the Service, we process information on their behalf, including:

Call Data: Phone numbers of callers, call recordings, call transcripts, call duration, and call metadata.

Client Configurations: Scripts, prompts, business rules, and other configurations provided by

Clients for use in the Service.

2.3 Information Collected Automatically

When you visit our Website, we automatically collect certain information, including:

Device Information: Browser type, operating system, device type, and unique device identifiers.

Usage Information: Pages visited, time spent on pages, links clicked, and referring URLs.

Log Data: IP address, access times, and system activity.

2.4 Cookies and Similar Technologies

We use cookies and similar tracking technologies to collect information about your interactions with our Website.
The types of cookies we use include:

Essential Cookies: These cookies are necessary for the Website to function properly and cannot be disabled. They enable core functionality such as session management and security.

You can control cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our Website.

HOW WE USE YOUR INFORMATION

3.1 To Provide and Improve the Service

We use information to operate, maintain, and improve the Service, including processing calls, scheduling appointments, generating transcripts, and providing analytics to our Clients.

3.2 To Communicate with You

We use your contact information to respond to your inquiries, provide customer support, send service-related announcements, and communicate about your account or our Services.

3.3 To Process Payments

We use payment information to process transactions and bill for our Services.

3.4 To Ensure Security and Prevent Fraud

We use information to protect the security of our Service, detect and prevent fraud, and enforce our Terms of Service.

3.5 To Comply with Legal Obligations

We use information as necessary to comply with applicable laws, regulations, legal processes, or governmental requests.

3.6 To Create Aggregated and De-Identified Data
We may create aggregated and de-identified data from information we collect. De-identification of any PHI is performed in accordance with 45 CFR § 164.514(b). We use aggregated and de-identified data to analyze trends, improve our products and services, and for other lawful business purposes.

3.7 For Marketing and Advertising

We use information to follow up on demo, meeting, and information requests; to send you information about our Services that you have asked for; and to measure and improve our advertising, including showing ads to people who have visited our Website or interacted with us, and to people with similar characteristics.

3.1 To Provide and Improve the Service

We use information to operate, maintain, and improve the Service, including processing calls, scheduling appointments, generating transcripts, and providing analytics to our Clients.

3.2 To Communicate with You

We use your contact information to respond to your inquiries, provide customer support, send service-related announcements, and communicate about your account or our Services.

3.3 To Process Payments

We use payment information to process transactions and bill for our Services.

3.4 To Ensure Security and Prevent Fraud

We use information to protect the security of our Service, detect and prevent fraud, and enforce our Terms of Service.

3.5 To Comply with Legal Obligations

We use information as necessary to comply with applicable laws, regulations, legal processes, or governmental requests.

3.7 For Marketing and Advertising

HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your information in the following circumstances:

4.1 With Service Providers

We share information with third-party service providers who perform services on our behalf, including:

Retell AI: Provides voice AI infrastructure for processing calls.

Twilio: Provides telephony services for call routing and delivery.

Amazon Web Services (AWS): Provides cloud hosting and data storage.

Stripe: Processes payments on our behalf.

Meta Platforms (Facebook and Instagram): Provides advertising, ad measurement, and lead form services.

HubSpot: Provides customer relationship management, email, and meeting scheduling services.

Google Workspace: Provides email and calendar services.

Make: Provides workflow automation that routes lead form submissions to our team.

These service providers are contractually obligated to use your information only for the

purposes of providing services to us and to maintain appropriate security measures.

4.2 With Clients

When End Users interact with the Service (for example, by calling a phone number powered by Callura), we share information about those interactions with the applicable Client. The Client’s use of that information is governed by their own privacy practices.

4.3 For Legal Reasons

We may disclose information if we believe in good faith that disclosure is necessary to: (a) comply with applicable law, regulation, legal process, or governmental request; (b) enforce our Terms of Service or other agreements; (c) protect the rights, property, or safety of Callura, our Clients, or others; or (d) detect, prevent, or address fraud, security, or technical issues.

4.4 Business Transfers

If Callura is involved in a merger, acquisition, sale of assets, or bankruptcy, your information

may be transferred as part of that transaction. We will notify you of any change in ownership or

control of your personal information.

4.5 With Your Consent

We may share your information with third parties when you have given us your consent to do so.

4.6 With Advertising Partners

We use Meta’s advertising tools, including the Meta Pixel and the Meta Conversions API. These tools collect or receive information about your interactions with our Website, such as pages viewed and forms submitted, and may receive hashed (encoded) contact information, such as an email address or phone number, to match those interactions to a Meta account. We may also provide hashed contact information of people who have interacted with us to Meta to show them our ads or to reach people with similar characteristics. Meta’s use of this information is governed by Meta’s own privacy policy. We do not share Protected Health Information, call data processed through the Service, or other information we process on behalf of our Clients with advertising partners.

4.7 With Analytics Providers

We partner with Microsoft Clarity to capture how you use and interact with our Website through behavioral metrics, heatmaps, and session replay, so we can improve and market our services. Website usage data is captured using first- and third-party cookies and other tracking technologies to determine the popularity of our services and online activity. We and Microsoft also use this information for site optimization, fraud and security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement at https://privacy.microsoft.com/privacystatement.

We do not sell your personal information. We may share your information in the following circumstances:

4.1 With Service Providers

We share information with third-party service providers who perform services on our behalf, including:

Retell AI: Provides voice AI infrastructure for processing calls.

Twilio: Provides telephony services for call routing and delivery.

Amazon Web Services (AWS): Provides cloud hosting and data storage.

Stripe: Processes payments on our behalf.

Meta Platforms (Facebook and Instagram): Provides advertising, ad measurement, and lead form services.

HubSpot: Provides customer relationship management, email, and meeting scheduling services.

Google Workspace: Provides email and calendar services.

Make: Provides workflow automation that routes lead form submissions to our team.

These service providers are contractually obligated to use your information only for the

purposes of providing services to us and to maintain appropriate security measures.

4.2 With Clients

4.3 For Legal Reasons

4.4 Business Transfers

If Callura is involved in a merger, acquisition, sale of assets, or bankruptcy, your information

may be transferred as part of that transaction. We will notify you of any change in ownership or

control of your personal information.

4.5 With Your Consent

We may share your information with third parties when you have given us your consent to do so.

4.6 With Advertising Partners

4.7 With Analytics Providers

DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide the Service, comply with legal obligations, resolve disputes, and enforce our agreements. For Clients, we retain account information and related data for the duration of the Client relationship and for a reasonable period thereafter as necessary for our legitimate business purposes.

For information processed through the Service on behalf of Clients (including End User data), our retention practices are governed by our agreements with the applicable Client. Following termination of a Client relationship, we retain Client Data for thirty (30) days, after which it is deleted unless we are required by law to retain it longer.

Aggregated and de-identified data may be retained indefinitely.

DATA SECURITY

We implement and maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and destruction.

These measures include:

• Encryption of data in transit and at rest.

• Access controls limiting access to personal information to authorized personnel.

• Regular security assessments and monitoring.

• Employee training on data protection and security practices.

While we take reasonable measures to protect your information, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your information.

We implement and maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and destruction.

These measures include:

• Encryption of data in transit and at rest.

• Access controls limiting access to personal information to authorized personnel.

• Regular security assessments and monitoring.

• Employee training on data protection and security practices.

YOUR RIGHTS AND CHOICES

7.1 Access and Correction

You may request access to the personal information we hold about you and request that we correct any inaccuracies. To make such a request, please contact us using the information provided in Section 12.

7.2 Deletion

You may request that we delete your personal information, subject to certain exceptions required by law or our legitimate business purposes. To make such a request, please contact us using the information provided in Section 12.

7.3 Data Portability

You may request a copy of your personal information in a structured, commonly used, and machine-readable format. To make such a request, please contact us using the information provided in Section 12.

7.4 Opt-Out of Marketing Communications

You may opt out of receiving marketing communications from us by following the unsubscribe instructions in those communications or by contacting us using the information provided in Section 12. Please note that even if you opt out of marketing communications, we may still send you service-related communications.

7.5 End Users

If you are an End User whose information has been processed through our Service on behalf of one of our Clients (for example, if you called a healthcare provider that uses Callura), please direct any requests regarding your personal information to that Client. We process End User information on behalf of our Clients and will assist our Clients in responding to such requests as required by our agreements with them.

7.6 How to Submit a Request

To exercise any of the rights described above, please submit a request to security@callura.io with the subject line “Privacy Request.” In your request, please describe the right you wish to exercise and provide sufficient information for us to verify your identity and locate your information. We will respond to verified requests within thirty (30) days, or as otherwise required by applicable law.

7.7 Advertising Choices

You can adjust the ads you see in your Facebook and Instagram settings and limit tracking through your browser or device settings. You may also ask us not to use your information for advertising audiences by emailing security@callura.io with the subject line “Advertising Opt-Out.”

7.1 Access and Correction

7.2 Deletion

7.3 Data Portability

7.4 Opt-Out of Marketing Communications

7.5 End Users

7.6 How to Submit a Request

7.7 Advertising Choices

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), including:

• The right to know what personal information we collect, use, disclose, and sell.

• The right to request deletion of your personal information.

• The right to opt out of the sale or sharing of your personal information. We do not sell personal information. We may “share” personal information, as that term is defined under California law, for cross-context behavioral advertising through tools such as the Meta Pixel and Microsoft Clarity. To opt out, email security@callura.io with the subject line “Do Not Share My Information.”

• The right to non-discrimination for exercising your privacy rights.

To exercise these rights, please contact us at security@callura.io. We will verify your identity before processing your request.

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), including:

• The right to know what personal information we collect, use, disclose, and sell.

• The right to request deletion of your personal information.

• The right to non-discrimination for exercising your privacy rights.

To exercise these rights, please contact us at security@callura.io. We will verify your identity before processing your request.

HIPAA AND PROTECTED HEALTH INFORMATION

When Callura processes Protected Health Information (“PHI”) on behalf of healthcare provider Clients, we do so as a Business Associate under HIPAA. Our use and disclosure of PHI is governed by the Business Associate Agreement we enter into with each such Client, as well as applicable provisions of HIPAA.

We implement safeguards required by HIPAA to protect the confidentiality, integrity, and availability of PHI. We only use and disclose PHI as permitted by our Business Associate Agreements and applicable law.

If you have questions about how your PHI is handled, please contact the healthcare provider whose services you are using. Callura processes PHI on behalf of healthcare providers and is not directly responsible for responding to individual patient requests regarding PHI.

CHILDREN’S PRIVACY

Our Website and Service are not directed to children under the age of thirteen (13), and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will take steps to delete that information as soon as possible. If you believe that we have collected information from a child under 13, please contact us at security@callura.io.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will notify you by posting the updated

Privacy Policy on our Website and updating the “Effective Date” and “Last Updated” dates at the top of this page. We encourage you to review this Privacy Policy periodically. Your continued use of our Website or Service after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will notify you by posting the updated

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:
Callura Limited Liability Company
30 N Gould St # 58109
Sheridan, WY 82801
Email: security@callura.io
We will respond to your inquiry as soon as reasonably practicable.