California Consumer Privacy Act

Last updated: May 5, 2022

This California Consumer Privacy Rights Notice (“Notice”) sets forth Yolla Calls International OÜ (“Yolla” or “We”) disclosure obligations under California law, including the California Consumer Privacy Act of 2018 (“CCPA”) and California Civil Code section 1798.83.

Under the California law CCPA Personal Information (“CCPA PI”) is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households (“Consumer” or “You”).

1. Information We Collected From Consumers

The CCPA identifies a number of categories of CCPA PI. In the year before the date this policy was updated, Yolla collected these categories of CCPA PI:

• Identifiers such as name, email address, account name, phone number;
• Unique and online identifiers associated with personal information – IP address, device IDs, or other similar identifiers;
• Commercial information – such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Internet, gaming or other electronic network activity information – such as browsing history, search history and information regarding an individual’s interaction with an internet website, application, or advertisement;
• Location Information;
• Inferences drawn from CCPA PI, such as individual profiles, preferences, characteristics, behaviors;
• For more information please see Yolla’s general Privacy Policy.

We collected the above categories of CCPA PI for the following purposes:

• Sign you up for the product and create your user account for Yolla;
• Process your payments;
• Provide customer service, give you information about your account, and respond to your requests;
• Preventing cheating, crime or fraud;
• Debugging errors in systems;
• Marketing and advertising;
• Internal research, analytics and development – e.g., user-preference analytics;
• Developing, maintaining, provisioning or upgrading networks, services or devices.

We collected the above categories of CCPA PI from the following sources:

• Directly from you – such as contact and billing info and customer service interactions;
• Generated by your use of our services – such as technical, equipment and usage information;
• Social media sites and other online platforms;
• Other companies – such as vendors, marketing firms;
• Publicly available sources – such as public records.

2. Information We Shared About Consumers

Over the past year, Yolla may have shared these categories of CCPA PI with entities that provide services for us, like processing your bill:

• Identifiers such as name, email address, account name, phone number;
• Unique and online identifiers associated with personal information – IP address, device IDs, or other similar identifiers;
• Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Internet, gaming or other electronic network activity information – such as browsing history, search history and information regarding an individual’s interaction with an internet website, application, or advertisement;
• Location Information ;
• Inferences drawn from CCPA PI, such as individual profiles, preferences, characteristics, behaviors;
• For more information please see Yolla’s general Privacy Policy.

We may have shared each of the above categories of CCPA PI with the following categories of third parties who perform services on our behalf:

• Product and services delivery companies;
• Marketing services companies;
• Billing and payment processing companies;
• Fraud prevention and authentication/identity verification entities;
• Analytics companies;
• For more information please see Yolla’s general Privacy Policy.

3. Sale of Personal Information

Yolla does not sell and will not sell your Personal Information.

4. Request Yolla Disclose At No Charge:

• Specific pieces of personal information Yolla has collected about you;
• Categories of Personal Information collected, used, and/or disclosed about you;
• Categories of sources from which Personal Information is collected;
• Business and/or commercial purposes for collecting and disclosing your Personal Information;
• Categories of third parties with whom your Personal Information has been disclosed/shared.

Right to Know Requests can be submitted to Yolla by email at privacy@yollacalls.com

5. Request Yolla to Delete At No Charge

Upon your request, Yolla will delete the CCPA PI collected about you, except for situations when that information is necessary for us to: (i) provide you with a service that you requested; (ii) perform a contract Yolla entered into with you; (iii) maintain the functionality or security of our systems; (iv) comply with or exercise rights provided by the law; (v) or use the information internally in ways that are compatible with the context in which you provided the information to us, or that are reasonably aligned with your expectations based on your relationship with us.

Deletion Requests can be submitted to Yolla by email at privacy@yollacalls.com

6. Request Yolla to Correct Inaccurate Personal Information At No Charge

You have the right to request Yolla to correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

As soon as Yolla receives your verifiable request to correct inaccurate personal information, Yolla will use commercially reasonable efforts to correct the inaccurate personal information as directed by you.

Correction Requests can be submitted to Yolla by email at privacy@yollacalls.com

7. Verified Request Process

Before responding to any of your requests, Yolla have to verify such requests.

Yolla account-holders: Yolla may verify the identity of the consumer making the request by either matching with the account information on file or through existing account authentication credentials.

Non-account holders: Yolla shall verify to a reasonably high degree of certainty, including matching at least three pieces of consumer personal information with that maintained by Yolla and/or if necessary, by a signed statement by consumer under penalty of perjury that the requestor is the consumer for which personal information is sought.

Authorized agent: You may designate an authorized agent to submit requests on your behalf. Your agent will need a valid power of attorney or written permission signed by you. If the agent relies on written permission, we’ll need to verify the agent’s identity. We may also contact you directly to confirm the permission.

8. Consumer Request Limitations

Please take into account that CCPA imposes some limitations regarding your requests to Yolla, including, but not limited to:

• Yolla is obligated to disclose/delete only upon a verifiable Consumer request from the consumer or an authorized agent acting on behalf of Consumer.
• Consumers may only make a personal information request twice in a 12-month period.
• Deletion is not required because if retention is necessary to maintain the Personal Information to fulfill the purposes enumerated in CCPA Section 1798.105

Yolla will confirm and respond to all requests within the timeframe required under the CCPA. In responding to any request to disclose/delete, Yolla shall maintain a record of the requests as required under the CCPA.

9. Non-Discrimination Policy

Yolla shall not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA, including, but not limited to, (a) denying goods or services, (b) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, or © providing a different level or quality of goods or services to the consumer.

10. Contact Us

You can find more details regarding how we treat your Personal Information or about our privacy practices in our general Privacy Policy.

If you have any questions, please contact us at: Yolla Calls International OÜ, Attention: Data Protection Department, Rävala pst 6-404A, Tallinn city, Harju county, Estonia or by email at privacy@yollacalls.com