Legal

Privacy Policy

Last updated: September 21, 2026

This Privacy Notice for ConfirmOk LLC ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Agency Programs. ConfirmOk provides many of its Services on behalf of government agencies and other organizations (each, an "Agency"), such as police departments, sheriff's offices, cities, counties, and aging agencies. When you participate in a program administered by an Agency, that Agency determines who participates in the program and how the program is administered, and ConfirmOk processes resident information on the Agency's behalf in order to provide the Services. Information collected specifically for an Agency's program is handled on behalf of that Agency and is subject to ConfirmOk's agreement with that Agency and to applicable law, including any public-records laws that apply to the Agency.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. 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 [email protected].

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.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not intentionally collect sensitive personal information unless it is necessary to provide the Services or you voluntarily provide it during a call, recording, check-in, or other interaction with us.

Do we collect any information from third parties? When an Agency administers a program, we may receive enrollment information about participating residents (such as names, phone numbers, schedules, and designated notification contacts) from that Agency. We do not purchase personal information from data brokers or other third-party sources.

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 process 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. We do not sell your personal information. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. 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. 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.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

Table of Contents

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, 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.

Personal Information Provided by You. 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. The personal information we collect may include the following:

Sensitive Information. We do not intentionally collect sensitive personal information unless it is necessary to provide the Services or it is voluntarily provided during a call, recording, check-in, or other interaction with us. For example, a caller or check-in participant may choose to mention health or other personal details during a recorded call. Any such information is used only to provide the Services and is handled as described in this Privacy Notice.

Information Provided by Participating Agencies. When an Agency enrolls residents in a check-in or PauseOk program, the Agency may provide us with resident enrollment information, such as names, phone numbers, call schedules, and designated notification contacts. We process this information on the Agency's behalf to operate the program. The Agency is responsible for obtaining each resident's (or their representative's) consent to participate and to receive automated calls.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

All 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.

2. How Do We Process Your Information?

In Short: 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 personal information for a variety of reasons, depending on how you interact with our Services, including:

3. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We disclose personal information to these service providers only as necessary to provide, secure, maintain, and support the Services, as directed by the applicable Agency or customer, or as required by law. We do not sell resident or customer personal information.

The categories of third parties we may share personal information with are as follows:

Telecommunications Providers. We use contracted telecommunications and communications service providers to place automated telephone calls, send SMS (text) messages, deliver email and other notifications, and otherwise operate the Services.

AI and Transcription Providers. For the PauseOk program, contracted AI and/or transcription service providers may process call recordings, transcripts, or related information when necessary to provide transcription, categorization of suspected scams, summaries, or draft incident reports. Learn more in "DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?"

We also may need to share your personal information in the following situations:

4. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. We may also permit service providers to use tracking technologies on our Services for analytics purposes, to help us understand how the Services are used and to improve them.

We do not use cookies or other tracking technologies for targeted, behavioral, or interest-based advertising, we do not permit third-party advertising networks to collect information about you on our Services, and we do not sell or share personal information collected through these technologies.

5. Do We Offer Artificial Intelligence-Based Products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including Mistral AI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

For the PauseOk program, contracted AI and/or transcription service providers may process call recordings, transcripts, and related information when necessary to provide transcription, categorization of suspected scams, summaries, or draft incident reports for the participating Agency.

Our AI Products

Our AI Products are designed for the following functions:

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

6. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements) or, for Agency programs, by the applicable Agency agreement or records-retention obligations described below. Except in those cases, no purpose in this notice will require us keeping your personal information for longer than thirty six (36) months past the termination of the user's account. In general:

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.

7. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, 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 to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

9. What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/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 CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

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.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at [email protected].

10. Controls for Do-Not-Track Features

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.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"

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
B. Personal information as defined in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information YES
C. Protected classification characteristics under state or federal law Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data NO
D. Commercial information Transaction information, purchase history, financial details, and payment information NO
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other 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, sensory, or similar information Images and audio, video or call recordings created in connection with our business activities YES
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 Information a caller or check-in participant may voluntarily disclose during a recorded call, such as health details NOT INTENTIONALLY COLLECTED — we do not seek this information, but it may be contained in a recording or transcript if voluntarily disclosed (see Section 1)

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

We will use and retain the collected personal information as needed to provide the Services or for:

Information maintained on behalf of an Agency may be subject to different retention periods, as described in "HOW LONG DO WE KEEP YOUR INFORMATION?"

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your 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 your personal information.

ConfirmOk does not sell resident or customer personal information, and we do not share personal information for cross-context behavioral or targeted advertising. We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

Depending upon the state where you live, you may also have the following rights:

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at [email protected], or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request 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 applicable laws.

Request Verification

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. We will only use personal information provided in your request to verify your identity or authority to make the request. 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.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. 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 submit a complaint to your state attorney general.

California "Shine The Light" Law

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 by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

12. PauseOk Scam-Interruption Program

1. Program Description. As part of the Services and at no additional cost, ConfirmOk provides the Agency with the PauseOk program, consisting of: (a) card-sleeve materials bearing the Agency's name and endorsement; (b) a dedicated telephone line (the "ConfirmOk Line") answered by a recorded greeting; and (c) recordings, transcriptions, and draft incident reports made available through the Agency's dashboard.

2. Not an Emergency Service. The ConfirmOk Line is an informational and reporting service only. It is not an emergency service, is not monitored live, and is not a substitute for 911. Program materials and recordings direct callers to dial 911 in an emergency. The Agency acknowledges that ConfirmOk does not dispatch, respond to, or intervene in any incident.

3. No Guarantee of Outcome. PauseOk is designed to help residents pause and report suspected fraud. ConfirmOk does not represent or warrant that the program will prevent any scam, loss, or crime, or that any funds will be recovered.

4. Draft Reports. Incident report drafts are generated automatically from call transcripts as a convenience. They are drafts only, may contain errors, and have no official status unless and until reviewed, corrected, and adopted by an authorized Agency officer. The Agency is solely responsible for the content of its official reports and any law-enforcement action taken.

5. Recordings, Transcription, and Consent. Calls to the ConfirmOk Line may be recorded and transcribed. Callers receive a recording disclosure in the greeting before any recording occurs. Recordings and transcripts may be processed — including by the contracted AI and/or transcription service providers described in this Privacy Notice — to transcribe the call, categorize the suspected scam, and prepare summaries and draft incident reports, and this information is made available to the participating Agency through its dashboard. The Agency and ConfirmOk will cooperate to ensure the greeting and program materials satisfy the call-recording consent requirements of the Agency's state.

6. Use of Name, Badge, and Voice. The Agency grants ConfirmOk a limited, revocable license to use the Agency's name, badge or insignia, and the recorded voice of its designated official solely to produce and operate PauseOk materials and the ConfirmOk Line for the Agency's own program. This license ends when the Agreement ends, or earlier upon the Agency's written request (including if the recorded official leaves office).

7. Data. Call recordings, transcripts, and reports generated for the Agency's program are collected and handled on behalf of that Agency and are subject to the applicable agreement with that Agency and to applicable law, including any public-records laws that apply to the Agency. ConfirmOk acts as a service provider and may disclose this information to contracted service providers only as necessary to provide, secure, maintain, and support the Services, as directed by the Agency, or as required by law. ConfirmOk does not sell this information. ConfirmOk may use de-identified, aggregated program data (such as call counts and estimated dollar amounts paused) for program reporting, analytics, service improvement, and similar legitimate purposes; no identifiable resident recording or information will be included in any public materials without the Agency's written approval.

13. ConfirmOk Daily Check-In Program

1. Service Description. ConfirmOk provides an automated telephone check-in service under which enrolled residents receive a scheduled daily call and confirm their well-being by response (such as pressing 1 or responding verbally). If a required check-in is not confirmed after the configured number of check-in attempts, ConfirmOk may notify the contacts designated by the Agency — or dispatch, where the Agency has so configured the program — through methods such as automated telephone call, text message (SMS), or email, depending on the Agency's configuration.

2. Not an Emergency or Medical Service. ConfirmOk is an automated wellness check-in and notification service only. It is not an emergency service, medical alert system, or life-safety device, is not monitored live, and is not a substitute for 911 or emergency services. When a required check-in is missed, ConfirmOk notifies the designated Agency or contacts according to the configured program; ConfirmOk personnel do not independently conduct welfare checks or emergency response, and ConfirmOk does not provide medical advice. The decision whether and how to respond to any missed check-in rests solely with the Agency.

3. A Missed Check-In Is Not a Determination. A missed check-in indicates only that no confirmation was received. It does not establish that a resident is in distress, and a confirmed check-in does not establish that a resident is safe. ConfirmOk makes no representation about any resident's actual condition.

4. Service Dependencies. The service depends on telephone carriers, networks, and other third-party systems outside ConfirmOk's control. Calls or notifications may occasionally be delayed, blocked, or fail due to carrier outages, network conditions, the resident's equipment, or incorrect contact information. ConfirmOk will make commercially reasonable efforts to deliver calls and notifications as scheduled and to notify the Agency of any known service disruption, but does not warrant uninterrupted or error-free operation.

5. Enrollment and Accuracy. The Agency is responsible for the accuracy of enrollment information it provides (including resident phone numbers, schedules, and notification contacts) and for obtaining each resident's or their representative's consent to participate and to receive automated calls.

6. Data. Resident enrollment information and check-in records are collected and used solely to operate the Agency's program, are handled on behalf of that Agency, and are subject to the applicable agreement with that Agency and to applicable law, including any public-records or records-retention obligations that apply to the Agency. ConfirmOk does not sell resident information and may disclose it to contracted service providers only as necessary to provide, secure, maintain, and support the Services, as directed by the Agency, or as required by law. ConfirmOk may use de-identified, aggregated service data (such as call and check-in counts) for program reporting, analytics, service improvement, and similar legitimate purposes.

7. Terms of Service. Limitations of liability and other contractual terms relating to the Services are set out in ConfirmOk's Terms of Service and the applicable customer agreement, not in this Privacy Notice.

14. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. 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.

15. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

ConfirmOk LLC
300 CARLSBAD VILLAGE DR
Suite 108A - 147
CARLSBAD, CA 92008
United States

16. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

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