Privacy Policy v2025.10

Effective Date: October 7, 2025 | Supersedes any prior Privacy Policy versions | Posted at https://diallog.com/privacy (or successor URL) | Archives of prior versions available on request per TOS Section 1.6 (Archives).

1. Introduction and Scope

Diallog Telecommunications Corp. (“Diallog”, “we”, “us”, “our”) is committed to protecting personal information in compliance with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) and other applicable privacy laws (“Laws”). This Privacy Policy outlines how we collect, use, disclose, and safeguard personal information in providing our telecommunications, VoIP, Internet, voice, data, and related Services (as defined in TOS Section 2 (Definitions)), including through our websites (collectively, the “Site”).

This Policy is incorporated by reference into Diallog’s Master Terms of Service (“TOS”) under TOS Section 1.3 (Incorporation) and forms part of your agreement with us. It applies to all Customers (as defined in TOS Section 2 (Definitions)), including Business Customers (per Business Services Schedule (BSS)) and consumers (per RSS). Capitalized terms not defined herein have the meanings given in TOS Section 2 (Definitions).

We collect only the personal information necessary to provide and improve the Services, manage accounts, comply with Laws, and as otherwise described herein. Personal information means information about an identifiable individual (e.g., name, contact details, payment info) but excludes business contact information used solely for business purposes.

The Diallog Privacy Coordinator is accountable for our privacy practices and can be contacted at privacy@diallog.com, or via the details at https://diallog.com/contact-us (or successor URL). Complaints or inquiries should be directed there.

Updates: Material changes (e.g., new uses of personal information) will be posted prominently on the Site and notified via email, invoice, or the Status/Notices Page (TOS Section 2 (Definitions)), with consent obtained where required by Laws or TOS Section 1.4 (Rolling updates & notice). Continued use constitutes acceptance.

2. Collection of Personal Information

We collect personal information you voluntarily provide, such as:

• Name, address, email, phone, payment/credit details, credit history, tax ID, or reseller ID for account setup, billing, and Service provisioning (TOS Section 4 (Charges, Billing, Payment & Changes)).
• Usage data, call metadata, IP addresses, location info (e.g., for 9-1-1 per TOS Section 6.9 (9-1-1 limitations (summary)) and VoIP 9-1-1 Emergency Calling Policy), and device identifiers for Service delivery, troubleshooting, and analytics.
• Information from Site interactions (e.g., registrations, forums, surveys, contests, feedback, resumes, downloads).
• Data from third parties (e.g., affiliates, marketing partners, credit bureaus) with your consent or as permitted by Laws.
• For Business managed CPE data, see BSS Section H (CPE (Ownership, Rental, Finance) & Returns); for Consumer home equipment, see RSS Section E (Home Equipment (CPE), Installation & Returns).
• Automatically collected non-personal data via cookies, pixels, or similar tools for Site functionality, analytics, and targeted ads (see Section 5 (Cookies and Tracking Technologies) below).

For Business Services (per the BSS), we may collect employee/end-user data for managed CPE or usage analysis (BSS Sections H (CPE (Ownership, Rental, Finance) & Returns), L (Billing & Security Instruments)). For Consumer Services (RSS), collection is limited to personal/household use (RSS Section G (Fair Use & Home-Use Only)).

Exemptions: We may collect/use/disclose without consent for legal, security, fraud prevention, or emergency reasons, as permitted by Laws (e.g., law enforcement requests per TOS Section 7.10 (Lawful access & disclosures)).

3. Use of Personal Information

We use personal information solely for identified purposes, including:

• Providing, maintaining, and improving Services (e.g., activation, billing per TOS Section 4 (Charges, Billing, Payment & Changes); modernization per TOS Section 5 (Provisioning, Service Changes, and Modernization)).
• Verifying identity, managing accounts, and ensuring compliance (e.g., AUP enforcement per TOS Section 7 (Acceptable Use, Security & Privacy)).
• Communicating updates, notices, or marketing (with opt-out options).
• Analyzing usage for internal business purposes (aggregated/anonymized where possible) including for AI-driven insights (aggregated/anonymized only).
• Targeted advertising, ratings, or identity consistency. We will obtain consent where required for interest-based advertising and provide controls in a cookie preferences center.
• Monitoring compliance with Laws, TOS, BSS (e.g., MMC per BSS E), or RSS.
• Facilitating 9-1-1 and emergency services (TOS Section 6.9 (9-1-1 limitations (summary))).

We do not use personal information for new purposes without consent, except as permitted by Laws.

4. Disclosure of Personal Information

We disclose personal information only as necessary:

• To underlying carriers, upstream providers, or affiliates for Service delivery (TOS Section 5 (Provisioning, Service Changes, and Modernization) and TOS Section 6 (Service Levels, Maintenance & Force Majeure).
• For billing, collections, or credit checks (TOS Section 9 (Credit, Deposits & Fraud Controls)).
• To comply with Laws, legal processes, or emergencies (TOS Section 7.10 (Lawful access & disclosures)).
• In business transfers (e.g., mergers), with safeguards.
• Aggregated/anonymized for analytics/marketing.

We do not sell or rent personal information without consent. Data may be processed/stored in Canada or other jurisdictions with appropriate safeguards (TOS Section 7.12 (Data location) For Business Customers requiring residency restrictions, specify in a TSA addendum.

5. Cookies and Tracking Technologies

We use cookies, web beacons, and similar tools for Site navigation, analytics, and ads. These track browser activity but not to identify users beyond Service needs. To disable:

• Chrome: Settings > Privacy and security > Cookies > Block third-party cookies.
• Firefox: Settings > Privacy & Security > Cookies > Custom > Block all cookies.
• Safari: Settings > Privacy > Prevent cross-site tracking; Block all cookies.
• Edge: Settings > Cookies and site permissions > Manage and delete cookies > Block.

The above Settings details are subject to change by the related browser developers, and are provided to you on a reasonable efforts basis (refer to your browser’s help documentation for current instruction). Disabling may limit Site functionality. We respond to applicable browser or platform privacy signals where required by law (e.g., Global Privacy Control in supported jurisdictions).

6. Safeguards, Retention, and Accuracy

We protect personal information with administrative, technical, and physical safeguards appropriate to its sensitivity (e.g., encryption for call recordings per TOS Section 7.9 (Call recording & monitoring)); encryption in transit (e.g., TLS) and encryption at rest where appropriate).

• Retention: Only as long as necessary for purposes or legal requirements (TOS Section 7.13 (Retention)); then securely deleted.
• Accuracy: We strive for accuracy; you must provide/update accurate info (e.g., 9-1-1 locations per TOS Section 10.10 (9-1-1 address association)).

7. Data Breaches and Security Incidents

If we confirm a Security Incident (TOS Section 2 (Definitions)) creating a real risk of harm (“Breach”), we will notify affected individuals and authorities per Laws and TOS Section 7.5 (Incident notification), providing available details and mitigation steps. You agree that any breach originating from your systems (e.g., due to failure to comply with TOS Section 7.3 (Your security obligations)) forfeits any claim against Diallog and triggers your indemnity obligations under TOS Section 8.8 (Customer indemnity).

Disclaimer: While we implement commercially reasonable safeguards, no system is immune to threats (e.g., ransomware, zero-day exploits per TOS Section 7.4 (Diallog security posture & disclaimer). Diallog disclaims liability for direct/indirect damages from breaches (e.g., lost profits, reputational harm, business interruption) except to the extent directly caused by our gross negligence, subject to TOS Section 8 (Warranties, Liability & Indemnities) limitations. You must maintain your own security (TOS Section 7.3 (Your security obligations)) and indemnify us for breaches from your systems (TOS Section 8.8 (Customer indemnity)).

8. Call Recording and Monitoring

Calls may be monitored/recorded for quality assurance with notice and consent (which may be implied where permitted by law). For other purposes, we obtain consent. User-enabled recordings (TOS Section 7.9 (Call recording & monitoring)) are your responsibility; we store them securely in Canada with encryption but disclaim liability for your compliance or misuse.

9. Your Rights and Access

You have rights to access, correct, or challenge your personal information:

• Request via Privacy Coordinator; we respond within 30 days (or as required by Laws).
• Withdraw consent (subject to legal/contractual limits; may affect Services).
• For Consumer Services, provincial protections apply (RSS Section I (Consumer Rights, Cancellations & Complaints (Integrated))).

10. Compliance and Complaints

We adhere to PIPEDA’s 10 principles (detailed in original but summarized here for brevity). Challenge compliance via the Privacy Coordinator. Unresolved issues can be escalated to the Office of the Privacy Commissioner of Canada.

This Policy supplements the TOS; in conflicts, precedence per TOS Section 1.5 (Precedence). Nothing herein limits Diallog’s rights under the TOS, BSS, or RSS, which prioritize our operational and legal interests.

11. Interpretation; Cross‑References. This Policy incorporates TOS Section 1.7 (Interpretation; headings; cross‑references; applicability to Schedules/Policies). Any cross‑reference in this Policy (including to the TOS, BSS, RSS, AUP, or VoIP 9-1-1 Emergency Calling Policy) will be interpreted per TOS Section 1.7, such that if a number and title conflict, the title governs, and references include successor sections.