SmartPlus Privacy Policy

Last updated: Aug 3rd, 2026

Overview of Privacy Policy

Welcome to SmartPlus. This Privacy Policy explains how AKUVOX (SINGAPORE) INNOVATION PTE. LTD. (hereinafter referred to as "Akuvox Singapore", "us", "we" or "our"), as the provider of the SmartPlus App, processes your App login and account data as a controller: what information is processed, how it is used and disclosed, how it is protected, and how you can exercise your data privacy rights. Personal data generated through the property services connected to your account (the "service content") are controlled by the property manager or other responsible customer for your project and are explained in the privacy policy presented after you log in. Our roles under the EU General Data Protection Regulation ("EU GDPR") are explained in Section A.

The service includes:

• Our product portal and user accounts that may be accessed at *cloud.akuvox.com (*cloud includes ecloud, ucloud, jcloud, scloud and so on), and all associated sites connected with it, excluding any third parties' sites (the "Portal");
• Online services accessible through the Portal ("Web Services");
• Software applications that can be downloaded to a mobile device ("Mobile Apps"), including Akuvox SmartPlus, and MySmart 2025;
• Related products ("Devices") of the service, including, but not limited to, door phones, indoor monitors, android video phones, access control terminals, and home control panels;
• Any services available on the Portal and the Mobile Apps ("Available Services").

The term "SERVICE" means the Portal, Web Services, Mobile Apps, Devices and Available Services.

We use encryption technology and organizational safeguards to protect your personal data, and we process personal data in accordance with the data protection laws that apply to us, including the EU GDPR, the California Consumer Privacy Act ("CCPA"), the Virginia Consumer Data Protection Act ("VCDPA") and the Brazilian General Data Protection Law ("LGPD"), where they apply.

A. Who we are

The controller of your App login and account data is AKUVOX (SINGAPORE) INNOVATION PTE. LTD., UEN 202538798R, with its registered office at 6 RAFFLES QUAY #14-02, Singapore (048580). Our contact details are set out in Section L.

Roles under the EU GDPR

Our role under the EU GDPR depends on the particular processing activity. For SmartPlus App account login or access credentials and any personal profile data that we process for our own purposes as the App provider, Akuvox Singapore acts as a controller. This Policy is addressed to that processing.

For the service content, the property manager or other responsible customer for your project is the controller, and Akuvox Singapore acts only as its processor or sub-processor on documented instructions. That processing is explained in the privacy policy presented after you log in, which also shows who the controller is for your project.

Akuvox (Xiamen) Networks Co., Ltd acts as our processor for the hosting, operation and maintenance of the cloud platforms and for technical support, including in relation to the App login and account data described in this Policy. This processing concerns cloud services that are activated and used. It does not mean that every item of App data is processed by every group entity.

These EU GDPR role descriptions do not determine roles under other privacy laws.

The controller for the service content connected to your account is displayed in the App after you log in.

B. What Personal Information We Collect

We process the information described below to provide App login and access and to operate the App, as explained in this Policy.

"Personal information" has the same meaning as "personal data" and includes any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity.

We ask you to provide the personal information that is needed for the services you choose to use. If you do not provide the required information, the SERVICE or some of its functions may be limited or unavailable.

The following sections describe the types of information processed when you register for and use the App. Not every category applies to every user. Information generated through the property services connected to your account is explained in the privacy policy presented after you log in.

1. User Account Registration

Depending on your account type, the following information may be supplied when your account is created:

Property Manager Account:

• Name
• Surname
• E-mail address

End User Account:

• Name
• Surname
• E-mail address
• Mobile phone number
• Address (if you are a residential user, we will process your residential address; if you are a business user, we will process your business address)

2. Use of the SERVICE

Depending on the functions you use, the Mobile Apps may request the permissions and process the information described below.

• Video calling, facial recognition and QR code login: camera permission.
• Audio and video calls: permission to record audio.
• Landline services: permission to access and modify contacts.
• Mobile phone number login: mobile phone number information.
• Log exports, facial image uploads and QR code login: permission to read external storage.
• Log exports: permission to write to external storage.
• Push notifications: notification permission.
• Call forwarding services: phone permission.
• Compatibility with your device: system operation information.
• Network selection and performance: network status information.
• Receiving calls when the app is not open: permission to start automatically and run in the background.
• Bluetooth door access: Bluetooth permission, precise location permission, sensor data, and automatic startup and background operation.
• Identification of end-user devices: MAC address, International Mobile Equipment Identity (IMEI), Anonymous Device Identifier (OAID) and International Mobile Subscriber Identity (IMSI).
• Detection and synchronization of identifiers and consolidation of connections: information about installed applications (app list).
• Display of audio and video call features over other applications: floating window permission, requested when you first use the relevant feature.
• Tiandy NVR monitoring and playback: the app integrates Alibaba Cloud, Alibaba Push, mPaaS, Alibaba Long Connection Channel and Alibaba Baichuan E-commerce SDKs. These components may run in the background and collect information at intervals, including your IP address and Google Advertising ID (GAID), and may request access to your advertising identifier permission.

Device permissions are requested through your device's operating system, and you can manage or withdraw them in your device settings. Withdrawing a permission may limit the related function.

3. Troubleshooting and Maintenance

To resolve issues you encounter while using the App and to keep it working properly, we process the following information when you use our Mobile Apps.

• Last login
• Duration of use
• System logs
• Installed application information

4. Service Subscriptions

Installers pay Akuvox Singapore for the SERVICE. Any fees that installers charge property managers or residential property owners are collected separately offline. The installer payment arrangement does not itself establish that a resident or other end user has entered into a payment contract with Akuvox Singapore.

5. Third-Party Services

When you enable a third-party service through the App, we may exchange the information needed to provide that integration. A third party that uses data for its own purposes is responsible for that processing under its own terms and privacy notice. Integrations used with the property services are explained in the privacy policy presented after you log in.

Your use of third-party services is subject to the third parties' terms of use or service and their respective privacy notices. We encourage you to read them carefully before you enable those services on your Devices.

We may also receive information about you from third-party services in order to provide the SERVICE. For processing subject to the EU GDPR, our role in that processing is determined by the activity concerned, as described in Section A.

You may object to this data collection at any time by using the contact details in Section L. Stopping the processing may affect the functions that depend on those data.

6. Sensitive Personal Information

Biometric data used for access control through the property services, such as facial recognition images, fingerprint data or palm vein data, are controlled by the property manager or other responsible customer and are explained in the privacy policy presented after you log in. We do not use them for our own profiling or product development.

Other information described in this Policy, such as precise location data, contacts and unique device identifiers (IMEI, IMSI), may also receive special protection under applicable law. We access such information only through the device permissions you grant and use it only to provide the requested SERVICE functions. We apply security measures, including encryption, access controls and limited retention, to protect it.

C. Cookies and Similar Technologies

Cookies are small files that websites store on your device. They help recognize your browser, remember preferences and support functions such as secure login. You can use your browser settings to block cookies or to be notified when cookies are set, but blocking essential cookies may prevent some website features or services from working correctly.

When you access and use the Portal and Mobile Apps, we may use cookies, anonymous identifiers and similar technologies to collect and store information on your device. Cookie identifiers, IP addresses and similar identifiers are personal data where they relate to an identified or identifiable individual. The roles described in Section A apply to this processing. We use cookies and similar technologies for the following purposes:

1. To ensure the safe and efficient operation of our SERVICE

We use authentication or security cookies and similar identifiers to keep you securely logged in and to help detect fraud or other misuse. These technologies also support efficient operation and faster login and response times.

2. To help you get easier access

These technologies can remember information you have entered and support one-click login and search history, so that you do not have to repeat the same steps.

3. Log files

The Portal may automatically generate log files containing IP addresses, browser types, internet service providers, referring and exit pages, operating systems, timestamps and clickstream information. We do not combine these logs with other information to create personal profiles.

4. Mobile analytics

Diagnostic tools may process usage events, performance information and crash logs to maintain the App and the services. Akuvox does not use personal data covered by this policy for its own profiling, advertising or product development.

D. How We Use Your Personal Information

We process your App login and account data as a controller for the purposes below. Processing of the service content on behalf of the property manager or other responsible customer is not covered by this Policy and is explained in the privacy policy presented after you log in.

We may use the personal information we collect for the following purposes:

1. To provide App login and access. We process your App login and account data through our cloud platforms at *cloud.akuvox.com (*cloud includes ecloud, ucloud, jcloud, scloud and others) to authenticate you and enable you to use the SERVICE.

2. To carry out troubleshooting and maintenance. Authorised support personnel, including those of Akuvox Xiamen, may access the logs and other data needed to investigate a reported issue. Where necessary for that investigation, we upload installed application information to https://maintenance.akuvox.com to analyze and diagnose issues with your application. Access is limited to the relevant task.

3. Service communications. We may send service notices or respond to enquiries about the App and your account. We do not use personal data covered by this policy for our own marketing.

4. To enhance the sharing functionality of our SERVICE. We may collect information about the applications installed on your device. This information is used solely to enable the sharing of content through these applications and to provide you with more convenient sharing options.

5. To verify software and provide service upgrades.

6. Legal obligations. We process personal data as needed to comply with legal obligations that apply to us and to establish, exercise or defend legal claims.

Legal bases for our own (controller) processing

Where the EU GDPR applies and we act as a controller for App login and personal profile data, we rely on the following legal bases:

• Providing App login and access, administering your App account and keeping the App and your account secure (including fraud prevention): our legitimate interests (Article 6(1)(f) GDPR) in operating the App for users whose accounts have been set up by their property manager or installer, and in protecting the App and its users. We do not rely on a contract between you and us for this processing.

Where we rely on legitimate interests, you have the right to object as described in Section G. Where we rely on consent, you may withdraw it at any time. For the service content, the legal basis is determined by the controller for your project and explained in the privacy policy presented after you log in.

E. How We Disclose Your Personal Information

We do not sell personal information to anyone for any purpose. We may disclose your personal information to the following categories of recipients:

1. Project Participants and Service Providers

We may disclose personal information to parties involved in providing or administering the SERVICE, including the relevant property owner, property manager, installer, distributor or local business partner, where their involvement requires it. Akuvox Xiamen processes App login and account data on our behalf as a processor for cloud platform hosting, operation, maintenance and technical support. Other third-party service providers may support the operations described in this Policy. You may request information about these disclosures using the contact details in this Policy.

2. Law Enforcement

We will share information with law enforcement agencies, public authorities or other organisations where required by applicable law. During transmission, we encrypt the data to protect it. You have the right to be informed of such disclosures where required by law.

3. Right to Know About Sharing (CCPA Requirement)

For users residing in California, you have the right to know whether your personal information is shared with third parties and the categories of such recipients. We only share your personal information with service providers (such as cloud hosting, push notification providers or analytics partners) strictly for business purposes. We do not sell your personal information to third parties.

F. Personal Data Storage and Transfers

Cloud service data for users in Europe is stored on servers in Frankfurt, Germany. Cloud service data for users in mainland China is stored on servers in mainland China. During data transmission, we encrypt and protect personal data to ensure its security.

Akuvox Xiamen, located in China, provides hosting, operation, maintenance and technical support for the cloud platforms and may therefore access personal data stored in Europe remotely. Access to personal data for the purposes described in this Policy is limited to authorised personnel and to the tasks concerned, and is subject to the roles and processing arrangements set out in Section A. Any transfer subject to the EU GDPR is made only in compliance with Chapter V of the EU GDPR, on the basis of the appropriate safeguards put in place between the relevant Akuvox entities, and supplemented by additional measures where needed. Encryption alone does not replace these requirements. You may request information about the recipients, the destination countries and the safeguards using the contact details in Section L.

G. Your Rights and Choices

You have the following rights in relation to your personal data, subject to applicable law.

You may exercise your rights regarding the App login and account data described in this Policy directly with Akuvox Singapore using the contact details in Section L. For the service content, please contact the controller for your project, whose details are displayed in the App after you log in; if you contact us about such data, we will forward your request to that controller. In the descriptions below, "the relevant controller" means Akuvox Singapore.

Right of access

You have the right to ask the relevant controller to confirm whether it processes your personal data and, where it does, to obtain access to those data and the following information:

• a) the purposes of the processing;
• b) the categories of personal data concerned;
• c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
• d) where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;
• e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
• f) the right to lodge a complaint with a supervisory authority;
• g) where the personal data are not collected from you, any available information as to their source;
• h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

Where personal data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards relating to the transfer.

Right to rectification

You have the right to ask the relevant controller to correct inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by means of a supplementary statement.

Right to erasure ("right to be forgotten")

You have the right to ask the relevant controller to erase personal data concerning you without undue delay where one of the following grounds applies, subject to any exceptions provided by law:

• a) your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• b) your personal data have been processed based on your consent, you have withdrawn that consent and there are no other legal grounds for the processing;
• c) you object to the processing and there are no overriding legitimate grounds for the processing (including where you object to direct marketing);
• d) your personal data have been unlawfully processed;
• e) your personal data have to be erased for compliance with a legal obligation to which the controller is subject.

If you would like to request erasure but are unsure whether it applies or whether any limitation applies, you can contact us using the details in Section L, and we will help you to direct your request appropriately.

Right to restriction of processing

You have the right to request restriction of processing where one of the following applies:

• a) the accuracy of the personal data is contested by you;
• b) the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead;
• c) the controller no longer needs the personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims;
• d) you have objected to the processing and verification of whether the controller's legitimate grounds override yours is pending.

Where processing has been restricted, with the exception of storage, the personal data concerned shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Right to data portability

You have the right to receive some of the personal data concerning you in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance. This right applies to personal data concerning you which:

• a) you have provided to the controller,
• b) are processed based on your consent or on a contract, and
• c) are processed by automated means.

Where these conditions are met, you also have the right to have such personal data transmitted directly from one controller to another, where technically feasible.

Right to object

Where processing is based on legitimate interests or the performance of a task carried out in the public interest, you may object on grounds relating to your particular situation. The relevant controller must then stop the processing unless it demonstrates compelling legitimate grounds that override your interests, rights and freedoms, or needs the data for the establishment, exercise or defense of legal claims. You may object to processing for direct marketing purposes at any time, and such processing must then stop.

Right to withdraw consent

Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Right to lodge a complaint

You have the right to lodge a complaint with the supervisory authority in the EU Member State of your habitual residence, place of work or place of the alleged infringement.

H. The Security of Your Personal Data

We use technical and organizational safeguards to protect personal information against unauthorized access, disclosure, misuse, alteration, destruction and loss. Our measures include:

1. Encryption to protect personal information during transmission;

2. Security features to help protect your account;

3. Reviews of our data collection, storage and processing practices, including physical security measures, to prevent unauthorized access to our systems.

I. How Long We Retain Your Personal Data

We retain personal data for different periods depending on the data and the purpose of the processing, as described below. Retention of the service content is determined by the controller for your project and explained in the privacy policy presented after you log in. Deleting an App account does not necessarily delete the service records held for that controller.

1. Personal information for which we act as a controller, such as App login and account information, is retained until the account is deleted, and thereafter only as long as necessary for the purposes described in this Policy or as required by law.

2. Where the retention period cannot be determined in advance, the criteria used to determine the period include the duration of the customer contract, statutory retention obligations, and the establishment, exercise or defense of legal claims.

J. Children's Privacy

The SERVICE is not intended to be accessed or used by children under 18 years old. If you are under the age of 18, you may use the SERVICE only with the involvement of your parent or legal guardian. If we obtain actual knowledge that an account is associated with a registered user under the age of 18, we will promptly take the steps required to address it, including deleting the information we hold as a controller and notifying the responsible service provider so that it can act on the data it controls. If you are a parent or guardian and discover that your child has provided personal information without your consent, please contact your service provider or us using the details in Section L, and the relevant controller will deal with the request.

K. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. The latest version is available on the Portal and in the Mobile Apps. We will notify you of material changes through the Portal, the Mobile Apps or, where appropriate, by e-mail.

L. Contact Us

If you have questions about, or wish to exercise your rights regarding, the App login and account processing for which Akuvox Singapore acts as a controller, you can contact Akuvox using the details below. For questions about the service content processed for your property, please contact the controller shown for your project after you log in. Please provide your name (or nickname), your preferred method of contact, and the details of your request or comment, together with any relevant website links.

Akuvox Data Protection Officer (DPO): Tyler Zeng, e-mail: dpo@akuvox.com. General support: support@akuvox.com.

Akuvox Singapore forwards requests concerning the service content to the responsible controller and does not decide their outcome in its place.

Akuvox - Device Privacy Policy - U.S. Addendum

Last updated: January 9, 2026

United States Addendum

This addendum supplements the main Privacy Policy for individuals covered by applicable U.S. state consumer privacy laws, including the California Consumer Privacy Act ("CCPA"). It summarizes the types of personal information that we collect, how such information may be used, the privacy rights which may be available to individuals who reside in the United States, and how to exercise such rights. Personal information that we process on behalf of a customer (such as the property manager responsible for your project) is addressed in the privacy policy presented after you log in, and we forward requests about that information to the customer.

Categories of Personal Information Collected

We collect several types of information from and about users of our Devices, including information:

• By which you may be personally identified (such as name, address, phone number, biometric identifiers or information, such as facial geometry scans) ("personal information");
• That is about you but individually does not identify you; and
• About your internet connection, the Devices you purchase, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you use the Devices.

The personal information we collect about you may include the following, as categorized by the California Consumer Privacy Act ("CCPA"):

• Identifiers, such as name, postal address, personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
• Commercial information, such as records and history of products or services purchased or considered.
• Biometric information, such as faceprints.
• Internet or other similar network activity, such as interactions with our Devices.
• Sensory data, such as audio, electronic, or other similar information.

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Devices and their features to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into with us, including for billing and collection.
• To notify you about changes to our Devices or any products or services we offer or provide.
• To allow you to participate in interactive features on our Website.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• For any other purpose with your consent.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Akuvox's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Akuvox about our Device users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply agreements to which we are a party, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Akuvox, our customers, or others.

Biometric Data Notice

Some Devices connected to property services may collect biometric identifiers and information, specifically facial geometry scans, for facial recognition and access control. The property manager or other responsible customer determines the purposes and legal requirements for that processing, which is explained in the privacy policy presented after you log in. Akuvox does not independently use such data to improve its own products.

We will not retain any personal information about you, including any biometric identifiers or information, for longer than necessary to fulfill the original purpose for which it was collected, which shall in no event exceed three years after you have last interacted with the Device. You may delete your biometric data at any time by deleting your user account. When you delete your account or upon expiration of the retention period above, we will delete your biometric identifiers and information from our systems unless we are legally required to retain it for a longer period.

By enabling facial recognition features or using a Device configured to collect such data, you acknowledge that you have been informed of our collection, use, and retention practices with respect to biometric data. If you have any questions regarding our biometric data policies or practices, please contact us at support@akuvox.com.

California Privacy Rights

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise such rights.

Right to know and data portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your CCPA Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

Right to Correct

You have the right to request that we correct any inaccurate personal data we maintain about you.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your CCPA Rights), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your CCPA Rights

To exercise your CCPA rights as described above, please submit a request by emailing us at support@akuvox.com or calling us at (+86) 592-213-3061 (ext. 7527). Only you, or someone legally authorized to act on your behalf, may submit a request to exercise your CCPA rights. You may also make a request to exercise CCPA rights on behalf of your child.

You may only submit a request to know twice within a 12-month period. Your CCPA rights request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact support@akuvox.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other U.S. State Privacy Rights

Depending on your state of residence, you may have rights under applicable state law concerning the personal information that we collect and maintain about you. These rights may include:

• The right to access the personal information that we maintain about you.
• The right to obtain a copy of the information we maintain about you.
• The right to request that we delete certain information we maintain about you.
• The right to correct any inaccuracies in the personal information we maintain about you.
• The right to withdraw your personal information from certain processing activities.
• The right to know how we have used your personal information, including whether we have shared it with other parties.
• The right to appeal decisions we make regarding your privacy rights.

The exact nature and scope of these rights vary by state. To exercise any applicable state privacy rights, please submit a request by emailing us at support@akuvox.com. We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact support@akuvox.com.

Only you, or someone legally authorized to act on your behalf, may make a consumer rights request. If you are a parent or legal guardian, you may also make a consumer rights request on behalf of your child. If you are an authorized agent making a request on behalf of an individual, we may request additional information from you to verify the request. We cannot respond to certain requests if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use the personal information provided in the request to verify the requestor's identity or authority to make the request and to facilitate and respond to the request.

Some states have varying timelines for when a response to a consumer rights request must be given. We endeavor to substantively respond to a verifiable consumer request within the timeframe required by applicable law. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically. The response we provide will explain the reasons we cannot comply with a request, if applicable. If we reject a request, you may have the right to appeal our decision. In such cases, you will be provided with details on how to request an appeal of our decision.

We will not discriminate against you for exercising any of your applicable state privacy rights. Unless otherwise permitted by law, we will not deny you goods or services, charge you different prices or rates for goods or services (including through granting discounts or other benefits or imposing penalties), provide you with a different level or quality of goods or services, or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services for exercising your privacy rights.