Last Updated: September 15, 2026

Oldham Technology, Inc. (“Oldham Technology,” “we,” “us,” or “our”) provides the Oldham Technology Connect app (the “App”) so that the employees and other authorized users of our business customers can make calls, send texts, message coworkers, and hold video calls. This Privacy Policy explains what information we collect through the App, how we use and share it, how long we keep it, and your choices.

1. About This Policy

The App is for business use. Accounts are set up for our business customers and their authorized users; you cannot create an account in the App. The organization that gave you access, usually your employer (“your organization”), manages your account and may have its own policies for business communications. This policy does not cover your organization’s privacy practices or other companies’ apps and websites.

2. Information We Collect

We collect information that you or your organization provides, information created as you use the App, and information from device features that you allow the App to access.

• Account information: your name, business email address, phone number and extension, login credentials, and organization name.
• Communications: who you communicate with; the content of your texts and chat messages and the photos and files you send; voicemail; and call and message records, such as date, time, and duration. Voice and video are transmitted in real time to connect your calls. If your organization turns on call recording, transcription, or AI call summaries, we also process those recordings, transcripts, and summaries.
• Contacts: if you allow access, the contacts on your device, plus any company directory your organization provides. Contact details may be sent to our systems so you can call and message contacts and see who is calling.
• Location: if you allow access, your device’s precise location at the moment you choose to share it in a message. The App does not track your location continuously.
• Device and usage information: device type, operating system, App version, IP address, network information, push notification tokens, call-quality statistics, crash reports, and diagnostic logs.
• Support information: what you tell us when you contact us for help.

3. App Permissions

The App asks for your permission before it accesses the device features below. You can change your choices at any time in your device settings. If you deny a permission, the related feature may not work (for example, calls require the microphone), but you can still use the rest of the App.

4. How We Use Information

We use information to:

• Provide the service: set up and authenticate accounts, connect calls, deliver messages, host video calls, send notifications, keep your history available on all your devices, and provide customer support.
• Keep the service reliable and secure: monitor performance and call quality, fix problems, and prevent fraud, spam, and abuse.
• Improve our products: understand how the App is used, fix bugs, and develop new features.
• Communicate with you: send service and security notices and information about our products and services. You can opt out of marketing messages at any time.
• Comply with the law: meet legal and regulatory obligations, including 911 requirements, respond to lawful requests, enforce our agreements, and protect the rights and safety of our users and others.

We may also use information for other purposes with your consent or at your organization’s direction. We may use aggregated or de-identified information that cannot reasonably identify you, and we will not attempt to re-identify it.

5. How We Share Information

We share information in the following ways:

• With the people you communicate with. They receive your calls, messages, and files and may see your name, phone number, or profile information.
• With your organization. Your organization’s administrators manage your account and, depending on their settings, may access information such as call and message records, voicemail, and recordings.
• With service providers. We use companies that help us run the service, such as our communications software provider, cloud hosting providers, Apple and Google push notification services, and customer support tools. If your organization turns on transcription or AI features, the content those features need is shared with the AI providers that power them. Service providers may use your information only to provide services to us, must give it the same or equal protection described in this policy, and may not use it to train their AI models.
• With carriers and telecommunications partners. To complete calls and deliver texts to and from other networks, we share the phone numbers, message content, and routing details required.
• With emergency services. If you call 911, we share your phone number and the location information on file for your account so responders can find you.
• For legal and safety reasons. When we believe in good faith that the law or legal process (such as a subpoena or court order) requires it, or that it is needed to protect the rights, property, or safety of Oldham Technology, our customers, our users, or the public.
• With affiliates and in business transfers. With companies under common ownership with Oldham Technology, which must follow this policy, and as part of a merger, acquisition, or sale of assets, with any notice the law requires.
• With your consent or at your direction.

We do not sell your personal information, and we do not share it for targeted advertising. We do not share your mobile phone number or text messaging opt-in information with third parties for their marketing purposes.

6. How Long We Keep Information

We keep personal information only as long as needed to provide the service, for the purposes in this policy, and to meet legal, tax, billing, and regulatory requirements, resolve disputes, and enforce our agreements. In general:

• Account information is kept while your account is active.
• Messages, call records, voicemail, and recordings are generally kept while your organization’s account is active, unless they are deleted sooner under your organization’s settings or our retention schedules, or the law requires us to keep them longer.
• Diagnostic data and logs are kept for a shorter period, unless we need them longer for security or troubleshooting.

When we no longer need information, we delete or de-identify it.

7. How We Protect Information

We use administrative, technical, and physical safeguards to protect personal information, including encrypting data in transit, limiting access to people who need it, and requiring our service providers to protect it. We also protect call records and other customer proprietary network information (CPNI) as required by Federal Communications Commission rules. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

8. Your Choices

• Permissions and notifications: change them at any time in the App or in your device settings.
• Marketing: unsubscribe using the link in any marketing email or by contacting us. We will still send messages about the service and your account.
• Withdrawing consent: where we rely on your consent, you can withdraw it at any time by changing your settings or contacting us. This does not affect processing that already happened.

9. Access, Correction, and Deletion

You can ask us to access, correct, or delete your personal information, or to delete your account, by emailing privacy@oldhamtechnology.com or using the contact information below. Your organization’s administrator can also update or remove your account.

We will verify your identity before acting on a request and may confirm it with your organization, since it manages your account. We will tell you how long your request will take. When an account is deleted, we delete the associated personal information, except information we must keep for legal, billing, security, or fraud-prevention reasons (see Section 6).

Depending on where you live, you may have other rights under state privacy laws, such as getting a copy of your information or appealing our decision on a request. We will not discriminate against you for exercising your privacy rights.

10. Children’s Privacy

The App is for business use and is not directed to children. We do not knowingly collect personal information from children under 13. If you believe a child has given us personal information, contact us and we will delete it.

11. Where Information Is Processed

Oldham Technology is based in the United States. We and our service providers may process information in the United States and other countries, where data protection laws may differ from those where you live. Wherever it is processed, we protect it as described in this policy.

12. Changes to This Policy

We may update this policy from time to time. We will post the updated version and change the “Last Updated” date above. If we make material changes, we will also notify you, such as in the App, by email, or through your organization.

13. Contact Us

If you have questions about this policy or want to make a privacy request, contact us:

Oldham Technology, Inc., Attn: Privacy, 1180 N Mountain Springs Pkwy, Springville, Utah 84663

Email: privacy@oldhamtechnology.com | Phone: (801) 877-2190