Vallo Privacy Notice

Last Updated: Apr 26, 2026

Introduction

This Privacy Notice ("Notice") describes how Hummingbird Ventures LLC, DBA Vallo ("Vallo," "we," or "us") collects, uses, and shares Personal Information from our business customers and visitors to our websites (e.g., govallo.ai) and our platform (collectively, "Sites"), where we act as a controller or business under applicable privacy laws.

When we collect Personal Information as a processor or service provider on behalf of business customers, we do so in accordance with our contract with them. If you have questions about how a business customer processes your Personal Information, please contact that business customer directly.

This Notice is incorporated into and subject to our Terms of Use.

Your Consent

By using the Sites and Services, you consent to the terms of this Notice. If you do not agree, please do not provide us with your Personal Information. We will provide notice and seek your consent before materially changing how we use your Personal Information where required by law.

Description of Our Services

Vallo provides AI-powered voice agent services that help SMB customers handle calls, generate transcriptions, and manage communications. Our Services may be updated over time. "Services" as used in this Notice means our voice agent platform, related applications, and the Sites.

Personal Information We Collect

"Personal Information" means information that identifies or is reasonably linkable to you, including information referred to as "personal data," "personally identifiable information," or similar terms under applicable law.

Information You Provide to Us

• Contact information: name, email address, phone number, and business address when you create an account, contact support, or communicate with us.
• Professional information: company name, industry, and account details.
• Communications: records of your interactions with us, including support inquiries.

Information We Collect Automatically

When you use our Sites, we and our service providers may automatically collect:

• Device and usage data: IP address, browser type, operating system, pages visited, time on page, access times, and similar technical data.
• Log files: IP address, user agent, and URLs visited, collected automatically when you access our Sites.
• Cookies and tracking technologies: See the Cookies section below.

Information Processed on Behalf of Business Customers

We collect and process the following categories of Personal Information on behalf of our business customers, through the dedicated phone numbers and voice agent services they have activated:

1. Caller ID information (name and phone number, where available);
2. Call recordings of calls placed to or through the Services;
3. Transcriptions of calls processed through the Services; and
4. Text messages (SMS/MMS) sent or received through the Services.

This data is collected to provide our business customers with voice agent functionality, call analytics, and related services. We and our business partners may use this data to improve the accuracy of the Service and provide analytics to our business customers.

How We Use Personal Information

We use Personal Information to:

• Provide and improve the Sites and Services;
• Communicate with you about your account, support requests, and Service updates;
• Personalize and optimize the Services;
• Send marketing and promotional communications (subject to your opt-out rights);
• Conduct research, analytics, and product development;
• Comply with our contracts, legal obligations, and regulatory requirements;
• Detect and prevent fraud, unauthorized access, and misuse; and
• Administer our general business operations.

Disclosure of Personal Information

We may share Personal Information with:

• Service providers and sub-processors that assist in providing the Services;
• Affiliated entities under common control with Vallo;
• Business customers on whose behalf we collected the data, or as directed by them;
• Professional advisors (attorneys, accountants, auditors) under confidentiality obligations;
• Government and law enforcement when required by law, regulation, or legal process;
• Successors in connection with a merger, acquisition, or sale of assets; and
• Other parties with your permission or as otherwise permitted by law.

We do not sell Personal Information in exchange for monetary consideration.

Cookies and Tracking Technologies

We use cookies and similar technologies to support Site functionality and service delivery. Cookies may collect information such as your IP address, browser type, pages visited, and session duration. You may control cookies through your browser settings. Note that disabling certain cookies may affect Site functionality. Where required by law, we will present a cookie consent banner.

Marketing Communications

U.S. Customers: You may opt out of marketing communications at any time by emailing legal@govallo.ai or using the unsubscribe link in our emails.

Non-U.S. Customers: Where required by law, we will obtain your consent before sending marketing communications. You may withdraw consent at any time by emailing legal@govallo.ai.

Third-Party Sites

Our Sites may contain links to third-party websites. Vallo is not responsible for the privacy practices of those sites. Please review their privacy policies directly.

Your Rights if You Are an EU, UK, or Swiss Data Subject

This section applies to EU, UK, and Swiss data subjects (including EEA countries Iceland, Liechtenstein, and Norway). "Personal Information" as used here means "personal data" under applicable European data protection law, including the GDPR.

Under applicable European data protection law, Vallo acts as both a "Controller" (for data you provide directly as a customer or site visitor) and a "Processor" (for data processed on behalf of our business customers through the Services). If Vallo is acting as a Processor for a business customer, please contact that business customer directly with questions about their data practices.

Legal Bases for Processing

Where Vallo is a Controller, we rely on the following legal bases:

• Consent: Where you have provided consent, which you may withdraw at any time.
• Contract: Where processing is necessary to perform or enter into a contract with you.
• Legitimate Interests: To improve our Services, prevent fraud, and support our business operations, where our interests are not overridden by your rights.
• Legal Obligation: Where processing is necessary to comply with applicable law.

Your Rights

Subject to applicable law and identity verification, EU, UK, and Swiss data subjects have the right to:

• Access: Obtain confirmation of and access to your Personal Information we hold.
• Rectification: Correct inaccurate or incomplete Personal Information.
• Erasure: Request deletion of your Personal Information in certain circumstances.
• Restriction: Request that we limit processing of your Personal Information in certain circumstances.
• Data Portability: Receive your Personal Information in a structured, commonly used, machine-readable format.
• Object: Object to processing based on legitimate interests or for direct marketing.
• Withdraw Consent: Where processing is based on consent, withdraw it at any time without affecting prior processing.
• Lodge a Complaint: File a complaint with your local data protection authority.

To exercise your rights, contact us as described in the "How to Contact Us" section below.

California Privacy Rights (CCPA)

This section applies to California residents and describes our practices as a "business" under the California Consumer Privacy Act ("CCPA").

Categories of Personal Information Collected

• Identifiers: name, address, email, phone number, IP address, and similar identifiers.
• Customer Records: account and profile information.
• Commercial Information: subscription and transaction records.
• Internet and Network Activity: browsing history, search history, and interaction data on our Sites.
• Audio and Electronic Information: call recordings and transcriptions processed through the Services.
• Inferences: derived from the above to support service delivery and analytics.

Sources of Personal Information

We collect Personal Information directly from you, from business customers, from automated data collection on our Sites, and from service providers and analytics partners.

Purposes of Collection and Use

As described in the "How We Use Personal Information" section above: service delivery and support, analytics and improvement, marketing, legal compliance, security, and general business operations.

Sale and Sharing

We do not sell Personal Information in exchange for monetary compensation. We may share identifiers, commercial information, and internet activity data with advertising networks and analytics providers for marketing purposes. We do not sell or share Personal Information of individuals we know to be under 16.

Your California Rights

Subject to verification of identity, you have the right to:

• Know/Access: Request information about the Personal Information we have collected about you, including categories, sources, purposes, and third parties.
• Correct: Request correction of inaccurate Personal Information.
• Delete: Request deletion of your Personal Information, subject to certain exceptions.
• Opt Out of Sale/Sharing: Opt out of the sharing of your Personal Information for cross-contextual behavioral advertising. To opt out, adjust your cookie preferences on our Site or enable a Global Privacy Control ("GPC") signal in your browser.
• Non-Discrimination: We will not discriminate against you for exercising your rights.

To submit a request: Email legal@govallo.ai or call (678) 820-6675. We will verify your identity before processing requests.

International Data Transfers

Our Services are available globally. Personal Information we collect may be transferred to and processed in the United States or other countries where Vallo or its Sub-processors operate. These countries may have data protection laws that differ from those in your country. Where required by applicable law, we rely on appropriate transfer mechanisms — including Standard Contractual Clauses for transfers from the EU, UK, and Switzerland — to protect your Personal Information in accordance with this Notice. For more information about international transfer safeguards, please contact us or refer to our Data Processing Addendum.

Data Retention

We retain Personal Information for as long as necessary to provide the Services, fulfill legal and contractual obligations, and support our legitimate business interests. Call recordings and transcriptions processed on behalf of business customers are retained in accordance with our agreement with those customers and applicable law. When data is no longer needed, we delete or deidentify it.

Security

We employ technical and organizational measures designed to protect Personal Information, including encryption, access controls, and ongoing monitoring. However, no system is perfectly secure, and we cannot guarantee the absolute security of your data. You can help protect your account by using a strong, unique password.

Children's Privacy

The Services are not directed to children under 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect Personal Information from children. If you believe we have received Personal Information from a child, please contact us at legal@govallo.ai.

Updates to This Notice

We may update this Notice from time to time. We will post the updated Notice on our Sites and note the revised date. Your continued use of the Sites and Services after changes are posted constitutes acceptance of the updated Notice.

How to Contact Us

Email: legal@govallo.ai Mail: Vallo, Attn: Legal, 675 Ponce de Leon Ave NE Suite 8500, Atlanta, GA 30308 Phone: (678) 820-6675

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