Privacy Policy

Effective Date: October 2026 Last Updated: October 2026

1. Introduction

This Privacy Policy describes how Milo ([company legal entity: needs legal input]) ("we," "us," or "our") collects, uses, shares, and protects information when you use our services through the Milo platform at justmilo.app, justmilo.co, and related subdomains (collectively, the "Services").

This Policy applies to:

• Tenants: businesses that have signed up for Milo's Services.
• Tenant Users: employees, contractors, or agents of Tenants who use the Services.
• End Customers: individuals whose data is processed through the Services by Tenants (e.g., call participants, leads, contacts).
• Visitors: anyone visiting our public websites.

2. Information We Collect

2.1 Information You Provide

• Account information: name, email, phone, company name, role.
• Billing information: payment method, billing address.
• Content submitted to the Services: contacts, contracts, calls, messages, notes.
• Communications with us: support requests, feedback, survey responses.

2.2 Information Collected Automatically

• Usage data: pages visited, features used, time spent, click paths.
• Device data: IP address, browser, operating system, device identifiers.
• Cookies and similar technologies (see Section 8).

2.3 Information from Third Parties

• Call tracking platforms (TrackDrive, Retreaver, Ringba, CallGrid, Convoso, and similar) when you connect them to the Services.
• Payment processors.
• Service providers and integration partners.
• Publicly available sources, including LinkedIn and business directories.

2.4 Data Processed on Behalf of Tenants

When you are a Tenant, the Services process data you submit (including data about your End Customers) on your behalf. You are the controller of that data; we are the processor.

3. How We Use Information

We use information to:

(a) provide, maintain, and improve the Services;

(b) authenticate users and secure accounts;

(c) process payments;

(d) communicate with you about your account, the Services, and Milo;

(e) provide customer support;

(f) generate aggregated and anonymized data and derived insights (see Section 5);

(g) develop and improve our products, features, and AI/ML models;

(h) detect, prevent, and respond to fraud, security incidents, and policy violations;

(i) comply with legal obligations; and

(j) operate Milo's own business activities, including the operations of affiliated businesses and subsidiaries.

4. Legal Bases for Processing (Where Applicable)

Where GDPR or similar laws apply, we rely on the following bases:

• Performance of a contract (providing the Services).
• Legitimate interests (improving the Services, securing the platform, generating aggregated insights).
• Consent (where required).
• Compliance with legal obligations.

5. Aggregated and Derived Data

Milo generates aggregated, anonymized, and de-identified data from Customer Data ("Aggregated Data") and insights, patterns, and benchmarks derived from Aggregated Data across the Milo platform ("Derived Insights").

Milo uses Aggregated Data and Derived Insights to:

• improve and develop its products, features, and ML models;
• create industry benchmarks, market analyses, and research;
• market its Services;
• inform the strategy and operations of Milo and its affiliated businesses; and
• pursue any other lawful purpose.

Milo does not re-identify Aggregated Data, and does not attribute Aggregated Data or Derived Insights to specific Tenants or End Customers when sharing externally.

6. How We Share Information

We share information only as follows:

6.1 With Service Providers

Cloud hosting, payment processors, analytics, customer support, email delivery, AI/ML providers, and other vendors who process data on our behalf under appropriate contractual protections.

6.2 With Other Tenants

We do not share your raw, identifiable Customer Data with other Tenants. Milo may share Aggregated Data and Derived Insights with other Tenants as part of the Services.

6.3 With Milo Affiliates

Milo may share information, including Aggregated Data and Derived Insights, with affiliates, subsidiaries, and related entities of Milo for purposes consistent with this Policy, including operating Milo-affiliated businesses.

6.4 Legal and Safety

We may disclose information if required by law, subpoena, or court order, or if necessary to protect rights, property, or safety.

6.5 Business Transfers

In a merger, acquisition, financing, or sale of assets, information may be transferred to the acquiring entity.

6.6 With Your Consent

With your explicit consent for purposes not otherwise described.

7. Data Retention

We retain personal information for as long as needed to provide the Services, comply with legal obligations, resolve disputes, and enforce agreements. Specific retention periods:

• Account data: for the duration of your account, and after termination for the period set out in the Master Services Agreement.
• Call recordings: as configured by the Tenant, subject to applicable law.
• Aggregated Data and Derived Insights: indefinitely.
• Billing records: as required by tax and accounting law.

8. Cookies and Tracking

We use cookies and similar technologies for authentication, preferences, analytics, and security. You can manage cookies through your browser settings. Disabling certain cookies may limit functionality.

9. Security

We implement reasonable administrative, technical, and physical safeguards to protect personal information, including encryption in transit and at rest, access controls, and audit logging. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If a security incident affects your information, we will notify you as required by law.

10. Your Rights

Depending on your jurisdiction, you may have rights including:

• access to your personal information;
• correction of inaccurate information;
• deletion of your information;
• restriction or objection to processing;
• portability of your information;
• withdrawal of consent (where processing is based on consent).

For Tenant Users and End Customers: requests regarding data processed on behalf of a Tenant should be directed to that Tenant, who is the controller of that data. We will support the Tenant in responding.

To exercise rights regarding data Milo controls, contact us at info@vabees.com.

11. International Transfers

Milo is based in [governing state: needs legal input]. By using the Services, you understand that information may be transferred to, stored in, and processed in jurisdictions other than your own. Where required, we use appropriate safeguards (such as Standard Contractual Clauses) for international transfers.

12. Children

The Services are not intended for individuals under 18. We do not knowingly collect information from minors.

13. California Privacy Rights (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, gives you the following rights over the personal information we hold about you:

• Know. Request the categories and specific pieces of personal information we have collected about you, the categories of sources, our business or commercial purpose for collecting it, and the categories of third parties to whom we disclose it.
• Delete. Request that we delete personal information we collected from you, subject to the exceptions the statute allows.
• Correct. Request that we correct inaccurate personal information we hold about you.
• Opt out of sale or sharing. Direct us not to sell or share your personal information. We do not sell personal information, and we do not share it for cross-context behavioral advertising.
• Limit use of sensitive personal information. Direct us to limit our use and disclosure of sensitive personal information to what is necessary to provide the Services.
• Non-discrimination. Exercise any of these rights without being denied service, charged a different price, or given a different level of quality. Any contract term purporting to waive these rights is unenforceable.

How to exercise them. Email info@vabees.com. We will acknowledge your request within 10 business days and respond within 45 calendar days, and we may extend once by a further 45 days where the statute permits, telling you why. We must verify your identity before acting on a request to know, delete, or correct, and we may ask for information sufficient to match you to the personal information we hold.

Authorized agents. You may use an authorized agent to submit a request on your behalf. We may require written proof of the agent's authority and may still verify your identity directly.

Where you are a Tenant User. Where we process personal information on a Tenant's behalf as a service provider, we will refer your request to that Tenant and assist them in responding.

We review and update this section at least every 12 months.

14. Call Recording and Telecommunications

The Services integrate with call tracking platforms that may record telephone calls. Tenants are solely responsible for:

• complying with all federal and state call recording laws (including one-party and two-party consent jurisdictions);
• providing required disclosures and obtaining consent from call participants;
• complying with TCPA, CAN-SPAM, and similar telemarketing laws.

Milo provides tools, not legal compliance. You must independently ensure your use complies with applicable law.

15. Changes to This Policy

We may update this Privacy Policy. Material changes will be communicated with at least the notice period set out in the Master Services Agreement. The "Last Updated" date at the top reflects the most recent revision.

16. Contact Us

Questions, requests, or concerns: Email: info@vabees.com Mailing address: [company address: needs legal input]