Privacy Policy

Last Updated: JANUARY 19, 2026

AffinityClick Inc.’s “Hushed” services are founded on the principle of helping people keep their private communications private without compromise — as they should be. 

The purpose of this Privacy Policy is to outline the commitment of AffinityClick Inc. (the “Company”) towards respecting your privacy and to comply with the applicable privacy laws and associated rules governing how or when any of your personal information is collected, used and disclosed while accessing the Company’s “Hushed” Services (as defined in the Company’s Terms of Service located at Terms of Service | Hushed (the “Terms of Service”). Your access to and use of the Services is subject to the Terms of Service. Any capitalized terms used but not defined in this Privacy Policy have the meanings provided in the Terms of Service. In case of any conflict between any provision of this Privacy Policy and any provision of the Terms of Service, the provision of this Privacy Policy shall govern.

The Company knows that you and all the Company’s users take your and their respective personal data and information very seriously, as does the Company. The Company strongly encourages you and all its users to familiarize themselves with this Privacy Policy to understand the circumstances where both non-identifiable or personally identifiable information may be collected or processed while using the Services. 

In this Privacy Policy, “personal information” means information about an identifiable individual.

Although all the provisions of this Privacy Policy are important, certain provisions of this Privacy Policy have been purposely fully capitalized and/or bolded to specifically and conspicuously draw and focus your attention to them. Please pay particular attention to all such capitalized and/or bolded provisions.

BY USING THE SERVICES, YOU ARE DEEMED TO HAVE READ AND ARE INDICATING YOUR ACCEPTANCE OF, AND YOU AGREE TO BE BOUND BY, THIS PRIVACY POLICY AND GIVE YOUR EXPLICIT, INFORMED CONSENT TO THE COLLECTION, USE AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, THEN YOU HAVE NO RIGHT TO ACCESS OR USE THE SERVICES AND YOU MUST NOT DO SO. 

European Residents: If you reside in the European Union, the European Economic Area or Switzerland or a country following substantially similar legislation regarding the protection of “personal data”, then please also see the Company’s European Privacy Policy below for further information on your rights under applicable European privacy laws.

California Residents: If you reside in California, then please also see the Company’s California Privacy Rights section below for further information on your rights under the California Consumer Privacy Act.

Residents of Other Jurisdictions: Certain other jurisdictions, at both national and sub-national levels (e.g. US states, Canadian provinces, etc.), may provide their residents with other legal rights and obligations that impact their residents’ access to and use of the Services and that may not be expressly addressed in this Privacy Policy. If you have any questions as to how the Company protects your rights as a resident of any such jurisdiction that are not otherwise discussed in this Privacy Policy, then please contact the Company at support@hushed.com.

1. Changes to this Privacy Policy.

The Company reserves the right, at its sole discretion, to update, modify or change this Privacy Policy at any time by publishing the updated, modified or changed Privacy Policy on the Website and/or through the App. If the Company makes any material updates, modifications or changes to this Privacy Policy, then the Company will provide prominent, advance notice of such material updates, modifications or changes on the Website and/or through the App. Any updates, modifications or changes to this Privacy Policy will be effective: (a) immediately for new users of the Services; or (b) upon the expiration of the applicable notice period related to such updates, modifications or changes as posted on the Website and/or through the App. The Company may require you to provide consent to the updated, modified or changed Privacy Policy in a specified manner before further use of the Services is permitted. If you do not agree to any update(s), modification(s) or change(s), then your recourse is to cease using the Services, failing which your Account and your access to the Services will immediately terminate. Otherwise, your continued use of the Services will constitute your acceptance of such update(s), modification(s) or change(s). PLEASE REGULARLY CHECK THE WEBSITE TO VIEW THE THEN-CURRENT PRIVACY POLICY.

2. Withdrawal of Consent.

You may withdraw your consent to this Privacy Policy at any time, unless such consent would frustrate the performance of a legal obligation. Your withdrawal may restrict the Company’s ability to provide the Services. There are limited circumstances in which the Company may collect, use or disclose personal information without your consent. They include, without limitation: (a) when the collection, use or disclosure of personal information is permitted or required by law; (b) in an emergency that threatens an individual’s life, health or personal security; (c) when the personal information is available from a public source; (d) when the Company requires legal advice from a lawyer; (e) for the purposes of collecting debt; (f) to protect the Company from fraud; and (g) to investigate an anticipated breach of an agreement or a contravention of law.

3. How the Company Collects Information.

The Company collects information about you from a variety of sources when you access or use the Services including, without limitation: (a) directly from you (when you sign up for an Account or use the Services); (b) from the Company’s business partners and service providers; (c) from third party sources; and (d) automatically from devices that you use to connect to any Services.

4. Types of Information the Company Collects and Why.

The amount and type of information that the Company collects about you depends on the nature of your interaction with the Services. The Company collects information only as may be necessary or appropriate to fulfill the purposes of your interaction with the Company and the Services. The Company collects the following information based on different scenarios of usage while accessing the Services:

a. Account Information.

When signing up for an Account, the Company collects your Login ID (including, without limitation, your Email address and password) – passwords are hashed and encrypted before being transmitted to the Company’s servers; as such the Company does not see the clear text version of your password. This information is used to verify your identity and authenticate you when you access the Services.

b. Contact Information.

i. your Login ID, which the Company uses to verify your identity and authenticate you;

ii. communications with the Company (e.g. interaction with the Company’s sales or customer support teams), which information is used to allow the Company to properly respond to any questions or inquiries you might have – the Company may also use such information to send you marketing and other promotional information;

iii. when buying phone numbers from certain countries, the Company and/or the Company’s partners may ask you to submit proof of identity and/or address verification information to comply with the requirements of local regulations in the countries from which such phone number(s) originate including, without limitation, your government issued identification (such as driver’s license information, state-issued identification number (e.g. social security, social insurance or similar number and/or information) and/or passport information); the Company may share such information with its third party telecommunication providers to fulfill applicable transaction requirements including, without limitation, pursuant to applicable “know your customer” and similar requirements to verify your identity and to provide the phone number to your Account; and 

iv. at your discretion, the Company allows you to add other contacts and phone numbers to your App’s address book until you choose to delete such information or your Account – you are entirely and solely responsible for any such information that you choose to add.

c. Usage Information.

i. like most website and app operators, the Company collects information about your interactions with the Services, such as which screens or pages you visit on the Website, what you click on, when you perform those actions, language preferences, etc. (see Section 8 below relating to “Cookies and Tracking” for more information on how the Company collects such information);

ii. message content contained within SMS/MMS segments as well as the source and destination numbers are stored on the App until you delete your message history, associated phone number or your Account; 

iii. call detail records (“CDRs”) are stored until you delete the call log, associated phone number or your Account – CDRs contains various attributes of each call such as time, duration, completion status, source number and destination number;

iv. voicemail recordings and voicemail greetings are stored until you delete voicemail recordings, voicemail greetings, the associated phone number or your Account; and

v. the Company may collect and use information relating to the location of your connected device if and when you choose to specifically activate and use the Services to search for phone numbers that may be geographically associated with your local vicinity.

You are entirely and solely responsible for any information that you disclose or share with other users through the Services. The Company strongly recommends that you use extreme caution in sharing any personal information with other persons through the Services. The Company is not responsible for any information that you disclose to other persons through the Services.

d. Billing Information.

Payment information is collected by the Company’s third party payment providers such as Apple, Google, Stripe or Coinbase, each of which may require you to provide billing details and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date). In most cases, the Company will have access to transaction reference numbers and/or your billing information pertaining to each payment; the Company does not, however, store or otherwise process any credit card information. This information is used to track payment and for processing purposes. Please refer to each payment provider’s terms and conditions and privacy policies as applicable. 

For ease, Stripe’s privacy policy may be found here: https://stripe.com/us/privacy and Coinbase’s privacy policy may be found here: https://www.coinbase.com/legal/privacy 

e. Information from Third Parties and Integration Partners.

i. The Company collects your information from third parties if you give permission to those third parties to share your information with the Company (e.g. if you enable service integrations with DropBox or Slack, they may send your information they have collected in accordance with their respective privacy policies to the Company, all of which will be controlled by such third party). This information is used to better serve you and optimize your usage of the Services; and

ii. To the extent permitted by applicable law, the Company may receive additional information about you, such as demographic data or fraud detection information and warnings, or other information about you from partner networks.

5. How the Company Uses the Information it Collects.

The Company uses your information for the purposes identified in this Privacy Policy at the time of collection or for a purpose related thereto including, without limitation, to develop and provide the Services. In addition to the uses described in Section 4 above, the Company may also use your information for the following purposes: 

a. verifying identity and authenticating information; 

b. registration; 

c. payment processing; 

d. monitoring information you transmit through the Services (including, without limitation, your Content) to operate the Services properly and to protect the Company, its users and the public; 

e. to send Email notifications and reminders related to the Services; 

f. providing the Services and operating the Company’s business; 

g. responding to customer requests and complaints; 

h. sending newsletters or other marketing information;

i. establishing and maintaining relationships with the Company’s users; 

j. optimizing experiences by performing analytics and conducting research;

k. conducting investigations, detecting fraud, abuse, security breaches and other harmful activity; 

l. resolving disputes and enforcing agreements and policies; and 

m. meeting and complying with legal and regulatory requirements (including, without limitation, pursuant to any applicable “know your customer” and similar requirements to verify your identity). 

The Company will not rent or sell personal information to any person.

6. How the Company Shares the Information it Collects.

The Company may disclose personal information to fulfill the purposes identified in this Privacy Policy, and for purposes related thereto, and to provide the Services, including as follows:

a. within the Company’s organization;

b. with the Company’s third party service providers, affiliates and trusted key partners who help the Company to provide certain aspects of the Services including, without limitation, to:

i. facilitate payment processing;

ii. facilitate sending customer Email surveys or marketing notifications;

iii. manage the Company’s sales and customer support services to you;

iv. deliver and help the Company track its marketing and advertising content;

v. help the Company provide core features of telecommunications services; and

vi. help the Company track website conversions and success metrics;

c. certain information may be shared with third parties or published when you follow links to third party websites, the Company does not own or control these third parties and when you interact with them you may be providing information to them directly – such third parties will have their own rules and policies in respect of the collection, use and disclosure of personal information and the Company encourages you to review these rules and policies;

d. information that you choose to share publicly or with others may be indexed through third party search engines – the Company does not control the practices of third party search engines so you need to be careful about the information you make public;

e. at your request or with your consent;

f. as required by applicable laws and related rules and regulations including, without limitation, as requested by law enforcement, pursuant to a subpoena or other governmental or regulatory authorities (including, without limitation, pursuant to any applicable “know your customer” and similar requirements to verify your identity);

g. with a buyer, investor, new affiliate, or other successor the Company or any affiliate undergoes a business transaction, such as a merger, acquisition, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), or a sale or other transfer of all or a portion of the Company’s assets or any affiliates or during steps in contemplation of such activities (e.g. negotiations and due diligence);

h. with the Company’s financial, insurance, legal, accounting or other advisors that provide professional services to the Company or as otherwise needed to safeguard the Company’s rights and meet the Company’s contractual obligations, for example for insurance purposes; and

i. the Company may collect statistics about the behavior of visitors to the Website – the Company may display this information, in aggregated form, publicly or provide it to other persons. 

7. International Transfers of Personal Information.

The Company will store personal information on the Company’s internal servers or with service providers. Personal information collected about you may be stored and/or processed outside of your jurisdiction of residence, including Quebec, other Canadian provinces and the United States. The Company’s service providers may also store and process personal information outside your jurisdiction. The Company continues to have exclusive control over such data; however, when information is stored or processed outside your jurisdiction, it may be subject to the laws of, and accessible by, legal authorities in those other jurisdictions. By submitting your personal information, engaging with the Website or using the Services, you consent to such transfer and storage. For more information about the Company’s data processing abroad, please contact the Company at support@hushed.com. 

8. Cookies and Tracking.

The Website uses “cookies”, which enables the Company to remember you and understand and save your preferences. A cookie is a string of information stored on your computer or mobile device, that your browser provides to the Website each time you return. The Company uses cookies to help the Company identify and track visitors to the Website, such visitors’ use of the Website, and their Website access preferences, to improve the Website and Services. 

When you first visit the Website, you will see a banner asking whether you wish to allow or decline the use of cookies and permitting you to access more information about how the Company uses such cookies. By clicking “Allow cookies” in that banner you agree to the use of all cookies as described in this Privacy Policy. If you click “Decline cookies” or modify the cookies you wish to allow in that banner, then the Website will not allow the use of those cookies. Additionally, you can set your browsers to refuse cookies before using the Website. If you do decline or refuse the use of cookies on the Website, then certain features of the Website and Services may not function properly, and this may also block cookies for any other website you visit.

Advertisements appearing on the Website may be delivered by advertising partners, who may also set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by the Company only and does not cover the use of cookies by any advertisers.

The Company also collects log data each time a device accesses the Company’s servers; log data includes details about the nature of each access including IP addresses, access times, device type, device manufacturer and model, device identifier (including Apple’s IDFA and Android’s advertising ID) operating system name and version, internet service provider, mobile carrier, time zone, language, Internet browser type and version, screen resolution, pages you view before and after using the Website or Services, links to third party applications and other hardware and software information. The Company will not respond to Web browser “do not track” signals. If you would like additional information about online tracking and various opt-out mechanisms, please see https://youradchoices.com/.

Because the Company links to social media sites, and from time to time may include third-party advertisements, other persons may collect personal information about your online activities over time and across different web sites when you visit the Website.

In addition, the Company may use Google AdWords, an online advertising service provided by Google, to serve ads on the Company’s behalf across the Internet and sometimes on the Website. Google uses your Internet searches, cookies, and similar identifiers (e.g. pixel tags) to collect information about your visits to the Website and your interaction with the Services to generate targeted advertisements to you on other websites that you visit across the Internet. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, please visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Website. Alternatively, you can opt out of a third party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page. http://www.networkadvertising.org/choices/.

Please note that not all tracking will stop even if you delete cookies.

9. Links to Other Websites.

The Company may offer links to other websites controlled by other entities. The Company is not responsible for, nor does the Company accept any liability for, how such other entities collect, use and disclose personal information. You should consult the privacy policies of these other websites before providing any personal information.

10. Security of Personal Information.

The Company is committed to the security of your personal information and takes steps to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal and other risks. The Company stores personal information in a secure location, accessible by designated staff and only uses it for the purposes set out in this Privacy Policy. You should please note, however, that the safety and security of your information is also your responsibility. You are responsible for keeping the Login ID allowing you to access the Services confidential. You must not share your Login ID with any other person. If you are made aware of your Login ID having been exposed, you must notify the Company immediately.

The Company uses appropriate security measures when the Company destroys personal information.

The Company routinely reviews and updates the Company’s security policies and controls to ensure ongoing personal information security, although the Internet is not a 100% secure environment so the Company cannot and does not guarantee the complete security and protection of the transmission and storage of your information.

11. Safety of Minors.

The Company encourages parents and guardians to be aware of their children’s online activities. The Company does not knowingly collect the personal information of minors (persons under the age of 18 or under such other age as required by the laws of their residence). If you are aware that a minor has provided the Company with personal information, please notify the Company at support@hushed.com. If it comes to the Company’s attention that the Company has collected personal information from a minor, then the Company may delete any such information without notice.

12. Retention of and Access and Change to Personal Information

The Company will only retain personal information that the Company collects for as long as is necessary and in accordance with applicable laws. Once the Company no longer needs your personal information to achieve the Company’s purposes or to provide the Services, the Company will, unless allowed to do otherwise by applicable laws, delete this information in accordance with applicable requirements. 

The Company makes reasonable efforts to ensure your personal information is accurate and complete. You may make a request to update, correct or delete your personal information at any time by submitting a request in writing to support@hushed.com. It is your responsibility to provide updates to your personal information and to maintain its accuracy.

You may request access to your personal information or request to know how the Company uses it or to whom it has been disclosed, subject to limited exceptions prescribed by law. Requests must be made in writing to support@hushed.com. The Company will respond to requests in accordance with applicable laws or provide notice if the Company requires longer to so respond. If permitted by applicable law, fees may be charged to access information, but you will be notified of such in advance so you can choose whether to proceed. Before providing you with access to your information, the Company may ask you for specific information to help the Company confirm your identity and right of access, and to provide you with the personal information that the Company holds about you, or to make the requested changes. In some cases, applicable law requires the Company to refuse to provide you with access to some or all the personal information the Company holds about you, or that the Company may have destroyed or deleted in accordance with the Company’s legal record-keeping obligations and privacy best practices.

A government agency may ask the Company to set aside a copy of specific information while the agency applies for legal process to compel the disclosure of that information. 

Please note that if you request deletion of certain information, the Company may not be able to provide you with certain services. The Company will explain the consequences of deletion at that time to assist you in your decision.

If the Company is unable to provide you with access to your personal information, then the Company will inform you of the reasons why, subject to any legal or regulatory restrictions. Such restrictions may include, for example, information about another individual that would reveal their personal information or confidential business information, or that would be prohibitively costly to provide.

13. Questions and Complaints.

You may direct complaints, concerns or questions regarding the Company’s compliance with applicable privacy laws and/or this Privacy Policy to support@hushed.com. If you remain unable to resolve the concern after speaking with a representative of the Company, you may also write to the Privacy Commissioner of Canada. 

14. Additional Rights.

Certain other jurisdictions, at both national and sub-national levels (e.g. US states, Canadian provinces, etc.), may provide their residents with other legal rights and obligations that impact their residents’ access to and use of the Services and that may not be expressly addressed in this Privacy Policy. If you have any questions as to how the Company protects your rights as a resident of any such jurisdiction that are not otherwise discussed in this Privacy Policy, then please contact the Company at support@hushed.com.

EUROPEAN PRIVACY POLICY

The following European Privacy Policy applies to you if you reside in the European Union, the European Economic Area, Switzerland or a country following substantially similar legislation regarding the protection of Personal Data (as defined below).

Personal Data and Processing. For the purposes of this European Privacy Policy:

Purposes and Legal Basis for Processing Personal Data. The Company processes data for the purposes as set forth in the Privacy Policy including to provide the Services and as explained in the sections of the Privacy Policy titled “How the Company Uses the Information the Company Collects” and “How the Company Shares Information the Company Collects”. To fulfill these purposes, the Company may access data, including Personal Data, to provide the Services, to correct and address technical, service or security problems, or in response to contractual requirements. Please see the Privacy Policy for additional details on how the Company collects, uses, discloses and shares data, makes automated decisions, and retains data, including Personal Data, about individual users.

The Company’s legal basis for the processing of Personal Data are: (i) consent or (ii) any other applicable legal basis, such as the Company’s legitimate interest in engaging in commerce, offering products and services of value to the customers of the Services, preventing fraud, complying with applicable governmental requirements, ensuring information and network security, direct marketing and advertising, and complying with industry practices.

Additional Rights for European Residents. As a resident of the European Union, the European Economic Area, Switzerland or a country following substantially similar legislation regarding the protection of Personal Data, individuals may have one or more of the following additional rights:

To exercise any of the above listed rights, please contact the Company as set forth below and provide sufficient details so the Company can respond appropriately. The Company will process any requests in accordance with applicable law and within a reasonable period of time. The Company may need to verify the identity of the individual submitting a request before the Company can address such request. 

Compelled Disclosures. The Company may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Data Protection Contact. Unless otherwise specified, the Company is the data controller with respect to the data provided through the Services and the Website. The Company’s Data Protection Contact for the Personal Data collected in connection with the Services is:

Attn: Privacy Team
support@hushed.com 

CALIFORNIA PRIVACY RIGHTS – FOR CALIFORNIA RESIDENTS ONLY

Sales of Information: The Company has not disclosed and/or sold personal information to third parties for a business or commercial purpose in the preceding 12 months. The Company does not sell the personal information of minors under 16 years of age without affirmative authorization. For clarity, the Company does not rent or sell any personal information to any third party.

If you wish to change personal information that you have provided to the Company, please contact the Company.

Your Rights: You have the right to request that the Company disclose to you what information the Company collects, uses, discloses and sells. You also have the right to request that a business deletes any personal information about you which the business has collected about you. To submit either of the above requests, you may call the Company at 1-877-278-3625 or contact the Company via Email at support@hushed.com. Please note for your protection, any request sent to the Company to delete your personal information will be subject to the following verification procedure: you are required to provide the last four digits of your credit card used to make a purchase. Also, please note that the Company only deletes Accounts with a valid “from” Email address (i.e. you must request your data deletion from the same Email used to create your Account). You have the right to direct the Company to not sell your information.

If you opt to exercise your privacy rights, the Company is required to verify your identity to prevent unauthorized access to your data. This may require the Company to ask you certain questions to confirm your identity or require you to provide state-issued identification. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, the Company will notify you if the Company rejects your request and notifies you of the reasons why the Company is unable to honour your request.

Right to Know and Access Information: You may access information that the Company maintains about you using the methods provided below. If the Company grants your request, then the Company will provide you with a copy of the personal information that the Company maintains about you in the ordinary course of business. This may include what personal information the Company collects, uses or discloses about you. The Company may not fulfill some or all your requests for access as permitted by applicable law.

Deletion of Information: You may request that the Company delete your personal information. Depending on the scope of your request, the Company may refrain from granting your request, as permitted by applicable law. For example, the Company may be legally required to retain your information in the Company’s business records. You may submit a deletion request using the methods provided on the Website or by Email at support@hushed.com.

The Company shall not discriminate against you for exercising any of your above rights.

You may designate an authorized agent to make a request to exercise your rights on your behalf. For your protection, the Company reserves the right to deny any request from an agent who does not submit proof that they have been authorized to act on your behalf.

See previous Privacy Policy