Privacy policy

This “Privacy Policy” describes the privacy practices of Nagish Inc. d/b/a Rylo and our subsidiaries and affiliates (collectively, “Rylo”, “we”, “us”, or “our”) in connection with our website located at https://www.rylo.com (collectively with any related websites and successor websites, the “Website”), your use of our mobile application (“App”) and any other services that we own or control and which post or link to this Privacy Policy (collectively, the “Services”), and the rights and choices available to you with respect to your information. This Privacy Notice is governed by our Terms of Service. Defined terms used herein and not otherwise defined have the meanings set forth in the Terms of Service.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR PERSONAL INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE WEBSITE OR USE OUR SERVICES.

Personal Information We Collect

Information you provide to us. Personal information you provide to us through the Services or otherwise includes:

• Contact Data, such as your first and last name, email and mailing addresses and phone number.
• Profile data, such as your username and password that you may set to establish an online account with us and preferences such as personal dictionary, quick responses and other Telecommunications Relay Services (“TRS”) customer profile data.
• Registration data, such as information that may be related to a service, an account, or an event you register for.
• Communications, such as information you provide when you contact us with questions, provide feedback about the Services, or otherwise correspond with us online.
• TRS User Registration Database information for IP CTS users, if you are a user of the federal IP CTS program, your full name; full residential address; telephone number; unique identifier such as the electronic serial number of your IP CTS device, the user’s log-in identification, or the user’s email address; the last four digits of your social security number or alternatives; date of birth; Registered Location; date of service initiation and (when applicable) termination; a digital copy of your self-certification of eligibility for IP CTS and the date obtained by the provider; and if you are an existing user, the date on which you last placed an IP CTS call. If the IP CTS user is under eighteen (18) years of age and the account was registered by a parent or legal guardian on the minor user’s behalf in accordance with Section 2.6 of our Terms of Service, we will additionally collect and transmit to the TRS User Registration Database the full name and residential address of the parent or legal guardian who registered the account and provided their parental consent for the minor's use of the platform.
• Marketing data, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.

Please note that we also collect aggregated and de-identified information and, in some cases, de-identify information. Such de-identified information is information which cannot be used to identify you and which is not considered personal information under data protection laws, such information is not covered by this privacy policy.

Information We Collect through Our Services

We also receive information from you that you input and provide when you use our Services (“Customer Data”). For example, any conversations you speak or type into the Services may be temporarily stored or recorded to facilitate the call and relay. We do not retain the audio or transcriptions of connected calls in the ordinary course of providing our Services to you. Once captions are delivered to your device, they are deleted from our servers. When you elect to store transcripts, they will be stored on your own device. However, your calls will be collected, and may be stored on a temporary or longer basis, in order for us to transcribe the communication or otherwise provide the Services to you. Additionally, Customer Data is collected and may be stored in the following instances:

• As a part of the Rylo Live service, we may record and store live conversations that you make available to the Services.
• As a part of the Rylo Voicemail service, voicemail transcripts will be stored until delivery and voicemail messages will be stored until they are pro-actively deleted by you.

‍Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services, including but not limited to, your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. In addition, we may request access or permission to certain permissions from your mobile device, including your mobile device’s contacts, microphone, or other features. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

We collect the following information about calls to facilitate reimbursement pursuant to the federal TRS program: call times, incoming telephone number and IP address at the time of call, outbound telephone number and IP address, total call minutes, the URL address through which the call is initiated.  

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons.

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites.

Web browsers may offer users of our Services the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly. Please see the section below entitled “Your Choices” for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

Information You Provide During the Job Application Process

We may also receive information about you if you submit a job application, inquire about opportunities with us, provide us your information at a recruiting event, or if we receive information about you from third parties in connection with our recruiting activities. Throughout this Privacy Policy, we will refer to this information as "Recruiting Data". Recruiting Data may include:

• name and contact information such as phone number, email address, and postal address;
• employment history such as prior employers and dates of employment;
• education history such as degrees earned and institutions attended;
• resume, CV, educational transcripts, and any information contained in or with such documentation;
• job qualifications and work eligibility information such as country of residence, visa and immigration status, and citizenship;
• reference information, such as name and contact details of your references;
• compensation information that you voluntarily provide, and which may depend on your region and applicable laws and regulations;
• background check information, subject to applicable law; and
• sensitive personal information that you provide voluntarily or which we request on a non-mandatory basis in order to comply with applicable law.

You are responsible for the Recruiting Data you provide or make available to us and all Recruiting Data you provide must be truthful, accurate, and not misleading in any way. You may not provide Recruiting Data that is obscene, defamatory, infringing, malicious, or that violates any law. To the extent you voluntarily provide any sensitive or special categories of information, as may be defined in applicable laws, you explicitly consent to our processing of such information as described in this Privacy Policy. Depending on your region or the region where an opportunity is located, we may be required to process certain sensitive personal information to comply with applicable local law. You are responsible for providing any notices and obtaining any consents necessary for us to collect and use personal information of your references as described in this Privacy Policy.

Customer Proprietary Network Information (“CPNI”)

We collect CPNI in connection with our provision of the Services.  CPNI includes information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service used by any customer of a TRS provider; and information regarding a customer's use of TRS contained in the documentation submitted by a TRS provider to the TRS Fund administrator in connection with a request for compensation for the provision of TRS.  

We take all reasonable measures to discover and protect against attempts to gain unauthorized access to CPNI.

We may use, disclose, or permit access to CPNI for the purpose of providing or lawfully marketing service offerings among the categories of service (i.e., type of TRS) for which we are the default provider for the customer without customer approval.  We also may use, disclose or permit access to CPNI derived from its provision of TRS without customer approval, for the provision of CPE or iTRS access technology, and call answering, voice or video mail or messaging, voice or video storage and retrieval services; for the provision of inside wiring installation, maintenance, and repair services; and to the extent necessary to accept and handle 911/E911 calls.

We may use, disclose, or permit access to CPNI upon request by the administrator of the TRS Fund or by the Federal Communications Commission (FCC) for the purpose of administration and oversight of the TRS Fund, including the investigation and prevention of fraud, abuse, and misuse of TRS and seeking repayment to the TRS Fund for non-compensable minutes.

We may use, disclose, or permit access to CPNI to protect our rights or property, or to protect users of the Services, other TRS providers, and the TRS Fund from fraudulent, abusive, or unlawful use of such services.  We may disclose CPNI in response to a legitimate law enforcement request.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Services. We use your personal information to:

• provide, operate and improve the Services, including to route emergency calls to the correct dispatchers;
• enable your communication with other users of the Services or participants in communications enabled by the Services;
• provide AI features of the Services as more fully set forth in the Rylo AI Supplementary Terms (Annex 2 of our Terms of Use);
• provide information about our products and services;
• establish and maintain your user account on the Services;
• enable security features of the Services, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Services and our communications;
• provide support and maintenance for the Services; and
• to respond to your requests, questions, and feedback.

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For research and development. We analyze use of the Services to monitor and improve the Services and to develop new products and services, including by studying user demographics and use of the Services, and to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition.

To send you marketing and promotional communications. We may send you marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the section below entitled “Your Choices”.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to comply with the requirements of the federal TRS program and to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities (including the Federal Communications Commission), and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) for audit and compliance purposes; and (e) enforce our Terms of Service.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated, or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated, or de-identified data by removing information that makes the data personally identifiable to you. Such anonymous, or de-identified data is not personal information.

For Recruiting Data. We may review and evaluate an application you submit, communicate with you regarding your application or other interest in opportunities with us; process your onboarding if you are hired; operate, improve, and maintain the security of our recruiting process; and comply with applicable laws and otherwise operate our business.

Use of your Personal Information. Where we are required by law to collect your personal information, or where we need your personal information to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Service. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.

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How We Share Your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Other Users of the Services and the Public. We may provide information about you to other users of the Services and other participants in communications enabled by the Services, and we may provide functionality that enables you to disclose personal information to such persons. For example, if you initiate communication with or receive communication from a third party through the Services, we may share basic information about you such as your name and phone number (e.g., caller ID).

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy. In some cases, we may specifically ask for your consent to share your personal information with our affiliates, such as when required by law.

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Services (such as customer support, hosting, analytics, email delivery, marketing, and database management services), consistent with this Privacy Policy and, if applicable, the FCC’s Customer Proprietary Network Information (“CPNI”) rules. We require these third parties to agree to privacy commitments in order to share information with them. Rylo also shares CPNI with the TRS Administrator and the FCC, in accordance with the FCC’s rules and practices for the Interstate TRS program.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, audit, fraud prevention and safety purposes described above, unless prohibited by applicable law or regulation. When calling 911, your phone number, location, and other information may be transmitted to local emergency service providers. Such information may also be provided to law enforcement and other public safety officials in order to assist them with respect to your call for emergency services.

Business transfers. We may sell, transfer, or otherwise share some or all our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of the Rylo, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay, or we may need to disclose your information in connection with enforcing our Terms of Service and/or other agreements.

With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so.

Published Support Requests: If you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users of the Services and may remove your personal information from the request.

How Long We Keep Personal Information

We generally discard information about you when we no longer need the information for the purposes for which we collect and use it–which are described in the section above entitled “How We Use your Personal Information”–and we are not legally required to continue to keep it. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Choices

In this section, we describe the rights and choices available to you.

Access, Update or Delete Your Information. You can view, access, edit or delete your personal information for many aspects of the Services. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account. You can also request that we delete your personal information by sending an email to privacy@rylo.com with “Please delete my personal information” in the subject line. We will verify your identity and then delete the personal information associated with your email address. Please note that we may retain certain information as required or permitted by applicable law, and we may deny your deletion request if retaining the personal information is necessary for us or our service providers under any permitted exceptions. If you are a parent or legal guardian who registered an Account on behalf of a minor user and provided parental consent, you may make the requests described above on the minor user’s behalf. We may require reasonable verification of your identity and your legal authority to act on behalf of the minor before acting on the request.

Opt Out of Marketing Communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the communication or by emailing 'unsubscribe' to support@rylo.com. You may continue to receive service-related and other non-marketing emails.

Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Services and third party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Choose Not to Use Certain Features: You may choose not to use certain features within our Services where the use of such features results in the processing of information you submit through the feature by a third party. For example, use of our AI features result in the sharing of information in accordance with the Rylo AI Supplementary Terms, found in our Terms of Use. If you do not wish to share information with the third party providing the AI feature, please do not use such feature.

Other Sites, Mobile Applications and Services

The Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications, or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security Practices

The security of your personal information is important to us. We employ organizational, technical, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

Minor Users and Children’s Privacy

Because the Services support Deaf and hard-of-hearing users, including Deaf and hard-of-hearing children, our Services may be used by minor users with the involvement of a parent or legal guardian as described in Section 2.6 (Accounts for Minors) of our Terms of Service.

Registration on behalf of a minor user. A minor user (under 18, or under the age of majority where the minor lives) may not register an Account themselves. The minor’s parent or legal guardian must register the Account on the minor user’s behalf, provide the parental consents and certifications required under our Terms of Service and applicable FCC rules, and supervise the minor user’s use of the Services.

What we collect about minor users. For each minor user, we collect the same categories of personal information described elsewhere in this Privacy Policy — including TRS User Registration Database information (full name, residential address, telephone number, date of birth, last four digits of social security number or alternative, and self-certification of eligibility) — about the minor user. 

What we collect about the minor's parent or guardian. In addition to the minor's information mentioned above, we collect the parent or legal guardian’s full legal name, residential address, relationship to the minor user, contact email, and contact phone number, both to satisfy our FCC obligations under 47 C.F.R. § 64.611 and to administer the Account. We may also request supporting documentation to show the parent or guardian's legal ability to provide consents and act on the specific minor's behalf.

Children under 13 and COPPA. If a minor user is under the age of 13, we collect, use, and disclose personal information from the minor user only in accordance with the Children’s Online Privacy Protection Act (“COPPA”). Before we collect personal information from a child under 13, we will obtain verifiable parental consent from the child’s parent or legal guardian using one of the methods permitted by COPPA. The parent or legal guardian may, at any time, review the personal information we have collected from the child, refuse to permit further collection or use of the child’s information, and request that we delete the child’s information. To exercise these rights, the parent or legal guardian should contact us at privacy@rylo.com. We may require reasonable verification of the parent’s identity before acting on a request.

If you believe we have collected personal information from a child under the age of 13 without verifiable parental consent — or have collected personal information from a minor user without the involvement of the minor’s parent or legal guardian as described above — please contact us at privacy@rylo.com. We will take appropriate steps to delete that information and restrict the relevant individual from future access to the Services.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Services.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to privacy@rylo.com. You may also write to us via postal mail at:

Nagish Inc. d/b/a Rylo
Attn: Legal
228 Park Avenue S, PMB 58177
New York, NY 10003
United States

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Regional Terms for Certain US States

The Website and our Services are hosted in and provided from the United States, and your use of our Website and Services is governed by United States law. If you are using the Website or Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our systems and facilities, and those of our third party providers and recipients of information, are located. Please see below for further information which may be applicable to certain individuals who are residents of certain US states, in some cases if and when we are subject to the data protection laws in those states (“Regional Laws”).

Your Consumer Rights

Certain privacy laws provide individuals in the applicable regions certain rights regarding their personal information. If a Relevant Law applies to you, you may submit a request to exercise your right(s) in relation to your personal information, as follows:

• Know/Access: You may request access to the specific pieces of personal information we have collected about you, which may, in accordance with Relevant Laws, be limited to the information collected in the prior 12 months.
• Correct/Rectify: You may request that we correct or rectify the personal information we have collected about you. Please note that we may decline to correct certain information as required or permitted by applicable law, and we may deny your correction request if retaining the personal information in its current state is necessary for us or our service providers under any permitted exceptions.
• Limit Use of Sensitive Personal Information: You may request that we limit the use of sensitive personal information, as defined in Relevant Laws, to certain purposes as set forth in the Relevant Laws.
• Delete/Erase: You may request that we delete the personal information we have collected about you. Please note that we may retain certain information as required or permitted by applicable law, and we may deny your deletion request if retaining the personal information is necessary for us or our service providers under any permitted exceptions. If you request to delete your personal information, certain of our Services may no longer be available to you.
• Restrict or Object: You may request that we limit the way we use your personal information or object to certain forms of processing.
• Data Portability: You may request for your personal information to be transferred directly to another organization.
• Automated Decision Making and Profiling: You have the right not to be subject to automated decision-making if it produces a legal effect that significantly affects you, with certain exceptions.
• Not to Receive Direct Marketing Communications: In some Relevant Regions, you may request to not receive our direct marketing messages, as more fully set forth below.

You can usually access, correct, or delete your personal information using your account settings and tools that we offer, but if you aren’t able to do that, or you don’t have an account, or you would like to contact us about one of the other rights, our contact information is set forth in the above section entitled “How to Contact Us”.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Under some Relevant Laws, you may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will respond to a verifiable consumer request within the time periods permitted under Relevant Laws. If we require more time, we will inform you of the reason and extension period in writing, in accordance with Relevant Laws.

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. Relevant Laws may require us to verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

California “Shine the Light” Law

California residents may request certain information regarding our disclosure (if any) of personal information to third parties for their direct marketing purposes, pursuant to California Civil Code Section 1798.83 (the California “Shine the Light” law). To make such a request, please contact us, identify yourself as a California resident and provide sufficient information so we can take appropriate action, such as your name, email address or any additional information required.

Nevada Residents

Though we do not as a matter of course “sell” “covered information” as those terms are defined by the applicable Regional Law, if you reside in Nevada and believe we have sold your covered information, please contact us as described in “How to Contact Us” above.