Privacy

RealDialer Privacy Policy

Effective date: August 27, 2026
Last updated: October 7, 2026

1. Who we are and what this policy covers

CloseDaily LLC, doing business as RealDialer ("RealDialer," "we," "us," or "our"), provides outbound calling software to real estate professionals and other businesses. This Privacy Policy explains what information we collect, how we use it, who we share it with, how long we keep it, and the choices available to you.

This policy covers:

• www.realdialer.com and our blog, marketing pages, and forms.
• The RealDialer application at app.realdialer.com, the administrative console, and any RealDialer mobile application.
• Support, billing, and sales communications with us.

The Services are sold to businesses for business use. They are not directed to consumers and are not intended for personal, family, or household purposes.

2. Two different roles, and why the distinction matters

RealDialer handles two very different kinds of personal information, and our responsibilities differ for each.

Information we handle for ourselves (we are the controller or business). This is information about our customers, prospective customers, website visitors, and the individual users who log in. We decide how it is used. Examples: your account details, your billing information, your support tickets, our website analytics.

Information our customers handle through us (we are the processor or service provider). This is the contact data our customers load into the platform and the calls they place: names, telephone numbers, mailing addresses, property records, call recordings, transcripts, notes, and dispositions relating to the people our customers call. Our customer decides who to contact, why, and on what legal basis. We process that information on the customer's instructions. We do not use it for our own marketing, we do not sell it, and we do not share it with other customers.

If you received a call from someone using RealDialer and you want your information corrected or removed, please read Section 12. The fastest resolution usually comes from the business that called you, but we will help.

3. Information we collect

3.1 Information you give us

• Account and profile. Name, business name, business address, email address, telephone number, job title, real estate license information where you provide it, brokerage or team affiliation, time zone, and profile photo.
• Authentication. Passwords are stored only as salted hashes. Where you use a passkey, we store a public key credential. We never see or store your biometric data or device passcode.
• Billing. Billing contact, billing address, plan and order details, tax status, and transaction history. Card numbers are handled by our payment processor and are not stored by us.
• Verification and compliance. Information we request to satisfy know your customer, robocall mitigation, and carrier onboarding requirements, such as business registration details, the names and doing business as names you use on calls, your principal place of business, and a compliance contact.
• Support and sales. The contents of your messages, tickets, demo requests, and any recordings or notes of support and sales calls with us.
• Content you create. Scripts, call outcome rules, list names, tags, notes, campaign settings, and provisioned message recordings.

3.2 Information our customers load or generate (customer contact data)

• Contact identifiers such as name, telephone numbers, email addresses, and mailing addresses.
• Property and parcel information, ownership records, listing status, and related notes.
• Call records: date, time, duration, direction, line used, caller identification presented, outcome and disposition, callbacks, and suppression status.
• Call recordings and transcripts where recording is enabled, along with any summaries, coaching notes, or analysis generated from them.
• Voicemail messages, message drops, and the content of emails and messages sent through the platform.
• Consent and opt out records that the customer enters or that the platform captures, including do not call requests and email consent confirmations.

3.3 Information collected automatically

• Device and connection. IP address, browser type and version, operating system, device identifiers, screen and viewport information, language, and referring page.
• Usage. Pages and features viewed, actions taken, timestamps, session duration, dialing session settings, error and diagnostic events, and performance metrics.
• Website visits. On realdialer.com we count visits with our own script and our own first party cookie (rd_vid, kept for one year). We record the pages viewed, how long each was in view and how far down it was read, the page or link that brought you, any campaign tags on that link, your device and browser type, your general location (city and region, as our network provider reports it), and a shortened form of your IP address (the network part only; we do not keep the full address).
• Security and audit logs. Sign in events, failed sign in attempts, password and passkey changes, permission changes, administrative actions, data exports, and acceptance of our terms and in product calling terms. Acceptance records are written to an append only log and are retained as evidence of consent.
• Telephony metadata. Call detail records generated by the underlying voice network, including originating and terminating numbers, routing, duration, disposition codes, and quality metrics.

3.4 Information from third parties

• Data suppliers. Where a customer purchases optional data or contact enrichment, we obtain property, parcel, ownership, and contact information from third party suppliers and public records, which may include do not call and litigation history indicators supplied by those vendors.
• Integrations you connect. Customer relationship management systems, calendars, email providers, automation platforms, and webhook consumers exchange data with us as you configure them.
• Carriers and network partners. Delivery status, number reputation and labeling information, porting information, and traceback inquiries.
• Payment processor. Confirmation of payment, the last four digits and brand of a card, and chargeback notices.
• Public sources. Business information used for verification and for marketing to prospective customers.

3.5 Customer proprietary network information

In providing voice functionality we may receive customer proprietary network information, meaning information about the quantity, technical configuration, type, destination, location, and amount of use of the telecommunications services you purchase. We use it to provide, bill for, secure, and support the Services, and we do not sell, trade, or disclose it outside RealDialer and the parties authorized to act on our behalf, except as required by law or legal process, to investigate fraud, to protect our rights and property, to protect against unlawful use of the Services, or as you authorize.

3.6 Affiliates

This part applies to people and businesses who apply to or take part in the RealDialer Affiliate Program at affiliate.realdialer.com ("affiliates"). For this information we are the controller or business.

• What we collect. Your application answers (how you plan to promote RealDialer, your audience size, your profession, and your promotion channels); your contact details (legal name, business name, email address, telephone number, and mailing address); the website and social media links you give us; your Form W-9 information, including your taxpayer identification number (TIN), tax classification, and signature; your payout details, including bank name, account type, routing and account numbers, or the email or mailing address a payout is sent to; the IP address, device, date, and time when you sign the Affiliate Agreement and the Form W-9, and the version of each document you signed; and click and referral data for your links (the time of each click, the page it led to, any sub ID, a keyed hash of the visitor's IP address, the signups and payments credited to you, and the referred customer's first name). We do not give affiliates any other information about the customers they refer.
• Why we use it. To review your application; to run the program, including crediting referrals and calculating commissions; to pay you; to meet tax reporting obligations, including Form 1099-NEC and backup withholding; to prevent and investigate fraud, self referrals, and breaches of the Affiliate Agreement; to keep the record of your signatures; and to contact you about the program.
• How we protect it. Your TIN and your bank account and routing numbers are encrypted (AES-256-GCM) before they are stored, only the last four digits are shown in the affiliate portal and the console, and the full numbers can be opened only by the account owner after a fresh passkey confirmation, which is logged. Your signed Form W-9 and your signed Affiliate Agreement are stored encrypted in private storage.
• Who we share it with. Banks and payment processors that send your payouts; the Internal Revenue Service and state tax authorities, for Form 1099 and other required tax reporting; our service providers that host, store, email, and secure the program on our behalf under contract; and others where the law requires it or as described in Section 6. We do not sell affiliate information.
• How long we keep it. Tax records, including your Form W-9 and payout records, are kept for seven years, in line with the account, billing, and tax records in Section 9. Signature records for the Affiliate Agreement and the Privacy Policy are kept permanently, like the other terms acceptance records in Section 9. Click data is kept while you are an affiliate and for seven years after, as part of the commission record. An application that is not approved is kept for two years and then deleted, except the record of what you signed.

4. How we use information

We use information to:

1. Provide, operate, provision, and maintain the Services, including placing and receiving calls, pacing dialing sessions, recording and transcribing where enabled, and delivering messages and emails you direct.
2. Create and secure accounts, authenticate users, and enforce permissions.
3. Process orders, bill you, collect payment, and maintain financial records.
4. Provide support, respond to inquiries, and communicate about outages, releases, and changes to the Services.
5. Monitor, investigate, and prevent fraud, abuse, unauthorized access, and violations of our terms, and enforce our agreements.
6. Meet legal, regulatory, and carrier obligations, including know your customer duties, robocall mitigation, caller identification authentication, responses to traceback requests, lawful process, and record keeping.
7. Maintain and improve the Services, diagnose problems, measure performance, and develop new features.
8. Generate transcripts, summaries, and coaching output from calls where those features are enabled.
9. Market RealDialer to businesses and prospective customers, subject to Section 11.
10. Create de identified and aggregated statistics that do not identify any person, which we may use for benchmarking, product development, and industry reporting.

We do not use the contact data or call content that customers process through the platform for our own marketing, and we do not sell it.

5. Artificial intelligence and automated processing

Where transcription, summarization, coaching, or assistant features are enabled, call audio and text are sent to third party speech recognition and language model providers that we engage under contract. The assistant reads call transcripts to point out follow ups, such as a callback that was promised but not scheduled, and drafts messages for your review. It never sends a message or changes a record without your confirmation.

• These providers may process the content only to return output to us. Our agreements prohibit them from using customer content to train their general purpose models.
• We do not use customer call content, contact data, recordings, or transcripts to train models we make available to other customers or to the public.
• Output is generated by statistical models, is not always accurate, and should be reviewed by a person before it is relied on.
• We do not make automated decisions that produce legal or similarly significant effects about the individuals our customers call.

6. How we share information

We do not sell personal information, and we do not share personal information for cross context behavioral advertising. We disclose information only as described here.

Service providers and subprocessors, each bound by contract to protect the information and to use it only to provide services to us, in these categories:

• Cloud hosting and infrastructure providers.
• Telecommunications carriers, voice infrastructure providers, and numbering and porting partners.
• Object storage providers used to hold call recordings.
• Speech recognition and artificial intelligence providers used for transcription and summaries.
• Transactional and marketing email delivery providers.
• Payment processing and billing providers.
• Data and contact enrichment suppliers, where a customer requests that service.
• Error monitoring, logging, and product analytics providers.
• Customer support and ticketing tools.

At your direction. To any integration, webhook endpoint, customer relationship management system, or other destination you connect. Once data reaches a third party you selected, that party's privacy practices govern it.

Within a customer account. Data in a customer account is visible to that customer's authorized users, administrators, and, where applicable, the account owner, according to the roles the customer configures. If your employer or brokerage owns the account, they can see the calls, recordings, notes, and activity in it.

For legal and safety reasons. To comply with law, subpoena, warrant, court order, or regulatory demand, to respond to traceback requests from the Industry Traceback Group, the Federal Communications Commission, state attorneys general, or law enforcement, to enforce our agreements, to investigate suspected fraud or abuse, and to protect the rights, property, or safety of RealDialer, our customers, our carriers, or the public.

Business transfers. In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, subject to reasonable confidentiality protections. We will provide notice through the Services or by email if a transfer materially changes how information is handled.

With your consent. For any other purpose we describe to you at the time.

Text messaging. No mobile information is shared with third parties or affiliates for their marketing or promotional purposes. Text messaging opt in data and consent are not shared with any third party, excluding the aggregators and providers that deliver our text messages. See Section 11.4.

7. Legal bases

Where a legal basis is required, we rely on: performance of our contract with you; our legitimate interests in operating, securing, and improving the Services and in marketing to businesses; compliance with legal obligations, including telecommunications and anti robocall requirements; and consent where we ask for it, which you may withdraw at any time.

8. Cookies and similar technologies

We use cookies and similar technologies to keep you signed in, remember preferences, secure the application against cross site request forgery and other attacks, measure site performance, and understand aggregate website usage. We use strictly necessary cookies and a limited set of analytics cookies. We do not use third party advertising cookies or advertising pixels that share personal information with advertising networks.

Website analytics. On realdialer.com we measure visits with our own first party script and cookie described in Section 3.3. The cookie is linked to you if you click a link in an email we sent you, sign up, book a demo, or sign in to the Services from the same browser. After that we can see your visits to realdialer.com and the pages you view, and we may use that to follow up with you about RealDialer (Section 4). We do not sell this information or share it for cross context behavioral advertising. realdialer.com also uses Google Analytics to measure aggregate traffic; Google receives information about your visit as described in Google's own policies, and you can block it with Google's browser opt out add on.

Your choices. If your browser sends Global Privacy Control or Do Not Track, our own script sends nothing. You can also use the "Do not track me" link at the bottom of any page on realdialer.com: it deletes our visit record for that browser and sets a cookie (rd_optout) so we stop counting it. Blocking or clearing cookies also stops it. Google Analytics does not respond to these signals on its own.

Most browsers let you block or delete cookies. Blocking strictly necessary cookies will break sign in and the dialer. Apart from our own website analytics, which honor Do Not Track as described above, we do not respond to browser Do Not Track signals, because there is no common standard for them. We honor Global Privacy Control signals as an opt out of any sale or sharing, to the extent applicable law requires, though as stated above we do not sell or share personal information.

9. How long we keep information

• Call recordings. Retained for the period your plan includes, currently 30 days on Foundation, 60 days on Operator, and 90 days on Command, counted from the date of the call, then deleted. If you need recordings for longer, including to satisfy your own record keeping obligations, you must export them within that window. We do not provide recording archival.
• Call detail records. The number dialed, the date and time, the caller ID used, how the call ended and how it was marked. Retained for five years from the date of the call, including after the account that placed it is deleted, because 16 CFR 310.5 requires a telemarketer to keep a record of each call for five years. What is kept after a deletion has the account's name and its contacts stripped out, it is not visible anywhere in the Services, and it is destroyed when the five years run out.
• Transcripts, dispositions, and notes. Retained for the life of the account unless you delete them sooner.
• Contact and list data. Retained for the life of the account, or until you delete it.
• Suppression and do not call records. Retained for at least five years, and after account closure where necessary, because retention is the only way to keep honoring an opt out. We do not delete a do not call record on request, since deleting it would allow the number to be dialed again.
• Consent and terms acceptance records. Retained as evidence of consent, in an append only log, for the life of the account and for the applicable limitations period afterward.
• Account, billing, and tax records. Retained as required by law, generally seven years.
• Security and audit logs. Typically twelve to twenty four months.
• Website visit records. A visit record that is not linked to a person is deleted 13 months after that browser was last seen. A record linked to you is kept while you are a customer or a prospect in our records, and is deleted when your account or your contact record is deleted, or when you use the Do not track me link in that browser.
• Backups. Data in encrypted backups persists for the backup cycle after deletion from live systems and is then overwritten.
• After account closure. Customer Data is available for export for thirty days if the account is in good standing, after which we may delete it. We may retain what we need to resolve disputes, enforce agreements, and meet legal obligations, including legal holds.

9.1 When you delete your account

You can request deletion from inside the mobile app, under Settings, from the privacy request page, and by writing to support@realdialer.com. You do not have to contact us first, and we do not offer deactivation in place of deletion.

Access ends the moment you confirm. Every signed in device is signed out, and the account cannot be used again. The removal itself is completed within thirty days, and we email you when it is finished. Because confirming ends access, there is no way to take the request back from inside the app; if you change your mind, write to support@realdialer.com before the thirty days run out and we will tell you whether the removal has already happened.

What is removed: the login, the profile and every saved device session; contacts and their phone numbers, emails and addresses; notes, texts, emails, files, call recordings and voicemail; lead sheets, support tickets and stored IP addresses. The subscription is canceled.

What is kept, and why:

• The call detail records described above, for five years, under 16 CFR 310.5.
• Every do not call and suppression record, for at least five years, under 47 CFR 64.1200(d)(6). Deleting one would allow the number to be called again, which is the opposite of what the person asked for.
• Billing records and which terms were accepted, as an accounting record, for the period a payment can still be disputed and for the applicable limitations period.

This is the exception in Cal. Civ. Code 1798.105(d)(8) and in Article 17(3) of the GDPR: a business may keep what it is legally required to keep. Everything outside that list goes. If a legal hold is in force because a claim has been made or is reasonably anticipated, the removal waits until the hold is lifted, and we will tell you that it is waiting.

10. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information, including:

• Encryption in transit using current TLS, and encryption at rest for stored recordings and database backups.
• Least privilege database access, with runtime accounts limited to only the tables and operations they need, and a verified grant contract enforced at deployment.
• Role based access control, multi factor authentication, and passkey support for accounts.
• Network isolation, host firewalls, intrusion prevention, and change controlled deployments with audit evidence retained for each release.
• Append only logging for consent and policy acceptance records.
• Restricted internal access on a need to know basis, and confidentiality obligations for personnel and vendors.

No system is perfectly secure. We cannot guarantee absolute security, and you are responsible for safeguarding your credentials, for not sharing seats, and for promptly notifying us of any suspected compromise. If we become aware of a breach affecting personal information, we will notify affected parties and regulators as required by law.

11. Your privacy rights and choices

11.1 Everyone

• Access, correction, and deletion. Use the privacy request page, or contact us at support@realdialer.com. Account users can also view and edit much of their information directly in the Services, and can delete the account from Settings in the mobile app. See section 9.1 for what a deletion removes and what it keeps.
• Marketing email. Every marketing message contains an unsubscribe link. You may also email us. We will still send transactional and service messages such as billing notices, security alerts, and outage notifications.
• Account closure. See Section 9 for what happens to data afterward.

11.2 United States state privacy rights

Depending on where you live, you may have the right to: confirm whether we process your personal information and access it; obtain a portable copy; correct inaccuracies; request deletion; opt out of sale, sharing for targeted advertising, and certain profiling; limit the use of sensitive personal information; and not be discriminated against for exercising a right. We do not sell personal information, we do not share it for cross context behavioral advertising, and we do not use it for profiling that produces legal or similarly significant effects.

To exercise a right, use the privacy request page, or email support@realdialer.com with the words "Privacy Request" in the subject line, and tell us what you are asking for and enough information for us to locate your records. We will verify your identity before acting, and we may decline a request we cannot verify. An authorized agent may submit a request with written proof of authority. We respond within the time the applicable law allows, generally forty five days, with one extension where permitted.

Appeals. If we deny a request, you may appeal by replying to our decision with the word "Appeal." We will respond in writing with our reasoning within the period your state's law requires. Several states also allow you to complain to your attorney general.

11.3 Requests about data our customers control

If your request concerns information a RealDialer customer loaded into the platform, we are the processor and the customer is the controller. We will refer your request to that customer and assist them in responding. Where the law directs your request to the controller, we will tell you who to contact if we are permitted to do so. See Section 12.

11.4 Text messages from RealDialer

If you give us your mobile number, RealDialer may text you about your account, such as setup, billing, service notices, and replies to your support requests. We text you product news and offers only if you agree to them, on our signup form or in Settings in the app, up to 4 messages a month. Agreeing to marketing texts is never a condition of buying anything. Message frequency varies. Message and data rates may apply.

• Stop. Reply STOP to any text from us and we will send you no more texts of any kind. Reply START to receive them again.
• Help. Reply HELP for help, or contact support@realdialer.com.
• Carriers are not liable for delayed or undelivered messages.

Texts a RealDialer customer sends you from their own account come from that customer, not from us. See Section 12.

12. If you received a call from a RealDialer customer

RealDialer is software. We do not choose who is called and we do not place calls on our own behalf. The business whose name and number appeared on the call is the caller, and that business decides who is contacted, what is said, and whether the call is recorded.

If you want to stop receiving calls:

1. Tell the caller directly. Ask to be added to their do not call list, on the call, by reply message, or in writing. Federal and state law require them to honor that request. Our platform records the request and blocks the number from further dialing in that account when the caller enters it, and that suppression cannot be reversed by re dispositioning the call.
2. Tell us. Use the report a call page, or email support@realdialer.com, with the telephone number that was called and the date, time, and caller identification number if you have them. We will identify the account, add the number to that account's suppression list where we are able, and pass your request to the customer. Where we see a pattern of abuse, we investigate and may suspend or terminate the account.
3. Registry. You may also register your number with the National Do Not Call Registry at donotcall.gov and with any registry your state maintains.

To request access to or deletion of information about you held in a customer's account, use the privacy request page or email support@realdialer.com. We will route the request to the customer that controls it and support them in responding. We can delete a call recording of you on request, subject to any legal hold. We will not delete a do not call or suppression record, because that record is what keeps you from being called again.

13. Children

The Services are for business use by adults. We do not knowingly collect personal information from anyone under eighteen. If we learn we have, we will delete it. Contact support@realdialer.com if you believe a minor has provided information to us.

14. Sensitive information not permitted

Our customers are contractually prohibited from using the Services to process protected health information, payment card data, financial account credentials, Social Security numbers, biometric identifiers, or other sensitive personal information. We are not a HIPAA business associate and the Services are not HIPAA or PCI DSS compliant. If you are a customer, do not put that information into the platform.

15. Location of processing

We operate in the United States and process and store information there. The Services are offered to customers in the United States and Canada. If you access the Services from another country, you understand that your information will be transferred to and processed in the United States, where privacy laws may differ from those in your location.

16. Changes to this policy

We may update this policy from time to time. Each update is a material change, a simple change, or another non-material change.

Material changes need your acceptance. A material change is one that expands how we collect, use, share, or keep your personal information or your contacts' information, or that otherwise reduces your privacy rights in a meaningful way. A material change takes effect only when you accept it. You will be asked to accept it the next time you sign in, and you will not be able to use the Services until you accept it or cancel.

Other changes take effect after notice. Any other change that is not a simple change, such as a clarification, a correction, or a change required by law, a regulator, or a carrier that does not reduce your rights, takes effect on the effective date stated in the notice. That date will be at least thirty (30) days after we give notice, except where a shorter time is required by law, a regulator, or a carrier. We give notice by email to the account owner at the email address on the account, and by a notice in the Services that describes what changed and links to the full updated policy. If you keep using the Services on or after that effective date, you accept the updated policy. If you object, you may cancel your account before the effective date by writing to support@realdialer.com or from your account.

Simple changes take effect when posted. We may make simple changes that clarify this policy, add a section describing a new feature or program, or do not reduce your privacy rights, by posting the updated policy. A simple change takes effect when it is posted, without the notice described above and without asking you to accept it again. A simple change never expands how we collect, use, share, or keep your personal information or your contacts' information.

We keep every version of this policy we have published, with the date each took effect. Prior versions are available on request.

17. Contact us

CloseDaily LLC, doing business as RealDialer

• Privacy questions and rights requests: the privacy request page, or support@realdialer.com
• Do not call requests and abuse reports: the report a call page, or support@realdialer.com
• General support: the support page, or support@realdialer.com
• Web: https://www.realdialer.com

We respond to privacy inquiries within the timeframes required by applicable law.