Privacy Policy

Last Updated: December 2025

1. Overview

DUBTEL LLC. (“DUBTEL,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy (“Privacy Policy”). This Privacy Policy describes how we collect and use your Personal Information when you visit our website at https://www.dubtel.com, you communicate with us, or we otherwise process your Personal Information (collectively, the “Platform”), except as specified below with respect to our role as a processor.

This Privacy Policy does not apply to data subjects of our customers whose Personal Information we may receive pursuant to DUBTEL services we provide to our customers. Our customers use our platform to store and process their own customers’ Personal Information, such as to:

Create their own websites and applications
Offer or provide their own products and services
Send electronic communications
Otherwise collect, use, share, or process Personal Information

In these cases, we act as a processor and service provider when providing these services to our customers (the “Processor Services”). When you give your data to one of our customers or when we collect your Personal Information on their behalf in connection with our Processor Services, our customer’s privacy notice, rather than this Privacy Policy, will apply.

If you do not agree with our policies and practices, do not use the Platform. By accessing or using the Platform, you agree and consent to this Privacy Policy.

2. Information That DUBTEL Collects About You

We collect information about you (“Personal Information”):

Directly from you when you provide it to us.When you subscribe to a newsletter, create an account, make a purchase, or request information, we may ask for your name, contact details, billing information, shipping information, and other identifiers. If you provide Personal Information about others, you are responsible for ensuring you have authority to do so.
From third parties.We receive information from marketing partners, advertising platforms, data vendors, event hosts, public databases, and research partners. This may include your name, professional details, contact information, and publicly available content.
Automatically when you use our Platform.We collect information about how you interact with the Platform, including: device details, IP address, activity logs, and data gathered via cookies, pixel tags, and similar technologies.

3. How DUBTEL Uses Information It Collects About You

For Functionality and Development of the Platform.We use Personal Information to operate, provide, improve, personalize, secure, and analyze the Platform. This includes:
- Providing network connectivity
- Diagnosing server issues
- Measuring usage
- Improving products, services, and technologies
- Updating system files and features
- Using cookies to enable core website functionality
To Provide AI Features.Some features may use artificial intelligence (“AI”) tools to enhance performance. Our AI usage:
- Supports direct services to you
- Does NOT train public or generalized AI models
- Uses specialized AI subprocessors under strict instructions
For Customer Support.We use your Personal Information to provide you with customer support for the Platform.
For Business Operations.We use information to operate our business; for example, to perform accounting, auditing, billing, reconciliation, and collection activities, or comply with contractual obligations.
To CommunicateWe use contact information to send messages; to communicate with you about the Platform and your account; to provide the Platform; to respond to customer service requests; to provide alerts such as security updates or changes in our policies or about subscriptions that are ending; and to send marketing or informational materials like newsletters or white papers, in accordance with your communication preferences. We occasionally conduct surveys or do focused research or studies through which you may choose to share information.
To Protect and Secure the Platform.We may use information to keep our Platform safe, such as crime or fraud monitoring and prevention or cybersecurity efforts.
For Advertising and Marketing.We may use Personal Information about you — including what advertisements you viewed and other information we collect — to provide personalized content, verify eligibility for promotional offers, engage in targeted advertising, and study campaign effectiveness. This includes using data collected from marketing partners through our affiliate referral program.
For Statistical Purposes to Improve the Platform.We may compile Platform statistics to help DUBTEL understand, anticipate, and respond to user needs. For example, if we identify increased interest in certain features, we may highlight them on the Platform home page. This helps us create a better user experience.
For Legal, Regulatory, and Compliance Purposes.We may use Personal Information to comply with legal or regulatory obligations, including to protect our legal rights.
Legal Basis for Our Use.Certain data protection laws (such as those for example, in the European Economic Area (EEA), the United Kingdom (UK), and Brazil) require us to identify a valid legal reason (called a “legal basis”) before we collect, use, share or otherwise process your Personal Information. Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, where we have a legal obligation to do so, or where the processing is in our legitimate interests (such as processing for administrative purposes, direct marketing, product development or improvement, preventing fraud or criminal acts and in support of information security) and not overridden by your data protection interests or fundamental rights and freedoms. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the time of collection. We will also tell you whether the requirement for that information is mandatory and explain any consequences to you if you do not provide the information. Similarly, if we collect and use your Personal Information based on our legitimate interests (or those of any third party), we will take reasonable steps to provide clear notice and describe our legitimate interests. DUBTEL is the Data Controller of all Personal Information collected through the Platform in the EEA and the United Kingdom, except with respect to the Processor Services (where DUBTEL is the Data Processor) or where a supplemental Privacy Policy says otherwise. The contact details for DUBTEL are set out in the "HOW TO CONTACT US” section. If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information for any specific processing activity, please contact us using the contact details provided under the “HOW TO CONTACT US” Section below.

4. How DUBTEL Protects Your Information.

We design our Platform to provide reasonable and appropriate administrative, technical and organizational security measures to protect your Personal Information against risks such as temporary or permanent loss, destruction, and unauthorized or unlawful access, alteration, use or disclosure. We require our suppliers and vendors to apply similar protections when they access or use Personal Information that we share with them.

5. How DUBTEL Shares Your Information.

We may disclose Personal Information with the following categories of third parties:

With Affiliates and Subsidiaries.We may share information with our corporate affiliates and subsidiaries for purposes limited to and consistent with this Privacy Policy.
With Service Providers.We may share information with our authorized vendors and suppliers to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service. We use a wide variety of software and tools at DUBTEL, and we process Personal Information using these tools as a regular course of business. We also share anonymized or aggregated information with suppliers for purposes such as analysis, identifying trends in the areas of our products and to help research and develop new DUBTEL services. Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use.
With PartnersWe may share information with our authorized vendors and suppliers to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service. We use a wide variety of software and tools at DUBTEL, and we process Personal Information using these tools as a regular course of business. We also share anonymized or aggregated information with suppliers for purposes such as analysis, identifying trends in the areas of our products and to help research and develop new DUBTEL services. Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use.
For Advertising and Marketing. We share your information with our third-party company partners to prepare and deliver advertising and marketing content, to provide content services and to enable them to provide you with more personalized ads and to study the effectiveness of our campaigns. In particular, we use third-party companies to communicate regarding goods and services that may be of interest to you, in accordance with your preferences. You may receive this content by a variety of means such as email, phone or when you access and use the Platform. Content may be based on information obtained, for example, through prior purchases or transactions, through your device’s physical location, through information about what advertisements and content you have viewed. For information about how to manage our advertising and marketing, please see the section entitled "Your Choices & Rights" below. You can choose whether to allow or deny uses and/or sharing of your device’s location by changing your device settings, but if you choose to deny such uses or sharing, our partners may not be able to provide you with the applicable Platform Services and content.
For Connections to Social Networks and Third-Party Services.If you connect third-party services to the Platform (including installing an app through our marketplace) you are agreeing to provide information about you to the third-party services under their respective terms and privacy policies. For example, if you choose to connect your YouTube account to the DUBTEL Services, this connection uses YouTube’s API services, and the Google Privacy Policy (locatedhere) will apply to you. If you have authorized us to access your information via the YouTube API services, in addition to our normal procedure for deleting stored data, you may revoke our access to your data via the Google security settings page, locatedhere.
Sales, Mergers & Acquisitions.We may disclose Personal Information as part of a contemplated or actual corporate transaction such as a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
For Legal, Regulatory, or Related Purposes.We may disclose your information to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders.
At Your Direction or With Your Consent.DUBTEL may disclose your Personal Information to any other person or entity where you consent to the disclosure or otherwise direct us to disclose the information.
We do NOT share your phone number or opt-in consent with third parties unless we’ve received your express written consent to do so.

6. Data Retention.

We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and for other purposes described in this Privacy Policy. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data: see “YOUR LEGAL RIGHTS” below for further information. And in some circumstances we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. Information From Children

We do not knowingly collect, use, disclose, sell, or share Personal Information from children under 16. If we learn that we have collected the Personal Information of a child under 16 we will take steps to delete the information as soon as possible. If you are under 16, do not provide any information about yourself to DUBTEL, including your name, address, telephone number or email address. If you become aware that Personal Information of a child under 16 years of age has been provided, please let us know using one of the methods provided under the “HOW TO CONTACT US” section below.

8. Links to Other Websites and Services.

We are not responsible for the practices employed by websites or services linked to or from the Platform, including the information or content contained therein. This Privacy Policy does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not operating on DUBTEL’s behalf, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service to which the Platform links – the inclusion of a link on the Platform does not imply endorsement of the linked site or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) - including any Personal Information you disclose to other organizations through or in connection with the Platform or other DUBTEL Services.

9. Do Not Track.

Some browsers incorporate a "Do Not Track" (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.

10. Your Legal Rights.

DUBTEL respects your rights related to your Personal Information. Depending on where you live, you may have rights to request access to, corrections of, or deletion of your personal data, and to make additional choices such as the kinds of marketing materials you receive (or choose not to receive marketing from DUBTEL at all). See below for more information, depending on your location. If your jurisdiction does not appear on the list below, you may still have privacy rights like those that appear below; you can contact us using the HOW TO CONTACT US section below to learn more.

11. European Privacy Rights.

If you are in Europe, you may have the following rights under the GDPR, the UK GDPR, or Swiss nFADP:

Rights to Access, Portability, Correction, or Deletion.If you would like to correct or update your Personal Information, or to request access to or deletion of your Personal Information, you may contact us by visiting the Platform or by using the contact details provided under the HOW TO CONTACT US section below. If you request a change to or deletion of your Personal Information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). Some of your information may also remain within our systems and other records where necessary for compliance with applicable law.
Right to Object.We may share information with our authorized vendors and suppliers to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service. We use a wide variety of software and tools at DUBTEL, and we process Personal Information using these tools as a regular course of business. We also share anonymized or aggregated information with suppliers for purposes such as analysis, identifying trends in the areas of our products and to help research and develop new DUBTEL services. Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use.
Right to Withdraw Consent.If we have collected your Personal Information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect (1) the lawfulness of any processing we conducted prior to your withdrawal, or (2) processing your Personal Information under other legal bases.
Right to Complain.If you believe we are using your Personal Information in a way that is inconsistent with this Privacy Policy or for more information about your rights, you can contact your local data protection supervisory authority. The UK supervisory authority is the Information Commissioner's Office (ICO). You can visit their website at www.ico.org.uk. If you are in the EU, you can find your local data protection authority here) will apply to you. If you have authorized us to access your information via the YouTube API services, in addition to our normal procedure for deleting stored data, you may revoke our access to your data via the Google security settings page, locatedhere. If you are in Switzerland, you can find your local data protection authorityhere. Additionally, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, you may contact JAMS Mediation, Arbitration, and ADR Services (https://www.jamsadr.com/eu-us-data-privacy-framework) to address complaints and provide appropriate recourse free of charge to you. Under certain conditions, you may invoke binding arbitration. For additional information on pre-arbitration requirements, please see Annex I of the DPF Principles. You may also contact us by using one of the methods provided under the "HOW TO CONTACT US" section below. We will respond to any complaint directly to us within 45 days.
Advertising and Marketing Choices.To exercise your choices regarding our use and disclosure of your Personal Information for advertising and marketing purposes, you may access or update your contact details or modify your communication preferences by using one of the methods provided under the “HOW TO CONTACT US” section below. Please also note that if you choose not to receive marketing communications from us, we may still send you communications related to your products or the Platform, such as information about a security update, service issue or product delivery. Some advertising content is delivered through the Platform’s use of cookies.

12. U.S. Privacy Rights

Residents of certain US states, such as California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, and other states to the extent they enact similar privacy laws, may have additional rights under your corresponding state laws (“collectively, US State Privacy Laws”). This section provides further information pursuant to the US State Privacy Laws.

Rights to Access, Portability, Correction, or Deletion.If you would like to correct or update your Personal Information, or to request access to or deletion of your Personal Information, you may contact us by visiting the Platform or by using the contact details provided under the HOW TO CONTACT US section below. If you request a change to or deletion of your Personal Information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). Some of your information may also remain within our systems and other records where necessary for compliance with applicable law.
Right to Object.We may share information with our authorized vendors and suppliers to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service. We use a wide variety of software and tools at DUBTEL, and we process Personal Information using these tools as a regular course of business. We also share anonymized or aggregated information with suppliers for purposes such as analysis, identifying trends in the areas of our products and to help research and develop new DUBTEL services. Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use.
Right to Withdraw Consent.If we have collected your Personal Information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect (1) the lawfulness of any processing we conducted prior to your withdrawal, or (2) processing your Personal Information under other legal bases.
Right to Complain.If you believe we are using your Personal Information in a way that is inconsistent with this Privacy Policy or for more information about your rights, you can contact your local data protection supervisory authority. The UK supervisory authority is the Information Commissioner's Office (ICO). You can visit their website at www.ico.org.uk. If you are in the EU, you can find your local data protection authority here) will apply to you. If you have authorized us to access your information via the YouTube API services, in addition to our normal procedure for deleting stored data, you may revoke our access to your data via the Google security settings page, locatedhere. If you are in Switzerland, you can find your local data protection authorityhere. Additionally, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, you may contact JAMS Mediation, Arbitration, and ADR Services (https://www.jamsadr.com/eu-us-data-privacy-framework) to address complaints and provide appropriate recourse free of charge to you. Under certain conditions, you may invoke binding arbitration. For additional information on pre-arbitration requirements, please see Annex I of the DPF Principles. You may also contact us by using one of the methods provided under the "HOW TO CONTACT US" section below. We will respond to any complaint directly to us within 45 days.
Advertising and Marketing Choices.To exercise your choices regarding our use and disclosure of your Personal Information for advertising and marketing purposes, you may access or update your contact details or modify your communication preferences by using one of the methods provided under the “HOW TO CONTACT US” section below. Please also note that if you choose not to receive marketing communications from us, we may still send you communications related to your products or the Platform, such as information about a security update, service issue or product delivery. Some advertising content is delivered through the Platform’s use of cookies.

13. Australian Privacy Rights

This section is addressed to Australian residents only and provides more information about your rights under the Australian Privacy Act. You can exercise your rights by using the details in the “HOW TO CONTACT US” section.

Data Subject Rights.You can request correction of your Personal Information by using the details in the “HOW TO CONTACT US” section. You may also have a legal right to obtain a copy of your Personal Information. You can make such a request by making a written request in one of the ways described in the “HOW TO CONTACT US” section below and we will respond to you by no later than 30 days of your request. We may charge a processing fee for this service where permitted by law. DUBTEL will provide reasons to you if we are unable to provide access or only provide limited access to your Personal Information.
Complaints.If you have any complaints regarding our handling of your Personal Information, our response to your request, or our compliance with the Privacy Act, or for more information about your rights, please contact us using the details in the “HOW TO CONTACT US'' section. However, if you are dissatisfied with our response, you may raise a complaint with the Office of the Australian Information Commissioner by contacting them at: https://www.oaic.gov.au/about-us/contact-us.

14. Canadian Privacy Rights

This section is addressed to Canadian residents only and provides more information about your rights under the Personal Information Protection and Electronic Documents Act 2000 (PIPEDA). You can exercise your rights by using the details in the “HOW TO CONTACT US” section.

Data Subject Rights.You can request correction of your Personal Information by using the details in the “HOW TO CONTACT US” section. You may also have a legal right to access and obtain a copy of your Personal Information. You can make such a request by making a written request in one of the ways described in the “HOW TO CONTACT US” section below and we will respond to you by no later than 30 days of your request. If you submit a request to exercise rights under PIPEDA, DUBTEL will ask you to provide certain information to verify your identity. This information will depend on your prior interactions with DUBTEL and the sensitivity of Personal Information at issue. We may charge a processing fee for this service where permitted by law. If DUBTEL denies your request, we will explain why.
Withdrawal of Consent.If we have collected your Personal Information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect (1) the lawfulness of any processing we conducted prior to your withdrawal, or (2) processing your Personal Information under other legal bases. Residents of Quebec Province may have additional rights; please refer to the European Privacy Rights section above for a description of rights that may be applicable, and contact us if you have any questions or would like to make any requests.

15. International Data Transfers

DUBTEL Inc. and LeadConnector LLC comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. DUBTEL has certified to the U.S. Department of Commerce that DUBTEL and LeadConnector adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. DUBTEL has certified to the U.S. Department of Commerce that DUBTEL and Leadconnector adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. DUBTEL further agrees to notify you without undue delay, if its self-certification under any of the Data Privacy Framework is withdrawn, terminated, revoked or otherwise invalidated and take appropriate steps to stop and remediate and unauthorized processing of such personal data.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, DUBTEL commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact DUBTEL at: [email protected]

16. Data Privacy Framework

DUBTEL is a global company with its headquarters in the United States. As such, we may transfer your Personal Information between the United States and our affiliates and business partners in other countries. We may also transfer your Personal Information to our affiliates or third-party service providers, who may be located in a different country to you (including India). DUBTEL transfers information internationally in order to operate efficiently, to improve performance, and to create redundancies to protect information in the event of an outage or other problem. In so doing, we will process your Personal Information in a way that meets the commitments of this Privacy Policy and complies with the law wherever we transfer it. Whenever DUBTEL transfers Personal Information beyond the country of origin, we will do so in accordance with applicable laws. For Personal Information originating in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland that is transferred to a DUBTEL entity outside the EEA, UK, or Switzerland, DUBTEL participates in the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and, as applicable, the UK extension to the EU-U.S. DPF, and/or the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). DUBTEL commits to the DPF Principles and, as needed, will take additional steps to provide appropriate safeguards for the Personal Information we transfer. The Federal Trade Commission has jurisdiction over DUBTEL’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF). DUBTEL may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. DUBTEL is liable in cases of onward transfers to third parties.

17. Privacy Policy Updates

DUBTEL may change this Privacy Policy at any time, at its discretion. We will notify you of changes if required by law. Your continued use of the Platform after we make changes is deemed to be acceptance of and consent to those changes, so please check the Privacy Policy periodically for updates.

18. How To Contact Us About This Privacy Policy

To ask questions about this Privacy Policy and our privacy practices, contact us at [email protected] or by mail at: DUBTEL Consulting LLC. ATTN: Legal Department 8050 Beckett Center Dr., Suite 124 West Chester, OH 45011.