1. Introduction and Scope
This Privacy Policy describes how Eleven Solutions LLC collects, uses, stores, discloses, secures, transfers, and otherwise processes information in connection with elev1solutions.com, customer portals, hosted VoIP, SIP, cloud PBX, numbers, SMS/MMS, recordings, voicemail, transcription, support, billing, compliance, fraud prevention, and related services.
It applies to customers, administrators, users, employees of customers, website visitors, payment contacts, support contacts, call and message participants, campaign recipients, and other individuals whose information is processed through the services. Customer may act as an independent controller or business, while Eleven Solutions may act as a controller, processor, service provider, carrier, or communications intermediary depending on context and law.
Customer is responsible for providing legally required privacy notices to its users and communication recipients and for establishing a lawful basis for Customer-controlled processing. Eleven Solutions does not provide Customer with legal advice or transfer Customer’s compliance duties.
2. Categories of Information Collected
We may collect information directly from Customer, account users, service usage, communications networks, carriers, payment processors, identity providers, fraud tools, public sources, regulators, traceback groups, and business partners. Categories include:
- Identity and business data: names, business names, addresses, emails, phone numbers, job titles, ownership, administrators, authorized users, tax data, incorporation records, government identification, KYC/KYB documents, sanctions-screening results, and verification status.
- Billing and transaction data: billing addresses, plan selections, invoices, payment status, processor tokens, transaction identifiers, bank or crypto references, screenshots or payment evidence, refunds, disputes, chargebacks, taxes, credits, and accounting records. Eleven Solutions generally does not store complete card numbers when a payment processor handles them.
- Technical and security data: IP addresses, device and browser details, operating systems, cookies, session identifiers, authentication events, login timestamps, API requests, SIP headers, registration events, endpoint identifiers, network logs, fraud signals, threat indicators, and policy-enforcement history.
- Telecommunications metadata: calling and called numbers, sender and recipient numbers, timestamps, duration, answer status, disconnect cause, routing, carrier, attestation, message delivery, number assignments, porting history, voicemail metadata, recording metadata, and CDRs.
- Communications content where enabled or supplied: call recordings, voicemail, transcriptions, SMS/MMS content, support tickets, emails, chats, documents, scripts, message templates, abuse reports, and consent evidence.
- Usage and configuration data: extensions, seats, features, PBX settings, forwarding rules, integrations, API usage, dashboard activity, storage use, campaign descriptions, opt-out data, and support history.
- Approximate location and emergency-location data: service addresses, billing locations, IP-derived region, registered 911 address, dispatchable location, and device location where a user or Customer provides or enables it.
3. Sources of Information
Information may be provided by Customer or its administrators, generated automatically through service use, supplied by a communications recipient, received from carriers and upstream providers, obtained from payment and identity-verification vendors, derived from fraud and reputation services, obtained from public records, or provided by regulators and law enforcement.
Customer must not submit personal information it lacks authority to provide. Customer represents that it has supplied all required notices and obtained all required permissions for information uploaded to or transmitted through the services.
4. Purposes of Processing
We process information where necessary to provide contracted services, comply with legal obligations, protect legitimate interests, obtain consent where required, and operate communications infrastructure. Purposes include:
- Creating, authenticating, verifying, administering, supporting, and securing accounts, users, numbers, routes, campaigns, devices, and integrations.
- Routing, transmitting, receiving, rating, billing, recording, transcribing, storing, troubleshooting, and delivering calls, messages, voicemail, and related communications.
- Processing payments, invoices, taxes, refunds, disputes, chargebacks, bank transfers, crypto confirmations, collections, and financial reporting.
- Detecting and preventing fraud, toll fraud, spam, illegal robocalling, spoofing, phishing, abuse, account compromise, sanctions violations, and security threats.
- Performing KYC, KYB, beneficial-owner verification, payment-risk assessment, campaign review, caller-ID verification, and compliance audits.
- Complying with subpoenas, court orders, warrants, preservation requests, emergency requests, regulatory inquiries, traceback requests, carrier obligations, CPNI rules, CALEA where applicable, and other legal duties.
- Providing E911 functionality, maintaining registered locations, supporting dispatchable-location requirements, and responding to emergency-service needs.
- Improving products, quality, routing, analytics, documentation, customer support, reliability, forecasting, capacity planning, and business operations.
- Enforcing contracts and policies, resolving disputes, protecting rights and property, and establishing or defending legal claims.
5. Voice, Messaging, Recording, and Communications Data
Telecommunications services necessarily process information about communications. We may process signaling and metadata required to route and secure traffic even when content features are disabled. Upstream providers and destination carriers may independently process the same traffic under their own legal obligations and privacy practices.
Where recording, voicemail, SMS/MMS, transcription, analytics, or storage features are enabled, communications content may be stored or processed. Customer controls whether to enable many of these features and is responsible for legally required consent and notices. Eleven Solutions may access content only as necessary for service delivery, support, security, abuse investigation, legal compliance, or policy enforcement.
Automated transcription and analytics may be inaccurate. Customer should not treat them as authoritative records and should apply appropriate human review.
6. CPNI and Telecommunications Confidentiality
Where Customer Proprietary Network Information rules apply, Eleven Solutions uses CPNI to provide the services from which it is derived, protect customers and networks, bill and troubleshoot, comply with law, and for other purposes permitted by applicable FCC rules. We use authentication and access controls intended to protect CPNI.
We may disclose CPNI to Customer-authorized users, carriers and vendors necessary to provide service, emergency services, and government authorities where permitted or required. Customer must keep account contacts current and restrict portal access to authorized persons.
Not every category of data or service is legally classified as CPNI. This section applies only to the extent required by law and does not narrow broader protections or permitted processing described elsewhere.
8. SMS Consent and Mobile Information
Mobile numbers and SMS opt-in consent collected for Eleven Solutions’ own messaging program are not sold or shared with third parties or affiliates for their independent marketing or promotional purposes. We may disclose them to messaging vendors and carriers solely to deliver messages, process opt-outs, secure the program, and comply with law.
Customer-operated messaging traffic is controlled by Customer. Customer must provide its own disclosures and may not use Eleven Solutions to sell, rent, or unlawfully share recipient data. STOP, HELP, and opt-out records may be retained to demonstrate compliance and prevent future unwanted messaging.
10. Legal Bases and International Privacy Laws
Depending on jurisdiction, processing may rely on performance of contract, compliance with legal obligations, protection of vital interests, consent, and legitimate interests such as providing secure communications, preventing fraud, improving services, and enforcing agreements.
Privacy laws may include the California Consumer Privacy Act as amended by the CPRA, other U.S. state comprehensive privacy laws, the EU General Data Protection Regulation, UK GDPR and Data Protection Act 2018, Canada’s PIPEDA and anti-spam rules, and equivalent laws. Applicability depends on facts, thresholds, roles, exemptions, and location.
Where Eleven Solutions acts as a processor or service provider and a legally required data processing addendum is appropriate, Customer may request one. Telecommunications secrecy, CPNI, lawful-intercept, emergency, fraud-prevention, and record-retention duties may limit certain privacy requests.
11. International Transfers
Information may be processed in the United States and other countries where Eleven Solutions, carriers, providers, or vendors operate. These countries may have different privacy laws. Where required, we use contractual safeguards or other lawful transfer mechanisms.
Communications routing may inherently cross jurisdictions based on internet paths, carrier interconnection, destination, roaming, redundancy, and infrastructure availability. Customer is responsible for evaluating whether its use permits such routing and transfers.
12. Security Measures and Incident Response
We use administrative, technical, and physical safeguards designed to protect information, including access controls, credential protection, logging, network controls, backups, vendor management, and incident response. No system is completely secure, and we cannot guarantee that unauthorized access, loss, interception, or disruption will never occur.
Customer is responsible for its endpoints, credentials, local network, user permissions, integrations, downloads, exported recordings, and downstream disclosure. Customer must notify Eleven Solutions immediately of suspected compromise and cooperate with containment.
Where a legally reportable breach occurs, Eleven Solutions will provide notices required by applicable law. Timing and content may depend on investigation, law-enforcement requests, affected systems, and the roles of Eleven Solutions and Customer.
13. Retention, Preservation, and Deletion
We retain information for periods reasonably necessary to provide service, bill, resolve disputes, prevent fraud, maintain security, satisfy tax and accounting duties, comply with carrier and regulatory requirements, respond to legal process, and enforce agreements. Retention varies by data type, service, jurisdiction, and account status.
Call recordings, voicemail, messages, transcriptions, logs, and CDRs may have separate retention settings or provider limitations. Deletion from the active portal may not immediately remove backups, immutable logs, legal holds, fraud records, suppression lists, or records retained by carriers and processors.
We may preserve information in response to litigation, subpoena, warrant, emergency request, traceback, regulatory inquiry, chargeback, fraud investigation, or anticipated dispute. After retention expires, information may be deleted, anonymized, or rendered inaccessible according to operational processes.
14. Privacy Rights and Requests
Depending on location and applicable exemptions, individuals may have rights to access, correct, delete, restrict, object, withdraw consent, receive portability, opt out of certain sharing or targeted advertising, or appeal a decision. Requests may be submitted to hello@elev1solutions.com and may require identity verification.
We may deny or limit requests where permitted, including when information is needed to provide service, protect security, detect fraud, maintain suppression records, comply with telecommunications or legal obligations, preserve evidence, exercise legal claims, or protect another person’s rights.
Where Eleven Solutions processes information solely for Customer, we may direct the requester to Customer. Customer must respond to its own users and recipients and may use available portal tools to fulfill requests.
15. Children and Sensitive Use
The services are intended for businesses and are not directed to children under thirteen. Customers must not knowingly use the services to collect children’s information without lawful authority and required parental consent. We may terminate accounts that target children unlawfully.
Customer must apply heightened safeguards to medical, financial, biometric, precise-location, government-identifier, and other sensitive information and must not transmit data prohibited by law, contract, carrier policy, or security standards.
16. Policy Changes and Contact
We may update this Privacy Policy to reflect legal, regulatory, technical, service, or business changes. The effective date will be posted. Material changes may be communicated through the website, portal, invoice, or account email where required.
Questions, privacy requests, compliance matters, and abuse reports may be sent to hello@elev1solutions.com or by mail to 1621 Central Ave #69526, Cheyenne, WY 82001. Customer must keep its account contact information current.
17. Controller, Processor, Service Provider, and Carrier Roles
Privacy terminology differs across laws. For account administration, billing, fraud prevention, website operation, legal compliance, and direct customer relationships, Eleven Solutions may determine purposes and means and act as a controller or business. For Customer-selected storage or processing of communications content, Eleven Solutions may act as a processor or service provider. For routing and telecommunications functions, specialized carrier and communications laws may apply instead of or alongside general privacy statutes.
Customer is generally responsible for determining the lawful purpose of calls, messages, recordings, campaigns, contact lists, and recipient information. Customer must provide instructions that comply with law and must not direct Eleven Solutions to process information unlawfully. Eleven Solutions may refuse an instruction that creates legal, security, carrier, or operational risk.
Role classification can vary by data element and activity within the same account. Nothing in this Policy is a categorical admission that a particular law, role, or duty applies. Contractual labels do not override mandatory legal classification.
18. Automated Decisions, Fraud Scoring, and Communications Analytics
We may use automated systems to assess fraud, payment risk, account compromise, spam, illegal robocalling, traffic anomalies, sanctions indicators, message deliverability, number reputation, and policy compliance. Inputs may include identity data, transaction history, IP information, device signals, traffic patterns, complaints, carrier feedback, and external risk data.
Automated outputs may trigger verification, limits, review, blocking, or temporary suspension. Material decisions may be reviewed by personnel where appropriate and legally required. Because fraud logic is security-sensitive, we may not disclose models, weights, thresholds, or intelligence sources.
Individuals may have rights relating to solely automated decisions under certain laws. Those rights are subject to scope, exemptions, security, fraud-prevention, telecommunications, and legal-obligation limitations. Requests should identify the account and decision at issue.
19. Government, Emergency, and Traceback Disclosures
We may disclose information when we reasonably believe disclosure is required by law, necessary to respond to an emergency involving danger of death or serious physical injury, needed to prevent fraud or network harm, or appropriate to cooperate with a lawful traceback. The information disclosed may include subscriber identity, account records, payment data, IP logs, numbers, routing, CDRs, content where legally authorized, and preservation status.
We assess legal process based on apparent validity, authority, jurisdiction, specificity, and applicable communications law. We may notify Customer when lawful and practical, but may be prohibited from doing so. Emergency disclosures may occur before formal process when law permits and circumstances justify urgent action.
Customer must not promise recipients that communications are anonymous or immune from disclosure. Telecommunications networks generate records at multiple providers, and Eleven Solutions cannot control records held by carriers, recipients, devices, payment providers, or government systems.
20. Data Minimization and Customer Configuration
Customer should enable only features needed for its business, collect only necessary information, restrict administrator access, use retention settings appropriate to legal and operational needs, and periodically delete or export data. Recording every call, retaining messages indefinitely, or giving all users broad portal access increases risk and may be disproportionate.
Eleven Solutions may provide configurable retention, permissions, recording, transcription, messaging, forwarding, and integration features. Availability of a setting does not mean the setting is lawful for every Customer. Customer must choose settings based on its purpose, jurisdiction, workforce, contracts, security, and recipient expectations.
Where technically and legally feasible, Eleven Solutions may aggregate, tokenize, pseudonymize, de-identify, redact, or minimize information. De-identified information may be retained and used for analytics, quality, security, research, and business planning, provided it is not reasonably reidentified contrary to law.
21. Vendor Governance and Subprocessors
Eleven Solutions uses vendors for hosting, storage, monitoring, support, email, payments, identity verification, fraud prevention, messaging, carrier services, analytics, and professional advice. We assess vendors according to risk and may use contracts, security review, access restrictions, and monitoring. No vendor ecosystem is risk-free.
Vendors may change as services evolve, costs change, carriers modify interconnection, or security and compliance needs develop. Where a law or data processing addendum requires notice of subprocessors, the applicable contractual process controls. Customer is responsible for reviewing notices and raising legally supported objections within the stated period.
Upstream telecommunications providers are not always conventional subprocessors because they may independently determine routing, legal retention, security, numbering, emergency, and regulatory processing. Their independent obligations may limit Eleven Solutions’ ability to instruct deletion, location, or processing method.