CCPA/CPRA NOTICE – UPDATED AUGUST 2026

California Privacy Rights Notice for California Residents

360 Technologies USA LLC

Last Update: August, 2026 | Applies to all 360 Technologies USA LLC platforms and services

This California Privacy Notice supplements the information contained in the 360 Technologies USA LLC Privacy Policy and applies solely to residents of the State of California (“consumers” or “you”). We provide this notice to comply with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

We do not sell, rent, trade, or share personal information for cross-context behavioral advertising. We use personal information only for operational purposes necessary to provide our services.

1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

In the past 12 months, we have collected the following categories of personal information:

• Identifiers: Name, email address, phone number, account credentials, user ID
• Customer Records: Business information, documents uploaded, workflow data, transaction history
• Protected Classification Information: Only if voluntarily provided by the user (e.g., in forms or documents)
• Commercial Information: Service usage history, interactions, preferences, purchase history
• Internet or Network Activity: Device information, IP address, logs, usage analytics, access patterns
• Geolocation Data: General (non-precise) location derived from IP address
• Professional or Employment Information: Only when voluntarily provided for service operations
• Sensitive Personal Information: May include identity verification documents or regulated data submitted by users
• AI-Generated Data: Summaries, analyses, and insights generated by our AI services

We do not collect:

• Biometric data
• Precise geolocation
• Sensory data
• Social Security numbers (unless for compliance verification)

2. SOURCES OF PERSONAL INFORMATION

We collect personal information from:

• Information you provide directly through our platforms (registration, forms, uploads)
• Automated system logs and analytics
• Documents or data you upload to our services
• Communications sent through our services
• Service providers supporting our operations
• Interaction with third-party integrations (with your consent)

3. PURPOSES FOR COLLECTING PERSONAL INFORMATION

We use personal information solely for legitimate business and operational purposes, including:

• Providing, maintaining, and improving our services
• Authenticating users and securing accounts
• Processing workflows, documents, and communications
• Detecting and preventing fraud or unauthorized access
• Ensuring platform reliability and performance
• Complying with legal and regulatory obligations
• Internal analytics and service optimization
• Customer support and dispute resolution
• Service security and integrity

We do not use personal information for:

• Targeted advertising or unrelated marketing
• Cross-context behavioral advertising
• Profiling for discriminatory purposes
• Purposes disclosed differently than in this notice

4. 360x AI SERVICES – SPECIAL DATA HANDLING (NEW – August 2026)

Important Distinction

360x AI has different data handling than Hi360x (described in Section 5).

What is 360x AI?

360x AI is an intelligent assistant integrated directly into Live 360, available in two pricing tiers (Free and Pro).

360x AI Data Practices

CRITICAL: 360x AI does NOT use your data for model training:

• Your data is processed exclusively for real-time query responses
• Processing occurs in-memory; responses are not retained after interaction
• Conversation history is stored in your Live 360 account (encrypted) for your reference only
• Your data is never used to train, improve, or fine-tune any AI models
• Your data is never shared with external AI model providers
• Your data is never used for profiling or discriminatory purposes

360x AI Data Rights (CCPA/CPRA)

As a California resident using 360x AI, you have the following rights:

• Right to Know: Request details about data collected through 360x AI
• Right to Delete: Request deletion of your 360x AI data
• Right to Correct: Request correction of inaccurate 360x AI data
• Right to Access: Access your 360x AI conversation history
• Right to Non-Discrimination: Exercising your rights will not affect service quality or pricing

Important: Because 360x AI does NOT use data for model training, there is no opt-out mechanism for “data used for training” — your data is never used for that purpose.

5. HI360X AI SERVICES – SPECIAL DATA HANDLING

Hi360x Data Collection

When you use Hi360x (our sales AI platform), we collect:

• Call recordings and transcripts
• Chat and email conversations
• Lead qualification data and scoring
• User corrections and feedback
• AI-generated summaries and analyses

Hi360x Data Practices

Hi360x data may be used for model training:

• To train and improve AI models
• For analytics and reporting
• For service optimization

Hi360x Data Rights (CCPA/CPRA)

As a California resident using Hi360x, you have the following additional rights:

• Right to Know: Request details about Hi360x data collected
• Right to Delete: Request deletion of Hi360x data (including training data)
• Right to Opt-Out: Opt out of having your Hi360x data used for AI model training
• Right to Correct: Request correction of inaccurate Hi360x data
• Right to Non-Discrimination: Opting out will not affect Hi360x service quality or pricing

How to Opt-Out of Hi360x Model Training

Email: info@360techusa.com
Subject: “Hi360x Opt-Out Request”

What happens when you opt out:

• Your data will not be used for future model training
• You will retain full access to Hi360x features
• No service degradation or price changes

Note: Hi360x model training uses only aggregated, anonymized data by default. You can opt out of even this limited usage.

6. SHARING OF PERSONAL INFORMATION

We do not sell personal information as defined under CCPA/CPRA.

We may disclose personal information only to:

6.1 Service Providers

Trusted vendors performing essential operational functions:

• Cloud hosting and data storage
• SMS and email delivery
• Security monitoring
• Infrastructure support

Status: These are “service providers” under CCPA, not “third parties.” Contractual restrictions apply.

6.2 Legal or Regulatory Authorities

We may disclose information when:

• Required by applicable law
• Responding to lawful requests
• Protecting rights, safety, or property of 360 Technologies or users

6.3 Corporate Transactions

In a merger, acquisition, or restructuring, personal information may be transferred under strict confidentiality.

6.4 Third-Party AI Assistant Integration (MCP)

IMPORTANT: If you connect our products to third-party AI assistants (Microsoft Copilot, OpenAI ChatGPT, Anthropic Claude, etc.) via MCP integration:

• Your data will be shared with third parties
• Under CCPA/CPRA, this may be considered a “sale” of personal information
• Third-party AI assistants may use your data for model training
• You have the right to opt out (see Section 6.4.1)

6.4.1 Opt-Out of MCP Data Sharing

You may opt out of data sharing through MCP integrations by:

Email: info@360techusa.com
Subject: “Opt-Out of Third-Party AI Integration”

7. RETENTION OF PERSONAL INFORMATION

We retain personal information only for as long as necessary to:

• Provide the services you use
• Fulfill the purposes in this notice
• Comply with legal obligations
• Maintain business records

Retention Schedules:

• Account data: Duration of subscription + 30 days
• Audit logs: 6 years minimum
• 360x AI conversations: Per your preference; can delete anytime
• Hi360x data: 12 months (or earlier upon request)
• Backups: 30 days rolling cycle

8. YOUR CCPA/CPRA RIGHTS

California residents have the following rights:

8.1 Right to Know

You may request:

• Categories of personal information collected
• Specific pieces of personal information collected
• Categories of sources
• Purposes for collection
• Categories of third parties receiving data

8.2 Right to Delete

You may request deletion of personal information collected from you, subject to legal exceptions:

• Data needed to complete transactions
• Data required by law
• Data necessary for security or fraud prevention
• Data you provide for purposes you requested

8.3 Right to Correct

You may request correction of inaccurate personal information.

8.4 Right to Opt-Out

We do NOT sell personal information, so the “opt-out of sale” right does not apply.

However, you may opt out of:

• Hi360x model training: Email info@360techusa.com
• Third-party AI integrations (MCP): Email info@360techusa.com

8.5 Right to Limit Use of Sensitive Personal Information

We use sensitive personal information only for operational purposes. We do not use it for:

• Profiling or discrimination
• Advertising or marketing
• Purposes outside this notice

You may request that we limit our use of sensitive information.

8.6 Right to Non-Discrimination

We will not:

• Deny services based on your exercise of CCPA/CPRA rights
• Charge different prices for the same services
• Provide different levels of service
• Retaliate for exercising your rights

Exception: We may offer financial incentives for data collection or use (e.g., discounts for opting in), provided the incentive is not unjust or coercive.

8.7 Authorized Agent

You may designate an authorized agent to submit requests on your behalf. We will require:

• Proof of agent authorization (power of attorney)
• Proof of your identity
• Signed authorization letter

9. HOW TO SUBMIT A REQUEST

9.1 Submission Methods

Email: info@360techusa.com
9.2 Request Details to Include

• Your full name and email address
• Description of your request (Know / Delete / Correct / Opt-Out)
• Specific data categories if applicable
• Proof of California residency (driver’s license, government ID, or utility bill)

9.3 Response Timeline

• Verification: 10-15 business days to verify your identity
• Fulfillment: Within 45 days of verification (extendable by 45 days with notice)
• Correction requests: 30 days to implement corrections

9.4 No Fees

We will not charge fees for processing most requests. However, we may charge a reasonable fee for:

• Frequent, repetitive requests (e.g., > 2 per year)
• Requests requiring significant technical effort

10. HI360X-SPECIFIC CCPA/CPRA RIGHTS

If you use Hi360x, additional rights apply:

Right to Know:

• Audio recordings (call transcripts)
• Text conversations
• AI-generated summaries
• Lead scoring results
• User corrections and feedback

Right to Delete:

• All Hi360x data associated with your account
• Including data previously used for AI model training

Right to Opt-Out:

• Of having Hi360x data used for model training
• Opting out does NOT affect your Hi360x service access

Right to Correct:

• Inaccurate Hi360x data

Categories of Hi360x Data:

• Audio data (recordings, transcripts)
• Text data (chats, emails)
• Behavioral data (corrections, interactions)
• Derived data (AI summaries, lead scores)

11. DATA SHARING WITH THIRD-PARTY AI ASSISTANTS (MCP)

Critical Disclosure

If you connect 360 Technologies products to third-party AI assistants via MCP integration:

• Your data will be transmitted to and processed by third parties
• Third parties may use your data for purposes outside your control
• Under CCPA/CPRA, this is considered “sharing” and may be a “sale”
• Third-party AI assistants typically use data for model training

Your Rights

You have the right to:

• Know: Third parties will receive your data
• Opt-Out: Refuse data sharing via MCP integration
• Access: Know which third parties have received your data
• Correct: Request third parties correct inaccurate data

How to Opt-Out

Email: info@360techusa.com
Subject: “Opt-Out of Third-Party AI Integration”

12. CHILDREN’S PRIVACY

We do not knowingly collect personal information from individuals under 18 years of age. Our services are intended for business use by adults. If we become aware of data from a minor, we will delete it promptly.

13. UPDATES TO THIS NOTICE

We may update this California Privacy Notice periodically to reflect changes in our practices, technology, law, or other factors.

When material changes occur, we will:

• Revise the “Last Updated” date
• Notify users via email or website notice (per CCPA/CPRA)
• Provide 30 days notice for significant changes

14. CONTACT INFORMATION

For questions or concerns regarding this Notice, contact:

📧 Email: info@360techusa.com (for privacy requests  or general inquiries)

California Attorney General Complaint: oag.ca.gov

15. RELATED POLICIES

• Privacy Policy: https://360techusa.com/privacy-policy/
• Terms & Conditions: https://360techusa.com/terms/
• Security Policy: https://360techusa.com/security/
• Data Protection & Security Addendum: Available upon request (info@360techusa.com)

Last Updated: August, 2026