NoDials

NoDials Privacy Policy

Effective date: 2026-10-08 (v1)

This policy explains how Capital Commission Management, LLC, doing business as NoDials ("NoDials," "we," "us"), handles personal information. NoDials delivers live phone calls with consumers who asked about mortgage protection insurance to licensed insurance agents. That means this policy covers two very different groups of people, so it is organized that way: the agents who use our Service, and the consumers whose calls we route.

1. If you are an agent

What we collect.

  • Account and licensing: your first and last name, email address, cell phone number, National Producer Number (NPN), and the states you tell us you are licensed in. We keep your NPN on file for compliance and may check it against the National Insurance Producer Registry.
  • Sign-in: your password, stored only as a scrambled hash; or, if you sign in with Google, your name, email, and Google account ID (we ask Google only for your basic profile and email); and the one-time codes we email you.
  • Wallet: your balance and ledger (every deposit, charge, credit, and correction), your auto-reload settings, and, for each saved card, only the brand and last four digits. Payments are processed by Whop, which is the merchant of record; Whop collects and holds your full card details and sends your receipts. We never see or store full card numbers.
  • Calls: for every call routed to you, the time, how long it lasted, who hung up, whether it became billable, the disposition you record (including any premiums you report), the notes you type about the call and their earlier versions, and the call recording and any transcript we make from it. Your voice is on those recordings.
  • Activity: whether your switch is on, your test-ring result, when you were last active, whether you have the app open, and the results we compute from your calls (for example, your take rate).
  • Technical data: IP address, browser and device type, and standard server logs; a cookie that keeps you signed in; and the analytics data described in Section 3.
  • Messages: emails and other messages you send us.

Where it lives. We run the Service on established platforms, each holding what it needs to do its job: Retreaver (call routing and call recordings), our call-center partners and their dialer (the consumer side of each transfer), Whop (payments and saved cards), Supabase (our database and sign-in), Vercel (website hosting), Cloudflare (domain and network), Resend (service email), Google (only if you choose Google sign-in), Microsoft Clarity and PostHog (analytics, Section 3), and our internal team messaging tools (our team gets notices about signups and account events, which may include your name and email). All are U.S.-based services and data is processed in the United States. Transcripts, when we make them, are produced on equipment we control.

How we use it. To run the Service: create and secure your account, confirm you are licensed, route calls to you, charge your wallet, send you service emails, support you, and resolve disputes. To run our business: review recordings and dispositions for quality, compliance, and coaching; compute performance figures; and keep business records. To improve the Service: analyze calls, dispositions, and usage, by people and by automated tools, to measure quality, train and coach agents, and build and improve features. To meet legal obligations. We may show your first name, last initial, and performance figures to other agents inside the Service, and we may use your first name and results in our marketing as the Terms of Service describe.

What we never do. We do not sell agent personal information, and we do not share it with third parties except the service providers above, our professional advisers, a buyer or successor if our business is sold or reorganized, or when the law requires it or it is needed to protect our rights.

2. If you are a consumer whose call we routed

If you spoke with an insurance agent after a call from one of our call centers, here is what happened to your information. A call center working for us called you about mortgage protection or similar life insurance, based on an inquiry record showing you had asked about those products. When you said you were interested, the call center transferred you live to a licensed insurance agent through our phone system.

  • We hold the record of that call: the phone number the call came from, the time and length of the call, your state and zip code, the information the call center passed along (such as your name, address, and the details of your inquiry), the agent who took your call, and a recording of the call. We may transcribe and analyze recordings to check quality and compliance and to improve our Service.
  • We share your information with the agent who took your call, so they can serve you. Once the call ends, that agent is responsible for their own follow-up contact with you and for honoring your requests. If you do not want to hear from them again, tell them, and they are required to honor it.
  • We do not sell your information, and we do not share it with any agent other than the one who took your call, except with our service providers, our professional advisers, or when the law requires it.
  • To ask us not to call you again, or to ask about the data behind a call, email support@nodials.com with your name and phone number. We will add your number to our do-not-call list, pass your request to the agent who took your call, and confirm when it is done. You can also add your number at donotcall.gov.

3. Website and app analytics

Our pages use Microsoft Clarity and PostHog to understand how the Service is used: which pages are visited, where people click, tap, and scroll, how far they get, and where they get stuck. Clarity can replay a visitor's session (mouse movement, clicks, scrolling) and masks the text you type into form fields. PostHog records page views and events. Both set cookies or similar identifiers and may collect your IP address, browser, and device type. We do not run these tools on our internal admin pages. Microsoft and PostHog process this data under their own privacy policies. We do not use advertising pixels on the Service today. You can limit these tools with your browser's cookie controls; the Service still works without them.

4. Cookies

We use a sign-in cookie (so you stay logged in), a short-lived cookie during the sign-in code step, an access cookie during invite-only periods, and the analytics cookies in Section 3. None of them is used for advertising.

5. Retention

  • Account, licensing, and wallet records: as long as your account is open, plus the period needed for legal, tax, licensing, billing, and dispute purposes.
  • Call records, recordings, transcripts, dispositions, and notes: kept while your account is open and afterward for as long as we need them to document charges, handle disputes, meet legal and compliance obligations, and improve the Service. Recordings are kept by our call-routing provider under its retention schedule as well as by us.
  • Do-not-call requests: kept permanently, because honoring them requires remembering them.
  • Analytics data: kept by Microsoft Clarity and PostHog under their own retention periods.
  • Deletion on request: email support@nodials.com from your account email. After we confirm the request came from you, we will delete your account data from our active systems within 30 days, except what we need to keep for the reasons above. Copies may remain in backups until they are overwritten in the normal course. Your wallet balance is forfeited when your account closes (see the Terms of Service).

6. Security

Data moves over encrypted (HTTPS) connections. Sign-in uses hashed passwords with a breached-password check, one-time email codes, or Google sign-in, and sessions live in secure, HTTP-only cookies. Full card details live only with Whop. Access to agent and call data is limited to the people and systems that need it to run the Service, and our logs record account identifiers rather than cell numbers or NPNs. No system is perfectly secure; if a breach affects your data, we will notify you as the law requires.

7. Your rights

Depending on your state, you may have the right to access, correct, delete, or get a copy of your personal information, and you will not be penalized for using those rights. Email support@nodials.com and we will respond within the time the law sets. We do not sell personal information. For consumers: a request to us stops future calls from our call centers and is passed to the agent who took your call; requests about that agent's own follow-up contact go to that agent.

8. Children

The Service is for business use by licensed adults. We do not knowingly collect information from anyone under 18, and our call centers do not knowingly call minors.

9. Changes

We will post updates here with a new effective date and notify agents of material changes by email or in the Service.

10. Contact

Capital Commission Management, LLC d/b/a NoDials 1600 E 8th Ave, STE A200 Tampa, FL 33605 Email: support@nodials.com

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