CHILDREN’S PRIVACY POLICY FOR MYPHONE

Effective Date: March 16, 2026

This Children’s Online Privacy Policy describes how Ooma, Inc., together with its wholly owned subsidiaries (collectively, “Ooma,” “we,” “our,” or “us”) collects, uses and discloses Personal Information provided by children under the age of 13 (“child,” “children” or “Child Users”) through the MyPhone services, applications, and equipment (“MyPhone”), including Ooma Telo (connects home internet to phone), Ooma Linx (wireless accessory that connects additional phones to Ooma Telo), physical phone handsets, web and phone portals and/or applications, and Voice over Internet Protocol (“VoIP”) services. All defined terms in this Children’s Privacy Policy shall have the same meaning as defined in the Privacy Policy.

Ooma does not knowingly collect Personal Information from children under the age of 13 without the consent of a parent or legal guardian. If we learn that Personal Information of a child has been collected through MyPhone without appropriate parental consent, we will take appropriate steps to delete this information. If you are a parent and discover that your child under the age of 13 has a registered account with MyPhone without your consent, please contact us at myphoneprivacy@ooma.com and request that we delete your child’s Personal Information from our systems.

This Children’s Privacy Policy applies to all Child Users of MyPhone. To learn more about our general privacy practices that apply to parents and our other users, please refer to the Privacy Policy.

  1. Creation of Profile

    For all known Child Users, we require a parent to set up an account using a valid credit/debit card and agree to our Terms of Service, Privacy Policy and this Children’s Privacy Policy. By creating or validating a profile associated with a MyPhone account and permitting your child to use MyPhone, you expressly agree to the practices described in this Children’s Privacy Policy and you consent to the collection, use, and disclosure of your child’s Personal Information as described herein. You can withdraw consent at any time by contacting us at myphoneprivacy@ooma.com and request that we delete that child’s Personal Information from our systems.

  2. Personal Information We Collect from Child Users

    We collect Personal Information from Child Users in the following ways through their use of MyPhone:

    • MyPhone Device Information, including IP address, hardware model, MAC address, serial number, and phone number associated with your MyPhone. We also collect information about your MyPhone’s status, including connectivity and operational status.
    • Call Information, including the phone numbers you call or receive calls from, the date/time of the calls, and the length of the calls.
    • Technical Information, including network quality metrics and other technical data related to call performance.
    • Voicemails, including information contained in voicemail greetings and messages. This information may be recorded and stored to provide you with our products and services, including via artificial intelligence if you elect to purchase our voicemail transcription service.
  3. How We Use Child Users’ Personal Information

    We use the information we collect to provide voice-to-voice communication through MyPhone and to allow parents and guardians to manage their child’s access to MyPhone. We do not knowingly enable Child Users to make their Personal Information publicly available.

    We also use the information we collect for the following purposes:

    • To provide MyPhone and its related services.
    • To improve our services and for other internal business purposes, such as evaluating and enhancing MyPhone, improving our services and troubleshooting.
    • To communicate with parents or legal guardians, and Child Users, such as when we receive a contact inquiry and send information about our policies, terms, and practices.
    • To help maintain the safety, security, and integrity of MyPhone, technology assets, and our users.
    • To comply with our legal and financial obligations.
  4. How We Share Child Users’ Personal Information

    We may share Child Users’ Personal Information in the instances described below. For additional information on your choices regarding Personal Information, see “How to access, manage and delete a Child User’s Personal Information” below.

    We may share or disclose a Child User’s Personal Information to third-parties in the following instances:

    • With the MyPhone Accountholder. We share your child’s information and activities (such as interactions with MyPhone) with the account associated with your MyPhone for purposes of maintaining the account, facilitating communications, and providing the services.
    • With our Service Providers. We may share your child’s information with third party vendors, service providers, contractors or agents to perform business, professional, or technology services and functions on our behalf and who are subject to confidentiality and security obligations. Our current list of service providers is available upon request. As required by applicable data protection laws, we impose contractual limits on how these service providers can use the Personal Information they receive.
    • Call Participants. MyPhone allows its users to communicate with call participants as part of its services. When using MyPhone, Child Users may voluntarily choose to share their Personal Information to individuals in those communications.

    We may also share their Personal Information if we have a good faith belief that access to or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, judicial proceeding, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; (d) protect the rights, property, or personal safety of Ooma, its users, or the public; or (e) as required or permitted by law. If Ooma is involved in a merger, acquisition, bankruptcy, change of control, or any form of sale of some or all of its assets, Personal Information may be transferred or disclosed in connection with the business transaction, subject to any applicable laws. We may also use and share de-identified or aggregated information in a manner that cannot be reasonably used to identify an individual user.

    Third Party Tracking and Advertising. We do not permit third parties to collect Personal Information from or about our Child Users over time for the purpose of serving targeted advertising through MyPhone.

  5. How to Access, Manage, and Delete a Child User’s Personal Information

    Withdrawing Your Consent

    At any time, parents or legal guardians may revoke their consent provided, refuse to allow us to further collect or use your child’s Personal Information, and direct us to delete your child’s Personal Information, subject to applicable law, by contacting us at myphoneprivacy@ooma.com.

    You may consent to the collection and use of your child’s information without consenting to the disclosure of information to third parties, except when disclosure is integral to providing our services.

    Request Access to Your Personal Information

    Parents or legal guardians may review the information collected from their Child User(s) at any time by contacting us at myphoneprivacy@ooma.com to fulfill this request.

    Modifying or Deleting Your Personal Information

    Ooma will retain the Personal Information collected from and about the Child User for as long as necessary to provide MyPhone services or as required by law and will de-identify or delete the Personal Information until we receive a deletion request or after the termination of the account in accordance with our standard data-retention policy or as required by law. To request deletion of Personal Information of a Child User at any time, please contact us at myphoneprivacy@ooma.com. We may not be able to modify or delete Personal Information in all circumstances.

  6. Data Retention

    We retain a Child User’s Personal Information for as long as reasonably necessary to provide MyPhone and related services and as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, or otherwise as permitted or required in accordance with applicable law.

  7. Updates and Changes to this Policy

    We may update this Children’s Privacy Policy from time to time. When we update this Children’s Privacy Policy, we may notify you by updating the “Effective Date” at the top of the new Children’s Privacy Policy, posting the new Children’s Privacy Policy, or providing any other notice as required by applicable law. We recommend that you review this Children’s Privacy Policy regularly to stay informed of our privacy practices.

  8. Contact Us

    If you have questions about this Children’s Privacy Policy, please contact us at:

    • Email: myphoneprivacy@ooma.com
    • Mailing address: Ooma, Inc., 525 Almanor Avenue, Suite 200, Sunnyvale, CA 94085
    • Phone: 1 (650) 566-6600