Privacy Policy

Overview

This Policy includes specific disclosures required by the laws of California, Colorado, Connecticut, Oregon, Texas, Virginia, and other states with comprehensive consumer privacy laws.

If you have questions, contact us at [email protected] or [your phone number].

1. Quick Summary

• We collect contact information, business information, payment information, and online activity data.

• Through the App, we also process the text messages, calls, and contact details that our business customers exchange with the people who contact them (their "leads"). That data belongs to the business; we process it on the business's behalf.

• We use information to deliver our Services, market to prospective customers, and run our business.

• We share information with service providers, advertising partners, and as required by law. App data is never shared with advertising partners, and the App contains no advertising or analytics SDKs.

• We do not sell personal information for money. We do share certain website information with advertising partners for cross-context behavioral advertising — you can opt out at any time.

• We record sales, onboarding, and support calls. Calls placed through the App are recorded only if recording has been enabled for that business's account; it is off by default.

• You have rights to access, delete, correct, and limit how we use your information. See Section 13 to exercise them. App users can also request deletion of their account from inside the App.

2. Mobile Communication Policy

2.1 Messages we send you

We value your privacy and are committed to protecting your personal information. We send text messages only to people who have agreed to receive them, as described on our SMS Program Terms page. These include appointment confirmations and reminders, onboarding and support messages, account and billing notices, and replies to messages you send us. We send promotional texts only if you have separately agreed to receive them.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the categories of sharing described in this Privacy Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding the service providers that deliver our text messages.

• Opt-Out: Reply STOP to any message to opt out at any time.

• Help: Reply HELP for support.

• Frequency: Message frequency varies based on your interactions with us.

• Cost: Message and data rates may apply.

• Delivery: Carriers are not liable for delayed or undelivered messages.

Phone numbers may be processed by service providers (our SMS senders Twilio and Signal House, and our CRM, GoHighLevel) only to deliver the messages you have consented to receive.

2.2 Messages sent through the App

Our business customers use the App to text and call their own leads from a business phone number that we provision for them. Those messages are sent by the business, not by our company; the business is responsible for having the consent it needs to contact its leads. Every conversation honors opt-out keywords automatically: a lead who replies STOP (or a similar keyword such as UNSUBSCRIBE or CANCEL) is unsubscribed from that business's number and receives no further texts from it unless they opt back in by replying START or UNSTOP. Message frequency depends on the lead's conversation with the business. Standard message and data rates apply. Messages are delivered by our telephony carrier, Signal House, solely to transmit them.

3. Information We Collect

We collect the following categories of personal information:

Category — Examples

Identifiers — First and last name, email, phone number, postal address, IP address, account username, business name

Commercial information — Products and Services purchased, subscription tier, billing history

Financial information — Payment card information (processed by Stripe), billing address

Internet activity — Pages visited, links clicked, time on Site, referring URL, device and browser data

Geolocation (approximate) — City and state derived from IP address — we do not collect precise geolocation

Audio recordings — Sales, onboarding, and support calls (see Section 9); calls placed through the App when recording is enabled for the business's account, and voicemails left for the business

Professional information — Job title, trade or industry, business size

Inferences — Profiles built from the above to evaluate fit for our Services

Sensitive personal information — Account login credentials, payment card information

App account data — Your name, work email address, and mobile phone number used to sign in to the App and to verify you; which business accounts you may access and your role in them

App content (processed for the business) — The phone numbers and names of the business's leads; the text messages and photos exchanged with them through the business's number; call records (time, duration, outcome); voicemails; call recordings where enabled

App device data — A push-notification token for your device, its platform (iOS or Android) and App version, and when you last used the App

App usage metering — The number of text segments and call minutes used by the business (billed to its our company account)

We do not knowingly collect: precise geolocation, racial or ethnic origin, religious beliefs, sexual orientation, immigration status, genetic data, biometric data, health information, or information about children under 16.

The App does not collect your location, your device's address book, your phone's own SMS or call log, browsing history, or health or financial information, and it does not contain advertising, analytics, or tracking SDKs. The microphone is used only during a call you place or answer in the App. The photo library is accessed only when you choose a photo to attach to a message. The App does not use the camera.

4. Where We Get Your Information

• Directly from you — when you fill out a form, book a call, sign up, contact us, or sign in to the App.

• From your device — through cookies, pixels, and similar technologies on our Sites; through the push-notification token your device issues when you allow notifications in the App.

• From our business customers — when a business adds you as an owner or staff member of its account, or when a business's leads contact it (their messages and calls reach us through the business's phone number).

• From advertising partners — Meta, Google, and other ad platforms that deliver our advertising.

• From service providers — including our CRM (GoHighLevel), payment processor (Stripe), telephony carriers (Twilio and Signal House), and analytics providers.

• From publicly available sources — business directories, public records, and similar.

5. How We Use Your Information

We use personal information for these business and commercial purposes:

• Provide and operate the Services and the App — account creation, billing, customer support, communications about your account; delivering the business's text messages and calls; sending push notifications for new messages and calls; metering text and call usage for billing.

• Sales and marketing — respond to inquiries, follow up on leads, send promotional emails and SMS messages (where consented), retarget on advertising platforms. App data is not used for marketing.

• Analytics and improvement — understand how the Sites and Services are used, diagnose problems, develop new features.

• Advertising — measure ad performance, build lookalike audiences, retarget visitors of our Sites. This is "sharing" under California law — see Section 7. This does not apply to the App.

• Quality assurance and training — review and use recordings of our own sales, onboarding, and support calls to train our team and improve service.

• Security and fraud prevention — detect, investigate, and prevent fraudulent or unauthorized activity, including logging every access to a business's account by our company staff.

• Legal compliance — comply with applicable laws, court orders, and regulatory requirements, including telecom messaging rules.

• Business operations — accounting, recordkeeping, audits, corporate transactions.

We will not use your sensitive personal information for purposes other than those permitted by California law without first offering you a right to limit such use.

6. How We Share Your Information

We share personal information with the following categories of recipients:

Recipient — Purpose

Service providers for the Sites and Services (e.g., GoHighLevel, Stripe, hosting providers, email/SMS senders, analytics providers) — To deliver the Services on our behalf under written contract

Service providers for the App: Supabase (authentication and database), Railway (application hosting), Signal House (telephony carrier that delivers text messages and calls), Apple and Google (push notifications through Apple Push Notification service and Firebase Cloud Messaging), Cloudflare (network security) — To operate the App on our behalf under written contract; each acts only on our instructions

Advertising partners (e.g., Meta, Google, TikTok, LinkedIn) — To deliver and measure advertising for our Sites — this is "sharing" under California law. App data is never shared with advertising partners

Professional advisors (lawyers, accountants, auditors) — For legal, accounting, and compliance purposes

Acquirers — In connection with a merger, acquisition, financing, or sale of assets

Government authorities — When required by law, subpoena, or court order

We require service providers to use personal information only for the purposes we authorize and under contractual obligations of confidentiality and security.

Between a business and its leads. When you contact one of our business customers, your messages, calls, and contact details are shown to the owner and staff of that business in the App, and to our company staff assigned to that business's account. We process this information as a service provider to the business.

7. Sale and Sharing of Personal Information

We do not sell personal information for money.

We do share the following categories of personal information collected on our Sites with advertising partners for cross-context behavioral advertising (which is treated as a "sale" or "sharing" under California, Colorado, Connecticut, and other state laws):

• Identifiers (e.g., online identifiers, IP address)

• Internet activity (e.g., pages visited, ads clicked)

• Inferences

You have the right to opt out of this sharing at any time:

• Use the Do Not Sell or Share My Personal Information link in our website footer (or visit [your website]/do-not-sell).

• Email [email protected] with subject line "Opt Out of Sale/Sharing."

• Enable a Global Privacy Control (GPC) signal in your browser — we automatically honor GPC for visitors from California, Colorado, Connecticut, and other states recognizing universal opt-out signals.

We do not sell or share any information collected through the App, and we do not knowingly sell or share personal information of consumers under 16 years of age.

8. Cookies, Pixels, and Tracking Technologies

We use cookies, pixels, software development kits, and similar technologies on our Sites to:

• Keep you logged in and remember your preferences (essential).

• Measure traffic and performance (analytics — PostHog, Google Analytics).

• Deliver and measure advertising (Meta Pixel, Google Ads, and similar).

The App uses none of these. It stores only your session and preferences on your device, sends no data to advertising or analytics providers, and does not track you across other companies' apps or websites.

Managing cookies on the Sites:

• Cookie preference center: click the "Cookie Settings" link in our footer to accept, reject, or customize cookies.

• Browser settings: most browsers let you block or delete cookies.

• Global Privacy Control: enabling GPC in your browser tells us to opt you out of sharing for advertising — we honor this automatically.

• Industry opt-outs: optout.aboutads.info and optout.networkadvertising.org.

We do not use session replay technology on our Sites.

9. Call Recording

9.1 Calls with our company

We record sales, onboarding, and support calls for quality assurance, training, recordkeeping, and dispute resolution. At the start of each call, we provide a verbal notice that the call is being recorded. By continuing the call after this notice, you consent to being recorded. If you do not wish to be recorded, please tell us at the start of the call and we will end or pause the recording.

Recordings are stored securely, accessible only to authorized personnel and our service providers, and retained as described in Section 11.

9.2 Calls placed or received through the App

Calls between a business and its leads are recorded only when call recording has been enabled for that business's account at the request of its owner; recording is off by default. When recording is on, the business is responsible for giving any notice and obtaining any consent required by the laws that apply to it and to the person it is calling (several states require the consent of every party). Recordings and voicemails are stored with our hosting provider, encrypted at rest, and are available only to the business's owner and staff and to our company staff assigned to the account. The business can ask us to turn recording off at any time.

10. Our app

The App is provided to businesses that are our company customers so that their owners and staff can text and call their leads from the business's phone number. Accounts are created by our company for its customers; there is no public sign-up.

• Who is responsible for what. For your own login and device data, our company is the business (controller). For the business's leads and their conversations, the business is the controller and our company acts as its service provider (processor); we use that data only to provide the App to the business.

• Permissions. The App asks for the microphone (only during calls), notifications (for new messages and calls), and the photo library (only when you attach a photo). It does not request location, contacts, camera, or access to your phone's SMS or call log.

• No tracking. The App does not track you across other companies' apps or websites and contains no advertising or third-party analytics. Diagnostics are not collected.

• Notifications. You can turn notifications off in your phone's settings at any time.

• Staff access. Our company staff assigned to a business can open that business's account in the App to provide support. Every such access is logged.

• Account deletion. In the App, go to Settings → Account → Request account deletion. Your request is completed within 30 days. You can also email [email protected]. Deleting your login does not delete the business's conversations, which belong to the business.

• Leads' choices. A lead who no longer wants to receive texts from a business can reply STOP at any time; the App honors it automatically.

11. Data Retention

We retain personal information for as long as is necessary to provide the Services and the App, fulfill the purposes described in this Policy, comply with our legal and accounting obligations, resolve disputes, and enforce our agreements.

Specifically:

Data Type — Retention

Customer account records — While the account is active, and indefinitely thereafter unless you request deletion or we determine the data is no longer needed for legal, accounting, or legitimate business purposes

Marketing leads — Indefinitely, until you request deletion or opt out, or until we determine the information is no longer needed

Billing and tax records — At least 7 years (required by law)

Call recordings (sales/onboarding/support) — Indefinitely, for training, quality assurance, and dispute resolution

Website analytics (identifiable) — Up to 26 months

Cookies — Session-only or up to 13 months, depending on type

Support tickets — While the account is active and for a reasonable period thereafter

App login, verification records, and device push tokens — While you have access to a business on the App; deleted within 30 days of a completed account-deletion request

App messages, call records, voicemails, and recordings — For as long as the business is a our company customer, then handled under the business's agreement with our company

App usage metering (text segments and call minutes) — With billing records, at least 7 years

You may request deletion at any time as described in Section 13. After deletion is processed, we may retain limited information necessary to comply with legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

Data Deletion

To disconnect your Facebook Page or Instagram account from our company, or to have the connection data deleted, email [email protected] (or ask your account manager). We remove the stored Page connection within 48 hours. Our company stores only the Page access token, Page name and linked Instagram account needed to publish posts you approved; no other Facebook data is kept.

12. Your Privacy Rights

Depending on the state where you reside, you have some or all of the following rights:

Right — What it means

Right to know / access — Get a copy of the personal information we have about you

Right to delete — Request deletion of your personal information

Right to correct — Fix inaccurate personal information

Right to portability — Receive your information in a portable format

Right to opt out of sale/sharing — Stop us from sharing your information for cross-context behavioral advertising

Right to limit use of sensitive PI — Restrict use of sensitive personal information to limited purposes

Right to non-discrimination — We will not deny services, charge different prices, or provide a different quality of service for exercising your rights

Right to appeal — If we deny your request, you can appeal (Virginia, Colorado, Connecticut, Texas, Oregon)

If you are a lead of one of our business customers and your request concerns the messages or calls you exchanged with that business, we will forward your request to the business or direct you to it, because that business controls the information.

13. How to Exercise Your Rights

You can submit a request in any of the following ways:

• Web form: [your website]/privacy-request

• Email: [email protected]

• Phone: [your phone number]

• In the App: Settings → Account → Request account deletion

We will:

• Acknowledge your request within 10 business days.

• Respond within 45 days. If we need more time, we will notify you and may extend by an additional 45 days.

• Provide the first request in any 12-month period at no charge.

Verification. To protect your information, we will ask you to confirm details we already have on file (such as your email address and the last interaction we had with you). We may ask for additional verification if the request involves sensitive information.

Authorized agents. You may designate an authorized agent to make a request on your behalf. We will require written, signed authorization, and we will verify the identity of the consumer.

Appeals. If we deny your request and you reside in Virginia, Colorado, Connecticut, Texas, or Oregon, you may appeal by emailing [email protected] with subject line "Appeal." We will respond within 45 days (Virginia, Connecticut, Oregon) or 60 days (Colorado, Texas).

14. State-Specific Disclosures

14.1 California (CCPA / CPRA)

In the past 12 months, we have:

• Collected the categories of personal information listed in Section 3.

• Disclosed for a business purpose to service providers and professional advisors.

• Shared for cross-context behavioral advertising with advertising partners (see Section 7) — website data only.

• Not sold personal information for monetary consideration.

• Not knowingly collected or sold personal information of consumers under 16.

California residents may also designate an authorized agent. We do not offer financial incentives in exchange for personal information.

You may also request information about disclosures we have made for direct marketing purposes under California's "Shine the Light" law by emailing [email protected].

14.2 Colorado (CPA), Connecticut (CTDPA), and Oregon (OCPA)

Residents of Colorado, Connecticut, and Oregon have the rights described in Section 12, including the right to opt out of targeted advertising, sale, and certain profiling. We honor Global Privacy Control as a universal opt-out signal.

14.3 Virginia (VCDPA)

Virginia residents have the rights described in Section 12. We do not engage in profiling that produces legal or similarly significant effects.

14.4 Texas (TDPSA)

Texas residents have the rights described in Section 12. As required by Texas law: We do NOT sell sensitive personal data. We do NOT collect or sell biometric personal data.

14.5 Other States

Residents of other states with comprehensive privacy laws (including Utah, Iowa, Montana, Tennessee, Indiana, Florida, Delaware, New Jersey, New Hampshire, Kentucky, Maryland, Minnesota, and Rhode Island) have the rights granted by the laws of their state. Contact us as described in Section 13 to exercise them.

15. Children's Privacy

The Sites and Services are not directed to children under 16, and the App is a business tool intended for adults 18 and older. We do not knowingly collect personal information from children under 16. If you believe we have collected information from a child under 16, contact [email protected] and we will delete it.

16. Data Security

The security of your personal information is important to us. We use reasonable administrative, technical, and physical safeguards to protect personal information, including encryption in transit (TLS), encryption at rest with our hosting providers, access controls, logging of staff access to customer accounts, and vendor due diligence. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

17. International Users

The Sites, Services, and App are operated from the United States. If you access them from outside the United States, your information will be transferred to and processed in the United States. By using them, you consent to that transfer.

18. Third-Party Links

The Sites may contain links to third-party websites and services. This Policy does not apply to those third parties. We encourage you to read their privacy policies.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top reflects the most recent change. If we make material changes, we will notify you by posting a notice on the Sites or in the App, or by email. We will update this Privacy Policy at least once every 12 months.

20. Contact Us

[your company legal name]

Email: [email protected]

Phone: [your phone number]

Web: [your website]/privacy-request

For privacy-specific questions, please use [email protected] rather than general support channels.