Last Updated: January 15, 2018
Links to Other Websites, Apps and Services
Our websites and other Services may contain links to other third-party websites, apps and services of interest. However, once you have used these links to leave our site, you should note that we have no control over such third-party services. Therefore, we cannot be responsible for the protection and privacy of any information that you provide while visiting such sites and services, and they are not governed by this privacy statement. You should exercise caution and should review the privacy statement(s) applicable to the third-party sites and services in question.
Collection of Your Information
We collect or receive information about your interactions with us. Depending on how you use our Services, your information may include, without limitation:
- registration-related information (such as name, addresses, email addresses, telephone numbers, occupation and information imported from social log in permissions granted to us);
- information about the Services that you use, how often you use them, and your responses to the offerings and advertisements presented or made available by us;
metadata we collect from or about any message(s) sent via our SMS Platform, including without limitation phone numbers each message was sent to and sent from;
information about the searches you perform on our websites or in our other Services and how you use the results of those searches;
- transaction-related information (such as credit card or other preferred means of payment, billing information, credit card number, expiration date, billing address and/or a history of purchases through our Services);
customer service information about you as a user of our Services;
- location data;
- information about any devices, connections and methods used to access and interact with us;
- other information specifically related to your use of Services, including information that you publicly post using tools made available by us;
- information based on your usage of our Services (“Usage Data”), which may be collected automatically by us or the services (or third-party services within our Services), which can include the IP addresses or domain names of the computers utilized by the users who use the Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (such as successful outcome and error), the country of origin, the features of the browser and the operating system utilized by the user, the various time details per visit (such as the time spent on each page within the Services) and the details about the path followed within the Services with special reference to the sequence of pages visited, other parameters about the device operating system and/or the user’s IT environment, and data, conversion rates, marketing and conversion data and statistics, reports, analytics data, reviews and surveys. Usage Data may sometimes be essentially anonymous when collected, but could be used indirectly to identify a person;
We collect personal information from all communications with Service end users including, without limitation, text messages, faxes, telephone calls, and regular “snail mail,” as well as from third-party outside sources including database vendors.
We may collect your phone number in the following ways:
- When you text a keyword to a Short Code (if applicable) managed by us or one of our customers, or call or text message a Long Code managed by one of our customers, we collect your phone number when the message or call is routed through our system.
- If you have previously provided your contact information to one of our customers, we collect your phone number when our customer connects their database with us.
Your information may be supplemented with additional information from other companies such as publicly available information, information about households and other information that we may append or match to your information.
For example, we may augment certain data with:
- Data submitted by you via our Short Code Service (if applicable). For instance, after texting one of our customer’s keywords on our Short Code, the Short Code may respond automatically asking you for your zip code. If you provide a zip code, we will use it to connect you to our customer’s representative or agent located nearest you.
- Data input manually by our customer during the course of a peer-to-peer conversation. For instance, our customer may ask you for your name during a text message conversation (or a voice call, if applicable), and then record your name alongside your phone number by typing your name into their contacts.
- Data collected from 3rd parties by matching your email, phone number, or other information provided to us by you or our customer. For instance, when one of our customers uploads a list of phone numbers of their own contacts, we may use a 3rd party service to determine which phone numbers can be text messaged (i.e. which numbers belong to cell phones and which belong to landlines).
- Metrics collected through normal usage of the SMS Platform or other Services. For instance, we may track and display to a customer the last time you sent or received a message.
- From information provided to us automatically from the database of our customer. For instance, if you signed up on a one of our customer’s website(s) and provided your name and phone number, we would store your name and display it to our customer at various relevant times (e.g. in our text messaging app used by customers).
We may also receive or collect certain technical information when you use our Services. This may include your browser or operating system, your manner of connecting to the Internet and the name of your Internet service provider or wireless carrier; your Internet protocol (IP) address; information about referring websites or services (websites or services you used immediately prior to using our websites or other Services; exiting websites or services (immediately after using our website or other Services); and data relating to malfunctions or problems occurring when you use our Services. Additionally, we may collect information about other software on your device for the limited purpose of protecting your security or improving your online experience.
Some web browsers incorporate a “Do Not Track” feature that signals to websites and Services that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and our Services, we do not respond to or honor “Do Not Track” signals at this time. As the technology and communication between browser and website improves, we may elect in our discretion to reevaluate the ability to honor “Do Not Track” signals and may make changes to our policy.
How Your Information may be used
Your information may be used for purposes that include, without limitation:
- to operate and improve the Services available through us;
- to personalize the content and advertisements provided to you (including to present offers to you on behalf of business partners and advertisers);
- to fulfill your requests for tools, software, functionality, features and other products, and services;
- to communicate with you and respond to your inquiries;
- to conduct research about your use of our products; and
- to help offer you other products, features or services that may be of interest.
We reserve the right to make full use of Usage Data. For example, we may use Usage Data to provide better service to Service visitors or end users, customize the Services based on your preferences, compile and analyze statistics and trends about the use of our Services and otherwise administer and improve our Services.
Sharing of Your Information
We may share aggregated, non-personally identifiable information, publicly and with our partners like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our websites and/or other products or services.
The contents of your online communications, as well as other information about you as a user of our Services, may be accessed and disclosed under the following circumstances: in response to lawful governmental requests or legal process (for example, a court order, search warrant or subpoena), in other circumstances in which we have a good-faith belief that a crime has been or is being committed by a user of our Services, that an emergency exists that poses a threat to the safety of you or another person, when necessary to protect either our rights or our property or for us to render the service you have requested.
Many of our Services let you share information with others. Remember that when you share information publicly, others besides us have access to it, and it may be indexable by search engines, or copied, forwarded, saved or archived by others.
Our offerings may include features or functionalities provided by third parties, or may integrate or interact with third-party products and services (including, without limitation, via APIs, plug ins, links, frames, embedding, or other interactions). In the process of providing such functionalities within our services, your browser or other tools or technology may send certain information to the third-party provider. The use of these third-party-provided features or functionalities is subject to their own privacy policies. For example, without limitation, we may use a third party for ad serving, retargeting, remarketing and/or for analytics, in which case such third party may have access to your data, subject to its policies. These third-party vendors may use their own cookies and/or other third-party cookies together to (a) inform, optimize, and serve ads across the web based on your past visits to our Services and others and (b) report to us how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site. If and to the extent from time to time we use Double Click or another Google brand for ad serving, analytics, remarketing, retargeting, etc., you can set certain preferences and opt-outs using Google Ads Settings, and Google Analytics’ currently available opt-outs.
Business partners or other third parties may receive data about groups of our users, but, except as otherwise permitted herein, do not receive information that personally identifies you. We may use agents and contractors in order to help operate our Services. Their use of information is limited to these purposes, except as otherwise permitted herein.
In the event that ownership of us was to change as a result of a merger, acquisition, or transfer to another company, your information may be transferred. If such a transfer results in a material change in the use of your information, you will be provided notice (which may be via updates to this page) about your ability to decline to permit such a transfer.
Any personal information which we may collect via the Services may be stored and processed in our servers located in the United States or in any other country in which we, or our affiliates, subsidiaries or agents, maintain facilities. You consent to any such transfer of personal information outside your country of residence to any such location.
General Disclosure Policy.
We reserve the right to disclose your personal information as described below. We reserve the right to disclose Usage Data without restriction.
We reserve the right to provide your personal information and Usage Data to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we control or that control us.
We reserve the right to provide access to your personal information and Usage Data to our trusted service providers that assist us with the operation and maintenance of our sites and services. For example, we may contract with third parties to process payments, host our servers, provide security and provide production, fulfillment, optimization, analytics and reporting services. We will use commercially reasonable efforts to ensure that our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.
If we sell or otherwise transfer part or all of our business or assets to another organization, such as in the course of an acquisition, merger, bankruptcy or liquidation, we may transfer your personal information and Usage Data.
Legal Process, Enforcement and Security Notice.
We reserve the right to disclose your personal information and Usage Data if we have a good-faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud or other illegal activity and (iii) to investigate, respond to, or enforce violations of our rights or the security of our sites and services.
When We Participate in a Joint Venture with Marketing Partners.
We may participate with another company or individual for purposes of jointly promoting our products, services, promotions or contests or their products, services, promotions or contests. We reserve the right to disclose your personal information to them for purposes of (i) compensation, transaction processing, fulfillment and support, and (ii) for purposes of offering you other products, services, promotions and contests. These joint venture marketing partners may also contact you about other products, services, promotions or contests.
Display of Advertising
Your information may be used for the presentation of advertisements. We may use ad networks to customize and display advertising on our Services. We may share certain information about you as a user (such as age, zip code or other information we have collected or received) with certain ad network and service providers to help them deliver more relevant content and advertisements through their networks. We may from time to time work with other companies for certain services such as analytics or advertising, and you may be subject to their privacy policies as well, though you may opt out through them directly or contact us with questions.
Your Choices about Your Information
You may choose to restrict the collection or use of your personal information in the following ways:
- Whenever you are asked to fill in a form on our website or our other Services, consider what information to include and exclude; in addition, sometimes there may be a box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
- We may provide you with access to your registration information and the ability to edit this information in your account settings dashboard and profile pages. Please be aware that even after you delete or update information within our Services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. Similarly, if and to the extent any information is indexable by search engines (including, without limitation, public profile information), it may not be updated by such search engines when we update it, and old versions may be archived by them or by third parties outside our control.
Some of our Services may provide you with additional information and choices about your privacy, which you should review.
If you have previously agreed to our using your personal information for direct marketing purposes, you may change your mind at any time by writing to us using the contact information below.
Our Commitment to Security
How to Contact Us
If you believe your information is wrong, we strive to give you ways to update it quickly or to delete it unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests for information residing on backup tapes).