Privacy Policy

Mobile Information Privacy and Data Sharing Policy

No Marketing or Promotional Use.
Mobile information, including without limitation telephone numbers, text messaging data, and related identifying information (“Mobile Information”), shall not be shared, disclosed, licensed, transferred, or otherwise made available to any third party or affiliate for purposes of marketing, promotion, solicitation, or advertising.

Permissible Disclosure to Subcontractors.
Mobile Information may be disclosed solely to subcontractors, vendors, or service providers engaged by the Company to perform operational support functions, including but not limited to customer service, technical assistance, and system maintenance. Any such subcontractors shall be bound by confidentiality and data protection obligations no less restrictive than those set forth herein and shall be expressly prohibited from using Mobile Information for any purpose other than the limited services for which they are engaged.

Exclusion of Text Messaging Originator Opt-In Data and Consent.
All categories of use expressly exclude the sharing or disclosure of text messaging originator opt-in data and consent. Such opt-in data and consent shall not, under any circumstance, be shared, disclosed, transferred, or sold to any third party, affiliate, or external entity, except as required by law or regulatory authority.

Compliance and Enforcement.
The Company shall maintain policies and procedures reasonably designed to ensure compliance with applicable data protection laws and regulations. Any violation of this Policy by subcontractors, vendors, or third parties shall be deemed a material breach of their contractual obligations and subject to immediate termination and/or legal remedy.