This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

What personal information do we collect from the people that visit our blog, website or app?

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number or other details to help you with your experience.

When do we collect information?

We collect information from you when you subscribe to a newsletter, fill out a form or enter information on our site. Provide us with feedback on our products or services

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To improve our website in order to better serve you.
• To allow us to better service you in responding to your customer service requests.
• To ask for ratings and reviews of services or products
• To follow up with them after correspondence (live chat, email or phone inquiries)

How do we protect your information?

• We do not use vulnerability scanning and/or scanning to PCI standards.
• We only provide articles and information. We never ask for credit card numbers.
• We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

• Understand and save user’s preferences for future visits.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
  You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

If you turn cookies off, some features will be disabled. It won’t affect the user’s experience that make your site experience more efficient and may not function properly. However, you will still be able to place orders.

Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.

Third-party links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

We use Google AdSense Advertising on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

• Remarketing with Google AdSense
• Google Display Network Impression Reporting
• Demographics and Interests Reporting
• DoubleClick Platform Integration

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.

You will be notified of any Privacy Policy changes:

• On our Privacy Policy Page

Can change your personal information:

• By emailing us
• By calling us

How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

It’s also important to note that we do not allow third-party behavioral tracking.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify you via email

Within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

To be in accordance with CAN-SPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us at and we will promptly remove you from ALL correspondence.

Text messaging consent and information privacy guidelines

Please be sure to read and adhere to the following guidelines and best practices:

Have an official business web presence.

• TCR evaluates the website provided for your business to confirm that it is a valid, legal business. Your business website must be active with a publicly reachable URL.
• If your website contains any reference to alcohol or other legal adult topics, it must require visitors to enter their birthdate to confirm they are of legal age.
• If your website gathers any lead or customer information for outreach, it must include a clear policy on how this private information is used.

Obtain informed consent from text message recipients.

• Recipients must opt-in to text messaging from your business specifically, not just by providing their mobile number.
• Consent cannot be bought, sold, or traded. You must obtain consent directly from the recipient. Purchasing or otherwise obtaining a list from a third party is prohibited.
• Provide a clear Privacy Policy regarding their personal information, including mobile numbers. A compliant Privacy Policy must state that no mobile information will be shared with third parties/affiliates for marketing/promotional purposes.
• Be prepared to provide proof of consent if requested.
• You can reply to inbound texts to gain consent for future messages.
  
• Explicit consent is required to reach out with promotional material when no inbound inquiry is documented. The recipient must have opted-in to receiving your messages in a written capacity, such as checking a box on a form. A prior relationship alone does not constitute opt-in consent.
• Public activity not directed specifically to you does not constitute consent. For example, if someone lists a house for sale, it does not mean they have consented to you contacting them via text.
• Allow recipients to opt-out.
  • Messages such as “STOP” and “UNSUBSCRIBE” must be honored, but any reasonably interpreted request should be considered an opt-out request.
  • Adding “STOP2END” to your message is a short and well-understood instruction for opting-out.

Text message content policies and guidelines

Your first message to a recipient should include the following.

• Identify your business – make sure your recipients know who is texting them.
• State message frequency – let recipients know how many texts they may receive in a given time period.
• Fees – provide information on whether or not the recipient may be required to pay for the text messages in accordance with their mobile phone plan.
• Offer – confirm any type of offer you made as part of text message sign up.
• Opt out – let recipients know how they can opt out of receiving text messages going forward.
• Don’t message people on a Do Not Call registry.

Based on carrier policies, there is some content you are prohibited from sending via our tracking numbers. 

• Spam, phishing, SHAFT (Sex, Hate, Alcohol, Firearms, Tobacco), and marijuana content are prohibited.
  • Content related to marijuana is prohibited, even within jurisdictions where it has been legalized for recreational or medical use. The carriers have specific rules banning this topic because of federal legal status.
• Anything illegal in the jurisdiction where the message recipient lives. 
• Hate speech, harassment, exploitative, abusive, or any communications originating from a hate group.
• Fraudulent messages.
• Malicious content, such as malware or viruses.
• Any content intentionally designed to evade filters.
• Message program evasion recycling numbers to avoid detection.
  • Constantly sending spam and then changing IPs and numbers to avoid detection.

10DLC messaging restrictions do not allow content across these categories (SHAFT, harassment, illegal substances, etc.). Some businesses may receive a rejection error that they are ineligible for resubmission due to these restrictions. You can learn more about these categories and errors on the Twilio campaign rejection error page. If you receive one of these rejection errors and believe the decision to be in error and would like to appeal the decision from Twilio and TCR,  please submit a ticket to our Support team.

All consent implied by a prior relationship or obtained via opt-in is only allowable within a reasonable timeframe.

The best way to stay compliant is to ensure your traffic aligns with Twilio’s Messaging Policy and T-Mobile’s Code of Conduct. You can also refer to CTIA’s Best Practices documentation and adopt industry standards into your operations and/or services.

For more information on messaging best practices, see Twilio’s US SMS guidelines and help article on forbidden messaging use cases.

How we handle violations

10DLC is an industry-wide regulation. If you violate these guidelines and receive complaints, the carriers may block your texts and contact TCR to suspend your campaign. If that happens, you will be unable to send messages from your account. In such an event, CallRail will have limited ability to expedite reinstatement. 

The account administrator(s) will receive a notice from CallRail explaining any complaints and what will happen. You will be notified if there is a possibility of remediation or if any fines will be levied.

Your ability to text may be removed or your account suspended while the investigation is underway. Our carriers and CallRail ultimately determine texting ability. We reserve the right to deny this service.

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information on our contact page.