Draft — under legal review

Privacy Policy

Last updated: [EFFECTIVE DATE]

Effective [EFFECTIVE DATE]. Shaw Wireless Inc ("Encore Text", "we") runs the Encore Text text-messaging platform at encoretext.com. This policy explains what we collect and how we use it.

Two kinds of data

1. Account data. Information about the businesses that use Encore Text and their staff: names, business details, email addresses, phone numbers, billing details and how they use the product. We are responsible for this data.
2. Customer contact data. Phone numbers, names, tags, consent records and message content that our customers upload or collect to text their own audiences. We process this data only on our customers' instructions to provide the service. Each customer is responsible for having the right to collect and text those contacts. If you got a text from a brand that uses Encore Text, contact that brand first. You can always reply STOP to opt out.

What we collect

• Information you give us: sign-up details, business verification details (such as legal name, EIN and website), support messages and beta applications.
• Payment information, processed by our payment provider. We don't store full card numbers.
• Messaging data: message content, delivery status, replies, opt-outs and timestamps.
• Technical data: IP address, browser, device and log data, and cookies needed to keep you signed in.

How we use it

• To run, secure and support the platform, including sending and delivering messages.
• To verify businesses, register senders with carriers, and prevent fraud, spam and abuse.
• To bill accounts and keep records the law requires.
• To improve the product, using aggregated or de-identified data where we can.
• To contact account holders about the service. Marketing emails to account holders include an unsubscribe link.

Text messaging data

We do not sell or rent mobile numbers. No mobile information will be shared with third parties or affiliates for their marketing or promotional purposes. Text messaging opt-in data and consent records will not be shared with any third parties, except the service providers who help us deliver messages and where the law requires it.

Who we share data with

• Service providers that run parts of the service for us, such as our messaging provider (Twilio), hosting and database providers, and our payment processor. They may only use the data to provide services to us.
• Mobile carriers and registration bodies, to register senders and deliver messages.
• Authorities, when required by law or to protect people, our customers or Encore Text.
• A buyer or successor, if Encore Text is sold or merged, under this policy.

How long we keep it

We keep account data while the account is open and as needed afterward for legal, tax and dispute reasons. Customers can export or delete their contact data at any time. When an account closes, we delete customer contact data within [90] days, except opt-out and consent records we must keep to show compliance.

Security

We use encryption in transit, access controls, separation between customer workspaces, multi-factor authentication for staff and audit logs of privileged actions. No system is perfectly secure.

Your choices and rights

You can ask to see, correct or delete your personal information by emailing support@encoretext.com. Depending on your state, you may have more rights, such as under California law. We will not discriminate against you for using them. To stop texts from a brand, reply STOP to any of its messages.

Children

Encore Text is for businesses. We don't knowingly collect data from children under 13.

Changes and contact

We will post changes here and update the effective date. For material changes, we will notify account holders. Questions: email Shaw Wireless Inc at support@encoretext.com.