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PRIVACY POLICY

1. INTRODUCTION 

SFCG, Inc. (“SFCG” or “We”) respects your privacy and is committed to protecting it through our compliance with this SFCG Privacy Policy (the “Policy”). 

This Policy applies to our business customers (“Customers”), their Customer Agents (as defined below), and Customers’ Recipients (as defined below), and explains how SFCG collects, uses, and discloses personal information.  SFCG is a business-to-business service provider, and we provide notification and messaging services that allow our Customers to contact and send messages and information to their recipients (“Recipients”) through mobile text messaging and phone calling services.  Customers generally use the Service via their employees, contractors, agents and administrators (collectively, the “Customer Agents”), who are individuals designated by the Customer; Customer Agents send messages to, and receive messages from, Recipients on behalf of the Customer.  This Policy primarily explains our data collection practices when collecting, storing and/or using data on behalf of our Customers as a service provider.   

If you are an individual Recipient who received a message from a Customer through SFCG and you wish to learn about how SFCG collects and uses your data, please see Section 2 below.  If you wish to opt-out from receiving additional messages from SFCG, please see Section 2 below. 

As used in this Policy, the term “Customer” collectively refers to a Customer and its Customer Agents.  The term “Customer” does not include Recipients.  

This Policy applies to information we collect: 

  • Via our Service. 

  • In email, text, and other electronic messages between Customers and our Service. 

  • Through mobile applications Customers download from our Service, which provide dedicated non-browser-based interaction between Customers and our Service. 

  • When Customers interact with our advertising and applications on third-party websites and services, if such advertising and applications include links to this Policy. 

This Policy does not apply to information collected by: 

  • SFCG offline or through any other means, including on any other website operated by SFCG or any third party; or  

  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Service. 

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Service. By accessing or using our Service, you agree to this Policy. This Policy may change from time to time (see Section 9 (Changes to Our Privacy Policy) below. Your continued use of our Service after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates. 

2. INFORMATION WE COLLECT ABOUT RECIPIENTS 

  • We collect certain data about Customers’ messages and the content of their messages with Recipients, such as the content of messages Customers send and receive, message timestamps, message length, reply rates, and other statistics and metadata (“Text Message Data”). We use this Text Message Data for our internal purposes such as data analysis, fraud prevention, developing and improving our Service, and identifying usage trends. For example, we may build recommendations into our Service based on aggregated and anonymized Text Message Data. Customers should note that any messages they send that are transmitted via SFCG may be accessible by certain third-party organizations used to transmit the messages, such as cellular networks and SMS gateway services. These organizations may have their own rules, policies, and security measures controlling who has access to messages transmitted through their services. 

  • From time to time, we may receive information about Recipients from third parties and other users.  We may also collect information about Recipients that is publicly available, or if Recipients share information with us via a social network (such as “liking” us on a social media site), in accordance with the terms of those sites.  

  • Customers provide information, including personal information of Recipients, to SFCG via their customer relationship management (“CRM”) integration with the Service, by uploading the information in a CSV file, or by entering it directly in the Service. 

  • The personal information of Recipients provided to SFCG varies by Customer and depends on what the Customer transfers from their CRM/CSV file to the Service, but this information will generally include at a minimum the Recipient’s first name, last name, and telephone number. This information is collected by SFCG solely to provide its Services to Customers and to improve and enhance its Service. 

  • Customers may provide SFCG with additional Recipient personal information by manually entering it into a “custom field” or creating a “tag” within the Service. Again, this depends on what a particular Customer decides to provide but may include (a) postal address; (b) limited education information in certain circumstances (such as school attended or field of study); (c) characteristics of protected classifications under state or federal law; and (d) professional or employment-related information. SFCG may use this information about Recipients to draw inferences from the categories identified in this section to create a profile about a Recipient reflecting the Recipient’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, or attitudes.  

  • In the course of using the Service, Customers are able to sync, and control the movement of, Recipients’ personal information between the Customer-operated platforms on which personal information resides (e.g., CRM platforms and other third-party services and platforms) (“Customer-Operated Platforms”) and the Service. As a result of this back-and-forth movement of Recipients’ personal information at the Customer’s request, SFCG by definition shares this personal information with the Customer-Operated Platforms and therefore with the entities that own and control these platforms. For example, a Customer may take Recipients’ personal information residing within a CRM platform (such as a Recipient’s name and phone number) and share it with the Service so it may contact that Recipient via the Service. Later, that same Customer may take the Recipient’s personal information, along with relevant information pertaining the Customer’s interaction with the Recipient via the Service (such as whether the Recipient opted-out, interacted, etc.) and sync that Personal Information back into the CRM platform. By enabling Customers to perform these activities and other similar integrations, SFCG must share the personal information with the Customer-Operated Platforms.  

  • SFCG does not sell any Recipient’s personal information to any third party. 

  • Customers, rather than SFCG, own and control Recipients’ personal information. 

  • We offer services enabling our Customers to send text and phone calls through our Service. This section discusses how individuals who receive a message from a SFCG Customer may opt-out of receiving messages from any particular Customer campaign. To unsubscribe from any SFCG Customer texting campaign, a Recipient may text “STOP,” “UNSUBSCRIBE,” or similar words or phrases as a response to the sender. SFCG will send the Recipient one follow-up text message to confirm that the Recipient has been unsubscribed. Please note that opt-outs are tracked separately for each SFCG Customer, so unsubscribing from one SFCG Customer will not unsubscribe a Recipient from communications from another SFCG Customer. 

  • To restart receiving text messages from a SFCG Customer, Recipients may text START to the Customer’s short code or long code. In the event Recipients use the Service with multiple SFCG Customers, we may send an automated message to clarify which Customer the Recipient wants to restart receiving messages and calls from. Standard message and data rates apply. 

3. INFORMATION WE COLLECT ABOUT CUSTOMERS AND HOW WE COLLECT IT 

We collect several types of information from and about Customers that use our Service, including information: 

  • By which Customer may be personally identified, such as name, email address, mobile phone number, your job title and company, and any other identifier by which you may be contacted online or offline (“personal information“); 

  • That is about a Customer  but does not identify the Customer; and/or 

  • About a Customer’s internet connection (including IP address), the equipment used to access our Service (including device ID), and usage details. 

We collect this information: 

  • Directly from Customers when they provide it to us. 

  • Automatically as Customers navigate through our Service. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies (as further described below). 

  • From third parties, for example, our business partners such as Google, Pardot, Wufoo, Facebook and LinkedIn.  For information about how to opt out of allowing Google Analytics to use your data, see https://tools.google.com/dlpage/gaoptout

Information Customers Provide to Us 

The information we collect on or through our Service may include: 

  • Information that Customers provide by filling in forms on our Service. This includes information provided at the time of registering to use our Service, subscribing to our Service, or requesting further services. We may also ask Customers for information when they report a problem with our Service. 

  • Records and copies of Customers’ correspondence (including email addresses), if they contact us. 

  • Details of transactions Customers carry out through our Service.  

  • Any other types of information Customers may provide. 

Information We Collect Through Automatic Data Collection Technologies 

As Customers navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about the Customer’s equipment, browsing actions, and patterns, including: 

  • Details of Customer’s visits to and use of our Service, including traffic data, location data, logs, and other communication data and the resources that Customers access and use on our Service. 

  • Information about Customers’ computer and internet connection, including IP address, operating system, and browser type. 

We also may use these technologies to collect information about Customers’ online activities over time and across third-party websites (such as Google (Analytics, Optimize, Google Ads), Pardot, Wufoo, Facebook (Pixel), and LinkedIn (Insight Tag)).  Such third parties may or may not honor do-not-track preferences in browsers, and SFCG has no control over such third parties’ processes.  If Customers have any questions about how such third parties use cookies and/or honor do-not-track preferences, they should contact such third parties directly.   

The information we collect automatically may include personal information, and helps us to improve our Service and to deliver a better and more personalized service, including by enabling us to: 

  • Estimate our audience size and usage patterns. 

  • Store information about Customers’ preferences, allowing us to customize our Service according to a Customer’s specific individual interests. 

  • Speed up Customers’ searches. 

  • Recognize Customers when they return to our Service. 

The technologies we use for this automatic data collection may include: 

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of a user’s computer.  For more general information about cookies, please see https://allaboutcookies.org/.  Users may refuse to accept browser cookies by activating the appropriate setting on their browsers. However, if this setting is selected, a user may be unable to access certain parts of our Service. Unless a user has adjusted their browser setting so that it will refuse cookies, our system will issue cookies when users direct their browsers to our Service.  

  • Flash Cookies. Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about a Customer’s preferences and navigation to, from, and on our Service. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing privacy and security settings for Flash cookies, see https://allaboutcookies.org/how-to-clear-flash-cookies

4. HOW WE USE CUSTOMERS’ INFORMATION 

We use information that we collect about Customers or that Customers provide to us, including any personal information for the following purposes: 

  • Presenting our Service and its contents to Customers. 

  • Creating and managing Customers’ accounts. 

  • Creating user preferences regarding emails and other communications. 

  • Providing Customers with information, products, or services that they request from us. 

  • Processing orders and other transactions, including billing. 

  • Providing support and assistance with our Service. 

  • Providing, developing, customizing, and improving our Service and the services provided to Customers. 

  • Enforcing and applying our Terms and Conditions (https://SFCG.com/terms-conditions/), our Acceptable Use Policy ( https://SFCG.com/acceptable-use-policy/), and other agreements, including for billing and collection purposes. 

  • Responding to correspondence and communications Customers send to us.  

  • Responding to claims that posting or other content violates third-party rights. 

  • Resolving disputes. 

  • Providing Customers with notices about their accounts, including expiration and renewal notices. 

  • Notifying Customers about changes to our Service or any products or services we offer. 

  • Preventing, detecting, and investigating security incidents and potentially fraudulent, illegal or prohibited activities.  

  • Fulfilling any other purpose for which Customers provide it. 

  • In any other way we may describe when Customers provide the information. 

  • For any other purpose with a Customer’s consent. 

We may also use Customers’ information to contact them about our other products and services that may be of interest to them. If a Customer does not want us to use their information in this way, the Customer should contact us at privacy@SFCG.com

5. DISCLOSURE OF CUSTOMERS’ INFORMATION 

We may disclose anonymized and/or aggregated information about our Customers, and information that does not identify any individual, without restriction.  

We may disclose personal information that we collect from Customers or that Customers provide as described in this Policy to: 

  • Hosting, technology, and communications providers (such as Amazon Web Services, Google, Twilio, Bandwidth, WP Engine, and Mashbox). 

  • Analytics providers (such as Sisense and Data Warehouse). 

  • Application performance monitoring and logging providers (such as Datadog).  

  • Payment and billing processors (such as Stripe and Bill.com). 

  • Marketing providers (such as for targeted advertising via ad agencies). 

  • Ad networks to communicate via advertisement (display, paid social, paid search). 

  • Authentication and security providers (such as Auth0, and CloudFlare). 

  • A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SFCG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SFCG about our Customers is among the assets transferred. 

  • Fulfill the purpose for which Customers provide it.  

  • Fulfill any other purpose disclosed by us when Customers provide the information. 

  • Use per Customers’ consent. 

We may also disclose Customers’ personal information: 

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.  

  • To enforce or apply our Terms and Conditions (https://SFCG.com/terms-conditions/), our Acceptable Use Policy (https://SFCG.com/acceptable-use-policy/), and other agreements, including for billing and collection purposes. 

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SFCG, our Customers, or others 

6. CHOICES ABOUT HOW WE USE AND DISCLOSE CUSTOMER INFORMATION 

We strive to provide Customers with choices regarding the personal information they provide to us. We have created mechanisms to provide Customers with the following control over their information: 

  • Tracking Technologies and Advertising. Customers can set their browsers to refuse all or some browser cookies, or to provide an alert when cookies are being sent. If a Customer disables or refuses cookies, some parts of our Service may then be inaccessible or not function properly. 

  • Promotional Offers from SFCG. If a Customer does not wish to have its contact information used by SFCG to promote our Service, the Customer can opt-out by sending us an email with the Customer’s request to privacy@SFCG.com. When Customers receive promotional emails, they may send us a return email asking to be omitted from future promotional email distributions. This opt out does not apply to information provided to SFCG as a result of a purchase, support request, product service experience or other transactions. 

We do not control third parties’ collection or use of Customer information to serve interest-based advertising. However these third parties may provide Customers with ways to choose not to have their information collected or used in this way. Customers can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website. 

Residents of certain states, such as California, Colorado, Connecticut, Nevada, Virginia, and Utah may have additional personal information rights and choices related to the use and disclosure of their personal information. Please see Sections 12 (Your State Privacy Rights) and 13 (California Resident Privacy Rights) below for more information. 

7. ACCESSING AND CORRECTING CUSTOMER INFORMATION 

Customers can review and change their personal information by logging into our Service and visiting their account profile page.  

Customers may also send us an email at privacy@SFCG.com to request access to, correct or delete any personal information that a Customer has provided to us. We cannot delete a Customer’s personal information except by also deleting the Customer’s user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. 

Residents of certain states (California, Connecticut, Montana, Tennessee, Texas, Utah, and Virginia) may have (or will soon have after their state privacy laws go into effect) additional personal information rights and choices related to the access to and correction of personal information. See Sections 12 (Your State Privacy Rights) and 13 (California Resident Privacy Rights) below for more information. 

8. DATA SECURITY 

SFCG stores all data in the United States of America. 

We have implemented measures designed to secure Customers’ personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information Customers provide to us is stored on secure servers behind firewalls. Any payment transactions will be processed through third parties and/or encrypted using SSL technology.  

Customers also have responsibility for the safety and security of their information. Where we have given a Customer (or where the Customer has chosen) a password for access to certain parts of our Service, the Customer is responsible for keeping this password confidential. We ask that Customers do not share their password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect Customers’ personal information, we cannot guarantee the security of Customers’ personal information transmitted to our Service. Any transmission of personal information is at the Customer’s own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Service.  

SFCG backs up data periodically over different time intervals (daily, weekly, monthly). Backups are preserved until a Customer requests the data be deleted.  

We will retain a Customer’s personal information only for as long as reasonably necessary to provide our Service to such Customer, to meet legal and accounting obligations, and for the purposes described in this Policy. We may anonymize and/or aggregate personal information and store it in order to analyze aggregate metrics and trends. 

9. CHANGES TO OUR PRIVACY POLICY 

It is our policy to post any changes we make to our Policy on this page with a notice that the Policy has been updated on our website home page. If we make material changes to how we treat Customers’ personal information, we will notify Customers through a notice on our website home page. The date the Policy was last revised is identified at the top of the page. Customers are responsible for ensuring we have an up-to-date active and deliverable email address for them, and for periodically visiting our website and this Policy to check for any changes. 

10. MINORS UNDER THE AGE OF 18 

Our Service is not intended for minors under 18 years of age (a “Minor”). Minors may not provide any personal information to or through our Service. We do not knowingly collect personal information from Minors. If you are a Minor, do not use or provide any information through our Service, register for our Service, use any of the features of our Service, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If a Recipient is a Minor, please contact the SFCG Customer sending the message to request the deletion of the Minor’s personal information. 

11. CONTACT INFORMATION 

To ask questions or comment about this Policy and our privacy practices or to exercise a Recipient’s rights with respect to your personal information, contact us at:  

SFCG, Inc. 

2 Massachusetts Avenue, NE, Suite 75273 

Washington , D.C. 20013 

415-851-4878 

privacy@SFCG.com 

12. YOUR STATE PRIVACY RIGHTS 

SFCG does not sell any personal information or provide any personal information to any third party for resale. 

This section pertains to Customer Agents who are residents of the following states: Colorado, Connecticut, Montana, Tennessee, Texas, Utah and Virginia. 

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, please see Section 13 below.   

Colorado, Connecticut, Montana, Tennessee, Texas, Utah and Virginia each provide (or will provide when their state privacy legislation goes into effect) their state residents with rights to: 

  • Confirm whether we process their personal information. 

  • Access and delete certain personal information. 

  • Obtain data in a portable format. 

  • Opt-out of personal data processing for targeted advertising and sales. 

  • Correct inaccuracies in their personal information, taking into account the information’s nature, processing, and purpose (except for Utah). 

  • Opt-out of processing for profiling and targeted advertising purposes. 

To exercise any of these rights please contact SFCG at privacy@SFCG.com.   

Nevada provides its residents with a limited right to opt-out of certain personal information sales. However, please note that SFCG does not currently sell data triggering that statute’s opt-out requirements. 

13. CALIFORNIA RESIDENT PRIVACY RIGHTS 

This section only applies to Customer Agents who reside in the State of California. 

SFCG does not sell any personal information or provide any personal information to any third party for resale. 

This section does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors or similar individuals. 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@SFCG.com.  

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include: 

  • Publicly available information from government records. 

  • Deidentified or aggregated consumer information. 

  • Information excluded from the CCPA’s scope, like: 

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; 

  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. 

In particular, we have collected the following categories of personal information from consumers that are Customer Agents within the last twelve (12) months:  

Category 

Examples 

Collected 

A. Identifiers. 

A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. 

YES 

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). 

A name, signature, address, telephone number. 
Some personal information included in this category may overlap with other categories. 

YES 

C. Protected classification characteristics under California or federal law. 

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). 

NO, except for information regarding gender identity and expression (such as pronoun use) 

D. Commercial information. 

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 

NO 

 

 

 

E. Biometric information. 

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. 

NO 

F. Internet or other similar network activity. 

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. 

YES 

G. Geolocation data. 

Physical location or movements.  

NO 

H. Sensory data. 

Audio, electronic, visual, thermal, olfactory, or similar information. 

YES, with respect to audio and visual information 

I. Professional or employment-related information. 

Current or past job history or performance evaluations. 

NO, except for a user’s business association with prior SFCG clients 

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). 

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.  

NO 

K. Inferences drawn from other personal information. 

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

NO 

We may use the personal information we collect for one or more of the purposes described in Section 4 (How We Use Your Information) above.  

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, SFCG has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below. 

Personal Information Category 

Category of Third-Party Recipients 

 

 

Business Purpose Disclosures 

Sales 

A: Identifiers. 

Websites and Social Media Branded Pages 

  • Displaying personalized advertisements and content: We process your personal information to conduct market research, advertise to you, provide personalized information about us on and off our Service and to provide other personalized content based upon your activities and interests. 

  • Improving our Service: We process your personal information to analyze overall trends and help us improve the user experience for our Service. 

  • Promoting the security of our Service: We process your personal information by tracking use of our Service and verifying and investigating activity. 

  • Providing our Service and our social media pages: We process your personal information to operate and administer our Services and social media pages and to provide you with the content you access and request. 

Communications 

  • Sending communications: We process your personal information to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS or push notifications, information about our products, news or events) about us and our partners. 

  • Handling contact and user support request: We process your personal information, if you fill out a “Contact Me” web form or request user support, or if you contact us by other means including but not limited to via phone. 

Webinars, programs, trainings, certifications and contests 

  • Managing and participating in webinars, contests, programs, training or promotions: We process your personal information if you register for a webinar, contest, promotion, training, or a program. 

  • Some webinars, contests, programs, trainings and promotions have additional rules containing information about how we will process your personal information. 

SFCG products and services: 

  • Providing our services: We process your personal information to perform our contract with you for the provision of our services and to satisfy our obligations under the applicable terms of use.  SFCG collects a user’s name and email address to associate with an individual’s user account. The user’s email is their unique method of signing in to the SFCG services. 

  • Optimizing the performance of our services: We process your personal information to optimize or improve the performance of our Service. 

  • Managing our customer and user accounts: We process your personal information to manage customer and user accounts generally, such as billing, customer correspondence and customer relationship management. 

  • Managing usage compliance: We process your personal information to assess and manage usage compliance with the applicable terms of use of our Service.  Each user’s IP address is collected in log files to facilitate auditing of activity on the platform. 

  • Preparing internal reports and business modeling: We process your personal information for internal reporting and business modeling purposes (e.g., forecasting, revenue, capacity planning, product strategy). 

  • Maintaining our security: We process your personal information for the purposes of maintaining SFCG’s own security, including investigating, detecting and preventing suspicious activity, fraud and cybercrime that may affect SFCG, its website, or its Service. 

  • Undertaking financial reporting: We process your personal information for the purpose of financial reporting. 

  • Aggregating data: We process your personal information for the purposes of aggregating this information to ensure that it no longer identifies any individual. 

None 

B: California Customer Records personal information categories. 

SFCG collects phone numbers associated with users. This number is used as a multi-factor authentication method, and for previewing scripts (text messages) that an admin or agent is composing. 

None 

C: Protected classification characteristics under California or federal law. 

We process your personal information (including sensitive categories of personal information such as race and ethnicity) to the extent you voluntarily consent to provide it to help us meet our broader community goals related to diversity and equality of opportunity.  

None 

D: Commercial information. 

None 

None 

E: Biometric information. 

None 

None 

F: Internet or other similar network activity. 

Advertising/Communications 

  • We process your personal information for the purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information. 

  • This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you Product perspective:  

Use of Product 

  • The SFCG service saves searches a client has performed to find conversations or user information. The service also includes “recently viewed” lists in various places. 

  • History/activity is also used to power in-product guides and tutorials, as well as emails with relevant information regarding a user’s journey. For example, if a user has not yet sent a message via the SFCG service, we might use that information to guide them through the steps to send messages. 

None 

G: Geolocation data. 

None 

None 

H: Sensory data. 

Communications 
Recording phone calls:  
We process your personal information, including recording phone calls (in accordance with applicable laws) for training, quality assurance, and administration purposes.  To the extent required under applicable law, we will give you the option to object to a call being recorded. 
 
Product perspective: 
Users can record video using their webcam, which then gets processed and sent to a contact as a MMS text message. 
Soon, with our Dialer product, SFCG will also record the conversations between agents and users. These recordings will be processed to determine sentiment and convert speech to text, with the transcript saved. 

None 

I: Professional or employment-related information. 

None 

None 

J: Non-public education information. 

None 

None 

K: Inferences drawn from other personal information. 

None 

None 

Your Rights and Choices  

California law provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. 

Right to Know and Data Portability 

Consumers have the right to request that we disclose certain information about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you: 

  • The categories of personal information we collected about you. 

  • The categories of sources for the personal information we collected about you. 

  • Our business or commercial purpose for collecting or selling that personal information. 

  • The categories of third parties with whom we share that personal information. 

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: 

  • sales, identifying the personal information categories that each category of recipient purchased; and 

  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

  • The specific pieces of personal information we collected about you (also called a data portability request). 

We do not provide a right to know or data portability disclosure for B2B personal information. 

Right to Delete  

Consumers have the right to request that we delete any of their personal information that we collected from the consumer and retained, subject to certain exceptions (the “right to delete”).  Recipients must contact the SFCG Customer sending messages and making calls to the Recipient for data deletion; SFCG is not able to process these requests.  Once we receive a consumer’s request and confirm the consumer’s identity, we will review the request to see if an exception allowing us to retain the information applies. We may deny a consumer’s deletion request if retaining the information is necessary for us or our service provider(s) to:  

  1. Complete the transaction for which we collected the personal information, provide goods or services that the consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with the consumer, or otherwise perform our contract with such consumer. 

  1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 

  1. Debug products to identify and repair errors that impair existing intended functionality. 

  1. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 

  1. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 

  1. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if the consumer previously provided informed consent. 

  1. Enable solely internal uses that are reasonably aligned with consumer expectations based on a consumer’s relationship with us. 

  1. Comply with a legal obligation. 

  1. Make other internal and lawful uses of that information that are compatible with the context in which the consumer provided it. 

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.  

We do not provide these deletion rights for B2B personal information. 

Exercising Your Rights to Know or Delete 

To exercise a consumer’s rights to know or delete described above, the consumer should submit a request using the contact information in Section 11 above. 

Only a consumer, or someone legally authorized to act on the consumer’s behalf, may make a request to know or delete related to such consumer’s personal information. 

A consumer may only submit a request to know twice within any 12-month period. The consumer’s request to know or delete must: 

  • Provide sufficient information that allows us to reasonably verify the consumer is the person about whom we collected personal information or an authorized representative. 

  • Describe the consumer’s request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

We cannot respond to a consumer’s request or provide you with personal information if we cannot verify the consumer’s identity or authority to make the request and confirm the personal information relates to the consumer.  

A consumer does not need to create an account with us to submit a request to know or delete.  

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.  

Response Timing and Format 

We will confirm receipt of a consumer’s request within ten (10) business days. If a consumer does not receive confirmation within the 10-day timeframe, the consumer should contact us using the contact information set forth in Section 11 above.   

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform the consumer of the reason and extension period in writing. 

If a consumer has an account with us, we will deliver our written response to that account. If a consumer does not have an account with us, we will deliver our written response by mail or electronically, at the consumer’s option.  

Any disclosures we provide will only cover the 12-month period preceding our receipt of the consumer’s request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide the consumer’s personal information that is readily useable and should allow a consumer to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to verifiable consumer requests unless they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform the consumer why we made that decision and provide a cost estimate before completing the consumer’s request. 

Non-Discrimination 

We will not discriminate against consumers for exercising any of their CCPA rights. Unless permitted by the CCPA, we will not: 

  • Deny the consumer goods or services. 

  • Charge the consumer different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. 

  • Provide the consumer a different level or quality of goods or services. 

  • Suggest that the consumer may receive a different price or rate for goods or services or a different level or quality of goods or services. 

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