Services Privacy Policy

Conferencing For Less, LLC. d/b/a Texting For Less ("Texing

For Less") is committed to protecting the privacy of your information.

This Privacy Statement describes Texting For Less's information practices

relating to your use of our account portal and associated platform services.

For information about our privacy policies governing your use of our websites

(“Texting For Less Sites”), please consult our separate Texting For Less

Website Privacy Policy.


1. Services Covered


In this Privacy Statement, “we,” “us,” “our,” or “Texting

For Less” refers to Texting For Less and our affiliates, which includes any person

or entity that controls Texting For Less, is controlled by Texting For Less, or

is under common control with Texting For Less (such as a subsidiary, parent

company, or employee).


Texting For Less offers a variety of platform services that

are collectively referred to as our "Services." Individuals who use

our Services through the account portal or who otherwise use the Services will

be referred to as “Customers.” By contrast, individuals who simply visit Texting

For Less websites will be referred to as “Visitors.”


2. Information Texting For Less Collects from You


Texting For Less collects information from Customers in

order to provide them with the best possible user experience. Some information

is collected only from Customers, and not Visitors:


Required Contact Information


When expressing an interest in obtaining additional

information about our Services or in registering to use them, Texting For Less

requires you to provide us with some basic contact information, such as name,

company name, address, phone number, and email address.


Billing Information


When purchasing our Services, Texting For Less requires you

to provide us with financial qualification and billing information, such as

billing name and address, credit card number, and the number of employees

within your organization that will be using our Services. We also track your

usage of our Services, such as the number of times you use our Services and

which ones you use, so we can properly bill you for your use of those Services.


Security, Fraud Prevention, and Network Management


We collect certain information from you to ensure the

security of our Services. For example, we collect your IP address when you

login to our account portal as part of our “Identity Confirmation” and “IP

Range Restrictions” security features. We also collect information from you and

your use of our Services that allows us to appropriately manage our networks.


Content of Your Communications and Related Data


We collect the content of your telecommunications and

related information in connection with your use of our Services. To transmit

your messages, voice broadcasts, and other communications, we collect the

content of what you communicate through our Services and transmit it to the

next carrier. Likewise, we collect and transmit related data to the next

carrier that is necessary to route and connect your communication to the

intended recipient.


Communications with Our Customer Support Team


When you reach out to our customer support team, we may use

the information that you provide us to identify and solve problems that have

arisen and to otherwise improve our Services.


Optional Information


Texting For Less may also ask you to provide additional

information, such as company annual revenues, total number of employees, and

industry. We may offer you the option to import your email address book or

calendar. This category of optional information includes any information that

you voluntarily provide to us.


Other information is collected from anyone who visits our

Sites, both Customers and Visitors. We refer to this information as Website

Navigational Information. To learn more about our information practices with

respect to this type of information, please consult our separate Texting For

Less Website Privacy Policy.


We do not knowingly collect any personal information

directly from children under the age of 13.


3. How Texting For Less Uses the Information It Collects


Texting For Less uses Website Navigational Information to

operate and improve our Sites. We also use the information about our Customers

(“Customer Data”), as well as the information about their contacts that they

have uploaded and stored on our Services (“Customers’ Contact Data”), to

improve our Services, develop new features, and to market and promote our

Services. For example, we use this data to:


connect our Customers with one another. For example, we may

use your Customer Data to offer you the opportunity to connect with other

Customers who you might know or who might share similar characteristics, such

as location or industry. We may also suggest connections between Customers

whose calls, messages, broadcasts, or campaigns target similar Contacts based on

analyses of Customers’ Contact Data or other anonymized aggregated data.


allow Customers to engage, interact, and communicate with

one another about their uses of our Services. For example, we may give you the

opportunity to notify Customers that you have connected with about your uses of

our Services, and you may receive similar notifications from other Customers.

These notifications may be initiated by you or by Texting For Less.


Texting For Less may use anonymized aggregate data from any

source to help improve our Services and for targeted advertising purposes,

including in conjunction with third parties.


The next Section discusses certain other categories of

information that are regulated by the Federal Communications Commission (FCC).

To the extent that this Section and Section 4 conflict, Section 4 is

controlling.


4. Consent for Use of Confidential Data and Customer

Proprietary Network Information


In order to better serve our Customers’ needs and to offer

them additional products and services, Texting For Less may analyze certain

information about their usage of our Services. Such analyses will be based on

your anonymized, aggregated data, and any information belonging to you will not

be personally identifiable. We will provide the results of any such analyses to

you in order to help you understand how other businesses that may be similar to

yours are using our Services. The information used for this analysis may

include:


Customer Proprietary Network Information


Information that is made available to the Texting For Less solely

by virtue of your relationship with us as a telecommunications carrier is known

under FCC regulations as Customer Proprietary Network Information

("CPNI"). This carrier- acquired, generated, or maintained

information relates to the quantity, technical configuration, type,

destination, location, and usage amount of your telecommunications services

purchased from Texting For Less. It also includes the content of specific

telecommunications that Customers make or receive, as well as the related local

and toll billing information.


Texting For Less acknowledges its duty under federal law

and/or any applicable state law to take reasonable measures to safeguard the

confidentiality of your CPNI.


Confidential Information


In some circumstances, Texting For Less may include in its

analyses Confidential Information (“CI”) that is not covered under the

definition of CPNI, such as your subscriber list or published information

(listed or unlisted). CI could include information like your name, telephone

number, address, and information related to non-telecommunications aspects of

our Services. We use your CI solely on an anonymized basis.


By using our Services, you grant Texting For Less permission

to use any CI and CPNI for the purpose of improving your experience with our

Services, providing insight into how you and other Customers use our Services,

and offering you any and all products and services available from us, including

offerings that are different from those you currently buy from us.


You have a right to disapprove of our uses of your CPNI and

CI as set forth above. You may withdraw the permission you have granted us by

agreeing to these terms at any time by notifying us in writing at Support@textingforless.com.


The next Section discusses certain other categories of

information that are regulated by the Federal Communications Commission

(“FCC”). To the extent that this Section and Section 3 conflict, Section 4 is

controlling.


5. Sharing of Information Collected


We may share Customer Data and Customers’ Contact Data with

third-party service providers or others who need access to the data to perform

their work on our behalf. For example, we may store this information on

third-party servers. Additionally, Texting For Less may share information

provided by Customers and Visitors with our agents so that these agents can

contact them on our behalf. Texting For Less may also share this information

with our agents to ensure the quality of information provided. Texting For Less

does not share, sell, rent, or trade personally identifiable information with

third parties for their promotional purposes.


Texting For Less uses a third party intermediary to manage

credit card processing. This intermediary is not permitted to store, retain, or

use Billing Information except for the sole purpose of credit card processing

on our behalf.


Texting For Less reserves the right to disclose personal

information about Customers or Visitors if required by law, if we reasonably

believe that disclosure is necessary to protect our rights, and/or to comply

with a judicial proceeding, court order, or legal process, or if we believe

that disclosure is reasonably necessary to protect the public from harm.


If we go through a corporate sale, merger, reorganization,

dissolution, or similar event, the Customer Data and Customers’ Contact Data

that we gather from you may be part of the assets transferred or shared in

connection with the due diligence for any such transaction. Any acquirer or

successor of Texting For Less may continue to use that data as set forth in

this Privacy Statement.


6. Customers’ Contact Data


Texting For Less Customers use our Services to host data and

information. Such information usually includes Customers’ Contact Data, such as

data about the contacts they wish to communicate with by using our platform. Texting

For Less processes Customers’ Contact Data on behalf of our Customers. We only

use Customers’ Contact Data for the purpose of providing Services to our

Customers.


6.1. Release of Contact Data. By uploading your Contact Data

to our Services, you release this information to us.


6.2. Right to Store and Use the Contact Data. By uploading

your Contact Data to our Services, you represent that you have the right to

store and otherwise use that Contact Data on our Services, as well as the right

to communicate with the Contact using that information.


6.3. Customer Responsibility for Maintaining a Secure

Account. Customers are responsible for maintaining the security and

confidentiality of their Texting For Less usernames and passwords. This is

important to protect the confidentiality of their Contact Data.


6.4. Requests for Deletion of Contact Data by the Contact.

Any Contact of a Texting For Less Customer who would like their data to be

deleted from a Customer’s account should send such requests directly to the

Customer. If contacted, however, Texting For Less will make our best effort to

accommodate requests that appear to be genuine and legitimate.


7. Friend Referral and Customer Testimonials


Customers and Visitors may elect to use our referral service

to inform their friends about our Sites. When using the referral service, Texting

For Less requests the friend’s name and email address. We will automatically

send the friend a one-time email inviting him or her to visit our Sites. We do

not store this information. Customers and Visitors are responsible for

obtaining the consent of any friend or referral that you provide to us.


Texting For Less posts a list of Customers and testimonials

on our Sites that contain information such as Customer names and titles. Texting

For Less obtains the consent of our Customers prior to posting this information

and Customer testimonials.


8. Security


Texting For Less uses proper security measures to protect

Customer Data from unauthorized access and to maintain that data’s accuracy.

When the Service is accessed using Internet Explorer version 6.0 or later,

Firefox version 2.0 or later, or Safari version 3.0 or later, Secure Socket

Layer ("SSL") technology protects Customer Data using both server

authentication and data encryption. Texting For Less has also implemented an

advanced security method based on dynamic data and encoded session

identifications, and we host our Sites in a secure server environment that uses

firewalls and other advanced technology to prevent interference or access from

outside intruders.


These technologies help ensure that Customer Data is safe,

secure, and only available to the Customer to whom the information belongs and

those to whom the Customer has granted access. Texting For Less also offers

additional enhanced security features within the Service that permit Customers

to configure security settings to provide an even greater level of security.


Texting For Less secures Customers’ Contact Data in the same

manner as that described above for securing Customer Data.


While Texting For Less utilizes electronic and physical

security to reduce the risk of improper access to or manipulation of data

during transmission and storage, we cannot guarantee the security or integrity

of the data and shall not be liable for breaches of security or integrity,

third-party interception in transit, or any damage caused to your computer or

other property by your use of the Texting For Less Services.


9. Correcting and Updating Your Information


Customers may update or change their registration

information by editing their user or organization record. To update a user

profile, please visit the Texting For Less Login Page, sign in with your login

information, and then click "My Account" and click “Personal Info.”

To discontinue your account and request that the information you maintained on

our Services be returned to you, please email Support@TextingForLess.com.

Requests to access, change, or delete your information will be handled to the

extent possible within 30 days.


10. California Privacy Rights and Customers’ Contact Data


The California Consumer Privacy Act (“CCPA”) (Cal. Civ. Code

§ 1798.100, et seq.) provides California residents with specific rights

regarding the use of their personal information. The CCPA defines “personal

information” as information that identifies, relates to, describes, is

reasonably capable of being associated with, or could reasonably be linked,

directly or indirectly, with a particular consumer or household. As described

in Section 6 above, Texting For Less Customers use our Services to host

Customers’ Contact Data that Texting For Less Customers collect.


Texting For Less operates as a service provider with respect

to Customers’ Contact Data. This means that we only use Customers’ Contact Data

for the purpose of providing Services to our Customers. To fulfill these

purposes, Texting For Less may access Customers’ Contact Data to provide our

Services, to address technical or other service problems, or to comply with

instructions of our Customers who provided the data. We do not access, retain,

use, or disclose Customers’ Contact Data for any other purpose.


If you, a California resident, wish to exercise your rights

to access, delete, or opt-out of the sale of your personal information, please

submit your request directly to the Customer who submitted your data to Texting

For Less. You may also contact us to request information about the Customer who

provided Texting For Less with your data by submitting your request to Support@TextingForLess.com.

Upon receiving your request, where possible, we will refer your request to the

Customer(s) who submitted your data and provide you with their contact

information. We are committed to upholding your privacy rights and will support

our Customers as needed in responding to your request.


11. Communications Preferences


Texting For Less offers Customers and Visitors who provide

their contact information a way to choose how we communicate with them. You may

manage your receipt of marketing and non-transactional communications by

clicking here or by clicking on the "unsubscribe" link located at the

bottom of our marketing emails. Additionally, you may send a request specifying

your communications preferences to Support@TextingForLess.com.


Customers cannot opt out of receiving transactional emails

related to their account with us or our Services.


12. Changes to this Privacy Statement


Texting For Less reserves the right to change this Privacy

Statement. Texting For Less will provide notification of the material changes

to this Privacy Statement on our Sites at least thirty (30) days prior to the

change taking effect.


Contacting Us


Questions regarding this Privacy Statement or the

information practices of our Sites should be directed to Texting For Less

Privacy by emailing support@textingforless.com or by mailing Texting For Less

Privacy, PO Box 348, Rutherford, NJ 07070.

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