LiveChat (Text, Inc.) rewrote its Privacy Policy almost from scratch. The new version is much longer and more detailed, and it adds real consumer protections — a clear 30-day response promise on privacy requests, a written promise not to sell personal data, and a full section on your rights in Europe, the UK, Switzerland and California. But it also widens what the company collects and does with it: a new category of data scraped automatically from your website, new tracking of your activity in courses and events, records of your consents and preferences, and a much broader use of automated profiling to target ads and marketing. The company also gave itself a standing right to use a business customer's name and logo in its marketing, and expanded how it can publish feedback and testimonials.
If you sign up for their webinars, academies, bootcamps or workshops, they now track your progress, attendance and 'engagement metrics' — essentially scoring how you interact with their material. This was not a listed data category before.
“including progress, engagement, communications, engagement metrics, preferences, and interactions with related content and materials;”
A brand-new category lets the company gather information about any website or domain you give them or where their chat widget runs — including the site's content and analytics — and says this can be done by automated means. The old policy mentioned using your website address to enrich your profile and train AI, but this goes further by naming website content itself as a collected data category.
“Information collected from or otherwise associated with websites, domains, or similar identifiers provided to **Text**, connected with an Engagement, or on which Services are deployed, including publicly available business information, website content, analytics information, service interaction information, and other lawfully available information associated with such identifiers. Such information may be collected through automated means;”
What you can do — If you run a site with the LiveChat widget installed, assume its public pages may be crawled and analyzed by Text. Ask support@text.com what they have collected about your domain if this concerns you.
Nearly every data category was rewritten to be wider. Location now explicitly includes approximate location worked out from your IP address; activity tracking now names session information, navigation history, feature usage, message delivery status and browsing information; and most categories end with catch-all phrases like 'and similar activity data'. The old list was narrower and more specific.
“location and geolocation information (including approximate geolocation derived from IP address), geographic region, usage logs, technical identifiers, and similar device, network, technical, and location information;”
The profiling section grew from one paragraph to a long one. They can now combine what they collect about you with information already in their records or 'lawfully obtained from other sources', build and enrich audience segments, and target ads and offers at you. They also warn that objecting to profiling can cost you features and may even end your contract. On the plus side, they added a promise not to use profiling for decisions with legal or similarly significant effects.
“Where permitted by applicable law, profiling may also be used to create or enrich audience segments, improve the relevance of marketing and advertising, tailor offers and promotional content, evaluate the effectiveness of campaigns, and identify products, services, features, or information that may be of interest to you.”
What you can do — Email support@text.com to object to or withdraw consent for profiling — but be aware they say this may limit features or end your agreement.
The previous policy led its sharing section with a broad promise never to share, sell, rent or trade your personal data with unrelated third parties. That sentence was deleted. What replaced it is narrower: they only promise not to sell data for money, and they still confirm they share information with advertising and analytics partners for their own marketing. The narrower promise is clearer and enforceable, but it covers less ground than the old one.
“**Text** does not sell Personal Data for monetary consideration. This does not restrict disclosures to service providers, telecommunications carriers, or other authorized parties”
What you can do — To stop the sharing with advertising and analytics partners on their websites, use the opt-out described in their Cookie Policy at livechat.com/legal/cookie-policy/.
They can now keep records of your consents, opt-outs and communications for as long as needed to prove they followed the rules. They also state that if deleting your data right away isn't practical — for example because it's in a backup — they will just restrict its use and let the normal backup cycle overwrite it later, rather than deleting it on request.
“Where immediate deletion is not reasonably feasible due to the manner in which information is stored, including in secure backups, we will restrict further use of the information and delete or overwrite it in accordance with our standard retention and backup cycles, unless continued retention is required or permitted by applicable law.”
Business customers can ask the company to stop using their name, logo or testimonial, but the new text makes clear that request only applies to future use. Anything already published, distributed, archived, or even just 'committed to production' stays out there. This limitation on the withdrawal right is new for the name-and-logo permission and is stated more firmly for feedback.
“Any such request will apply prospectively only and will not require **Text** to withdraw, recall, modify, or cease use of materials that were created, published, distributed, or committed to production or distribution before **Text** received the request.”
What you can do — If you don't want your company name or logo used in LiveChat's marketing, email support@text.com now — waiting means anything already published stays published.
Testimonials, reviews and case study material — which can include your name, job title, photo, likeness and voice — can now be shared with outside publishers, platforms and service providers to prepare and distribute them. The old policy allowed this too, but the new text restates it alongside a firmer statement that no further approval from you is needed once you've given feedback.
“Once Feedback has been voluntarily provided by or on behalf of the Client, the Client authorizes **Text** to exercise the rights described in this Section without further approval, unless otherwise agreed in writing with the Client.”
The company can still rewrite this policy whenever it wants, with no notice to you — you only find out by noticing a new date at the top. This is slightly better than before, since changes now take effect on a stated date rather than the instant they're posted, but there is still no advance notice and no chance to object.
“We may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, our Engagements, business operations, technologies, or data processing practices.”
What you can do — Check the 'Last Updated' date on the policy periodically if this matters to you.
Handing over your email for one thing — an event signup, a downloaded guide, a question — may now be used to send you unrelated marketing. They also state outright that certain service, billing and security messages cannot be turned off.
“you may not be able to opt out of certain such communications where they are necessary for those purposes”
What you can do — Use the unsubscribe link in any marketing email, or email support@text.com, to stop promotional messages.
The security section now adds that, as far as the law allows, they don't promise unauthorized access can always be stopped and aren't responsible for incidents outside their reasonable control. They also disclaim responsibility for sensitive data submitted against the rules and for anything third-party integrations do with your information. This is largely a restatement of previous disclaimers in firmer, broader language.
“To the fullest extent permitted by applicable law, **Text** does not warrant that unauthorized access can always be prevented and is not responsible for incidents caused by circumstances outside its reasonable control.”
The old policy said they would notify you if the company merged or its assets were transferred, by updating the policy and where possible other ways. That commitment is gone. The new section says a buyer may process your data under this policy 'and any additional notice provided' — leaving whether you get told up to them.
“Any successor or acquiring entity may process such information in accordance with this Privacy Policy, applicable law, and any additional notice provided in connection with the transaction.”
The policy was rebuilt from 8 sections into 9, with new numbering, new headings, and rewritten plain-English summaries throughout. Much of the old text survives in reworded form, but many parts are new.
## 1\. Your Global Privacy Rights
## 1\. Introduction
The company added a whole new category of information it collects — public information about any website or domain you give them or where their chat tool is installed. It says this can be gathered automatically, meaning by crawling your site.
_Public website information:_ Information collected from or otherwise associated with websites, domains, or similar identifiers provided to **Text**, connected with an Engagement, or on which Services are deployed, including publicly available business information, website content, analytics information, service interaction information, and other lawfully available information associated with such identifiers. Such information may be collected through automated means;
They now list a category for tracking how you take part in their webinars, academies, bootcamps and workshops — including your progress, engagement scores, and how you interact with the materials.
_Educational and participation data:_ Information relating to registrations, attendance, participation in educational initiatives, events, webinars, academies, bootcamps, workshops, and other similar initiatives offered by **Text,** including progress, engagement, communications, engagement metrics, preferences, and interactions with related content and materials;
They now keep detailed records of every privacy choice you make — what you agreed to, when, how, and when you changed your mind. This is a compliance record, and they say they can keep it long-term.
_Consent, preference, and compliance information:_ Information and records relating to your communication and privacy preferences, consents, permissions, opt-ins and opt-outs, suppression requests, withdrawals of consent, the date, time, source, and method by which a preference or consent was provided or withdrawn
The old policy had one short paragraph on profiling. The new one describes combining your data with other information they hold or buy, building audience segments, and targeting ads and offers at you. They did add a promise not to use profiling for decisions with legal or similarly serious effects.
3.4. Profiling Activities. By engaging with us, you acknowledge and agree to our use of your Personal Data for profiling purposes involving automated methods, ensuring you receive the most pertinent information and features from the Engagements you select and combining the data you provide with our existing records.
Where permitted by applicable law, profiling may also be used to create or enrich audience segments, improve the relevance of marketing and advertising, tailor offers and promotional content, evaluate the effectiveness of campaigns, and identify products, services, features, or information that may be of interest to you.
If you hand over your contact details for any single reason — downloading a resource, signing up for an event, asking a question — they may now use it to send you unrelated marketing too. They also state you cannot opt out of certain service and account messages.
3.10. Communication. By participating in the Engagements, you agree to be contacted by us to receive electronic communications regarding your interactions with Engagements. You may opt-out of receiving these types of communications by adjusting the device settings anytime.
If you provide contact information to **Text** in connection with a particular Engagement, request, registration, event, resource, or other interaction, we may use that information to communicate with you in connection with that interaction and, where we have an appropriate legal basis, which may include your consent or our legitimate interests, to provide other marketing or promotional communications that may be of interest to you.
The old policy already let them use a business customer's name and logo. The new version adds that if you ask them to stop, the request only applies going forward — they don't have to pull back anything already published or in production.
3.11. The Client logo. You give **Text** and its affiliates worldwide, royalty-free, non-exclusive and unlimited in-time consent to use your company name, logos, and other information to identify you as a Client and for marketing and promotional purposes, including **Text**'s websites and sales materials.
Any such request will apply prospectively only and will not require **Text** to withdraw, recall, modify, or cease use of materials that were created, published, distributed, or committed to production or distribution before **Text** received the request.
Feedback, reviews and testimonials can be republished with your name, job title, photo, likeness and voice. The new text adds that they can also share this material with outside publishers and platforms, and that once you give feedback no further approval is needed.
3.16. Feedback and Attribution. Feedback and related contributions may include the Client's name, logos, and other brand identifiers
**Text** may also share Feedback-related materials with publishers, platforms, and service providers solely to prepare, publish, or distribute those materials.
The company now states plainly that it does not sell personal data for money, and that it does not use tracking inside its chat product to run third-party ads or follow end users across unrelated businesses.
**Text** does not use cookies or similar technologies within the Services to provide third-party advertising, conduct cross-site or cross-context behavioral advertising, or target an End User based on activity across unrelated Clients.
A new section spells out the rights you can exercise — access, correction, deletion, objection, withdrawing consent, portability — and commits to answering verified requests within 30 days.
We will respond to verified requests within 30 days, subject to any extensions permitted by applicable law due to the complexity or number of requests
A new Section 8 explains rights for people in Europe, the UK, Switzerland and California in one place, including the right to complain to a data protection regulator.
## 8\. Jurisdiction - specific rights
The old policy simply told you not to send sensitive data like health or biometric information. The new version says the product isn't built for it at all, allows it only under a separate signed agreement, and says the company can delete or block such data if it shows up.
2.5. Sensitive data Caution. When using our Engagements, avoid sharing (or having us send) any sensitive data (like genetic data, biometric data, or health data, as defined by applicable data protection laws and regulations). You acknowledge that We bear no liability whatsoever for such data you provided to us, whether in connection with a data breach or otherwise.
the Client shall not provide or cause to be provided Sensitive Personal Data to **Text** for Processing through the Services, and **Text** may delete, restrict, isolate, or otherwise refrain from further processing such information.
The retention section is expanded. It now says they may keep records of your consents, opt-outs and communications for as long as needed to prove compliance, and that data in backups may survive a deletion request until the normal backup cycle overwrites it.
5.2. Retention. We will only collect and retain your data which is relevant to the purposes for which it is collected, subsequently authorized by you, or if otherwise permitted by law or by the Agreement.
Retention periods may also reflect the need to maintain records of consents, permissions, communication preferences, opt-outs, suppression requests, communications, and related compliance records for as long as reasonably necessary to provide the Engagements, demonstrate compliance with applicable law or contractual requirements, manage communication preferences, or to establish, exercise, or defend legal claims.
Previously an updated policy took effect the moment it was posted. Now it takes effect on the date written at the top of the document — a small improvement in predictability, though there is still no advance notice to you.
The updated version will be indicated by an updated "Last update" date, and the updated version will take effect immediately as soon as it is accessible.
When we make changes, we will revise the "Last Updated" date at the beginning of this Privacy Policy. The updated version of this Privacy Policy becomes effective on the date specified at the beginning of this document.
The old policy opened its sharing section with a broad promise never to share, sell, rent or trade personal data with unrelated third parties. That sentence is gone, replaced by a narrower promise not to sell data for money.
We neither share, sell, rent, trade, nor otherwise transfer your Personal Data to unrelated third parties, except as necessary to provide and support the Services
**Text** does not sell Personal Data for monetary consideration.
The old policy said they would tell you if the company merged or was sold, by updating the policy and by other means where possible. The new corporate-transaction section drops that commitment.
We will notify you if any of these events occur by updating this Privacy Policy and, when feasible, through other methods.
Any successor or acquiring entity may process such information in accordance with this Privacy Policy, applicable law, and any additional notice provided in connection with the transaction.
Detailed sections about commenting on their blog through Facebook, Twitter, Disqus or Google, and about social media buttons, were cut and folded into a general section on third-party integrations.
3.19. Comment system. In order to post comments on our Website (i.e. our blogs), you must sign in to Facebook, Twitter, Disqus, or Google, as we use social-media plugins to allow you to leave comments on our blogs. No Personal Data is tied to your posts.
Two typo-broken links were corrected — the Cookie Policy link in the California section and the Marketplace, Developer Program and Partner Program links.
[Cookie Policy](https://www.livechat.com/egal/cookies-policy/)
[Cookie Policy](https://www.livechat.com/legal/cookie-policy/)
COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED
| 1 | We, Text, Inc. and our affiliate ("**Text**", "Company" or "we") value your privacy and we are committed to safeguarding your personal information and being transparent about the data we collect and how we use it. | |
| 1 | ## 1\. Introduction | |
| 2 | 2 | |
| 3 | Our Privacy Policy applies to all interactions you may have with **Text** and is intended to help you understand our practices concerning the collection, use, and disclosure of information. We retain the right to amend or update this Privacy Policy at any time. The updated version will be indicated by an updated "Last update" date, and the updated version will take effect immediately as soon as it is accessible. | |
| 3 | 1.1. About This Privacy Policy. Text, Inc. and its Affiliates ("**Text**", "we", "us", or "our") respect your privacy and are committed to protecting information we process about you. This Privacy Policy applies to the processing of information, including Personal Data, by **Text** in connection with the Engagements described in this Privacy Policy. It describes the categories of information we process, the purposes for which we process it, when we disclose it, the rights available to individuals under applicable law, and the safeguards we apply to protect it. | |
| 4 | 4 | |
| 5 | **Please note:** It is vital to read and understand our Privacy Policy. By engaging in any form of communication with **Text**, you acknowledge you have read and understood this Privacy Policy. Should you disagree with our policy, we kindly ask you not to interact with any aspect of our business. | |
| 5 | **Please note:** It is vital to read and understand our Privacy Policy. By engaging in any form of communication with **Text**, you acknowledge that you have read and understood this Privacy Policy. The summaries below are provided for convenience only and do not modify or replace the provisions of this Privacy Policy. | |
| 6 | 6 | |
| 7 | For the purposes of this Privacy Policy, all capitalized terms used but not defined herein shall have their respective meanings in the [Terms of Use](https://www.livechat.com/legal/terms-of-use/). | |
| 8 | ||
| 9 | 7 | Legal stuff made easy |
| 10 | 8 | |
| 11 | Your privacy is important to us. We're committed to protecting your data and being transparent about how we handle it. Our Privacy Policy covers all your interactions with us and is designed to help you understand how we collect, use, and share information. When you communicate with us in any way, you acknowledge that you've read and understood this Policy. If you disagree with any part of it, you should not interact with Us. | |
| 9 | This Privacy Policy explains how Text handles information in connection with your interactions with us, including what information we process, why we process it, when we disclose it, what rights may be available to you, and how we protect it. Depending on the circumstances, Text may act as a Data Controller or a Data Processor. | |
| 12 | 10 | |
| 13 | ## 1\. Your Global Privacy Rights | |
| 11 | 1.2. Scope. Depending on the nature of the applicable Engagement and the purposes for which Personal Data is processed, Text may act either as a Data Controller or a Data Processor. Accordingly, certain provisions of this Privacy Policy apply only where **Text** acts as a Controller, while others apply where **Text** acts as a Data Processor. Where relevant, this Privacy Policy identifies the applicable role. This Privacy Policy does not govern the privacy practices of our Clients or other third parties, including in connection with products, services, websites, applications, or other offerings provided by Clients to their End-Users. Such processing remains subject to the applicable Client's own privacy notices and policies. Where **Text** processes Personal Data on behalf of a Client, the Client remains responsible for determining the purposes and legal bases for processing of Personal Data, providing any notices required by applicable law, obtaining and maintaining any required consents, permissions, or other lawful basis and communication preferences, withdrawals of consent, or opt-out requests, where applicable, and otherwise ensuring that its its collection and use of Personal Data through the Services complies with applicable privacy laws and the Agreement. Requests relating to Client Personal Data should generally be directed to the relevant Client, although **Text** will assist the Client in responding to such requests where required by applicable law and the applicable Agreement, including the DPA. Nothing in this Privacy Policy limits or modifies the respective obligations of **Text** or the Client under the applicable Agreement, including the DPA. | |
| 14 | 12 | |
| 15 | 1.1. No matter where you live, where you reside, where your citizenship lies, or where your data originates from, your interactions with **Text** are governed by this Privacy Policy and you agree to the data practices described in this policy. | |
| 13 | 1.3. Changes to this Privacy Policy. We may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, our Engagements, business operations, technologies, or data processing practices. When we make changes, we will revise the "Last Updated" date at the beginning of this Privacy Policy. The updated version of this Privacy Policy becomes effective on the date specified at the beginning of this document. | |
| 16 | 14 | |
| 15 | 1.4. Relationship with Other Documents. Where you use the Services as a Client, this Privacy Policy forms part of the Agreement together with the Terms of Use and the Data Processing Addendum ("DPA"), as provided in the Terms of Use. Any applicable Order Form and product-specific or service-specific terms may also form part of or apply under the Agreement in accordance with their terms. Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in the applicable Terms of Use or DPA, as applicable. In the event of a conflict between documents forming or incorporated into the Agreement, the order of precedence set out in the Terms of Use applies. In particular, to the extent of any conflict relating to the Processing of Personal Data subject to the DPA, the DPA governs to the extent of that conflict. | |
| 16 | ||
| 17 | 17 | ## 2\. Data We Handle |
| 18 | 18 | |
| 19 | 2.1. Scope of Engagements. Information collection and processing occur through various interactions, including but not limited to: (i) Clients using our services via different platforms, e.g. Website, [Marketplace](https://www.livechat.com/legal/for-marketplace/), [Developer Program](https://platform.text.com/developer-terms), [Partner Program](https://www.livechat.com/legal/for-partners/), Services API, or any other products, or services we offer (collectively referred to as "Services"), or (ii) Non-Clients connecting with us outside service agreements, like (a) Visitor visiting/navigating our online website (website URL) operated by us ("Website") or otherwise communicating with us through various communication channels in whatever form, including but not limited to social media channels, phone/e-mail, SMS, the chat window on our Website, or giving feedback and making inquiries or signing up for our marketing communication or our newsletters, and (b) Participant attending events we host. All these interactions are referred to as "Engagements'' within this policy, irrespective of the depth or nature of your association with us. | |
| 19 | 2.1 Engagements. **Text** processes information through various interactions with individuals and organizations, regardless of the communication channel, technology, device, or method used to collect or process it. For purposes of this Privacy Policy, all such interactions (including but not limited to social media channels, phone, email, SMS, the chat window on our Website, giving feedback, making inquiries, signing up for our marketing communication) are collectively referred to as "Engagements", and may include, without limitation: (a) Clients, including individuals acting on their behalf using, administering, purchasing, evaluating, or otherwise interacting with the Services, APIs, Website, [Marketplace](https://www.livechat.com/marketplace/), [Developer Program](https://developers.livechat.com/developer-terms), [Partner Program](https://www.livechat.com/legal/partner-program-terms/), hosted communication tools, authentication mechanisms, integrations, applications, customer support channels, artificial intelligence features, and any other products or services offered by **Text**; (b) Visitors of our Websites or our other online properties; (c) Individuals communicating with **Text** through available communication channels; (d) Participants registering for, attending, or otherwise participating in activities, initiatives, programs, surveys, or feedback, or events organized or made available by **Text;** and (e) otherwise interacting with **Text** in connection with its business operations and activities. | |
| 20 | 20 | |
| 21 | 2.2. Roles in Data Handling. This policy applies uniformly to all types of Engagements, whether you visit our Website (as a Visitor), attend an event (as a Participant), or use/access our Services (as a Client). Depending on your Engagements with us (Visitor, Participant, or Client), we act either as: (a) a Data Processor (Service Provider), under our Agreement with you, when you process Client Data that you supply or control through the Services; or (b) Data Controller for Personal Data and attribution information we collect or you share with us outside the Agreement (e.g. Website interactions, events, Feedback submitted directly to us or via integrated services or third party services); and for certain technical or operational information about Services usage or as part of the Services Data. In every case, we process your information in line with this Privacy Policy. | |
| 21 | 2.2. Our Role in Data Handling. Depending on the nature of the applicable Engagement and the purposes for which Personal Data is processed, **Text** may act either as a Data Processor or as a Data Controller. Where **Text** processes Client Personal Data on behalf of a Client in connection with the Services, **Text** acts as a Data Processor and processes such Personal Data in accordance with the Client's documented instructions and the applicable Agreement, including the Data Processing Addendum ("DPA"). This includes, where applicable, Personal Data processed when a Client uses communication features of the Services to communicate with its End-Users or other recipients. In doing so, we may process Personal Data relating to the Client's Users, End Users, and other individuals who use, access, communicate through, or otherwise interact with the Services or with **Text** in connection with the Client's use, administration, or operation of the Services. Depending on the applicable Engagement, such information may include identifiers, authentication credentials, contact information, communications and content, usage information, technical and security information, consent, preference, and compliance information, and other information necessary to provide, secure, maintain, support, and improve the Engagements, as permitted under the Agreement. **Text** may also act as a Data Controller with respect to certain Personal Data processed in connection with the Services, where **Text** independently determines the purposes and means of such processing. This may include certain technical or operational information about Services usage, as well as information generated or collected in connection with the operation, security, performance, analytics, improvement, or development of the Services. **Text** also acts as a Data Controller with respect to Personal Data processed for its own business operations, including operating our Websites, marketing activities, communications, educational initiatives, events, recruitment activities, business relationships, product development, analytics, ensuring the security of our business operations, and other Engagements described in this Privacy Policy. | |
| 22 | 22 | |
| 23 | 2.3. Grounds for Processing. When acting as a Data Controller, signifying that we have authority over the reasons and methods behind processing your data, including Personal Data, we rely on various legal bases for it. These include: (i) Agreement/Your request: to provide the Engagement and to respond to your requests, (ii) Legal Compliance: to adhere to our legal obligations, (iii) Your Consent, and (iv) Legitimate Interests: such as to operate, secure and provide you with our Engagements functionality (e.g. Website, chat window), understand and improve them; support promotion and operational management, maintain the reliability of our systems and related technologies and other Client services and support purposes; and to receive, analyze, and use Feedback and related attribution data, including for marketing/publicity as described below. In such scenarios, we consistently strike a balance between our interests and your privacy rights. As a Data Processor, our relationship is governed by the Agreement with you, which sets out our respective obligations and rights. | |
| 23 | 2.3. Grounds for Processing. Where applicable law requires a legal basis for processing Personal Data, **Text** relies on one or more of the following legal bases, depending on the applicable Engagements and the specific purpose of processing: (i) Processing may be necessary to enter into or perform a contract with you, including taking steps at your request before entering into a contract, providing the applicable Engagement, administering your account or subscription, processing transactions, and responding to requests relating to the contractual relationship; (ii) Processing may be necessary for Text to comply with applicable laws, regulations, court orders, legal processes, tax and accounting obligations, governmental requests, and other binding legal or regulatory requirements; (iii) based on your consent for specific purposes; and (iv) for the legitimate interests pursued by **Text** or a third party, provided that those interests are not overridden by your interests, fundamental rights, or freedoms. Such legitimate interests may include operating, administering, securing, maintaining, supporting, and improving the Engagements; preventing fraud, misuse, and security threats; communicating with individuals and managing customer and business relationships; understanding how the Engagements are used; conducting analytics, statistical analysis, benchmarking, and business intelligence; developing and evaluating products, features, and technologies; protecting **Text**'s business, rights, property, and users; and conducting marketing or promotional activities as described in this Privacy Policy. Before relying on legitimate interests, **Text** considers the nature and necessity of the processing, the reasonable expectations of the individuals concerned, and the potential impact of the processing on their rights and freedoms. Where **Text** acts as a Data Processor, the relevant Client determines the applicable legal basis for processing Client Personal Data, and **Text** processes such data in accordance with the Client's documented instructions and the applicable Agreement. | |
| 24 | 24 | |
| 25 | 2.4. Types and Sources of Data. Our Engagements may collect and process your information including Personal Data depending on how you interact with us, the choices you make, and the Engagements and features you use. The sources of this information include what you share, our automated systems, and third-party sources and contain both your Personal and Non-Personal Data, including, but not limited to: | |
| 25 | 2.4 Types and Sources of Data. The information we collect depends on how you interact with our Engagements, the choices you make, the features you use, and the nature of your relationship with **Text.** We may collect information directly from you, from the organization you represent, automatically through the Engagements, from our Clients, from integrated services, from publicly available sources, from our service providers, and from other lawful third-party sources. The categories of information we may process include, but are not limited to: | |
| 26 | 26 | |
| 27 | 1. _Identifiers:_ Contact information and Services-related details, e.g. your full name, email address, physical address, phone number and IP address, user name, password, technical identifiers and usage data (such as IP address, device and browser information, authentication data and other identifiers you provide, your Authorized-Users', Guest-Users' and End-Users' data you provide us with; | |
| 27 | 1. _Identifiers:_ Information that identifies, relates to, or may reasonably be associated with an individual, such as name, email address, phone number, postal address, authentication credentials, IP address, username, business contact information, subscription identifiers, device identifiers, and other similar identifiers; | |
| 28 | 28 | |
| 29 | 2. _Commercial information:_ Transactional information, or other purchasing or consuming histories and tendencies, payment data\_,\_ subscription information and supporting tickets; | |
| 29 | 2. _Commercial information:_ Information relating to subscriptions, transactions, billing activities, payment-related information, support history, tickets, purchasing history, customer relationship information, and similar commercial records; | |
| 30 | 30 | |
| 31 | 3. _Electronic and network activity information:_ This includes records of your interactions with our Engagements (e.g. Website, chat window on our Website and chat logs, Website history) and other records, e.g. pages visited, links clicked, referring URL, records on how you reached and used our Engagements, performance metrics, start and end times of your interactions and other actions taken on our Engagements and details of such actions; | |
| 31 | 3. _Internet and electronic activity:_ This includes records of your interactions with our Engagements, including interaction history; chat and messaging logs; pages visited; links clicked; referring URLs; session information; navigation history; feature usage; records of communications sent or received; delivery and interaction status; and timestamps; performance metrics; usage patterns, communication records; browsing and diagnostic information, and similar activity data; | |
| 32 | 32 | |
| 33 | 4. _Device and geolocation:_ e.g. IP address, operating system, device type, browser details, country preferences, mobile network information, and device phone number, location, usage logs, and your geographic region; | |
| 33 | 4. _Device, technical, and geolocation information:_ Information relating to the devices, networks, and technologies used to access or interact with the Engagements, including IP address, browser type and details, operating system, device type and characteristics, language settings, country or region preferences, mobile network information, device phone number, location and geolocation information (including approximate geolocation derived from IP address), geographic region, usage logs, technical identifiers, and similar device, network, technical, and location information; | |
| 34 | 34 | |
| 35 | 5. _Shared content and contribution data_: content you submit in events, social media, community spaces, our Website chat, survey forms, and Feedback used to attribute such contributions publicly, as permitted by the Agreement; | |
| 35 | 5. _Communications and Content:_ Information you provide when communicating with **Text** through the Engagements, including support requests, chat conversations, e-mails, surveys, forms, Feedback, event participation, social media interactions, comments, reviews, community contributions, and other similar communications; | |
| 36 | 36 | |
| 37 | 6. _Inferences:_ Profiles created or enriched based on your data, including information collected through our chat widgets and connected systems, reflecting interests, characteristics, preferences, and demographics, to improve personalization, analytics, and user experience. | |
| 37 | 6. _Inferences:_ information derived from other information we process that may reflect interests, characteristics, preferences, engagement patterns, demographics, product usage trends, or other insights used to personalize Engagements, improve user experiences, conduct analytics, support product development, and enhance our business operations; | |
| 38 | 38 | |
| 39 | Some of this information comes from third-party sources (e.g. cookies, web beacons, and other tracking technologies) to help us serve relevant ads and other services to you, as explained further herein. Note that our Privacy Policy does not apply to any third-party sources, their products, or sites that may be displayed to you, or other sites linked to or from our Engagements. Additionally, our Privacy Policy does not address the practices of other entities who advertise our Engagements, and who may use tracking technologies (like cookies, pixel tags and other technologies) to provide and personalize ads, and you should refer to their respective privacy policies for more. | |
| 39 | 7. _Public website information:_ Information collected from or otherwise associated with websites, domains, or similar identifiers provided to **Text**, connected with an Engagement, or on which Services are deployed, including publicly available business information, website content, analytics information, service interaction information, and other lawfully available information associated with such identifiers. Such information may be collected through automated means; | |
| 40 | 40 | |
| 41 | 2.5. Sensitive data Caution. When using our Engagements, avoid sharing (or having us send) any sensitive data (like genetic data, biometric data, or health data, as defined by applicable data protection laws and regulations). You acknowledge that We bear no liability whatsoever for such data you provided to us, whether in connection with a data breach or otherwise. | |
| 41 | 8. _Educational and participation data:_ Information relating to registrations, attendance, participation in educational initiatives, events, webinars, academies, bootcamps, workshops, and other similar initiatives offered by **Text,** including progress, engagement, communications, engagement metrics, preferences, and interactions with related content and materials; | |
| 42 | 42 | |
| 43 | Legal stuff made easy | |
| 43 | 9. _Consent, preference, and compliance information:_ Information and records relating to your communication and privacy preferences, consents, permissions, opt-ins and opt-outs, suppression requests, withdrawals of consent, the date, time, source, and method by which a preference or consent was provided or withdrawn, applicable notice or consent language, and other records or evidence maintained to demonstrate or manage compliance with applicable requirements. | |
| 44 | 44 | |
| 45 | 1. How We Collect Data: | |
| 46 | We collect and process information through various interactions, whether you're using our Services, visiting our Website, or attending events. We call these interactions "Engagements" in this policy. | |
| 45 | 2.5 Sensitive Personal Data. Where **Text** acts as a Data Processor, the Services are not intended for the Processing of Sensitive Personal Data, and **Text** and the Client do not intend to, and shall not knowingly, collect, process, or transmit Sensitive Personal Data through the Services, unless otherwise expressly agreed in writing by the parties under a valid product-specific Business Associate Agreement ("BAA"), where applicable. The Client remains responsible for determining whether its use of the Services involves Sensitive Personal Data, providing any required notices, obtaining any required consents or other lawful basis, implementing any additional safeguards required by applicable law, and complying with the Agreement and, where applicable, the BAA. In the absence of an applicable BAA, the Client shall not provide or cause to be provided Sensitive Personal Data to **Text** for Processing through the Services, and **Text** may delete, restrict, isolate, or otherwise refrain from further processing such information. Where **Text** acts as a Data Controller, **Text** does not ordinarily seek to collect Sensitive Personal Data unless such processing is necessary for a specified purpose, permitted by applicable law, and subject to any additional requirements applicable to such data. To the fullest extent permitted by applicable law and the Agreement, **Text** is not responsible for Sensitive Personal Data submitted or otherwise made available through the Services or the Engagements, in violation of this Section, the applicable Agreement, or the applicable BAA. | |
| 47 | 46 | |
| 48 | 2. Our Role: | |
| 49 | We might handle your data in different ways, depending on how you interact with us. Sometimes, we control your data; other times, we process it based on a contractual relationship with you. | |
| 47 | Legal stuff made easy | |
| 50 | 48 | |
| 51 | 3. Why We Process Your Data: | |
| 52 | We use your data to provide our Services, fulfill a request you've made, comply with the law, follow your instructions, operate with your consent, or use the data in ways that help us provide and improve our Services, all while respecting your privacy. | |
| 49 | 1. We process information through the different ways in which individuals and organizations interact with Text, which we call "Engagements." Information may come directly from you, from the organization you represent, from our Clients, automatically through the Engagements, from integrated services, publicly available sources, service providers, or other lawful third-party sources. | |
| 53 | 50 | |
| 54 | 4. What Data We Collect: | |
| 55 | We collect and process your information, including Personal and Non-Personal Data, based on your interactions and choices. Sources include what you share, our systems, and third-party sources. This can include your name, last name, contact details, what you subscribe to, your online activities on our Website, your device details, location, and any opinions or preferences you share. | |
| 51 | 2. Depending on the circumstances and purpose of the processing, Text may act as a Data Controller or a Data Processor. When we process Client Personal Data on behalf of a Client, we act as a Data Processor in accordance with the applicable Agreement, including the DPA. We may act as a Data Controller for certain Services-related technical or operational information and for our own business operations. | |
| 56 | 52 | |
| 57 | 5. Data from Other Sources: | |
| 58 | We also get data from cookies and similar tech tools, which help us show you relevant ads and improve our Services or your Client experience. Remember, our policy doesn't cover third-party sites or ads. | |
| 53 | 3. We may process your data to perform a contract, comply with legal obligations, or, where permitted by law, act on your consent or pursue legitimate interests. When Text acts as a Data Processor, the relevant Client determines the applicable legal basis. | |
| 59 | 54 | |
| 60 | 6. Be Careful with Sensitive Data: | |
| 61 | Please avoid sharing sensitive information while using our Engagements (like health or biometric data) with us. We are not liable for such data. | |
| 55 | 4. Depending on the Engagement, we collect and process your information, including Personal and Non-Personal Data, based on your interactions and choices. Sources include what you share, our systems, and third-party sources. This may include identifiers, commercial information, internet and electronic activity, device, technical and geolocation information, communications and content, inferences, public website information, and educational or participation information. | |
| 62 | 56 | |
| 63 | ## 3\. How We Process Your Information | |
| 57 | 5. The Services are not intended for Processing Sensitive Personal Data unless otherwise expressly agreed in writing under an applicable product-specific BAA. Clients are responsible for ensuring that any such processing complies with the applicable Agreement, BAA, and applicable law. | |
| 64 | 58 | |
| 65 | 3.1. Processing Purposes. As long as we process your information, including your Personal Data, we will continue to do so for the following purposes: | |
| 59 | ## 3\. How We Use Information | |
| 66 | 60 | |
| 67 | 1. _Service Delivery and Enhancement_: To provide, maintain, operate, and improve the Services, Services API, Partner Program, our Website, chat window on our Website and related technologies including collecting and analyzing statistical information about you and your interactions with our said services. This includes: (i) facilitating effective service delivery, (ii) continuously improving the said services and our related technologies, as well as monitoring their performance, (iii) researching, developing, and innovating new services, products, features and related technologies, (iv) providing testing, training, machine learning capabilities, (v) providing the Client support services, resolving issues, and requests for assistance, (vi) enabling Partners and Developers to access Client Personal Data during its authorized processing, (vii) as otherwise provided in our Agreements with you. | |
| 61 | 3.1. Text processes information, including Personal Data, only to the extent necessary for the purposes described in this Privacy Policy and, where applicable, the Agreement. As long as we process your information, including your Personal Data, we will continue to do so only to the extent necessary for one or more of the purposes described below and, where applicable, the Agreement: | |
| 68 | 62 | |
| 69 | 2. _Safety and Security:_ To ensure and improve security of the Engagements, Website and related technologies, preventing frauds and abuses; monitoring the performance of the Engagements, Website, retaining data for backup and disaster recovery purposes, debugging as well as detecting fraudulent, illegal, and malicious activities. | |
| 63 | 1. _Delivering and Operating the Engagements:_ To establish, provide, maintain, operate, administer, secure, improve, and develop our Engagements and related technologies. This includes, where applicable: (a) creating, managing registrations, subscriptions, licenses, and user profiles and participation records, including verifying eligibility, identity, processing payments and administering commercial relationships; (b) providing access to the Engagements and related functionality; (c) providing customer support, technical assistance, operational services and responding to inquiries; (d) measuring participation, engagement, attendance, adoption, and effectiveness of the Engagements; (e) researching, developing, testing, validating, training, improving, and deploying services, products, features, technologies, programs, artificial intelligence capabilities, machine learning systems and related capabilities; (f) monitoring availability, performance, reliability, functionality and quality of the Engagements; (g) enabling Partners and Developers to access Client-related information, including Personal Data, during authorized processing; (h) administering events, educational initiatives, webinars and similar Engagements; (i) performing our obligations under the applicable agreements; and (j) enabling communications through supported communication channels, including provisioning and managing communication identifiers, transmitting, routing, receiving, and delivering communications, maintaining delivery and status information, and supporting related operational and compliance functionality. | |
| 70 | 64 | |
| 71 | 3. _Compliance and Protection_: Meeting legal obligations, including billing, law enforcement, government, court inquiries, investigations, subpoenas, or similar legal processes, safeguarding our rights and interests and yours. | |
| 65 | 2. _Operating, Securing, and Protecting Our Business:_ To protect the confidentiality, integrity, availability, and security of the Engagements, our business operations, customers, personnel, and third parties. This includes: authentication and access management; fraud prevention; cybersecurity monitoring; abuse detection and prevention of unauthorized activities; incident response; backup and disaster recovery; business continuity; debugging and troubleshooting; vulnerability management; monitoring system performance, availability, and reliability; enforcing our agreements and policies; and protecting the rights, property, safety, and legitimate interests of Text, our Clients, and others. | |
| 72 | 66 | |
| 73 | 4. _User Engagement and Personalization:_ Targeting our Engagements experience for you as well as to improve our pending operations or to create and improve new Engagements, recognizing you and remembering your information when you return to our Engagements; maintaining robust communication and offers based on your activity, interactions, profiling, feedback, and usage of the Engagements, and related technologies, including statistical information. | |
| 67 | 3. _Compliance with Legal Obligations:_ To comply with applicable laws, regulations, court orders, governmental requests, regulatory requirements, tax obligations, accounting requirements, industry standards, or other legal obligations. We may also process information to establish, exercise, defend, investigate, or enforce legal claims or contractual rights, investigate suspected unlawful activity, or respond to lawful requests from public authorities. | |
| 74 | 68 | |
| 75 | 5. _Marketing and Communication:_ Keeping you informed about offers, tailored marketing campaigns, other promotion-related information/activities, important service-related notices and updates via email, push notification and/or social media and other types of communications that may be of interest to you. | |
| 69 | 4. _Communications, Marketing and Promotions:_ We may communicate with you in connection with the Engagements, including to respond to requests and inquiries; provide administrative, transactional, security, account, billing, and service-related notices and updates; provide information about changes to the Engagements; and manage our customer, partner, developer, and other business relationships. We may also send or otherwise provide marketing and promotional communications, including offers, tailored marketing campaigns, newsletters, product or service recommendations, event invitations, promotional information, and other communications that may be relevant or of interest to you. Such communications may be delivered through email, phone, SMS or other messaging services, push notifications, in-product or in-app messages, social media, or other available communication channels. We may personalize or tailor marketing and promotional communications based on information about your interactions with the Engagements, preferences, interests, commercial relationship with **Text,** and other information described in this Privacy Policy, including profiles or inferences derived from such information, where permitted by applicable law. If you provide contact information to **Text** in connection with a particular Engagement, request, registration, event, resource, or other interaction, we may use that information to communicate with you in connection with that interaction and, where we have an appropriate legal basis, which may include your consent or our legitimate interests, to provide other marketing or promotional communications that may be of interest to you. Service-related and transactional communications may be necessary for the administration, security, operation, or performance of the applicable Engagement, or to comply with the Agreement or applicable law, and you may not be able to opt out of certain such communications where they are necessary for those purposes. You may opt out of marketing and promotional communications at any time by using the unsubscribe mechanism provided in the communication or contacting us at [support@text.com](mailto:support@text.com). Opting out of marketing or promotional communications will not prevent us from sending non-promotional communications relating to your account, transactions, security, use of the Engagements, or our contractual or legal obligations. | |
| 76 | 70 | |
| 77 | 6. _Data Insights:_ To aggregate, pseudonymise, and anonymise personal data for research and development, improvement of our Engagements, to understand how you interact with our Engagements and for statistical, and benchmarking purposes. | |
| 71 | 5. _Improving the Engagements:_ To understand how the Engagements are used and to improve, secure, develop, test, and evaluate our products, services, features, technologies, analytics, automation, artificial intelligence, and machine learning capabilities. This may include identifying usage patterns, improving performance and user experience, developing new functionality, supporting research and innovation, conducting statistical analysis and benchmarking, generating operational insights, and enhancing security. The Client represents that it has the rights necessary to provide its content, identifiers, and data and to authorize the processing described in this Privacy Policy and the Agreement. Where reasonably possible and appropriate for the intended purpose, including for statistical analysis and benchmarking, **Text** uses aggregated, pseudonymized, anonymized, or de-identified information. | |
| 78 | 72 | |
| 79 | 7. _Contributions:_ To enable and administer interactive features (e.g., forums, comment systems, surveys, social integrations) and process Feedback and other contributions you or your Authorized Users submit (directly or via integrated services or third-party services), including to operate, assess, improve, and develop our Engagements and Services, create case studies, testimonials, or marketing materials, and to publicly attribute Feedback-related materials to Client or Authorized Users. | |
| 73 | 6. _Contributions, Feedback and Community Participation:_ Where you voluntarily submit (directly or via integrated services or third-party services) Feedback, participate in surveys, community initiatives, educational activities, beta programs, events, or similar Engagements, we may process such information to administer and improve the existing Engagements; develop new products and features; understand customer needs; evaluate customer satisfaction; identify product improvements; prepare educational, support, and knowledge materials; support our business operations; create case studies, testimonials, or marketing materials, and publicly attribute Feedback-related materials. The use of Feedback is subject to the Agreement where relevant. | |
| 80 | 74 | |
| 81 | 3.2. Registration Data. **Text** receives the necessary details (including Personal Data and other Clients' information) in order to complete your registration on our Website. This ensures you have access to the Engagements you have subscribed to, e.g. first name, last name, company name, address, website address, e-mail address and credit/payment card information if you decide to move beyond the free Services, otherwise, credit/payment card information is not required). In addition to the above, we also collect other types of information (including Personal Data) depending on how you use our Engagements, including any data extracted, derived, or inferred from identifiers such as the website address provided during registration. When reaching out to **Text** the Client might be asked to provide similar data to what they had given during the registration process on our Website. | |
| 75 | 7. _User Engagement, Analytics, Personalization, and Profiling:_ **Text** may use automated methods, including profiling, to analyze how individuals interact with the Engagements, understand preferences and usage patterns, recognize returning users, measure engagement, personalize content and functionality, recommend and tailor relevant products, services, features, offers, marketing communications, promotions, or advertising. For these purposes, **Text** may combine information you provide or that we collect through the Engagements with other information associated with you, including information contained in our existing records or lawfully obtained from other sources. Such processing may involve information about your interactions with the Engagements, communications, participation history, product usage, preferences, commercial relationship with **Text**, and other information described in this Privacy Policy. Where permitted by applicable law, profiling may also be used to create or enrich audience segments, improve the relevance of marketing and advertising, tailor offers and promotional content, evaluate the effectiveness of campaigns, and identify products, services, features, or information that may be of interest to you. We do not use profiling to make decisions that have legal or similarly significant effects on an individual, unless such processing is permitted by applicable law and appropriate safeguards are in place. Where required by applicable law, individuals may object to, restrict, or withdraw consent for profiling by contacting [support@text.com](mailto:support@text.com). Exercising such rights may affect the availability of optional personalization or other features where the relevant processing is reasonably necessary to provide those features, potentially resulting in the termination of our Agreement. | |
| 82 | 76 | |
| 83 | 3.3. Data Compliance. You hereby acknowledge and agree that the processing, including the transfer of your Personal Data and other Clients' information (including the Personal Data), has been and will continue to be carried out in accordance with points 6 and 7 herein (and, where applicable, has been notified to the relevant authorities of the Member State where the Company is established or has its representative) and does not violate the relevant provisions of that Member State. | |
| 77 | 3.2 Client name and logo. The Client grants **Text** and its Affiliates a worldwide, royalty-free, non-exclusive right to use the Client's company name, logo, and other brand identifiers to identify the Client as a customer of **Text** and for related marketing and promotional purposes, including in customer lists, on **Text**'s Websites, in sales presentations, and in other marketing materials, subject to the Client's applicable brand guidelines. The Client represents that it has all rights and authority necessary to grant this authorization and may request that **Text** discontinue future use of its company name or logo by contacting **Text** at [support@text.com](mailto:support@text.com). Any such request will apply prospectively only and will not require **Text** to withdraw, recall, modify, or cease use of materials that were created, published, distributed, or committed to production or distribution before **Text** received the request. | |
| 84 | 78 | |
| 85 | 3.4. Profiling Activities. By engaging with us, you acknowledge and agree to our use of your Personal Data for profiling purposes involving automated methods, ensuring you receive the most pertinent information and features from the Engagements you select and combining the data you provide with our existing records. This enhances our advertising efforts, helping to refine offerings and keep you informed about updates relevant to Engagements you use. You can opt-out of profiling at any time by contacting [support@text.com](mailto:support@text.com). Please note, that revoking this consent might limit our ability to provide specific Engagements, potentially resulting in to the termination of our Agreement. | |
| 79 | 3.3 Cookies and other Tracking Technologies. Depending on how you interact with our Engagements, we, and our authorized service providers, may use cookies, pixels, local storage technologies, beacons, and similar technologies on our Websites, within or in connection with the Services, and on other websites, applications, or online properties where the Services are installed, integrated, embedded, or otherwise made available. On our Websites and other Text-controlled online properties, these technologies may be used to operate, secure and improve the applicable Engagements, remember preferences and settings; conduct analytics and research, understand and measure usage and engagement, personalize content and functionality, measure the effectiveness of communications and campaigns; measure the effectiveness of communications and campaigns; and support marketing and advertising activities, including providing or tailoring advertising based on browsing activities, interactions, preferences, and interests. Information collected through these technologies may be combined with other information we process about you, including information obtained through the Engagements or from other lawful sources, for the purposes described in this Privacy Policy. Within the Services\*\*,\*\* cookies and similar technologies are used primarily to operate, provide, secure, support, analyze, maintain, and improve the Services; authenticate users; remember settings; measure performance and usage; troubleshoot issues; and support product development and related operational purposes. **Text** does not use cookies or similar technologies within the Services to provide third-party advertising, conduct cross-site or cross-context behavioral advertising, or target an End User based on activity across unrelated Clients. Where cookies or similar technologies are deployed through the Services or on websites, applications, or other properties operated by a Client, the respective roles and responsibilities of **Text** and the Client depend on the nature and purpose of the processing. Where **Text** processes Personal Data on behalf of a Client, **Text** acts as a Data Processor or Service Provider, as applicable, and may process such information on behalf of the Client in accordance with the applicable Agreement, including the DPA. The Client remains responsible for determining the applicable purposes and legal bases for such processing and for providing any notices, obtaining any consents, establishing any other lawful basis, or any other measures required by applicable law for cookies, integrations, advertising technologies, or other third-party technologies that the Client enables, configures, or deploys in connection with the Services. Our authorized service providers and partners may also use or set cookies and similar technologies in connection with the Engagements. Certain third parties may process information for their own purposes as independent controllers, in which case their processing is governed by their own terms and privacy notices. Additional information about our use of cookies and similar technologies, including available privacy choices, is provided in our [Cookie Policy](https://www.livechat.com/legal/privacy-policy/legal/cookie-policy/) and, where applicable, through our consent management tools. | |
| 86 | 80 | |
| 87 | 3.5. Access to the Client URL. By sharing your website URL, including any data extracted from publicly available sources (such as website addresses provided during registration) within Services, you confirm that you have the necessary rights to share its content and data, and agree and acknowledge that **Text** may use, collect, and process publicly available data from your website for the purposes of providing and enhancing our Services, training Artificial Intelligence ("AI") models, improving the functionality and performance of the Services, and other legitimate business operations outlined in this Privacy Policy and the Agreement. | |
| 81 | 3.4 Feedback and attribution. Where a Client or an individual voluntarily provides feedback, comments, quotations, reviews, testimonials, case study materials, or other contributions ("Feedback"), **Text** may use such Feedback for product improvement, research, educational materials, case studies, testimonials, marketing materials, and other related business purposes. The Client authorizes **Text** and its Affiliates, subject to the Client's applicable brand guidelines, to reproduce, publish, distribute, adapt, create derivative works from, and publicly attribute the Feedback in any media, including on websites, in sales materials, social media, case studies, press releases, events, and investor materials. **Text** may also share Feedback-related materials with publishers, platforms, and service providers solely to prepare, publish, or distribute those materials. Where included in the Feedback, such attribution may identify the Client using its name, logo, or other brand identifiers in accordance with Section 3.2 and may identify an individual contributor by name, job title or role, image, likeness, or voice. Once Feedback has been voluntarily provided by or on behalf of the Client, the Client authorizes **Text** to exercise the rights described in this Section without further approval, unless otherwise agreed in writing with the Client. The Client represents that it has obtained and will maintain all rights, authorizations, consents, and permissions necessary to provide the Feedback and grant the rights described in this Section, including on behalf of its Users, and that such use does not infringe any third-party rights. Where an individual's consent is required by applicable law, the Client represents that it has obtained and will maintain the corresponding consent from the relevant individual. An individual may withdraw consent for future uses by contacting [support@text.com](mailto:support@text.com). Withdrawal will not affect materials created, published, distributed, archived, or committed to production before the request was received. | |
| 88 | 82 | |
| 89 | 3.6. The Client Responsibilities Regarding Personal Data. The Client is solely responsible for the processing of Personal Data (including but not limited to its transfer) in accordance with the relevant data privacy law, including obtaining necessary consents or having other valid legal basis for processing. The Client must obtain all necessary permissions and consents as may be required by any relevant data privacy law when collecting, storing, processing and transferring Personal Data via **Text** and its Sub-Processors. The Client ensures the accuracy, quality, and legality of Personal Data and the means by which the Client acquired them. Instructions given by the Client for Personal Data Processing must comply with relevant data protection laws. In addition, as a Data Controller, Client shall (a) as required by applicable law, provide notice to its End-Users, Authorized-Users, Guest-Users, as well as obtain their consent (if required) or have other legal basis for processing and transferring their personal data to **Text** and its Sub-Processors in line with Data Processing Addendum ("DPA"). | |
| 83 | 3.5 Login and Authentication Services. Certain Engagements may permit authentication via third-party identity providers, including enterprise identity providers, social login providers (such as Facebook Connect and Google Sign-In), OpenID providers, SSO services, and similar authentication services. These providers may share information with **Text** in accordance with your settings and the applicable provider's terms and privacy policy. Such information is processed solely to authenticate users, administer accounts, provide access to the Engagements, maintain security, and support the requested authentication functionality (including through Supporting Applications), and the operation of the applicable Engagements. Your use of such authentication services remains subject to the applicable terms and privacy policies of those providers. We do not control how these providers handle your information and encourage you to review their applicable policies before enabling such integrations. Specifically, where our Services access or use information obtained from Google APIs, such access and use will comply with the [Google API Services User Data Policy](https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements. You acknowledge and agree that the use of third-party authentication services is at your discretion and risk and remains subject to the applicable provider's terms and privacy practices. **Text** is not responsible for the acts or omissions of such third-party providers, including their processing of Personal Data. | |
| 90 | 84 | |
| 91 | 3.7. Access and Managing Your Personal Data. Individuals have the right to manage their Personal Data. Reach out to [support@text.com](mailto:support@text.com) (or via the support e-mail of the Services you use) for any data access, modification, copy, or deletion requests. If we can't remove certain data, we will inform you of the reasons. If you decide to discontinue our Services, you can request deactivation of your Services by emailing us at [support@text.com](mailto:support@text.com) (or via support e-mail of the Services you use). | |
| 85 | 3.6 Third-Party Integrations and Connected Services. The Engagements may rely on, integrate with, connect to, or otherwise enable the use of third-party tools, applications, software, embedded content, widgets, open-source components, websites, platforms, plug-ins, APIs, marketplaces, communication platforms, artificial intelligence providers, social media functionality, and other similar third-party technologies, whether selected by you or made available by us as part of the Services' experience, (collectively, "Third‑Party Integrations"). Third‑Party Integrations are provided for your convenience and operate independently from **Text** and remain subject to their own terms, privacy notices, and processing practices. Certain Engagements may include embedded media, social media functionality, interactive widgets, sharing tools, community features, or other third-party functionality that enables interactions with external platforms or services. Such functionality may collect technical information relating to your interactions with the Engagements, including browser information, IP address, pages visited, and other usage information, and may use cookies or similar technologies necessary for their operation. **Text** does not control and is not responsible for the availability, security, content, or privacy practices of Third-Party Integrations. Before enabling or interacting with Third-Party Integrations, users should review the applicable terms and privacy policies governing those services. When you enable or use Third-Party Integrations, information may be exchanged between the Engagements and the applicable third-party provider to facilitate the requested functionality. Any independent processing carried out by the applicable third-party provider is governed by that provider's own terms and privacy practices. | |
| 92 | 86 | |
| 93 | 3.8. Deleting Your Personal Data. Upon written request, **Text** will delete your Personal Data using a standard method accepted by **Text** and in accordance with **Text's** data retention policy, unless it is unworkable due to the purposes of processing or due to technical issues. The standard response time is 30 days, which may be extended in complex cases and we will inform you of any such extension. | |
| 87 | Legal stuff made easy | |
| 94 | 88 | |
| 95 | 3.9. Geo-Location data. **Text** may have access to your geo-location data as we collect and process IP addresses of all devices used for Engagements. Collecting and processing your geo-location data refers to mobile devices as well as computers. It happens regardless of whether you are a Client or a Non-Client. | |
| 89 | We use information to provide, operate, secure, maintain, support, improve, and develop our Engagements; comply with legal obligations; communicate with you; conduct marketing where permitted by law; conduct analytics, statistical analysis, and benchmarking; support research, innovation, artificial intelligence, and machine learning; administer feedback, events, and other participation; and personalize your experience where permitted by law. | |
| 96 | 90 | |
| 97 | 3.10. Communication. By participating in the Engagements, you agree to be contacted by us to receive electronic communications regarding your interactions with Engagements. You may opt-out of receiving these types of communications by adjusting the device settings anytime. Users who leave their contact details while accessing particular sections of our Website might receive additional messages not described above. | |
| 91 | We may use automated methods, including profiling, for personalization, recommendations, marketing, and advertising where permitted by applicable law. We do not use profiling to make decisions that have legal or similarly significant effects unless such processing is permitted by law and appropriate safeguards are in place. | |
| 98 | 92 | |
| 99 | 3.11. The Client logo. You give **Text** and its affiliates worldwide, royalty-free, non-exclusive and unlimited in-time consent to use your company name, logos, and other information to identify you as a Client and for marketing and promotional purposes, including **Text**'s websites and sales materials. | |
| 93 | On Text-controlled Websites and online properties, cookies and similar technologies may support analytics, personalization, marketing, and advertising. Within the Services, Text does not use cookies or similar technologies to provide third-party advertising, conduct cross-site or cross-context behavioral advertising, or target an End-User based on activity across unrelated Clients. | |
| 100 | 94 | |
| 101 | 3.12. Client's Authorized-Users, Guest-Users and End-Users data. **Text** may process data of Authorized-Users (individuals operating the Services), Guest-Users (individuals with access to specific features under your Services) and End-Users (individuals contacting you via the Services or interacting with your website integrated with or utilizing our Services) to facilitate your operation of the Services and its provision to End-Users. This information will be treated in line with the Agreement. The type of information (including Personal Data) we may receive includes a first name, last name, e-mail address, other contact details, chat content data and potentially other information (e.g., profile picture, network, username, user ID, age range, language, country). As such, **Text** requests all its Clients to inform their users of our Services' integration and, where necessary, to obtain any necessary permissions which the Client is obliged to perform on its own. Note that when End-Users interact with you using our Services and/or visit other sites integrated or utilizing the Services, your privacy policy governs the information collected instead of this Privacy Policy. However, this Privacy Policy does not apply to the services that our Clients provide to their End-Users. They have their own policies about the collection, use, and disclosure of the personal information of their End-Users. | |
| 95 | Third-Party Integrations operate under their own terms and privacy practices. More information about individual privacy rights is provided in Section 4. | |
| 102 | 96 | |
| 103 | 3.13. Links and Promotions. You may click through certain links or promotions that will enable you to purchase or use our Services provided by promotional partners or other sites or commerce providers. We may also partner with third parties to display advertising on our Website or to manage and serve our advertising on other sites and may share Personal Data with them for this purpose. Some of those entities may share with us certain information (including Personal Data) that you provide to them. By clicking through to those links or promotions, you agree to allow us to receive and use any shared information (including Personal Data), except credit card details (account number, expiration date) that you may provide to such entities, under the same terms as if you provided it to us directly. In addition, when you register for the Services, through our promotional partner, that partner may share your data with us (including Personal Data). For example, when you use an external social network (like your Facebook account) to log in to the Services or to interact with us in another way, you agree to allow us to receive and use any information (including Personal Data), from your social network profile and account (please see your social network's privacy policy or support documents for more information about sharing of information with connected accounts). You may share your information (including Personal Data) with other sites or entities that create professional marketing lists to receive special offers and promotions from their partners. Depending on their agreement with us and their privacy policy, these entities or sites may subsequently share your data with us (including Personal Data). **Text** has no responsibility and assumes no liability if another such entity (e.g., website or commerce provider) collects, uses, or shares any information (including Personal Data) about you in violation of its own privacy policy or the applicable law. | |
| 97 | ## 4\. Your Privacy Rights | |
| 104 | 98 | |
| 105 | 3.14. Children's personal data. We do not knowingly collect Personal Data from anyone under the age of 16. If you notice we collect and process Personal Data of anyone under the age of 16 unintentionally, please contact us at [support@text.com](mailto:support@text.com) (or via support e-mail of the Services you use). We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Privacy Policy by instructing their children never to provide Personal Data through our Engagements. | |
| 99 | 4.1 Requests Relating to Personal Data. Where **Text** processes Personal Data as a Data Controller, and subject to applicable law and verification of your identity, you may exercise the following rights you may contact us at [support@text.com](mailto:support@text.com): (i) access and obtain information regarding the Personal Data we process about you; (ii) request correction of inaccurate or incomplete Personal Data; (iii) request deletion of Personal Data, subject to applicable legal, contractual, security, operational, or regulatory retention requirements; (iv) object to or restrict certain processing activities; (v) withdraw consent where processing is based on consent, without affecting the lawfulness of processing conducted before such withdrawal; (vi) and request portability of Personal Data where required by applicable law. These rights are not absolute and may be subject to exceptions and limitations permitted or required by applicable law. Before responding to a request, **Text** may take reasonable steps to verify the identity of the individual submitting the request and to confirm that the request relates to Personal Data processed by **Text** in its capacity as a Data Controller. We will respond to verified requests within 30 days, subject to any extensions permitted by applicable law due to the complexity or number of requests, using a standard method accepted by **Text** and in accordance with **Text's** data retention policy. We may retain Personal Data where and to the extent that retention is necessary or permitted to comply with a legal obligation, establish, exercise, or defend legal claims, protect security and integrity, protect the rights, freedoms, or legitimate interests of **Text**, or others, or rely on another applicable legal exception. Where immediate deletion is not reasonably feasible due to the manner in which information is stored, including in secure backups, we will restrict further use of the information and delete or overwrite it in accordance with our standard retention and backup cycles, unless continued retention is required or permitted by applicable law. | |
| 106 | 100 | |
| 107 | 3.15. Cookie usage and other tracking technologies. By using our Engagements, you acknowledge and agree to our use of cookies and similar tracking methods, which help us make your experience better and understand how you use our Engagements. These technologies are used to ensure essential functionality, remember your preferences, improve your experience, and, in some cases, tailor ads to your interests, to gather certain information automatically upon your use or navigation of our Engagements or any sites where our Services are installed. We work with some third-party partners who may also set cookies on your device. Please note, we don't control these third-party cookies, and our Privacy Policy doesn't cover their services. You can learn more about how we use cookies and how to manage them in our [Cookie Policy](https://www.livechat.com/legal/cookies-policy/). Remember, if you limit the use of cookies, some features of our Engagements might not work as intended. For transparency, we and our authorized partners may use cookies and other similar tracking technologies, such as (but not limited to) pixels and web beacons, to gather information about users' (including Clients and Non-Clients) activities on Website and other sites where our Services are installed to ensure tailored advertising based on your browsing activities and interests. These tools allow us to see what content is useful to you and help us provide more of what you like. Although you might not see them, they work in a similar way to cookies but are directly embedded in our web pages. | |
| 101 | 4.2 Requests Relating to Client Personal Data. Where **Text** acts as a Data Processor, requests relating to Client Personal Data should generally be directed to the relevant Client. **Text** will assist the Client in responding to such requests as required by the applicable Agreement, including the DPA. | |
| 108 | 102 | |
| 109 | 3.16. Feedback and Attribution. Feedback and related contributions may include the Client's name, logos, and other brand identifiers, and you authorize **Text** and its Affiliates, subject to your brand guidelines, to reproduce, publish, distribute, adapt, create derivative works from, and publicly attribute such Feedback using those identifiers and, where included, an individual contributor's name, job title/role, image/likeness, and voice, to the extent permitted by applicable law, for business purposes in any media (e.g., websites, sales materials, social media, case studies, press releases, events, investor materials) without further approval once Feedback is provided, and to share such Feedback-related materials with publishers, platforms, and service providers solely to prepare, publish or distribute them. The Client represents and warrants that it has obtained, and will maintain, all rights, consents, and permissions necessary to grant the foregoing rights (including on behalf of its Authorized Users) and that such grant does not infringe any third-party rights. Where consent is required by law, this Section constitutes the Client's consent and the Client represents it has obtained and will maintain corresponding consents from individuals, who may withdraw consent by written notice to **Text**, which will apply to future uses, and **Text** is not required to recall, delete, reprint, or remove materials already printed, distributed, archived, or paid/placed. | |
| 103 | ## 5\. How We Disclose Information | |
| 110 | 104 | |
| 111 | 3.17. Web and Mobile analytics. We use both web and mobile analytics software, which allows us to better understand the functionality of our Services across various devices and platforms, allowing us to enhance user experience and improve performance. These analytics tools may record information such as how often you use our Website or application, the events that occur during your interactions, aggregated usage, geographical location, performance data, and the source which our Services was downloaded or accessed. We may link the information. We store within these analytics tools to Personal Data you submit within Engagements. | |
| 105 | 5.1 **Text** does not sell Personal Data for monetary consideration. This does not restrict disclosures to service providers, telecommunications carriers, or other authorized parties where necessary to provide the Engagements in compliance with applicable requirements, to respond to a complaint or investigation, protect legitimate interests, or otherwise as described in this Privacy Policy. | |
| 112 | 106 | |
| 113 | 3.18. Social media (features) and widget. Our Website includes social media features, enabling you to engage with content on social media platforms directly from the Website you are visiting. like the 'Facebook Like' button and widgets, a Twitter 'Share This' button, embedded content from YouTube, or interactive mini-programs that run on our Website. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing them. | |
| 107 | 5.2 Within the Text Group. We may share information with our Affiliates, subsidiaries, parent companies, and other entities under common control for purposes consistent with this Privacy Policy, including service delivery, internal administration, security, compliance, business operations, product development, customer support, analytics, and corporate governance. We may also disclose information in connection with an actual or proposed merger, acquisition, financing, investment, corporate reorganization, bankruptcy, sale of assets, or similar corporate transaction. Where appropriate, such disclosures will be subject to confidentiality obligations and applicable legal requirements. | |
| 114 | 108 | |
| 115 | 3.19. Comment system. In order to post comments on our Website (i.e. our blogs), you must sign in to Facebook, Twitter, Disqus, or Google, as we use social-media plugins to allow you to leave comments on our blogs. No Personal Data is tied to your posts. You subscribe to our blogs by providing your email address. We will only use this Personal Data to send you an email notification when new blogs have been posted and when users comment on a blog that you have previously commented on. We will not use this information for any other purpose. You have the opportunity to opt-out of our blog e-mails by using the 'unsubscribe' button. | |
| 109 | 5.3 Service Providers and Sub-Processors. We engage trusted service providers, contractors, professional advisors, subprocessors, and other authorized partners to support the operation of the Engagements. We may disclose Personal Data and other information to such providers where necessary for hosting, infrastructure, payment processing, communications and messaging delivery, telecommunications and network services, analytics, customer support, security, identity management, artificial intelligence capabilities, marketing, business operations, and other services necessary to operate our business. Where such providers process Personal Data on our behalf and where required by applicable law, they are contractually required to process information only on our instructions, implement appropriate safeguards, maintain confidentiality and security of the information entrusted to them. | |
| 116 | 110 | |
| 117 | 3.20. Login Integration Services. Depending on the Services you use, you may have the option to log in using third-party authentication providers, such as Facebook Connect, Google Sign-In, and other OpenID-based services. These services authenticate your identity and may give you the option to share certain Personal Data with us, including, but not limited to, your name, email address, or public profile information, to facilitate your access to the Services (for example, by pre-populating chat forms or enabling social features. Where applicable, we may use the Personal Data provided by Login Integration Services to support the operation, enable seamless integration of our Services, and user experience of our Services (including through Supporting Applications). Your use of these Login Integration Services is subject to the terms, privacy policies, and permissions settings of the respective third-party providers. We do not control how these providers handle your information and encourage you to review their applicable policies before enabling such integrations. Specifically, where our Services access or use information obtained from Google APIs, such access and use will comply with the [Google API Services User Data Policy](https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements. You acknowledge and agree that the use of Login Integration Services is at your discretion and risk, and we disclaim any liability for acts or omissions of such third-party providers, including with respect to their processing of Personal Data. | |
| 111 | 5.4 External Links. The Engagements may contain links to websites, applications, or services operated by third parties. This Privacy Policy does not apply to those third parties, and **Text** is not responsible for their content, security, or privacy practices. We encourage you to review the privacy notices of any third-party services before providing information to them. | |
| 118 | 112 | |
| 119 | 3.21. Third‑Party Services. The Services may rely on, integrate with, or allow you to connect to certain third-party tools, websites, software, open-source components, or applications, whether selected by you (e.g., via plug-ins, APIs, or Marketplace add-ons) or made available by us as part of the Services' experience (collectively, "Third‑Party Services"). These Third‑Party Services are made available for your convenience but operate independently and are governed solely by their own terms and privacy policies. Our Agreement does not apply to Third‑Party Services, and their inclusion does not grant you any rights beyond those expressly provided in this Agreement. Where required by law, you are responsible for obtaining any End‑User notices or consents before directing us to share data with any Third‑Party Services. | |
| 113 | 5.5 Disclosure to Public Authorities and Law Enforcement. We may disclose information where necessary to comply with applicable laws, regulations, court orders, governmental requests, or legal processes; establish, exercise, defend, or enforce legal rights; investigate suspected fraud, abuse, unlawful activity, or security incidents; protect the rights, property, safety, or security of **Text**, our Clients, users, employees, or third parties; or otherwise comply with applicable legal obligations. We will provide notice where required and permitted by applicable law. | |
| 120 | 114 | |
| 121 | 115 | Legal stuff made easy |
| 122 | 116 | |
| 123 | 1. Why We Process Your Data: we use your information, including personal details, to: | |
| 117 | We may disclose information within the Text group and to service providers, Sub-Processors, professional advisers, and other authorized parties where necessary for the purposes described in this Privacy Policy. Some third parties may process Personal Data independently under their own terms and privacy notices. | |
| 124 | 118 | |
| 125 | a) Provide and improve our Services, Website, Chat Widget and apps to keep them running smoothly and securely. This includes using your data for the Services' operation, innovation, security, legal reasons, and marketing. We may also anonymize or aggregate your data for research. | |
| 119 | We may also disclose or transfer information in connection with a corporate transaction, or where necessary to comply with applicable law, legal process or governmental requests, protect rights or security, investigate suspected unlawful activity, or establish, exercise or defend legal claims. | |
| 126 | 120 | |
| 127 | b) Profiling and Advertising: We use your data to show you relevant information, ads, and to keep you in the loop with our latest offers! You can opt out of this by contacting us. | |
| 121 | We do not sell Personal Data for monetary consideration. | |
| 128 | 122 | |
| 129 | 2. You can be sure that data processing complies with relevant data privacy laws. If you're handling personal data using our Services, make sure you're also playing by the rules, getting all the necessary legal bases such as consent, and keeping the data in check, since you share with us data of the people operating your Services and End-Users. | |
| 123 | ## 6\. How We Protect Information and How Long We Keep It | |
| 130 | 124 | |
| 131 | 3. Your data, your rules! Want to change or remove your personal info? Just let us know, and we'll help you manage it. | |
| 125 | 6.1 Security. **Text** will take reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and up to date. We use appropriate technical and organizational measures designed to protect information against loss, misuse, and unauthorized or unlawful access, disclosure, alteration, and destruction. These safeguards are designed to take into account the nature of the information processed, the risks associated with processing activities, applicable legal requirements, industry standards, and the evolving security landscape. While we implement appropriate safeguards, no method of transmission over the Internet or method of electronic storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of information processed through the Engagements. To the fullest extent permitted by applicable law, **Text** does not warrant that unauthorized access can always be prevented and is not responsible for incidents caused by circumstances outside its reasonable control. Where required by applicable law, we will notify affected individuals or the relevant Client of a Personal Data breach in accordance with applicable legal and contractual requirements. Where **Text** acts as a Data Processor, our security commitments are further described in the Agreement, including the DPA. | |
| 132 | 126 | |
| 133 | 4. Saying goodbye? Upon request, we'll delete your personal data, unless it's needed for the purposes we've told you about or we run into technical snags. | |
| 127 | 6.2 Retention. We retain your data for as long as necessary to fulfill the purposes for which it was collected and limit the storage period to the minimum necessary, unless a longer retention period is required or permitted by applicable law or the Agreement. Retention periods depend on the nature of the information, the Engagements involved, applicable legal requirements, contractual obligations, operational needs, and our role as a Data Controller or Data Processor. Retention periods may also reflect the need to maintain records of consents, permissions, communication preferences, opt-outs, suppression requests, communications, and related compliance records for as long as reasonably necessary to provide the Engagements, demonstrate compliance with applicable law or contractual requirements, manage communication preferences, or to establish, exercise, or defend legal claims. Where **Text** acts as a Data Processor, retention and deletion of Client Personal Data are governed by the Agreement and the Client's documented instructions. Where information is no longer required, we will delete, anonymize, or otherwise securely dispose of it, unless continued retention is required or permitted by applicable law. When we retain information is processed for the improvement orand development of our Engagements, or new products, or and features, we take steps to eliminate information that directly identifies you, and we **Text** uses aggregated, pseudonymized, anonymized, or de-identified information where reasonably possible and appropriate for the intended purpose, as described in Section 3.1(5), the information only to uncover collective insights about the use of our Engagements, not to specifically analyze personal characteristics about you. | |
| 134 | 128 | |
| 135 | **Text** respects your privacy and is committed to safeguarding the data you entrust to us. We neither share, sell, rent, trade, nor otherwise transfer your Personal Data to unrelated third parties, except as necessary to provide and support the Services, in accordance with the Agreement, to comply with the law, with your instructions, and certain other situations, as elaborated below: | |
| 129 | Legal stuff made easy | |
| 136 | 130 | |
| 137 | 4.1. Affiliates. **Text** retains the right to share your data, including Personal Data within your Services with our parent, subsidiary, affiliated, or successor companies. The protections of this policy apply to the information we disclose in these circumstances. If our company merges or its assets or operations are transferred, the involved entities will handle your Personal Data according to this Privacy Policy. We will notify you if any of these events occur by updating this Privacy Policy and, when feasible, through other methods. | |
| 131 | We use appropriate technical and organizational measures designed to protect information against loss, misuse, and unauthorized or unlawful access, disclosure, alteration, or destruction. No system or method of transmission can be guaranteed to be completely secure. | |
| 138 | 132 | |
| 139 | 4.2. Sub-Processors. **Text** holds the right to disclose and you hereby agree to the disclosure and transfer of your Personal Data and other information related to you to our authorized, trusted service providers to carry out specific business activities, e.g. hosting, credit card processing, security, Client/support services, conducting research and analysis, cloud computing, marketing and other related services. We share only what is necessary, bind them by confidentiality and appropriate safeguards' obligations. Upon request, we can provide you with a current list of entities which may have access to Personal Data within your Services. Some Sub-Processors may also process Personal Data on their own independent legal bases, as described in their terms/privacy policies. Where required, you are responsible for ensuring you have required legal basis, such as consent or notice for that processing. | |
| 133 | Where required by applicable law or the Agreement, we will provide notification of a Personal Data breach to affected individuals or the relevant Client. | |
| 140 | 134 | |
| 141 | 4.3. Third‑Party Services. Certain Third‑Party Services may automatically exchange, process, download or upload data, including Personal Data, in order to function. These services operate under their own terms and privacy policies, which govern your use of them and, where applicable, our independent arrangements with their providers. **Text** does not author, own, or control any Third‑Party Services. We disclaim all responsibility for any data, including Personal Data, collected or processed by such services, as well as any warranties or representations regarding their accuracy, availability, security, legality, performance or continued operation. You are solely responsible for determining the type and scope of any data, including Personal Data, you choose to disclose or make accessible to Third-Party Services. Where required by applicable law, you are also responsible for obtaining any notices, consents, or other legal bases from End Users prior to enabling such data sharing. Please note that this Privacy Policy does not apply to any Third‑Party Services, or to how they handle your information. Your access to, or use of them is at your own discretion and risk. | |
| 135 | We retain information only for as long as necessary for the purposes for which it is processed, or as otherwise required or permitted by applicable law or the Agreement. When information is no longer required, we delete, anonymize, or otherwise securely dispose of it, subject to applicable retention requirements and backup cycles. | |
| 142 | 136 | |
| 143 | 4.4. External Links. Our Services may direct you to external sites or services maintained by third parties, whose privacy practices may differ from ours. Though we may link to them, we don't control their content or privacy practices and have no responsibility for the privacy practices of such other sites run by other entities. We recommend reviewing their privacy policies when you visit external sites. Our Privacy Policy pertains solely to information collected by **Text** and does not extend to your interactions with other sites or services. | |
| 137 | ## 7\. International Transfer | |
| 144 | 138 | |
| 145 | 4.5. Disclosure to Public Authorities and Law Enforcement. **Text** may be required to disclose Personal Data and other information in response to lawful requests from public authorities, including for national security or law enforcement purposes; when complying with legal processes like subpoenas, government requests, court orders or government requests; to establish or exercise our legal rights or defend against legal claims; to uphold or defend our legal rights, ensure your safety or the safety of others, take action regarding any illegal activities or investigate potential fraud. Note that courts of equity, such as U.S. Bankruptcy Courts, or governmental authorities may, under certain circumstances, permit your Personal Data and other information to be shared or transferred to third parties (other than those described above) without your permission. We reserve the right to disclose your data, including Personal Data, in response to legal requests, to comply with applicable laws, or to prevent harm (in particular, in situations where you breach the Agreement, misuse funds, undertake other unlawful actions against us or others, or in the event of your fraudulent or illegal activity while interacting with us or using the Engagements). Notification to you will only be provided when legally required; otherwise, it will be at our sole discretion, following the specified rules governing disclosure herein. Disclosures are based on our Agreement with you or our legitimate interest in protecting our legal rights and those of others, compliance with legal obligations, and our legitimate interest in fulfilling legal obligations imposed by legal authorities. | |
| 139 | 7.1 **Text** operates globally and may process information in countries other than the country where the information was originally collected. Where Personal Data is transferred internationally, **Text** implements appropriate safeguards designed to protect such information in accordance with applicable data protection laws. Depending on the circumstances, these safeguards may include: the European Commission's Standard Contractual Clauses; the UK International Data Transfer Addendum; the EU-U.S. Data Privacy Framework; the UK Extension to the EU-U.S. Data Privacy Framework; the Swiss-U.S. Data Privacy Framework; or other lawful transfer mechanisms recognized under applicable law. | |
| 146 | 140 | |
| 147 | 141 | Legal stuff made easy |
| 148 | 142 | |
| 149 | You should know our promise: we take your privacy seriously. | |
| 143 | Text operates globally, so information may be processed in countries other than the country in which it was originally collected. Where Personal Data is transferred internationally, we use safeguards required or recognized by applicable law, including the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, the applicable Data Privacy Framework, or other lawful transfer mechanisms. | |
| 150 | 144 | |
| 151 | Following this Privacy Policy, we may share your data with our affiliated companies or during mergers. You'll be notified of such significant changes. | |
| 145 | ## 8\. Jurisdiction - specific rights | |
| 152 | 146 | |
| 153 | We share necessary data with trusted service providers, ensuring confidentiality and security. They're also committed to keeping your info safe. | |
| 147 | 8.1 European Economic Area, United Kingdom, and Switzerland. Individuals located in the European Economic Area ("EEA"), the United Kingdom, and Switzerland may have additional rights under applicable data protection laws, including the General Data Protection Regulation ("GDPR"), the Data Protection Act 2018, which encompasses the UK General Data Protection Regulation (UK GDPR), the Swiss Federal Act on Data Protection ("FADP"), and other applicable legislation. Subject to applicable law, such individuals may have the right to: request access to Personal Data; request correction of inaccurate Personal Data; request deletion of Personal Data; request restriction of processing; object to certain processing activities; withdraw consent where applicable; request data portability; and lodge a complaint with the competent supervisory authority. All collection, use, and disclosure of Personal Data described in this Privacy Policy apply equally to individuals in these regions. Where **Text** acts solely as a Data Processor on behalf of a Client, requests relating to Client Personal Data should generally be directed to the relevant Client. | |
| 154 | 148 | |
| 155 | In certain situations, when integrating with third-party offerings, you control the data you share. We may also share your data with external sites that you visit. We do not have control over third-party offerings or external sites; please review their terms and privacy policies. | |
| 149 | 8.2 California. Residents of California may have additional rights under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), subject to applicable exceptions and limitations. Depending on applicable law, California residents may have the right to know what categories of Personal Data we collect and process; access Personal Data; request deletion; request correction; request portability; opt out of certain processing where required by law; limit the use of certain sensitive Personal Data where applicable; and exercise their rights without unlawful discrimination. **Text** does not sell Personal Data for monetary consideration and does not use Personal Data within the Services for cross-context behavioral advertising involving End-Users. However, we do share certain information with advertising or analytics partners in connection with our Websites and our own marketing activities to provide you with tailored ads. California residents may opt out of such sharing at any time as described in our [Cookie Policy](https://www.livechat.com/legal/cookie-policy/). We disclose the categories of Personal Information listed in Sections 2 ("Data We Handle") and 5 ("How We Disclose Information") of this Privacy Policy. To exercise any of the rights above, or if you are a business Client that requires a CCPA/CPRA addendum to our Agreement, please email [support@text.com](mailto:support@text.com). We may need to verify your request before we can act on it. | |
| 156 | 150 | |
| 157 | We may also disclose data to comply with legal requests, protect rights and safety, or investigate fraud without prior notification in certain cases. | |
| 151 | 8.3 Data Controller. Where **Text** acts as a Data Controller, the entity responsible for the processing of Personal Data is Text, Inc., 101 Arch Street, 8th Floor, Boston, MA 02110, United States of America, unless otherwise stated in connection with a specific Engagement. | |
| 158 | 152 | |
| 159 | ## 5\. How We Secure Your Information And How Long We Keep Your Information | |
| 160 | ||
| 161 | 5.1. Security. **Text** will take reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We use appropriate technical and organizational measures to protect the Personal Data that we collect and process about you against loss, misuse, and unauthorized access, disclosure, alteration, and destruction. While processing Personal Data, we take into account the risk involved in the processing and the nature of the Personal Data. While we implement safeguards designed to protect your information, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. We cannot and do not guarantee or warrant the security of your Personal Data or any information you disclose or transmit to us. We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied, or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse, or alteration of Personal Data that may affect you so that you can take the appropriate actions. We may also occasionally contact you to determine that your Personal Data is still accurate and current. | |
| 162 | ||
| 163 | 5.2. Retention. We will only collect and retain your data which is relevant to the purposes for which it is collected, subsequently authorized by you, or if otherwise permitted by law or by the Agreement. This means that we retain your data for only as long as it is necessary to achieve the purposes for which it was collected and limit the storage period to the minimum necessary, unless a longer retention period is required or permitted by law, or the Agreement. When we retain information for the improvement and development of our Engagements or new products/features, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Engagements, not to specifically analyze personal characteristics about you. | |
| 164 | ||
| 165 | 153 | Legal stuff made easy |
| 166 | 154 | |
| 167 | We work hard to make sure your personal information is kept safe and accurate. We use various methods to protect your data from being lost, misused, or accessed without permission. | |
| 155 | Depending on where you are located and which privacy laws apply, you may have additional rights regarding your Personal Data. | |
| 168 | 156 | |
| 169 | Even though we have protections in place, we can't guarantee total safety, especially online, from intrusion by others, and we can't promise your data is 100% invincible. If someone does get unauthorized access and it affects data subjects, we'll let you know ASAP so you can take action, if needed. This is why you should also take standard precautions to protect your data, your credentials, and access to the Services. We'll notify you of significant data breaches as required. | |
| 157 | Individuals in the EEA, United Kingdom, and Switzerland may have rights under applicable European, UK, or Swiss data protection laws, including rights of access, correction, deletion, restriction, objection, portability, withdrawal of consent, and the right to lodge a complaint with a competent supervisory authority. | |
| 170 | 158 | |
| 171 | We only keep the information that's needed for its original purpose, what you've allowed us to use it for, or what the law or our Agreement with you permits. We won't hold onto it any longer than necessary, unless there are legal or contract reasons to do so. When we use your data to improve our Services or develop new ones, we remove any details that can directly identify you. We focus on general trends, not individual details about you. | |
| 159 | California residents may have additional rights under the CCPA/CPRA. Text does not sell Personal Data for monetary consideration and does not use Personal Data within the Services for cross-context behavioral advertising involving End-Users. We may share certain information with advertising or analytics partners in connection with our Websites and our own marketing activities, subject to applicable privacy choices. | |
| 172 | 160 | |
| 173 | Speaking about retention, we keep data only as needed, following your authorization or legal requirements. | |
| 161 | Text, Inc. also participates in the applicable EU-U.S., UK Extension, and Swiss-U.S. Data Privacy Framework programs as described above. | |
| 174 | 162 | |
| 175 | ## 6\. Data Transfer Compliance | |
| 163 | ## 9\. Additional Privacy Notices | |
| 176 | 164 | |
| 177 | **Text** operates globally, which means your data may be processed outside of your country. We take careful steps to legally transfer data across borders and ensure that your data receives suitable protection regardless of geography. We may need to transfer your Personal Data to our authorized partners outside of your jurisdiction, including outside the European Economic Area (EEA), USA, the United Kingdom, and in countries that are not subject to an adequacy decision by the European Commission and that may not provide for the same level of data protection as your jurisdiction. | |
| 165 | 9.1 Age Restrictions and Children's Privacy. The Engagements are not directed to individuals under the age of sixteen (16), or such higher minimum age as may be required under applicable law. **Text** does not knowingly collect Personal Data directly from children through the Engagements. If you believe that Personal Data relating to a child has been provided to **Text** without appropriate authorization, please contact us at [support@text.com](mailto:support@text.com) (or via support e-mail of the Services you use), so that appropriate action may be taken. | |
| 178 | 166 | |
| 179 | We will only transfer data to our authorized partners who need the information in order to provide services to or perform some activities, and only for a purpose consistent with this Privacy Policy or the Agreement. In each case, we take care to use appropriate safeguards to ensure your Personal Data remains protected. The safeguards we use are the European Commission-approved Standard Contractual Clauses, the UK International Data Transfer Addendum, Data Privacy Framework, and other appropriate legal mechanisms. | |
| 167 | 9.2 Corporate transactions. **Text** may disclose or transfer Personal Data and other information in connection with an actual or proposed merger, acquisition, financing, investment, reorganization, bankruptcy, sale of assets, or similar corporate transaction. Any successor or acquiring entity may process such information in accordance with this Privacy Policy, applicable law, and any additional notice provided in connection with the transaction. | |
| 180 | 168 | |
| 181 | We will not transfer your Personal Data originating in the EU, UK or Switzerland to them unless we ensure such authorized partner is obliged to provide appropriate level of privacy protection to your Personal Data as required by the Principles of the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF or the Swiss-U.S. Data Privacy Framework and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). | |
| 169 | 9.3 DPO and EU Representative. Text, Inc. has designated Text SA as its European Union representative to serve as a contact point between our Company and individuals or data protection authorities in the EU and in regard to our obligations under the GDPR. You can contact Text SA via email: [support@text.com](mailto:support@livechat.com). **Text**'s Data Protection Officer is Maciej Malesa. Correspondence may be sent to Text, Inc., 101 Arch Street, 8th Floor, Boston, MA 02110, United States of America, or by email to [support@text.com](mailto:support@livechat.com). | |
| 182 | 170 | |
| 183 | Legal stuff made easy | |
| 171 | 9.4 Data Privacy Framework Notice. Text, Inc. complies with the EU-U.S. Data Privacy Framework program ("EU-U.S. DPF"), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) collectively, the "Data Privacy Framework", as administered by the U.S. Department of Commerce, to the extent applicable. Text, Inc. has been certified by the U.S. Department of Commerce as adhering to the Data Privacy Framework Principles with respect to the processing of Personal Data received from the European Union, the United Kingdom (and Gibraltar), and Switzerland in reliance on the applicable Data Privacy Framework. If there is any conflict between the terms in this Privacy Policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, please click [here](https://www.dataprivacyframework.gov/s/). To view our certification page, please visit this [website](https://www.dataprivacyframework.gov/s/participant-search/participant-detail). | |
| 184 | 172 | |
| 185 | **Text** operates globally, and your data may be processed outside your country. We ensure that data transfer across borders complies with legal requirements. Your data may be transferred to our authorized partners outside your jurisdiction, including non-EU, non-UK, and non-Swiss countries. | |
| 173 | Text, Inc. has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive a timely acknowledgment of your complaint or if your complaint is not satisfactorily addressed, please visit the following [website](https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers) for more information and to file a complaint. This service is provided free of charge to you. | |
| 186 | 174 | |
| 187 | We make sure that when we move your data to other countries, it's still protected, no matter where it's processed. We use the SCCs approved by the European Commission, Data Privacy Framework and other measures. This includes sending your data to places outside the European Economic Area (EEA), the USA, and the UK, even countries with different data protection laws. | |
| 175 | Questions or complaints regarding our participation in the Data Privacy Framework should be directed to us at [support@text.com](mailto:support@livechat.com). If your DPF complaint cannot be resolved through the above channels, you may, under certain conditions, invoke binding arbitration for certain residual claims not resolved by other redress mechanisms. To learn more, click [the Data Privacy Framework website](https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf) | |
| 188 | 176 | |
| 189 | We won't transfer your EU, UK, or Swiss-originated Personal Data without being sure our authorized partners provide the required level of privacy protection as mandated by the EU-U.S. Data Privacy Framework, UK Extension, Swiss-U.S. Data Privacy Framework, and GDPR. | |
| 177 | The Federal Trade Commission has jurisdiction with enforcement authority over Text, Inc.'s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. | |
| 190 | 178 | |
| 191 | ## 7\. Processing Jurisdiction-Specifics | |
| 179 | The contact details for supervisory authorities in the European Union and the United Kingdom can be found on the following [websites](https://ico.org.uk/make-a-complaint/). | |
| 192 | 180 | |
| 193 | 7.1. GDPR regulation. **Text** complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (commonly known as The General Data Protection Regulation - GDPR). As such, we are responsible for the processing of Personal Data we receive under this Privacy Policy regarding providing the Service and subsequently transferring this data to its authorized partners. Furthermore, we also enable our users to remain in compliance with the GDPR, including the transfers of Personal Data from the EU, EEA, and Switzerland. | |
| 194 | ||
| 195 | 7.2. UK GDPR (United Kingdom Residents). In addition to our GDPR compliance, **Text** acknowledges and respects the data protection regulations within the United Kingdom. We are committed to safeguarding your privacy while adhering to the Data Protection Act 2018, which encompasses the UK General Data Protection Regulation (UK GDPR). All collection, use, and disclosure of Personal Data described in this Privacy Policy apply equally to individuals in the United Kingdom. | |
| 196 | ||
| 197 | 7.3. CCPA/CPRA (California Residents). We recognize the rights granted by the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA"). The ways we collect, use, and disclose "Personal Information" (as defined by CCPA/CPRA) are described throughout this Privacy Policy and apply equally to California residents. Under these laws you may, subject to verification of your identity and residency, exercise the following rights: (i) get a copy of the Personal Information we hold about you; (ii) correct any inaccurate personal information and have your personal information deleted if you believe any of your personal information is inaccurate or incomplete, unless an exception applies; (iii) opt-out of sharing - we do not sell Personal Information for monetary consideration, but we do share certain information with advertising partners to provide you with tailored ads. You may opt out of this sharing at any time (see our [Cookie Policy](https://www.livechat.com/egal/cookies-policy/) for details). We disclose the categories of Personal Information listed in Sections "Data We Handle" and "How We Share Information" of this Privacy Policy. To exercise any of the rights above, or if you are a business Client that requires a CCPA/CPRA addendum to our Agreement, please email [support@text.com](mailto:support@text.com). We may need to verify your request before acting on it. | |
| 198 | ||
| 199 | 181 | Legal stuff made easy |
| 200 | 182 | |
| 201 | 183 | Remember, depending on where you are, different rules might apply to how we handle your data, but we always aim to keep it safe and respect your rights: |
| 202 | 184 | |
| 203 | - We follow a set of rules called GDPR, which is all about protecting your Personal Data if you live in Europe or are a European citizen. | |
| 185 | \- We follow a set of rules called GDPR, which is all about protecting your Personal Data if you live in Europe or are a European citizen. | |
| 204 | 186 | |
| 205 | - For UK residents, we respect the UK's own data protection laws, called the UK GDPR, which is part of the Data Protection Act 2018, to protect your privacy. | |
| 187 | \- For UK residents, we respect the UK's own data protection laws, called the UK GDPR, which is part of the Data Protection Act 2018, to protect your privacy. | |
| 206 | 188 | |
| 207 | - If you're from California, we process your Personal Information under the CCPA and CPRA. | |
| 189 | \- If you're from California, we process your Personal Information under the CCPA and CPRA. | |
| 208 | 190 | |
| 209 | We don't sell your data but we do share it with trusted partners to show you ads. If you want out, check our Cookie Policy. | |
| 191 | We don't sell Personal Data for monetary consideration, but we may share certain information with trusted partners to show you ads. We do not use Client Personal Data or End User Personal Data within the Services for cross-context behavioral advertising. If you want out, check our Cookie Policy. | |
| 210 | 192 | |
| 211 | ## 8\. Notice | |
| 193 | We're part of a program called Data Privacy Framework, which ensures that we properly handle personal data from the European Union, the United Kingdom, and Switzerland. | |
| 212 | 194 | |
| 213 | 8.1. In compliance with the EU-US Data Privacy Framework Principles, **Text** commits to resolving complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, Swiss, and United Kingdom individuals with DPF inquiries or complaints should first contact: [support@text.com](mailto:support@livechat.com). | |
| 214 | ||
| 215 | **Text, Inc.**, has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive a timely acknowledgement of your complaint or if your complaint is not satisfactorily addressed, please visit the following [website](https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers) for more information and to file a complaint. This service is provided free of charge to you. | |
| 216 | ||
| 217 | If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. To learn more, click [here.](https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf) | |
| 218 | ||
| 219 | 8.2. If you, as an individual, have a complaint about how we have processed your Personal Data, please contact us at [support@text.com](mailto:support@livechat.com). We will do our best to resolve your complaint promptly and fairly. However, if you are not satisfied with our response, you have the right to complain to a supervisory authority. | |
| 220 | ||
| 221 | The contact details for supervisory authorities in the European Union and the United Kingdom can be found on the following [websites](https://ico.org.uk/make-a-complaint/). | |
| 222 | ||
| 223 | 8.3. Data gathering entity. Conducting its activity, under the business name of Text, Inc. with its office at 101 Arch Street, 8th Floor, Boston, MA 02110, United States of America, shall be the entity gathering Personal Data and other information. | |
| 224 | ||
| 225 | 8.4. Commercial transactions. Text, Inc. reserves the right to use its Privacy Policy, Personal Data, and other provided data and information for the benefit of an entity that has become either a dependent entity, an associated entity, or has come into being as a result of a merger or transformation of Text, Inc. | |
| 226 | ||
| 227 | 8.5. Contractual relationship. Registering for our Services means you're entering into a contractual agreement with Text, Inc. Therefore, this Privacy Policy, along with any other documents related to the Services you select, collectively make up the Agreement between you, the Client, and Text, Inc. | |
| 228 | ||
| 229 | 8.6. DPO and EU Representative. Text, Inc. has designated Text SA as its European Union representative to serve as a contact point between our Company and individuals or data protection authorities in the EU and in regard to our obligations under the GDPR. You can contact TEXT SA via email: [support@text.com](mailto:support@livechat.com). Our Data Protection Officer is Maciej Malesa Text, Inc. 101 Arch Street, 8th Floor, Boston, MA 02110, United States of America, email: [support@text.com](mailto:support@livechat.com). | |
| 230 | ||
| 231 | 8.7. Data Privacy Framework Notice. Text, Inc. complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Text, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Text, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. | |
| 232 | ||
| 233 | To learn more about the Data Privacy Framework (DPF) program please click [here](https://www.dataprivacyframework.gov/s/). | |
| 234 | ||
| 235 | To view our certification page, please visit this [website](https://www.dataprivacyframework.gov/s/participant-search/participant-detail). | |
| 236 | ||
| 237 | The Federal Trade Commission has jurisdiction with enforcement authority over Text, Inc., compliance with the EU-U.S. DPF, UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. | |
| 238 | ||
| 239 | Legal stuff made easy | |
| 240 | ||
| 241 | We're part of a program called Data Privacy Framework, ensuring that we handle personal data from the European Union, the United Kingdom, and Switzerland properly. | |
| 242 | ||
| 243 | 195 | If you want to learn more about this program, click here [https://www.dataprivacyframework.gov/s/](https://www.dataprivacyframework.gov/s/) |
| 244 | 196 | |
| 245 | 197 | You can also check out our certification page for more details. [https://www.dataprivacyframework.gov/s/](https://www.dataprivacyframework.gov/s/) |
| 246 | 198 | |
| 247 | The Federal Trade Commission keeps an eye on us to make sure we follow the rules of this program. | |
| 199 | The Federal Trade Commission keeps an eye on us to ensure we follow the program's rules. |