This Corporate SMS & Data Privacy Policy (“Policy”) governs the collection, storage, use, protection, and non-disclosure of personal contact information — including mobile telephone numbers and email addresses — submitted to our organization through any communication channel, enrollment form, or business engagement.

This Policy applies to all corporate contacts, prospective partners, clients, vendors, and any individual who voluntarily provides contact information to our organization for the purpose of business communication. By providing your contact information and consenting to communications, you acknowledge that our organization is bound by and operates in strict accordance with the commitments set forth herein.

This Policy is publicly available and reflects the standing operational standards of our organization with respect to contact data privacy. It is not a legal minimum — it is our actual practice.

We collect only the contact information that you voluntarily provide, limited to what is necessary for direct business communication. This may include:

• Full name and professional title
• Business organization or company name
• Mobile or direct telephone number
• Business or personal email address
• Preferred method of contact

We do not collect sensitive personal information beyond what is necessary for legitimate business communication purposes. We do not require financial data, government-issued identification numbers, health-related information, or any other sensitive personal categories through standard contact enrollment channels.

Any information collected is obtained directly from the individual to whom it belongs. We do not source, purchase, or acquire contact information from external data providers, brokers, or list vendors.

Contact information provided to our organization is used solely for direct, consensual, organization-to-individual business communication. Permitted uses include:

• Responding to inquiries, requests, or communications you have initiated
• Sending transactional or informational messages relevant to your business relationship with us
• Providing service updates, scheduling coordination, or project-related notifications
• Delivering communications that you have explicitly consented to receive at the time of enrollment

We will not use your contact information for purposes inconsistent with those stated at the time of collection without first obtaining your renewed and explicit consent. We do not engage in unsolicited bulk commercial messaging campaigns using contact information provided for business communication purposes.

All contact information collected by our organization is treated as strictly confidential corporate contact data. We hold this information in trust and are committed to the following non-disclosure principles without exception:

This confidentiality commitment applies unconditionally. Your contact information is not an asset that is monetized, licensed, exchanged, or used as consideration in any transaction. It exists solely to facilitate the direct business communication relationship you have chosen to establish with our organization.

Internally, access to contact information is restricted to authorized personnel with a documented, legitimate operational need. Access is logged, monitored, and subject to regular internal review.

Our organization operates an SMS communication program for direct business messaging with consenting contacts. The following terms govern participation in and management of that program.

5.1 — SMS Opt-In Consent

Enrollment in SMS communications is entirely voluntary and requires your explicit, affirmative consent obtained at the point of contact enrollment. Consent to receive SMS messages is never assumed, implied, or inferred from a business relationship alone. You will not receive SMS messages from our organization without having first provided documented consent.

Consent to receive SMS is not a condition of doing business with our organization. Declining SMS enrollment in no way affects your access to our services or the quality of our business relationship.

5.2 — Message Frequency & Content

Message frequency varies based on the nature and activity of your engagement with our organization. Messages are limited to content directly relevant to your business relationship with us. We do not transmit promotional, advertising, or commercial solicitation content via SMS to corporate contacts.

5.3 — Message & Data Rates

Standard message and data rates from your mobile carrier may apply to messages sent to or received from our organization. We are not responsible for any carrier charges assessed in connection with SMS communications.

5.4 — SMS Opt-Out & Removal

You may withdraw your consent to receive SMS communications from our organization at any time, at no cost, using either of the following methods:

Upon receipt of a valid opt-out request by either method, we will process your removal from SMS communications within a commercially reasonable timeframe, not to exceed five (5) business days. You may receive one final confirmatory message acknowledging the processing of your opt-out request. No further messages will be sent following confirmation.

5.5 — Suppression & Re-Enrollment

Once an opt-out is processed, your mobile number will be added to our internal suppression registry. Suppressed numbers will not be re-enrolled in SMS communications without your renewed, explicit, and separately documented written consent. The suppression registry is maintained independently of standard contact records to prevent inadvertent re-activation.

This prohibition applies regardless of the nature or relationship of the third party, including but not limited to:

• Corporate affiliates, subsidiaries, or parent organizations
• Joint venture or co-marketing partners
• Marketing vendors, advertising platforms, or promotional networks
• Analytics, data enrichment, or audience profiling services
• Data brokers, list aggregators, or contact database providers
• Any unrelated third-party entity regardless of stated purpose

SMS originator opt-in data represents a direct expression of personal consent and trust. We treat it as such. The protection of this data category is unconditional and is not subject to exception, business justification, or contractual arrangement with external parties.

In the event that any regulatory, legal, or judicial obligation requires disclosure of contact information, we will provide only the minimum information required by law, notify affected individuals to the extent permitted, and actively resist any overbroad disclosure request through all available legal means.

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your contact information from unauthorized access, disclosure, alteration, loss, or destruction. Our security practices include:

• Role-based access controls that restrict data access to authorized personnel with a documented operational need
• Encrypted transmission of contact data in transit using industry-standard protocols (TLS/HTTPS)
• Secure storage environments that are not publicly accessible or network-exposed without appropriate controls
• Internal access logging and audit trails for systems containing contact data
• Regular review and assessment of data handling practices to ensure continued operational compliance with this Policy

While we employ robust and continuously reviewed security practices, no data transmission or storage infrastructure can be guaranteed to be entirely immune to security incidents. In the unlikely event of a data security incident that materially affects your contact information, we will notify affected individuals as required by applicable law and communicate the nature of the incident, the data involved, and the steps being taken to address it.

We retain your contact information for as long as your business relationship with our organization remains active, and for a reasonable period thereafter as required for legitimate operational, legal, or compliance purposes. Retention periods are established in accordance with applicable law and internal data governance standards.

When contact information is no longer required for the purposes for which it was collected, it is securely deleted or irreversibly anonymized in accordance with our internal data retention schedule. We do not maintain contact records indefinitely as a matter of passive accumulation.

Contact information associated with an SMS opt-out will be retained in our suppression registry for the sole purpose of honoring and enforcing the opt-out request. This suppression record will not be used for any active communication or commercial purpose and will not be shared externally.

Subject to applicable law, individuals whose contact information is held by our organization have the following rights, which we are committed to honoring in good faith:

• Right of Access: You may request a copy of the contact information we hold about you and confirmation of how it is being used.
• Right of Correction: You may request the correction or updating of inaccurate, outdated, or incomplete information.
• Right of Deletion: You may request the deletion of your contact information from our active records, subject to any lawful retention obligations that may apply.
• Right to Restrict Use: You may request that we temporarily restrict the active use of your information while a correction or deletion request is being evaluated and processed.
• Right to Withdraw Consent: You may withdraw any previously granted consent to communications at any time without penalty, including SMS consent as described in Section 5.
• Right to Data Portability: Where technically feasible and legally applicable, you may request your contact data in a structured, commonly used, machine-readable format.

To exercise any of these rights, please contact our Privacy Officer directly using the contact information provided in Section 12. We will acknowledge all verified requests promptly and respond within a timeframe consistent with applicable legal requirements and the nature of the request.

Your contact information is collected solely to facilitate a direct, consensual business communication relationship. It holds no commercial value to our organization outside of that purpose. We do not participate in data marketplaces, behavioral advertising ecosystems, or any commercial exchange that involves the transfer of personal contact data as consideration.

This commitment is not contingent upon opt-out mechanisms or legal technicalities. It is an affirmative and unconditional organizational position.

We may update this Policy periodically to reflect changes in our internal practices, applicable law, or industry standards. The effective date displayed at the top of this document reflects the most recent revision.

For material changes — meaning changes that meaningfully alter the rights of contacts or the protections afforded to their data — we will provide direct advance notification to known contacts through their registered communication channel prior to the change taking effect. Material changes will not be applied retroactively without renewed consent where required.

Continued engagement with our communications following adequate notice of a Policy update constitutes acknowledgment of the revised terms. Individuals who do not wish to accept a material update may exercise their right of deletion or opt-out as described in this Policy.

For privacy-related inquiries, data access or deletion requests, opt-out requests submitted by email, questions regarding this Policy, or any concern about how your contact information is being handled, please contact our designated Privacy Officer.

Privacy contact information is maintained on our organization’s official website. All privacy inquiries will be acknowledged in a timely manner and handled with full confidentiality and professionalism. We take all privacy concerns seriously and are committed to resolving them fairly and transparently.

If you believe your data privacy rights have been violated, you also have the right to lodge a complaint with the relevant data protection authority or regulatory body in your jurisdiction.