1) Scope and application

This Privacy Policy explains how Smart Growth Services (“SGS,” “we,” “us”) collects, uses, discloses, and protects information when you access or use any SGS-branded, SGS-operated, or SGS-provided products and services (collectively, the “Service”).

The Service may be offered under different product names (including industry-specific systems) and may change over time. This Privacy Policy applies to all such offerings unless we expressly state otherwise in writing.

This Privacy Policy applies to:

·       Visitors to our websites

·       Prospective customers who contact us

·       Clients and authorized users who use the Service

It does not apply to third-party websites, products, or services that we do not control.

2) Definitions

“Client” / “you”: The business entity purchasing or using the Service.

“Authorized User”: An individual authorized by the Client to access the Service.

“End Customer”: Your customer, lead, or contact.

“Client Data”: Information submitted to the Service by or on behalf of the Client, including End Customer information.

“Third-Party Platforms”: Tools we connect to, configure, or rely on to provide the Service (e.g., CRM/automation platforms, SMS/email/telephony providers, payment processors, analytics providers, hosting providers, domain registrars).

3) Roles: SGS vs Client

3.1 Client is the sender and controller for marketing communications

When you use the Service to send SMS, emails, or other communications to End Customers, you (the Client) determine the purpose and content of those communications and are responsible for obtaining required consents and honoring opt-outs.

3.2 SGS processes Client Data to provide the Service

SGS processes Client Data on the Client’s behalf to provide, maintain, and improve the Service, including to configure automations, deliver messages, provide support, and troubleshoot issues.

4) Information we collect

We may collect the following categories of information:

4.1 Information you provide to us

·       Account and contact information (e.g., name, email, phone number, business name)

·       Billing information (e.g., payment method details; note that payment processing may be handled by a payment processor)

·       Support communications (e.g., emails, tickets, chat messages)

·       Onboarding details (e.g., business details needed for setup, verification, A2P registration)

4.2 Information collected automatically

·       Device and usage information (e.g., IP address, browser type, pages viewed, timestamps)

·       Log data and diagnostic data

·       Cookies and similar technologies (see Section 8)

4.3 Client Data (including End Customer information)

Clients may upload or input Client Data into the Service, which can include End Customer contact information and communication history.

5) How we use information

We use information for the following purposes:

·       Provide, operate, and maintain the Service

·       Set up and configure accounts, domains, phone numbers, email sending, and integrations

·       Process payments and manage billing

·       Provide customer support and respond to requests

·       Monitor, prevent, and address fraud, abuse, security incidents, and technical issues

·       Improve and develop the Service, including new features

·       Comply with legal obligations and enforce our agreements

6) How we share information

We may share information in the following circumstances:

6.1 Service providers and Third-Party Platforms

We may share information with vendors and Third-Party Platforms that help us provide the Service (for example, hosting providers, analytics providers, SMS/email/telephony providers, CRM/automation platforms, and payment processors).

6.2 Legal and compliance

We may disclose information if required to do so by law or if we believe disclosure is necessary to:

·       Comply with legal process

·       Protect rights, safety, and property of SGS, our Clients, End Customers, or the public

·       Investigate fraud, security, or technical issues

6.3 Business transfers

If SGS is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction.

6.4 With your direction

We may share information when you instruct us to do so, including when you connect Third-Party Platforms.

7) Data retention

We retain information for as long as necessary to provide the Service, comply with legal obligations, resolve disputes, and enforce agreements.

Client Data retention may depend on your subscription status, Third-Party Platform retention rules, and technical constraints. Clients are responsible for exporting and backing up their data.

8) Cookies and tracking

We may use cookies and similar technologies to operate our websites and understand usage.

You can control cookies through your browser settings. Disabling cookies may affect certain features.

9) Security

We use commercially reasonable administrative, technical, and organizational measures designed to protect information. However, no method of transmission or storage is 100% secure.

10) Your choices and rights

Depending on your location and applicable law, you may have rights to access, correct, delete, or restrict certain information.

To make a request, contact us at [email protected]. We may need to verify your identity and authority.

If you are an End Customer and you received communications from a Client using the Service, please contact that Client directly to exercise your rights or to opt out.

11) Children’s privacy

The Service is not intended for children under 13 (or under 16 where applicable). We do not knowingly collect personal information from children.

12) International data transfers

If you access the Service from outside the United States, your information may be processed in the United States or other locations where our vendors operate.

13) Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Continued use of the Service after changes become effective constitutes acceptance.

14) Contact

Questions about this Privacy Policy: [email protected]