Privacy Policy

Last Updated: February 3, 2026

1. Introduction

This Privacy Policy applies specifically to our SMS messaging program and describes:

• What personal information we collect when you opt-in to SMS alerts
• How we use and protect your information
• Your rights regarding your personal information
• How to contact us with privacy questions or concerns

By opting into our SMS program, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with our practices, please do not opt-in to the program.

2. Information We Collect

2.1 Information You Provide Directly

When you opt-in to our SMS program, we collect:

Information Type	Purpose
Mobile Phone Number	Required to send SMS messages to you
Email Address	Used for account management and alternative contact
Consent Timestamp	Records when you provided consent (compliance requirement)
Opt-in/Opt-out Status	Tracks your subscription preferences

2.2 Information Collected Automatically

When you interact with our SMS messages, we may automatically collect:

• Message Delivery Status: Whether messages were successfully delivered
• Message Interaction Data: Whether you clicked links in messages (if applicable)
• Carrier Information: Your mobile carrier name
• Device Information: Device type and operating system (when available)
• Response Data: Your replies to our messages (e.g., STOP, HELP commands)

2.3 Information We Do NOT Collect

We do not collect:

• Precise geolocation data through SMS
• Contents of your other text messages
• Your contact list or address book
• Financial information (credit cards, bank accounts)
• Social Security numbers or government IDs

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Primary Uses

• Send SMS Messages: Deliver marketing, promotional, and transactional messages you've opted to receive
• Manage Your Subscription: Process opt-ins, opt-outs, and subscription preferences
• Provide Customer Support: Respond to your questions and support requests
• Comply with Legal Obligations: Maintain records required by TCPA, FCC, and other regulations

3.2 Secondary Uses

• Service Improvement: Analyze program performance and improve message content and timing
• Fraud Prevention: Detect and prevent fraudulent activity and abuse
• Analytics: Generate aggregated, anonymous statistics about program engagement
• Internal Business Purposes: Conduct internal research and business planning

3.3 Legal Basis for Processing (GDPR)

If you are located in the European Economic Area, our legal basis for processing your information is:

• Consent: You have provided express consent to receive SMS messages
• Contract Performance: Processing is necessary to provide the service you requested
• Legal Obligation: Compliance with applicable telecommunications laws
• Legitimate Interest: Improving our services and preventing fraud

4. Information Sharing and Disclosure

4.1 We Do NOT Sell Your Information

DM18 Marketing Digital does NOT sell, rent, or trade your phone number or personal information to third parties for their marketing purposes.

4.2 Service Providers

We may share your information with trusted third-party service providers who help us operate the SMS program, including:

• SMS Platform Providers: Companies that facilitate message delivery (e.g., Twilio, Bandwidth, MessageBird)
• Data Storage Providers: Cloud hosting and database services
• Analytics Providers: Services that help us analyze program performance

These service providers are contractually required to:

• Use your information only to provide services to us
• Protect your information with appropriate security measures
• Not use or disclose your information for their own purposes

4.3 Legal Requirements

We may disclose your information when required by law or in response to:

• Valid legal process (subpoenas, court orders, search warrants)
• Government or regulatory requests
• Law enforcement investigations
• Protection of our legal rights and safety
• Prevention of fraud or illegal activity

4.4 Business Transfers

If DM18 Marketing Digital is involved in a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the successor entity. You will be notified of any such change via SMS or email.

4.5 With Your Consent

We may share your information for other purposes with your express consent.

5. Data Retention

5.1 Active Subscribers

While you are an active SMS subscriber, we retain your information to provide the service.

5.2 Opt-Out Records

We retain opt-out records indefinitely. This is required by TCPA regulations to ensure we never send messages to numbers that have opted out, even if those numbers are later reassigned to new subscribers.

5.3 Deletion Requests

If you request deletion of your personal information:

• We will delete your phone number and email address within 30 days
• We will retain your opt-out status permanently (compliance requirement)
• We may retain anonymized or aggregated data that cannot identify you
• We may retain information necessary for legal compliance or dispute resolution

5.4 Inactive Accounts

If you have not received messages for 24 months due to inactivity, we may delete your contact information while retaining your opt-out status.

6. Security Measures

We implement industry-standard security measures to protect your information:

6.1 Technical Safeguards

• Encryption: Data encrypted in transit using TLS/SSL protocols
• Secure Storage: Data stored in encrypted databases
• Access Controls: Role-based access restrictions
• Authentication: Multi-factor authentication for system access
• Monitoring: Continuous security monitoring and logging

6.2 Organizational Safeguards

• Employee Training: Regular privacy and security training
• Confidentiality Agreements: All personnel sign confidentiality agreements
• Vendor Management: Due diligence on third-party security practices
• Incident Response: Procedures for responding to data breaches

6.3 Security Limitations

Important: No method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. SMS messages are not encrypted end-to-end and may be vulnerable to interception.

7. Your Rights and Choices

You have the following rights regarding your personal information:

7.1 Right to Opt-Out

You can stop receiving messages at any time by texting STOP, UNSUBSCRIBE, CANCEL, END, or QUIT. Your opt-out will be processed immediately.

7.2 Right to Access

You can request a copy of the personal information we hold about you. Contact us at supportdm18marketing@camburatomico.com with your request.

7.3 Right to Correction

If your information is inaccurate or incomplete, you can request that we correct it. Contact us with updated information.

7.4 Right to Deletion

You can request deletion of your personal information (subject to legal retention requirements for opt-out records). We will process deletion requests within 30 days.

7.5 Right to Data Portability

You can request an export of your personal information in a machine-readable format (JSON or CSV).

7.6 Right to Object

You can object to certain processing of your information, such as use for analytics or marketing purposes.

7.7 How to Exercise Your Rights

To exercise any of these rights, contact us at:

• Email: supportdm18marketing@camburatomico.com
• Subject Line: "Privacy Rights Request"
• Include: Your phone number, email address, and specific request

We will respond to all requests within 30 days (or as required by applicable law).

8. California Privacy Rights (CCPA/CPRA)

8.1 Information We Collect (California Categories)

Category	Examples	Collected?
Identifiers	Phone number, email address	YES
Commercial Information	Subscription status, message history	YES
Internet Activity	Link clicks (if applicable)	Limited
Geolocation Data	Precise location	NO
Sensitive Personal Information	SSN, financial data, health data	NO

8.2 Sale and Sharing of Personal Information

We do NOT sell or share your personal information for cross-context behavioral advertising.

• Sale: We have NOT sold personal information in the past 12 months
• Sharing: We have NOT shared personal information for cross-context behavioral advertising

8.3 Your California Rights

California residents have the right to:

• Know: Request disclosure of personal information collected, used, disclosed, and sold
• Delete: Request deletion of personal information (subject to exceptions)
• Correct: Request correction of inaccurate personal information
• Opt-Out of Sale/Sharing: While we don't sell or share, you can opt-out if practices change
• Limit Use of Sensitive Information: We don't collect sensitive personal information
• Non-Discrimination: We will not discriminate against you for exercising your rights

8.4 How to Exercise California Rights

California residents can submit requests by:

• Email: supportdm18marketing@camburatomico.com
• Subject Line: "California Privacy Rights Request"

We will verify your identity before processing your request. We will respond within 45 days (extendable by an additional 45 days if necessary).

8.5 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. The agent must provide:

• Written authorization signed by you
• Proof of their identity

8.6 Do Not Sell My Personal Information

While we do not sell personal information, California residents can use this link to learn more: Do Not Sell My Info

9. Children's Privacy

Our SMS program is not intended for individuals under 18 years of age.

• We do not knowingly collect information from anyone under 18
• You must be 18 or older to opt-in to our SMS program
• If we discover we have collected information from someone under 18, we will delete it promptly
• Parents or guardians who believe we have collected information from a minor should contact us immediately

10. International Users

Our SMS program is primarily intended for users in the United States.

10.1 Data Transfers

Your information may be transferred to and processed in the United States or other countries where our service providers operate. These countries may have different data protection laws than your country of residence.

10.2 European Economic Area (EEA) Users

If you are located in the EEA, you have additional rights under GDPR, including:

• Right to withdraw consent at any time
• Right to lodge a complaint with a supervisory authority
• Right to restrict processing in certain circumstances

11. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements.

11.1 Notification of Changes

When we make material changes, we will notify you by:

• Sending an SMS message to your registered phone number
• Sending an email notification
• Posting a notice on our website
• Updating the "Last Updated" date at the top of this policy

11.2 Continued Use

Your continued participation in the SMS program after changes are posted constitutes acceptance of the updated Privacy Policy. If you do not agree with the changes, you may opt-out by texting STOP.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

12.1 Complaints

If you believe we have not adequately addressed your privacy concerns, you have the right to:

• File a complaint with us: Email us with details of your concern
• Contact the FCC: Federal Communications Commission (for TCPA complaints)
• Contact the FTC: Federal Trade Commission (for consumer protection issues)
• Contact your State Attorney General: For state privacy law violations
• EEA Residents: Lodge a complaint with your local data protection authority

Thank you for trusting DM18 Marketing Digital with your personal information. We are committed to protecting your privacy and providing transparency about our practices.