SMS Policy

This Privacy Policy describes how Community.com, Inc. (“we,” “our,” or “us”) collects, uses, and otherwise processes personal data that you provide to us, or that we obtain or generate, to provide you with our messaging services, including our apps, features, software, and website (“Community”).

1. Our services

We issue unique phone numbers (or other communication accounts) (“Community Numbers”) to individuals and entities or their designees (collectively, “Community Leaders”). A list of promoted Community Numbers is available here. Community Leaders can use Community to message with the individuals who have agreed to message with them (“Community Members”).

Please also read our Terms of Service (“Terms”), which describe the terms under which you use Community and our Customer Terms, which applies to Community Leaders and related customers.

Our collection of information

We collect the following when you use Community:

Messaging Info

When you interact with Community Numbers (including by sending text messages to or calling a Community Number), we collect your messages, including message-related information (such as the phone number from which the message was sent, when the message was sent, the content of the message, any attached files or media, and data from interactive features such as reactions, effects, stickers, scheduling, polls, and payments). When calling a Community Number, we may also collect additional message information, such as the content of a voicemail, duration of the call, and keys pressed. When you interact with messages sent via Community, we collect information about those interactions too. We refer to all of this as “Messaging Info.”

Keep in mind that Community Leaders who receive your message info via Community can save a copy and use that information outside of Community. This includes any personal information you send in a message (for example, your address), so be careful with what you choose to share. If you don’t fully complete your registration with a Community Leader via Community, then some or all of your Messaging Info may not be delivered to them.

Contact Info

We may collect information, such as your name, email, phone number, and demographic information such as your date of birth, gender identity, location, or interests (collectively, “Contact Info”) from you when you register with Community or from a Community Leader. Once you register your information on Community, you may be able to connect to additional Leaders without reentering your Contact Info again each time. If you start a conversation with a Community Leader from a supported website or Internet-based messaging service, the required Contact Info and signup process may vary (e.g., the registration process may be integrated into their website or email).

Member Info

We or the Leader may analyze your activities (including your Contact Info, Messaging Info, and imported data) and generate insights about you (“Member Info”). For example, if you tell a Community Leader that your favorite ice cream flavor is chocolate, the Community Leader may tag you as a “chocolate lover.” Such insights may be manually or automatically generated on Community or imported by Community Leaders from outside of Community. Community Leaders may be able to save or sync their Community address book for use outside of Community, which may include your Contact Info and Member Info.

Leader Info

To sign up as a Community Leader, you need to provide intake information and/or set up a Community account. This may involve your name, email address, phone number, business information, and other information. Through that account, you may also provide email addresses and other login information for additional authorized users for the account. You may customize your account by providing a profile name, profile picture, bio, social media handles, automated responses, branded images, and voicemail messages. If you integrate your Community Leader account with another service, we may receive information from that integration, such as your business information, information about your contacts, or financial information. This includes, for example, syncing your address book, your customer or marketing platform, or other data source. You can disconnect your integrations at any time, which will stop syncing Community with that service going forward (existing data may remain on Community). Collectively, we refer to this information associated with a Community Leader’s account as “Leader Info.”

Technical Info

When using Community, including registering to become a Community Member or a Community Leader when using our apps and website, clicking on links or media in messages sent via Community, or using Leaders’ online properties that embed our tags or forms, we collect Internet, electronic activity, and other information automatically from the devices and browsers that you use and from the messages that you send (collectively, “Technical Info”). This includes information about the type of device and operating system you use, your phone number, your IP address and location, cookie and device identifiers, the type and version of browser you use, app version, and your ISP or wireless carrier. We may also collect information about your location, such as by using your IP address to determine your approximate location. When using our apps and website as a Community Leader, we also collect information about the links you send or click on, pages you view, other information about how you use Community, and other standard server log information.

Payment Info

In certain situations, you may provide us or our payment processors with payment information, such as your credit or debit card number, card expiration date, CVV code, and billing address.

Correspondence

When you contact our customer support or sales teams, participate in one of our surveys, contests, or promotions, or communicate with us in any other way, we’ll collect whatever information you volunteer or that we need to resolve your question.

Other Info

We may also receive or sync information about you from other sources, including from Community Members, Community Leaders, third-party services, partners, and organizations. We may aggregate or de-identify the information described above. Aggregated or de-identified data (meaning data that cannot reasonably be tied to you or used to identify you) is not subject to this Privacy Policy.

3. Our use of information

We use the information described above for the following business purposes:

to manage and promote Community Numbers, onboard people to Community, and enable messaging with Community Leaders;
to operate the Community platform for Community Leaders, including by offering our websites and apps, analyzing Messaging Info and Contact Info, automating and scheduling messages, and integrating with external systems and data;
to market Community to potential and current Community Members and Community Leaders;
to otherwise develop, operate, improve, deliver, promote, maintain, and protect Community services (including troubleshooting, data analytics, testing, research, statistical and survey purposes) ;
to send you communications and respond to your communications (for example, we may use email to respond to support inquiries or to share information about Community);
to manage our relationship with you (including providing you with the information, products and services that you request from us); and
to keep Community and our users safe and secure, to enforce our Terms and other usage policies, to comply with legal requirements, and to protect or exercise our legal rights or defend against legal claims.

4. Our disclosure of information

We may share the information described above in the following ways:

With Community Leaders. We may share your information with the Community Leaders you are interacting with via Community. Community Leaders may be able to save or sync copies of their Community address book for use outside of Community, which may include Contact Info and Messaging Info. The information practices of Community Leaders are not covered by this Privacy Policy. Before signing up to message with a Community Leader via Community, we encourage you to review that Community Leader’s privacy policy.
With Community Members and the general public. If you are a Community Leader, we may share your account information (such as your Community Number, profile name, profile picture, branded images, and voicemail message) and messages with Community Members and the general public.
With vendors and service providers. We may share your information with third-party vendors and service providers that provide services to us, such as telecommunications companies or internet platforms that process and deliver messages, the cloud platforms and services we use to host and process data, online platforms where we deploy our services, the marketing/ad platforms we use to acquire users, data analytics software, security and debugging services, communication tools, our payment and billing processors, content moderation tools, website hosting software, research and survey tools, third party auditors, and data management tools.
With corporate affiliates. We may share your information with our corporate affiliates.
In business transfers. We may share information about you as part of a merger or acquisition. If we are involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.
For legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Community.com, Inc. and our affiliates, users, and the public.
With your consent. If you consent, we may also share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

If you access third-party services via Community, these third-party services may be able to collect information about you, including information about your activity on Community, in accordance with their own privacy policies.

5. Our use of cookies

When you use Community, we use cookies, pixel tags, local storage, and other similar technologies (collectively, “cookies”), including third-party cookies, to collect information from your browsers or devices. By using Community, you consent to our use of cookies and similar technologies and our cookie policy. You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). If you choose to refuse, disable, or delete these technologies, some of the functionality of Community may no longer be available to you.

6. Your rights & choices

If you are a Community Member and you want to stop receiving text messages from a particular Community Number, message “STOP” (case insensitive) to their Community Number. You can later send the message “START” (case insensitive) to their Community Number to start receiving their messages again. As a Community Member, you can also view, update, and delete most of your personal information on Community by texting “HELP” to the Community Number and clicking on the link to your member portal. You can also easily unsubscribe from Leaders using this method. If you want to stop receiving messages from all Community Numbers, email privacy@community.com. Note: if you unsubscribe from a Community Leader’s messages, they won’t be able to send you additional messages via Community, but we and they may still have your information.

You can delete your information by emailing privacy@community.com. You may also be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, and to request access to, rectification, erasure, and portability of your information or more information about our information practices. Requests should be submitted in writing by emailing us at privacy@community.com. We will comply with your requests as required by applicable law. Keep in mind that Community Leaders may still retain copies of your information, like your Contact Info and Messaging Info, even after you have deleted the information from Community. If you want a Community Leader to delete your information, you will need to contact them directly. Review that Community Leader’s privacy policy to learn more.There may be legal requirements for us to retain your information, for instance if we receive valid legal process asking us to preserve data or if we are investigating potential violations of our Terms.

You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). If you choose to refuse, disable, or delete these technologies, some of the functionality of Community may no longer be available to you.

7. California privacy disclosures

If you are a California resident, the California Consumer Privacy Act (“CCPA”) permits you to request that we disclose to you the following information covering the past twelve months: the categories of personal information we collected about you and the categories of sources from which we collected such personal information; the specific pieces of personal information we collected about you; the business or commercial purpose for collecting or selling (if applicable) personal information about you; the categories of third parties with whom we shared personal information about you; the categories of personal information about you that we sold and the categories of third parties to whom we sold such personal information (if applicable); and the categories of personal information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or disclosed such personal information (if applicable). Additionally, you may request that we delete personal information we have collected from you as defined under the CCPA.

You can use the tools described in “Your Rights and Choices” or email us at privacy@community.com to exercise your rights under the CCPA. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Depending on your request, we may ask you to take steps to verify your identity, such as by texting us from the phone number you used when signing up and/or providing additional information. We will not discriminate against you for exercising your rights and choices. If we receive your request from an authorized agent purporting to act on your behalf, we will ask the agent to provide proof that it has valid written authority to submit requests on your behalf, and we may ask you to verify your identity directly with us and to confirm that you provided such agent with power of attorney.

We collect and disclose personal information for business purposes as follows:

Statutory category of personal information (PI) (Cal. Civ. Code § 1798.140)	Collected	Disclosed for a Business Purpose	Examples
Identifiers	Yes	Yes	Contact Info, correspondence info, and leader info as described above
California customer records information	Yes	Yes	Contact Info, correspondence info, and leader info as described above
Characteristics of protected classifications under California or federal law	Yes	Yes	Age, gender, and other information collected on Member registration
Commercial information	Yes	Yes	Leader info and Member Info, as described above
Biometric information	No	n/a	n/a
Internet or other electronic network activity information	Yes	Yes	Technical info as described above
Financial information	Yes	Yes	Payment Info from Leaders, which may be shared with our payment processing vendors
Geolocation information	Yes	Yes	We collect location information during Member registration; Member Info as described above
Audio, electronic, visual, thermal, olfactory, or similar information	Yes	Yes	Media shared via Community, voicemails, branded images that Leaders upload to their account
Professional or employment-related information	Yes	Yes	Leaders may have multiple accounts, and we may know that the accounts are employed by the Leader
Education information	Yes	Yes	A school Leader account may collect educational info and discuss educational topics
Inferences from the above-listed information	Yes	Yes	Member Info as described above

In the past 12 months, we have not sold your personal information to third parties. We have shared your information with third parties with Community Leaders at your direction and for business purposes as described in the table above. When personal information is collected, we collect it from the sources described in the “Our collection of information” section above. The personal information is used for the purposes described in the “Our use of information” section above. When personal information is disclosed for a business purpose, we disclose it for the purposes described in the “Our disclosure of information” section above.

Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

8. European privacy disclosures

If you are an individual in the European Economic Area, the UK, or Switzerland, please read this section, which provides additional information applicable to you.

We collect and process information about you only where we have legal bases for doing so under applicable laws in your country. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:

we need it to provide you with our services consistent with our Terms, including to operate Community, provide customer support and personalized features, and to protect the safety and security of Community;
it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to promote Community and to protect our legal rights and interests;
you give us consent to do so for a specific purpose;
where the processing is necessary to protect the vital interests of an individual;
the processing is necessary for the performance of a task
we need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. If we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using Community.

When we share information of customers in the European Economic Area, the UK, or Switzerland, we make use of the European Commission-approved standard contractual data protection clauses (a copy of which can be obtained by emailing us at privacy@community.com), or other appropriate legal mechanisms to safeguard the transfer. Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.

Individuals in the EEA, UK or Switzerland have the rights described above in the “Your rights & choices” section, and may exercise those rights by contacting us as provided in the “Your rights & choices” section. You may lodge a complaint with a supervisory authority if you believe our processing of your information is unlawful.

9. International transfers

By using Community and providing us with information, you understand and agree that we may transfer and store your information on servers located outside your resident jurisdiction. Where permitted by applicable law, to the extent you are a resident of a country other than the United States, you consent to the transfer of such data to the United States for processing by us in accordance with this Privacy Policy. Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to your home country.

10. Changes to this privacy policy

We may modify this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Last updated” date above and post the new Privacy Policy on community.com. If we make any changes that materially change the ways we process or protect your information, we will provide additional notification of the changes as required by applicable law.

11. Our contact information

You can reach us at Community.com, Inc, 1547 9th street, Santa Monica CA 90401. If you have any questions about this Privacy Policy or our practices, please email us at privacy@community.com.

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