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Twilio SMS Service — Privacy Policy

1. Introduction

This Privacy Policy describes how Joliez Agency collects, uses, stores, and protects your personal information when you use SMS messaging services powered by Twilio. This policy applies specifically to SMS communications and relates to our general Privacy Policy.

2. Information We Collect

When you opt-in to SMS services, we collect and process:

• Phone Number: Your mobile phone number provided during signup or account verification
• Email Address: Your email address as a fallback contact method
• Account Information: Your name, user ID, and account status on Joliez Agency portal
• Opt-In Preferences: Your choices for authentication, transactional, and promotional messaging
• Messaging Metadata: Message timestamps, delivery status, and engagement (opens, clicks)
• Device Information: Carrier name, device type, and operating system (for troubleshooting)
• Location Data: Approximate location inferred from phone number for carrier routing only

3. How We Use Your Information

We use your information for the following purposes:

• Authentication & Security: Sending OTP codes and verification messages to protect your account
• Portal Communications: Notifying you of booking status, casting opportunities, and application updates
• Operational Alerts: Sending emergency notifications about service disruptions or security issues
• Import Notifications: Alerting you when data imports or bulk updates affect your profile
• Promotional Messages: Sharing Joliez Agency news, exclusive opportunities, and special events (if opted-in)
• Service Improvement: Analyzing message engagement to optimize communication timing and content
• Compliance: Meeting legal, regulatory, or law enforcement requirements
• Support: Resolving service issues or responding to customer inquiries

4. Data Retention

• Active Account: Phone number and preferences retained while your account is active
• Message History: SMS logs retained for 90 days for compliance and troubleshooting
• Opt-Out Records: STOP/HELP requests maintained per carrier requirements for 18 months
• Account Closure: After account deletion, SMS history archived for 180 days then purged
• Legal Holds: Information retained longer if required by law or litigation

5. Data Sharing

We share your information with:

• Twilio (Service Provider): SMS delivery platform that processes your phone number and message content. Twilio is SOC 2 Type II certified and complies with GDPR, HIPAA, and other standards.
• Mobile Carriers: AT&T, Verizon, T-Mobile, Sprint, and other carriers that route your SMS messages. They receive only phone number and message routing data.
• Legal/Law Enforcement: Government agencies only when required by valid legal process (subpoena, court order)
• Service Partners: Third-party vendors providing analytics or support services (all are bound by NDAs)

We do NOT sell, rent, or distribute your phone number or SMS content to marketers, data brokers, or third parties for their independent marketing purposes.

6. Data Security

• Encryption in Transit: All SMS communications encrypted using TLS/SSL protocols
• Encryption at Rest: Phone numbers and message logs encrypted in secure databases
• Access Controls: Limited employee access to phone numbers; audit logging of all access
• Network Security: Firewalls, intrusion detection, and regular security scanning
• Twilio Security: SOC 2 Type II compliant infrastructure with 24/7 security monitoring
• Incident Response: Rapid response procedures for potential data breaches

7. Your Rights & Choices

• Access Your Data: Request a copy of your phone number and SMS preferences by emailing contactus@joliezagency.com
• Correct or Update: Change your phone number or preferences in your account settings anytime
• Delete Phone Number: Request removal of your phone number; transactional SMS still available via email fallback
• Opt-Out Promotional: Reply STOP to any SMS or disable in account settings
• Opt-Out All SMS (except auth): Contact support to disable all non-authentication SMS
• Do Not Track: We honor Do Not Track requests for SMS engagement analytics

8. State & Regional Privacy Rights

California (CCPA): You have the right to know, delete, and opt-out of sale of personal information. This policy describes these rights in detail.

European Union (GDPR): Your phone number is processed as personal data. You have the right to access, rectification, erasure, and portability. Legal basis for processing: Contractual necessity (authentication) and consent (promotional messages).

Other Jurisdictions: We comply with applicable state privacy laws including Virginia, Colorado, Connecticut, and Utah.

9. TCPA Compliance

• Your phone number is obtained with your express written consent via our signup form
• Authentication and transactional messages comply as "established business relationships"
• Promotional messages require separate prior express written consent (opt-in checkbox)
• You can revoke consent at any time by replying STOP or contacting support
• We maintain a do-not-call list and honor all opt-out requests within 2 business days
• Calls or texts to emergency numbers or with-held numbers are prohibited

10. International Transfers

Your information may be processed in the United States and other countries where Twilio and our partners operate. By consenting to SMS services, you consent to international data transfers. We ensure adequate safeguards are in place for all transfers (Standard Contractual Clauses, Privacy Shield equivalents, or adequacy determinations).

11. Children's Privacy

SMS services are not intended for individuals under 18. If you are under 18, you must have parental consent to use these services. We do not knowingly collect information from children under 13.

12. Third-Party Links & Services

SMS messages may contain links to third-party services. This privacy policy applies only to Joliez Agency SMS communications. Third-party services have their own privacy policies, and we are not responsible for their practices.

13. Policy Changes

We may update this policy periodically. Significant changes will be communicated via email or SMS notification. Your continued use of SMS services after changes constitutes acceptance of the updated policy.

14. Contact & Data Requests

For privacy concerns, data access requests, or to exercise your rights:

• Email: contactus@joliezagency.com
• Portal: Privacy settings available in your account dashboard
• Mail: Contact Joliez Agency support for mailing address
• Response Time: We respond to requests within 30 days or as required by law

15. Twilio's Privacy Framework

Our SMS services are powered by Twilio. For Twilio's full privacy practices, security certifications, and data processing agreements:

• Twilio Privacy Policy: twilio.com/legal/privacy
• Twilio Security: twilio.com/security
• Data Processing Agreement: Available upon request for enterprise customers
• Sub-processors: twilio.com/legal/subprocessors

16. Acknowledgment

By providing your phone number and consenting to SMS services, you acknowledge that:

• You have read this Privacy Policy
• You understand how your information will be used and shared
• You consent to data processing as described
• You understand your rights and how to exercise them

Questions? Contact support at contactus@joliezagency.com or visit the Get Scouted portal for additional resources.