SMS Privacy Policy

Introduction

NeuroFinancial Inc. ("we," "us," or "our") operates NeuroFin, a SaaW business automation platform. Registered business users send SMS messages, which our AI processes to create structured business records. We are committed to protecting the privacy and security of information collected through our SMS messaging services. This SMS Privacy Policy explains how we collect, use, disclose, and protect SMS-related information.

Information We Collect

Client Business Information

When businesses sign up for our SMS services, we collect:

• Business name, address, and contact information
• Owner/operator name and email
• Business phone number(s)
• Business type and industry
• Payment information (processed securely through third-party payment processors)
• Account credentials (username, encrypted password)

End-Customer SMS Information

Our client businesses use our platform to manage their customer SMS communications. Information they input includes:

• Customer names
• Phone numbers
• Natural language task requests (unstructured text)
• AI-generated business records (tasks, invoices, events, etc.)
• Submission timestamps
• Confirmation message content
• SMS opt-in consent status and timestamp
• SMS opt-out status and timestamp
• Message delivery statistics

Automated SMS Data

We automatically collect SMS-related technical information:

• Message delivery status (delivered, failed, pending)
• Carrier information
• Opt-out keyword responses (STOP, UNSUBSCRIBE, etc.)
• Message timestamps
• SMS usage metrics per client business

How We Use SMS Information

Platform Operations

• Send one-time password (OTP) verification codes for account authentication
• Process inbound SMS requests from registered users
• Generate AI-powered business records from natural language
• Deliver confirmation SMS with task summaries
• Maintain two-way conversational messaging
• Process opt-in and opt-out requests automatically
• Maintain suppression lists to honor opt-out preferences
• Provide SMS delivery reports to client businesses
• Send administrative communications about SMS service status

Compliance and Security

• Maintain SMS opt-in/opt-out compliance records (TCPA)
• Prevent fraud and abuse of SMS services
• Enforce our SMS usage policies
• Comply with telecommunications regulations
• Respond to legal requests related to SMS communications

Service Improvement

• Analyze SMS delivery performance and reliability
• Optimize message routing and carrier relationships
• Debug SMS delivery issues
• Develop new SMS features based on usage patterns

No Third-Party Sharing of SMS Data

We do NOT sell, share, or transfer customer SMS opt-in consent data or phone numbers to third parties.

Customer SMS information belongs exclusively to the client business that collected it. NeuroFin does not:

• Sell customer phone numbers to marketers, advertisers, or data brokers
• Share SMS opt-in consent data with any third party
• Transfer customer phone numbers between different client businesses
• Use customer contact information for our own promotional purposes
• Provide SMS data to third parties except as required by law or for essential service providers

Limited Service Provider Sharing

We share SMS information only with essential service providers who help us deliver SMS functionality:

• Twilio: SMS message delivery infrastructure (contractually obligated to protect data)
• Firebase/Google Cloud: Secure database storage for SMS records

These providers are contractually obligated to protect information, use it only for the specific services they provide to us, and not share or sell customer data.

SMS Data Security

We implement strict security measures to protect SMS-related information:

• Encryption in transit (HTTPS/TLS for all SMS API communications)
• Encryption at rest for SMS records and phone numbers
• Secure authentication and access controls for client businesses
• Regular security audits of SMS infrastructure
• Employee access restrictions (need-to-know basis only)
• Automatic opt-out processing to prevent unauthorized messaging
• Rate limiting and abuse detection systems

However, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security but maintain industry-standard protections.

SMS Data Retention

We retain SMS-related information for specific periods based on legal and operational requirements:

• Active SMS Records: Retained while client account is active
• SMS Consent Records: Retained for 4+ years per TCPA requirements
• Message Logs: Retained for 90 days to 2 years for compliance and debugging
• Opt-Out Records: Retained indefinitely to permanently honor opt-out preferences
• Delivery Reports: Retained for 1 year for client access

When information is no longer needed, we securely delete or anonymize it. Opt-out records are maintained permanently to ensure opted-out customers never receive future messages.

Your SMS Privacy Rights

For Client Businesses Using Our SMS Platform

• Access: View and export your SMS records and customer data
• Correction: Update customer phone numbers and SMS preferences
• Deletion: Request deletion of customer SMS data (subject to retention requirements)
• Data Portability: Export SMS customer lists in standard formats
• Account Closure: Close your account and delete SMS data

For End-Customers Receiving SMS Messages

If you are a customer receiving SMS messages through our platform:

• Opt-Out Rights: Reply STOP to any message to opt out immediately and permanently
• Data Access: Contact the business directly to request your SMS data
• Correction: Contact the business to update your phone number
• Deletion: Request deletion of your SMS data from the business
• Platform Concerns: Contact us at support@neurofininc.com if the business is unresponsive

TCPA Compliance

Our SMS services are designed to comply with the Telephone Consumer Protection Act (TCPA) and related federal regulations:

• Prior express consent required before any SMS message
• Clear opt-out instructions in every message
• Immediate, automatic opt-out processing
• No messages sent to opted-out numbers
• Time-of-day restrictions (no messages 9pm-8am local time)
• Comprehensive consent and message logging
• Regular compliance audits

California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

• Right to know what SMS information is collected and how it's used
• Right to delete SMS information (subject to legal retention requirements)
• Right to opt-out of sale of SMS data (we do not sell SMS data)
• Right to non-discrimination for exercising privacy rights

To exercise these rights, contact us at support@neurofininc.com.

Children's Privacy

Our SMS services are designed for businesses and not directed to individuals under 18. We do not knowingly collect SMS information from children under 18. If we learn we have collected such information, we will delete it promptly.

Client businesses are responsible for ensuring COPPA compliance if they send SMS messages to minors.

International SMS

Our SMS services are operated in the United States. If you access our services from outside the U.S., SMS information will be transferred to, stored, and processed in the United States. By using our SMS services, you consent to this transfer.

Legal Disclosures

We may disclose SMS information when required by law or to:

• Comply with legal processes (subpoenas, court orders, law enforcement requests)
• Enforce our SMS Terms of Service
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or others
• Investigate fraud, TCPA violations, or security issues

Business Transfers

If NeuroFin is involved in a merger, acquisition, or sale of assets, SMS information may be transferred as part of that transaction. We will notify affected businesses and provide information about any choices available regarding the transferred data.

Changes to This SMS Privacy Policy

We may update this SMS Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on this page with a new "Last Updated" date
• Sending email notification to client businesses for significant changes
• Providing notice through the platform dashboard

Your continued use of our SMS services after changes take effect constitutes acceptance of the updated policy.

Contact Us

For questions, concerns, or requests regarding this SMS Privacy Policy or our SMS data practices: