Textline Privacy Policy
For previous Privacy Policies, please see: www.textline.com/legal/privacy-policy-2020
Last revised on March 15, 2023, effective as of July 10, 2023.
This privacy policy (“Privacy Policy”) describes the information Textline, Inc. (“Textline” or “we”, “us” or “our”) collect from or about users (“you”) of our website (the “Site”) and the information we collect on behalf of our clients who employ our technology to use our text messaging and other services (the “Services”).
This Privacy Policy does not apply to third parties that Textline does not own or control. Such third parties are not under Textline’s control and Textline is not responsible for their privacy or security practices.
Any order forms or additional agreements to which users agree governing the provision of optional Textline features shall take precedence over the terms of this Privacy Policy to the extent of any differences, so please read such order forms or additional agreements carefully. This includes Data Processing Agreements and policies governing applicable law, including our General Data Protection Regulation (GDPR) Privacy Notice.
Textline participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Textline’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks below. In particular, Textline remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Textline proves that it is not responsible for the event giving rise to the damage. With that said, on light of recent decisions by the European Court of Justice, we are no longer relying exclusively on EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield and are working to implement other transfer mechanisms such as Standard Contractual Clauses to address any transfers of personal data to the U.S., consistent with applicable law.
1. Collection, Use, and Disclosure of End Users’ Information
a. Personal Information You Provide Us
We collect, process, and retain personal information from you and any devices you may use when you use or interact with our Site and Services, and in other ways described below. For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual. The personal information we may collect includes name, phone number, email address, company name, and website. In the course of providing Services to our clients, Textline may collect personal information about End Users of our clients. Textline uses this information to provide our Services to our clients.
We receive and store information you enter on our Site or give us in any other way, including your name, mailing address, phone number, email address, and payment information, as well as company name, and colleagues’ names and email addresses. We collect information about your use of our Site, such as the pages you view and other interactions you have. We receive and store certain types of information whenever you interact with our Site. We may automatically collect information about your use, navigation of, and interactions with our clients’ applications, websites, or other online services when our client has installed our technology on its properties.
When you update information, however, we often maintain a copy of the unrevised information in our records. A client may deactivate its Textline account by following the deactivation process set forth on the Site. Some information may remain in our records after account deletion. You are able to access, add to, update, correct, amend, or delete certain information about you, including personal information. EU, UK, and Swiss data subjects also have a right to access their information. Please see the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks section below. Please contact us at dpo@textline.com if you have questions or concerns about accessing, correcting, or deleting your personal information.
b. Information Clients Provide to Us
We receive and store any personal information about our clients that clients enter on the Site, through the Services, or clients provide to us in any other way (“Client Data”). Clients can choose not to provide us with certain information, but then they may not be able to take advantage of some of our features. We use Client Data for such purposes as responding to their requests for Services, customizing the content they see, communicating with them about our products, and marketing our Services to them.
In order for clients to use all of our features, they must register for an account with Textline. We require clients’ organizations, email addresses, names, and passwords during the registration process. Further information may be required if clients choose to purchase paid components of the Services, such as credit card and billing information.
If a client purchases Textline online tools to collect and analyze user and usage data for its websites, applications, or services, Textline will communicate with it about the services it purchases by email. Clients consent to receiving such confirmations by email. If clients contact us via email, we may retain a record of their contact information and any information they provide us in their messages to respond to them. We may receive a confirmation when clients open an email from Textline.
We may also send emails with news or promotions. If clients do not want to receive news or promotional emails from us, they may contact us at textline@textline.com (this will not affect emails related to certain important, legal, or service-related messages such as outage information).
c. Cookies and Tracking Technologies
Our Site uses “cookies,” tagging and other tracking technologies to help enable us to enhance or personalize your online browsing experience. This information includes computer and connection information such as statistics on your page views, traffic to and from our Site, referral URL, ad data, your IP address, and device identifiers. This information also may include your browsing history, transaction history, and your web log information.
Cookies are alphanumeric identifiers transferred to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages on our Site are visited and by how many people. Like most internet sites, Textline uses cookies to enhance our users’ experience on the internet. These cookies do not collect personal information, and we do not combine information collected through cookies with other personal information to tell us who you are or what your name or email address is.
Most browsers allow you to prevent the browser from accepting new cookies, to be notified when you receive a new cookie, or to disable cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Site may not work or may not work as designed. Note that if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences.
Your browser or device may include “Do Not Track” functionality. Our information collection and disclosure practices, and the choices that we provide to visitors, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.
We use Google Analytics, a web analytics service provided by Google, Inc., on our Site. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Site, compile reports on the Site’s activity, and provide other services related to Site activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The Site does not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies.
d. Information From Other Sources
To improve our Services, we may receive information about clients from other sources and add it to our account information. Like the information clients provide to us, we do not share this information with anyone except authorized third parties in connection with providing clients with our Services. Textline also uses third party partners for credit card processing who may require and store your credit card and billing information.
We do not disclose clients’ information to unaffiliated third parties without clients’ consent, or as otherwise described in this Privacy Policy (for example, as necessary to respond to legal requirements).
e. Use and Disclosure of Personal Information
This section describes our policies for handling information provided to us by our clients using our Services or other sources of their choosing. We provide our clients with the ability to create profiles in order to effectively communicate with them via communications tools such as text messaging (SMS, MMS), and the ability to export information, at our client’s direction, to other applications. To do this, our clients integrate our technology into their applications, websites, or other online services.
Our clients’ collection, use, and disclosure of personal information is separately governed by their privacy policies. Our clients may collect information about their users directly; in that case, each of our clients are responsible for ensuring that their information collection follows their privacy policies and terms of use.
We use your personal information to help us personalize and continually improve your experience on the Site, including fulfilling requests for information, analyzing and compiling trends and statistics, and communicating with you. For information about how to manage your information and the choices you have, see how to limit the use of your information below. The choices you have depend on where you reside.
At the direction of our clients. We collect information about you at the direction of our clients and may append information to your profiles from third party sources. We do this to provide our Services, which enable our clients to optimize their communications with, and understanding of, their users. We consider our clients’ information to be confidential to that client. Accordingly, we do not disclose your information to unaffiliated third parties except in response to our clients’ explicit instructions, as provided for in an agreement between us and our client, or as otherwise described in this Privacy Policy (for example, as necessary to respond to legal requirements), in our Data Processing Agreement, or GDPR Privacy Notice.
To our agents. We employ other companies and people to perform tasks on our behalf and need to share client and your information with them to provide products and services. Examples include billing, processing payments, providing marketing assistance, and providing customer service. Our agents use the same level of privacy protections as we do. Unless we tell you differently, Textline does not share, and Textline’s agents do not have any right to use, personal information collected from our Site and Services beyond what is necessary to assist us.
To our affiliates and corporate parents. Textline may provide services or sell products jointly with affiliated businesses. We may share your information collected from our clients that is related to such transactions with those affiliated businesses. We require our affiliates, via contract, to provide the same level of privacy protection as set forth in this policy and they do not have the right to share or use personal information for any purpose other than for an authorized transaction. Additionally, in some cases, we may change our ownership or corporate organization, or may choose to buy or sell assets. Your information may be transferred to another entity, its affiliates, or service providers in connection with the transaction. You acknowledge that such transfers may occur, and that Textline or its successor organization may continue to use your information as set forth in this policy.
If we ever were to engage in any onward transfers of your personal information with third parties for a purpose other than which it was originally collected or subsequently authorized, we would provide you with an opt-out choice to limit the use and disclosure of your personal information.
To comply with applicable law. We may also release personal information when we in our sole discretion believe in good faith that release is necessary or appropriate to comply with the law, enforce or apply our conditions of use and other agreements, or protect the rights, property, or safety of Textline, our employees, our clients, or others. We also may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
2. California Privacy Notice
This California Privacy Notice applies to any California residents about whom we have collected personal information from any source, including through your use of our Sites and Services, by engaging us to inquire about or obtain the various products and services that we offer, or by communicating with us electronically, by telephone, in paper correspondence, or in person. This Notice includes disclosures and rights regarding Client Data. The provisions contained within this section are intended to provide notices in compliance with the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (together, the “CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in this Privacy Policy and in our Data Processing Agreement.
The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of personal information, as well as rights to access, delete, correct, and restrict the use, sale, and sharing of certain personal information we collect about them. California residents have the right to opt-out of the sale/sharing of their personal information, including for purposes of cross-context behavioral advertising and targeted advertising. California residents also have the right not to receive discriminatory treatment by for the exercise of their privacy rights under the CCPA. This California Privacy Notice does not apply to certain personal information that is already subject to certain federal and state regulation.
If you are a California resident, you may submit a request to exercise these rights by emailing us at dpo@textline.com. If you are a visually-impaired customer, a customer who has another disability or a customer who seek support in other language, you may access this California Privacy Notice by emailing us at dpo@textline.com or mailing us at Textline, Inc., 1901 Avenue of the Stars, Suite 200 Los Angeles, CA 90067.
b. Personal Information We Collect
We may ask you to provide us with certain personal information that can be used to contact, identify, or locate you when you use our Sites and Services, purchase our products, or use our services. Personal information we collect includes:
Sensitive personal information. Certain types of personal information that we collect, as described above, may constitute “sensitive personal information” under California law including:
Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories.
We will not retain any information we collect from you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
c. Sources of Personal Information
We may collect personal information from the following categories of sources:
We may supplement the information described above with information we obtain from other sources, including from both online and offline data providers.
c. Use and Disclosure of Personal Information
We may collect, use, or disclose personal information about you for the purposes detailed in Section 1(e).
We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. “Business purposes” means the reasonably necessary and proportionate use of personal information for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, the operational purposes of our service providers and contractors of our clients, and other purposes compatible with the context in which the personal information was collected.
d. Your California Privacy Rights
If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:
How to submit a request. You may exercise any of the rights described in this section by emailing us at dpo@textline.com or mailing us at Textline, Inc. 1901 Avenue of the Stars, Suite 200, Los Angeles, CA 90067.
Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on. In order to verify you, you must provide us with your first and last name and phone number. These rights are also subject to various exclusions and exceptions under applicable laws.
We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.
Authorized agents. You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. If you designate an authorized agent to exercise your various rights under the CCPA, we may require that you provide your authorized agent with written permission to exercise your various rights and to verify your own identity with us. If your authorized agent does not submit proof that they have been authorized by you to submit verified requests, we reserve the right to deny such a request that we have received and will explain to your authorized agent why we have denied such request.
The authorized agent may submit a request to exercise these rights by emailing us at dpo@textline.com or mailing us at Textline, Inc., 1901 Avenue of the Stars, Suite 200, Los Angeles, CA 90067.
Household data. We currently do not collect Household Data. If we receive a Right to Know or Right to Delete request submitted by all members of a Household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13, as we do not collect personal information from any person under the age of 13.
Direct marketing by third parties. We do not disclose personal information to third parties for their own purposes, and you may opt-out of any disclosures of non-identifiable personal information. However, because California residents have the right to request information regarding such practices under California’s “Shine the Light” Law, please contact us using the information provided at the end of this Privacy Policy. You must include your full name, email address and postal address in your email or mail request so that we can verify your California residence and respond. “Personal information” under this California law means any information that identified, described, or was able to be associated with an individual at the time of disclosure.
We will continue to update our business practices as direct regulatory guidance becomes available.
e. Notice of Financial Incentives
We may offer discounts on products and services – including those offered by us, our affiliates, and third-party business partners – by joining our email subscription lists, and participating in other promotions. The availability of these promotions to you at any given time will vary. If and when we offer such programs, we may ask for your personal information (such as your name and email address) as a prerequisite to your participation in the program.
Clients may join these programs by visiting the Site and using the Services. If clients do not do not want to receive news or promotional email from us, they may contact us at textline@textline.com.
3. Information Security
Clients’ Textline account information is protected by a password for your privacy and security as well as other reasonable security measures. We use reasonable safeguards to protect the security of clients’ information during transmission, including by encrypting all of the information clients input. Only employees or agents who need personal information to perform a specific job are granted access to it. All of our employees are kept up to date on our privacy and security practices.
While Textline uses commercially reasonable means to secure information provided to us, we do not guarantee that such information will not be improperly accessed, disclosed, or destroyed by breach of any of our safeguards. Clients are responsible for the security of their information that is transmitted to us or that is viewed, downloaded, or otherwise accessed when using unencrypted, public or otherwise unsecured networks.
4. Conditions of Use
Your use of the Site and Services and any possible dispute over privacy are subject to this Privacy Policy, our Terms of Use, Data Protection Agreement, and GDPR Privacy Notice, including limitations on damages, dispute resolution, and application of California state law.
5. International Users
This section does not apply to EU and Swiss Data subjects. Please see Section 8 below and our GDPR Privacy Notice if you are an EU, UK, or Swiss Data subject. If you use our Website outside of the United States, you understand and consent to the transfer of your personal information to, and the collection, processing, and storage of your personal information in, the United States and elsewhere. The laws in the U.S. and these countries regarding personal information may be different than the laws of your state or country.
6. Use of Textline’s Site by Children
Textline’s Site is not intended for children under the age of 16. Accordingly, we will not knowingly collect or use any personal information from children that we know to be under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us using the information in Section 9. If we become aware that we have collected personal information from children without verification of parental consent, we will take steps to remove that information from our servers.
7. Changes to this Privacy Policy
We may make changes to this Policy from time to time. We will post any changes here, and such changes will become effective when they are posted. Your continued use of our Site and Services following the posting of any changes will mean you consent to those changes.
8. EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
a. Definitions
For purposes of this section only, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Textline or to which Textline discloses personal information for use on Textline’s behalf.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of Textline to identify (together with other information) a living individual. Personal information does not include information that is anonymized or aggregated. For the purposes of data received from Switzerland under the Swiss-U.S. privacy shield, personal information also includes ideological views or activities, information on social security measures or administrative or criminal proceedings and sanctions.
“Sensitive information” means any personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information that concerns health or sex life, and information about criminal or administrative proceedings and sanctions.
b. EU-U.S. and Swiss-U.S. Privacy Shield
Textline participates in and complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the European Union, the United Kingdom, and Switzerland to the United States.
Textline has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
With that said, on light of recent decisions by the European Court of Justice, we are no longer relying exclusively on EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield and are working to implement other transfer mechanisms such as Standard Contractual Clauses to address any transfers of personal data to the U.S., consistent with applicable law.
c. Principles
Notice: Textline receives personal information about individuals in the EEA, UK, and Switzerland collected by Textline and its clients, and personal information about clients in the EEA, UK, and Switzerland. The types of information collected and the uses of that information are described in the privacy policy above.
Textline will subject all personal information received via the EU-U.S. and Swiss-U.S. Privacy Shields to these Principles.
Choice: Textline will offer individuals the opportunity to choose whether their information is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at the address given below. Textline offers an opt-out to individuals whose personal information is disclosed to non-agent third parties. Additionally, Textline will not use sensitive personal information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless Textline has received the individual’s affirmative and explicit consent (opt-in). Textline will treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.
Data Integrity: Textline will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Textline will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.
Transfers to Agents: Textline contracts with third parties who perform business functions on our behalf. Textline uses these third parties to assist with activities such as billing, processing payments, providing marketing assistance, and providing customer service. These entities may have access to personal information if needed to perform their functions for Textline.
For information received under the Privacy Shield, Textline will require its agents to safeguard personal information consistent with this Policy by contract, obligating the agent to provide at least the same level of protection as is required by the Privacy Shield Principles.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Textline’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Textline remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Textline proves that it is not responsible for the event giving rise to the damage.
Access and Correction: Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to dpo@textline.com. If requested to remove data, we will respond within a reasonable timeframe.
Security: See “Information Security,” above.
d. Enforcement
Textline will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy. Any employee that Textline determines is in violation of this policy will be subject to disciplinary action.
Textline is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
e. Dispute Resolution
Textline’s accountability for personal information that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Textline remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal information on its behalf do so in a manner inconsistent with the Principles, unless Textline proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Textline commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Textline by email at dpo@textline.com
Textline has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
9. Questions or Concerns
If you have any questions or concerns regarding privacy at Textline, please send us a detailed message to dpo@textline.com or to Textline, Inc., 1901 Avenue of the Stars, Suite 200, Los Angeles, CA. 90067. Your privacy is important to us and we will make every effort to resolve your concerns.
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