Messaging Privacy Policy

1. Scope

This policy applies to personal information collected and processed through:

• SMS and text message programs, including Service SMS and Marketing SMS
• Email communications related to operator placement and account management
• In-app or web chat communications via our CRM platform
• Phone call records and voicemail associated with your account

2. Data Collected Through Messaging

When you communicate with GWT via SMS, email, or other messaging channels, we may collect:

• Identifiers: phone number, email address, name, and account ID
• Message Content: content of messages sent to and received from GWT
• Metadata: message timestamps, delivery status, open rates for email, and response timing
• Opt-In/Opt-Out Records: records of your consent choices and any opt-out requests
• Device Information: carrier name and device type, where available from carrier delivery reports

3. How We Use Messaging Data

GWT uses messaging data to:

• Deliver service communications related to your operator placement and account
• Send marketing communications to users who have consented to our Marketing SMS program
• Maintain records of consent for TCPA and other regulatory compliance
• Improve messaging content, timing, and relevance based on engagement patterns
• Detect and prevent fraud or unauthorized use of our communications systems
• Respond to your support requests and inquiries

4. Legal Basis for Processing

GWT processes messaging data on the following legal bases:

• Consent: service and marketing SMS messages are sent only to individuals who have provided written opt-in consent through our forms
• Contract: service-critical communications, such as billing and placement updates, are necessary for the performance of our service agreement
• Legitimate Interest: we maintain messaging records to fulfill legal and compliance obligations under TCPA and applicable state laws

5. Third-Party Messaging Services

GWT may use third-party services to operate its messaging programs, including CRM, SMS delivery, email delivery, calling, scheduling, and related communication platforms. These service providers access only the data necessary to deliver communications on GWT's behalf and are not permitted to use your data for their own marketing purposes.

6. No Sale of Messaging Data

GWT does not sell, rent, or trade your phone number, email address, message content, SMS consent records, or opt-in data to any third party for their own marketing purposes. We do not share your phone number with unaffiliated third parties except as required by law or as necessary to deliver our services as described in this policy.

7. Data Retention for Messaging

GWT retains messaging data as follows:

• Consent Records: retained as needed for compliance purposes
• SMS Message Logs: retained for up to 3 years unless a longer period is required by law
• Email Communication Records: retained for up to 3 years from last active engagement unless a longer period is required by law
• Opt-Out Records: retained as needed to honor opt-out preferences

8. Your Rights Regarding Messaging Data

• Opt-Out: Reply STOP to any SMS or click unsubscribe in any marketing email to stop receiving that type of communication
• Access: Request a copy of your communication history by emailing [email protected]
• Correction: Request correction of inaccurate contact information at any time
• Deletion: Request deletion of your messaging records, subject to legal retention requirements

9. Security of Messaging Data

GWT implements technical and organizational measures to protect messaging data, including access controls, encryption in transit, and regular security reviews of our communication systems. We limit access to messaging data to staff who need it to provide services.

10. Compliance

GWT's messaging programs are operated in compliance with applicable communications and privacy laws, including TCPA, CAN-SPAM, CTIA Messaging Principles and Best Practices, and applicable state privacy laws where required.

11. Contact for Messaging Privacy Issues