This Privacy Policy governs the manner in which Dial Raven LLC (“Dial Raven”, “Company,” “our,” “us,” or “we”) collects, uses, maintains, and discloses information collected from users (each, a “User”) on our website or platform (“Platform”), available from or otherwise, and any successors to the foregoing (“Platform”), including the Dial Raven Chat mobile application (the “App”). It also applies to users who contact us through other communication methods such as email or phone.

Please read this Notice carefully. If any term in this Notice is unacceptable to you, please do not use our Website or provide us with any personal information.In this Notice, when we talk about “Personal Information,” we mean any information that is related to an identified or identifiable natural person.This Notice does not apply to any products, services, websites, mobile applications, or content (including advertising) offered by third parties or that may be linked to or from the Website. Data collected by these third parties is covered by their own privacy notices.

Depending on your relationship with us, we may collect the following categories of Personal Information from you:

Information We Collect Directly From You

We collect Personal Information when you:

Information We Automatically Collect About You

We use automatic technologies such as cookies and web beacons to collect:

Information We Collect From Other Sources

We may receive information from affiliates, partners, and public sources like:

We may use your Personal Information to:

We may share your information with:

De-identified or aggregated information may be shared for analytics and reporting.

We are committed to protecting your privacy, including how we handle information related to SMS/text messaging. This section outlines how we collect, use, and share mobile data specifically for text message communications.

No Selling or Sharing of SMS Opt-In Data

We do not sell, share, or rent your mobile number, SMS opt-in data, or consent information to third parties for any marketing or promotional purposes.

No Third-Party Marketing Use

No phone number or mobile information will be shared with third parties or affiliates for marketing or promotional use. All such categories specifically exclude SMS/text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Permitted Use of Data by Service Providers

We may share your mobile number and SMS opt-in status only with trusted third-party service providers (such as messaging platforms, telecom carriers, and infrastructure vendors) who assist us in:

These providers are contractually obligated to use your information solely for these services and not for their own marketing or unrelated purposes.

Opt-Out and Revocation of Consent

You may withdraw your consent to receive SMS messages at any time by:

Please note that standard message and data rates may apply depending on your mobile service provider.

We use reasonable administrative, technical, and physical safeguards to protect your Personal Information. However, no data transmission or storage system can be guaranteed to be 100% secure.

Our Website is not intended for children under 13 (or 16 where applicable). We do not knowingly collect Personal Information from children without parental consent.

We are not responsible for the privacy practices or content of any external websites linked to from our Website.

We may update this Privacy Policy periodically. The revised version will be posted with an updated “Last Updated” date.

If you have questions or concerns about this Privacy Policy or wish to exercise your privacy rights, please contact us at:📧 [email protected]

Phone Calls/Text Messages. With your consent, we may engage in communications, which may include phone calls and text messages made using an automatic telephone dialing system or artificial prerecorded voice. You are not required to consent to such communications as a condition of purchasing products or services, and you may revoke consent at any time by contacting us via the methods in Section 10 “How to Contact Us.”

Push Notifications to Mobile Devices. With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (Civil Code Section 1798.100, et seq.) (“California Law”), provides eligible California residents with specific rights with respect to our collection, retention, disclosing, selling, sharing, and use of Personal Information. This section on Additional Information for Residents of California supplements this Notice and applies solely to eligible residents of the State of California. Any terms used but not defined in this section have the same meaning as defined in California Law.

Collection of Personal Information

In the preceding twelve (12) months, we have collected categories of Personal Information as discussed in Section 1 “Your Information We Collect” from the sources of Personal Information as discussed in Section 2 “How We Collect Your Information.” The business or commercial purpose for collecting that information is disclosed in Section 3 “How We Use Your Information.”

Disclosure of Personal Information

In the preceding twelve (12) months, we may have disclosed your Personal Information for a business or commercial purpose described in Section 3 “How We Use Your Information” to the categories of third parties described in Section 4 “With Whom Do We Disclose Your Information.”

Sales and Shares of Personal Information

We do not sell your Personal Information for monetary profit.

We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

California Privacy Rights

California Law provides consumers with specific rights regarding their Personal Information. The following section describes your California Law rights and explains how to exercise those rights. Your California Law rights include the:

If you have an opt out preference signal enabled (e.g., the Global Privacy Control), you will automatically be opted out of the sale or sharing of your information, but we may ask you to confirm your preference if you have previously consented to the sale or sharing of your Personal Information. To download and use a browser supporting the opt-out preference signal, please visit https://globalprivacycontrol.org/orgs. If you choose the opt-out preference signal, you will need to enable it for each supported browser or browser extension you use.

If a transaction requires the use or disclosure of your Sensitive Personal Information in order to complete the transaction, we will notify you and provide instructions on how you can reauthorize such use or disclosure.

Exercising Your Rights

To exercise your California privacy rights, please submit a request by contacting us via the methods in Section 10 “How to Contact Us.”

Identify Verification

We may require you to prove your identity to exercise certain rights. Depending on your request, we will ask for information such as your name, your telephone number, email address, and/or date of last communication with us. We may also ask you to provide a signed declaration confirming your identity. We will only use Personal Information provided in your consumer request to verify your identity or authority to make the request.

Only you, your parent, guardian (if you are under 13 years or age), conservator, a person to whom you have given power of attorney, or an authorized agent may make a verifiable consumer request related to your Personal Information. You may, however, make a verifiable consumer request on behalf of your minor child if necessary. Your verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative. We cannot respond to your request if we cannot verify your identity or authority to make the request. You may only make a verifiable consumer request for your right to access twice within a 12-month period.

Data Retention

We retain your Personal Information so long as necessary for the purposes for which it was collected or otherwise processed. When determining the retention period, we take into account criteria, such as the type of services requested by or provided to you, the nature and length of our relationship with you, use of our Website, and the impact on the Website functionality if we delete your Personal Information.

Notice of Financial Incentive

We may offer you various incentives, including special offers, discounts, rewards, and coupons pursuant to certain rewards and loyalty programs (each, a “Rewards Program”), throughout the year for providing us with your Personal Information. Categories of Personal Information that may be collected pursuant to a Rewards Program, include, but are not limited to the categories of Personal Information described in Section 1 “Your Information We Collect.”

We do not assign a monetary value to the data we collect, but based on a good-faith estimate, we believe the value received from your Personal Information is reasonably equal to the value of the benefit we offer you pursuant to a Rewards Program. This estimate is not specific to any specific individual who participates in a Rewards Program (a “Member”) and may vary by Member. We have calculated such value by taking into consideration, without limitation, relevant factors related to the estimated value of such information to us, as set forth under California Law.

If eligible, you may opt into a Rewards Program by following the instructions set forth in a Rewards Program’s terms and conditions and, if applicable, by creating a member account on the Rewards Program’s website. Material terms of participating in a Rewards Program, including all terms and conditions concerning the collection, use and retention of a Member’s Personal Information, are set forth in the applicable terms and conditions, this Notice, and/or our Terms of Service and should be carefully reviewed prior to participation in a Rewards Program.

You have the right to cancel your membership and participation in a Rewards Program at any time. To opt out of a Rewards Program, including the receipt of emails provided pursuant to your status as a Member of a Rewards Program, please contact us via the methods in Section 10 “How to Contact Us.”

For eligible residents of Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia, you also have rights with respect to the Personal Information, also known as personal data, that we collect about you. This section supplements this Notice and applies solely to eligible residents of Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia. Any terms not defined in this section have the same meaning as defined under applicable Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia privacy law, including the Colorado Privacy Act, Connecticut Data Privacy Act, Montana Consumer Data Privacy Act, Oregon Consumer Privacy Act, Texas Data Privacy and Security Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act. Subject to certain exceptions, if you are an eligible resident of one of these states, you have certain privacy rights which may include, depending on your state of residency:

NOTICE TO TEXAS CONSUMERS: We may sell your sensitive personal data.

You do not need to create an account with us to exercise your Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia privacy law rights. To exercise the rights described in this section, including your opt-out rights, please submit a consumer request to us by contacting us via the methods in Section 10 “How to Contact Us.”

If you are located in Canada, the Personal Information Protection and Electronic Documents Act and applicable provincial privacy legislation (collectively, “Canadian Privacy Laws”) govern the collection, use and disclosure of personal information by organizations in the course of commercial activities. If you are located in Canada, this Canadian Privacy Rights section applies to you. Additionally, in certain Canadian provinces, provincial privacy legislation will apply to you, namely, for the Province of Alberta – the Personal Information Protection Act (Alberta), for the Province of British Columbia – the Personal Information Protection Act (British Columbia) and for the Province of Quebec – the Act respecting the protection of personal information in the private sector also applies to you and the expression “Canadian Privacy Laws” therefore also includes reference to these provincial laws. If you live in Canada and any part of our general Privacy Notice conflicts with this Canadian Privacy Rights section, this Canadian Privacy Rights section governs to the extent of the conflict.

Personal Information

Under Canadian Privacy Laws, personal information means any information about an identifiable individual, which may, in certain circumstances, include information gathered from your use of the Services.

Consent

In Canada, express or implied consent is the legal basis upon which organizations may collect, use and disclose personal Information. Accordingly, personal information will only be collected, used, and disclosed by us for the purposes described above in this Privacy Notice under the heading “How We Use Your Personal Information”, with your express or implied consent. We will collect your express consent for any sensitive personal information that we may collect, use, or disclose. Otherwise, your continued use of the Services signifies your consent to our collection, use, and disclosure of your personal information as described in this Privacy Notice, as it may be amended from time to time after you have been informed of any such amendment. Your continued use of the Services after having been informed of any amendment to this Privacy Notice will be deemed a consent by you to any such amendment; if you do not agree with this Privacy Notice or any amendment, do not access the Services.

If you provide personal information of a third party to us, you represent that you have complied with the requirements of Canadian Privacy Laws with regards to its collection before providing it to us and for us its use and disclosure as set out in this Privacy Notice.

Online Behavioural Advertising

With respect to the information that we collect using cookies or similar technologies that we have described above, you can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and an opt-out tool created by the Network Advertising Initiative. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Your Rights

Withdrawal of Consent

Under Canadian Privacy Laws, you have the opportunity to withdraw your consent at any time to our collection, use or disclosure of your personal information, subject to reasonable prior notice and applicable legal and contractual restrictions. Depending on the nature of the personal information for which you choose to withdraw your consent, if you do withdraw your consent we may not be able to provide our products and services to you; we will explain the implications of withdrawing consent to you when we receive your notice of withdrawal. If you withdraw your consent in respect of any personal information that has been provided to third parties, we will advise such third parties of your withdrawal to the extent required by Canadian Privacy Laws.

Right to be informed

You have the right to be information about the personal information that we collect, use, process, disclose, retain and have deleted about you. You may request additional information to clarify the extent of your consent.

Right to an Accounting

You have the right to receive an accounting of the categories of third parties to whom we have disclosed your personal information.

Rights of Access, Correction

You have the right to access the personal information we maintain about you and you have the right to correct or supplement your personal information if it is inaccurate or misleading and to have it completed if it is incomplete. Where appropriate, to have personal information that you have corrected or supplemented transmitted to third parties who have had access to your personal information.

Right to be notified of a Data Breach

If you are in Quebec, you have the right to be informed of a confidentiality breach involving your personal information that may cause you a serious harm. If you are in the rest of Canada you have the right to be informed of a breach of security safeguards affecting your personal information where there is a real risk of significant harm to you.

Right to Lodge Complaints

You have the right to lodge a complaint about our collection, use or disclosure of your personal information with the Office of the Privacy Commissioner of Canada and any applicable provincial privacy commissioner’s office having jurisdiction.

Additional Rights in Quebec

If you are in the province of Quebec, you have the following additional rights:

Right of Deletion

You may request under certain circumstances the deletion of your personal information.

Right to Data Portability

As of September 22, 2024 you will have the right to be provided, in a structured, commonly used and machine-readable format, with a copy of your personal information or to have it transferred directly to another entity or person.

To exercise the above rights, please get in touch with us using the contact information provided below under the heading “Contact Us”. We will consider and process your request within a reasonable period of time and in any event within thirty days of receipt of your request or such longer time as we may be permitted under Canadian Privacy Laws. Please be aware that under certain circumstances, Canadian Privacy Laws may limit your exercise of these rights.

If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If we refuse to rectify your personal information, we will attach a statement to the record that sets out the reason why we have refused to make the rectification.

We will also retain the personal information that has been the subject of an access request or a rectification request for as long as necessary to allow you to exhaust any recourse provided by law.

International Transfers

As noted above in this Privacy Notice, your personal information may be transferred to and stored at a location outside of your jurisdiction of residence. Please note that local data protection laws where your personal information is stored or processed may not provide as much protection as the data protection laws in force in your jurisdiction of residence, but we nevertheless ensure that we take reasonable steps to ensure that your personal information will not be used by such persons storing or processing the information for any purpose other than assisting us for the purposes described in this Privacy Notice. If you would like to receive more information about our policies and practices with respect to our use of service providers outside of Canada who handle your personal information or if you have any questions about our collection, use, disclosure or storage by any service providers outside of Canada on our behalf, please contact us at the address below under the heading “Contact Us”.

If you provide personal information of a third party to us, you represent that you have complied all the obligations imposed by Canadian Privacy Laws regarding the transfer of personal information outside the jurisdiction of residence.

Business Transfers

Where we disclose your personal information in the event of a business transfer described in our Privacy Notice above, we will ensure that the information is treated confidentially by the parties to the transaction and that the information will be protected by security safeguards appropriate to its sensitivity. If the transfer is completed we will require that the parties to the transaction continue to treat your personal information in accordance with Canadian Privacy Laws.

Service providers

Where we disclose personal information to services providers, we ensure that they are bound by contractual obligations to:

Electronic Messages

We send electronic messages for the purposes described above in this Policy, however, notwithstanding Our Opt-in/Opt-out Policy described above, Canada’s anti-spam legislation contains special rules that regulate the way in which we may send these electronic messages to you. If you are located in Canada we will only send electronic messages to you if we have your prior opt-in consent, unless an exception or a specific form of implied consent applies. You may learn more and sign up for our electronic mailing list by clicking here.

Information security and governance

Our internal policies and practices provide for:

Each employee who uses personal information is bound by confidentiality obligations and has received appropriate training. In addition, each employee may only access personal information that is necessary for the performance of his or her duties. In the event of a breach, our governance policies and practices provide for sanctions.

Dial Raven Chat Mobile Application

This section applies specifically to the Dial Raven Chat mobile application (the “App”), our omni-channel messaging and automation application for channels such as WhatsApp, Instagram, Messenger, and Telegram. It supplements the rest of this Privacy Policy; where this section addresses the App specifically, it governs your use of the App.

1. Introduction

At Dial Raven, we respect the privacy and confidentiality of the personal data of our clients, associates, and users of the App. This section explains how we collect, use, disclose, protect, and retain personal data in connection with the App, in accordance with applicable data protection laws.

2. How We Collect Your Personal Data

Personal data means information that identifies an individual, whether on its own or in combination with other information. We obtain personal data in connection with the App when you:

Register for an account on the App or our related platform services;
Connect a messaging channel (such as WhatsApp, Instagram, Messenger, or Telegram) to the App;
Respond to marketing communications sent through our authorized vendors;
Are referred to us by an existing client or partner;
Inquire about our products or solutions;
Submit a contact form on our website; or
Communicate with us via email or written correspondence.

3. Types of Personal Data We Collect About You

In connection with the App, we may collect:

Contact information, such as your name, email address, and phone number;
Account and profile details, such as your business name and role;
Message content and contact lists you process through connected messaging channels, which we handle on your behalf to provide the App's features;
Payment card information, processed through secured payment gateways; and
Device and usage information, such as device type, operating system, app version, and diagnostic data.

4. How We Use Your Personal Data

We use the personal data you provide us for one or more of the following purposes:

To provide, operate, and maintain the App and related platform services;
To deliver, route, and automate messages across the channels you connect;
To process payments through secured payment gateways;
To analyze usage of the App and improve our products and services;
To process payables and receivables and handle billing and payment activities;
To communicate with you, including responding to inquiries and feedback;
To conduct direct marketing where permitted, and to inform you about products or services that may interest you;
To fulfil our contractual obligations to you; and
To comply with applicable legal and regulatory requirements.

5. Who We Disclose Your Personal Data To

We disclose some of the personal data you provide us to external parties that help us operate the App, including:

Professional service providers and platform infrastructure providers;
Messaging channel providers and telecom carriers necessary to deliver your messages;
Email service vendors;
Cloud hosting and storage providers; and
Payment gateway providers.

We may also disclose personal data to regulators, law enforcement, or other authorities where legally required. Our service providers are contractually obligated to use your information solely to provide services to us and not for their own purposes.

6. How We Manage the Collection, Use and Disclosure of Your Personal Data

Obtaining consent. Before we collect, use, or disclose your personal data for a purpose not described in this Privacy Policy, we will notify you of the purpose and obtain your consent. We will not collect more personal data than is reasonably needed for the stated purposes, and we will seek fresh consent if the original purposes change. Consent may be implied where you voluntarily provide information for an obvious purpose, such as registering for the App where sharing data with our service providers is necessary to deliver the service. Consent is not required where an exception under applicable law applies, such as data that is publicly available, disclosures required by law or to public agencies, information necessary for investigations or legal proceedings, or emergency situations.

Withdrawal of consent. If you wish to withdraw consent, you should give us reasonable advance notice. We will explain the likely consequences of withdrawal, such as our inability to continue providing the App or to inform you about future products and services. You may withdraw consent by email, in writing, or by using unsubscribe or opt-out features where available.

In-app and website technologies. We use cookies and similar technologies on our website, and analytics and diagnostic technologies within the App, to recognize you, maintain your preferences, and understand how our services are used. Most cookies are session cookies that are automatically deleted when your session ends. You may disable cookies through your browser settings and limit App analytics through your device settings, though doing so may limit functionality.

Third-party consent. We obtain consent only from individuals who engage with us directly. If you provide personal data of third parties to us — including contacts whose messages you process through the App — you represent that you have obtained any consent required by applicable law before providing it to us.

7. How We Ensure the Accuracy of Your Personal Data

We take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading, and kept up to date. We may periodically ask you to verify your personal data. Please promptly inform us of any changes to your personal information.

8. How We Protect Your Personal Data

We have implemented appropriate information security and technical measures — including data encryption, firewalls, and secure network protocols — to protect your personal data against loss, misuse, destruction, unauthorized modification, access, and disclosure. Personal data is shared internally only with authorized personnel on a need-to-know basis, and third-party processors must provide sufficient guarantees that they implement appropriate security measures.

9. How We Retain Your Personal Data

We maintain a document retention policy that tracks retention schedules for the personal data you provide, in paper or electronic form. We do not retain personal data longer than is necessary for business or legal purposes, and we destroy it securely when the applicable retention period expires.

10. How You Can Access and Make Correction to Your Personal Data

You may request information about how your personal data has been used or disclosed. We will respond to your request as soon as possible, generally within 30 days. We may need to verify your identity before fulfilling a request, and a reasonable processing fee may apply where permitted by law. If you find that the personal data we hold about you is inaccurate, incomplete, misleading, or not up to date, you may ask us to correct it, and we will do so within 30 days of a validated request.

11. Deletion of Personal Data

You may request deletion of your personal data, including your App account and associated data, by contacting us at the email address in the “Contacting Us” subsection below. Upon receipt of your request, we will verify and validate it and then process the deletion in accordance with applicable law.

12. Transfer of Personal Data

Your personal data may be transferred to, and stored at, locations outside your jurisdiction of residence. Where we transfer personal data internationally, we take reasonable steps to ensure it receives a standard of protection comparable to that required in your jurisdiction, including through contractual safeguards with the recipients.

13. Contacting Us

If you have any query or feedback regarding this section, or any complaint relating to how we manage your personal data in connection with the App, you may contact us at support@dialraven.com. Please include your full name, contact information, and a brief description of your query or complaint. We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time.

14. Changes to this Section

We may update this section from time to time. We will notify you of any changes by posting the latest version of this Privacy Policy on our website. Changes take effect upon posting.