Our Commitment to Privacy
Our privacy commitments are fundamental to the way we run our business. Unless otherwise noted or governed by law, these commitments apply to everyone who has a relationship with us – including clients, service partners, agents, vendors, third parties, and website visitors. SMSVS is committed to providing you with the best overall experience in all of our products and services. We strive to strike the right balance between using your data to ensure the quality of those experiences and protecting your privacy.
This policy applies to all information we collect including information about you, information we collect directly from you, information we automatically collect, information we collect through our website and mobile applications, and information we collect about you from third parties.
Personal Data, also referred to as PII or personally identifiable information, is information that identifies or reasonably can be used to identify you. Examples include your: (i) name, (ii) mailing address, (iii) email address, (iv) phone number, (v) date of birth or age, (vi) bank account or credit/debit card number, (vii) purchase information, (viii) mobile device information, (ix) how you use our sites, platform and mobile applications, (x) geo-location, (xi) social media information, (xii) health information, and (xiii) biometric data, such as fingerprints or voice recordings.
Personal Data We Collect
A. What We Collect
Device Information. SMSVS receives Personal Data from your devices, including IP address, location, GPS data, web browser type, mobile operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, push notification tokens, and, if you register with your social media account (such as Facebook, Google or LinkedIn), your applicable social media identifier.
Service Data (including Session and Usage data. To help us understand how you use our websites and the Platform and to help us improve them, we automatically receive information about your interactions, like the pages or other content you view, your actions within the websites and Platform, and the dates and times of your visits. When you access our websites or use the Platform, we receive Personal Data generated through such use, either entered by you or third parties (for example, online profile information, schedules, attendee info, etc.), or from our websites or the Platform themselves (for example, duration of session, use of webcams, connection information, servicing information, etc.). We may also collect usage and log data, including diagnostic data to help us support the services.
Call, Email and Text Information. We work with third-party partners to facilitate calls, emails and text messages to you. We may receive Personal Data about these communications including the date and time of the call, email or SMS message, and whether the call was answered, or the message was received or opened. We will share your Personal Data with such partners to facilitate these communications and to help us provide information and services to you.
Biometric Information. Following your registration on the Platform, we will collect biometric information, which consists of your physical or behavioral characteristics. The biometric information may be used to verify personal identity or to detect fraud and may be shared with third-party partners. Examples of physiological characteristics that we may collect include, but are not limited to, your fingerprints or facial features. Behavioral characteristics that we may collect include, but are not limited to, your voice, gestures, typing rhythm, or gait. Examples include voice recordings for support purposes; facial recognition systems for identity verification; or fingerprints for computer log on.
Call and Screen Recordings While Providing Services Using the Platform. While you are providing customer support and other services through the Platform, we may employ tools to: (a) record or listen to your calls or view your emails or texts; and (b) view you through your computer camera during your calls; and (c) video your desktop screens. These tools may be utilized without notice but only occur while you are logged into the Platform to provide services or participate in certification courses. These tools are used to provide support to you and to assist in improving your performance in providing customer support services.
Third Party Analytics. We use third party technologies, such as Facebook Analytics and Google Analytics, to help us to understand how you use our website and the Platform and ways that we can improve your experience. These technologies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content and improve the Platform and your experience. We also use social media buttons and plugins that allow you to connect with your social network in various ways, including Facebook, Twitter, and LinkedIn. These sites may set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
Personal Data from Cookies and Similar Technologies. We are continuously improving the Platform through the use of various third-party web analytics tools, which help us understand how visitors use our websites, desktop tools, platform, and mobile applications, what they like and dislike, and where they may have problems. We collect Personal Data through the use of “cookies”, tracking pixels, and similar technologies to understand how you navigate through our systems and interact with SMSVS advertisements, to learn what content is popular, and to save your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you open our website or use the Platform. You can consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept certain cookies from us, you may be missing out on certain features of our websites and the Platform.
Location Information. We collect your location-based information for the purposes such as providing and supporting users of the Platform, for fraud prevention and for security monitoring.
Servicing Information. When you use the Platform, we collect your servicing information, such as login and logout times, calls taken, accounts accessed, schedules, etc.
Mobile Device Log Information. If you use a mobile device to interact with an SMSVS website or platform, we will collect (a) location information (using GPS, IP addresses, or information from cell towers or WiFi access points) and (b) mobile device information (hardware settings, crashes, browser information, or system activity).
B. Personal Data You Provide to Us
Your Profile Information. When you register to use the Platform, you may give us Personal Data such as your name, email address, phone number, date of birth, physical address, Social Security number, driver’s license number or other government-issued identification number, biometric data such as images of your face, hand, retina or ear, fingerprints, behavioral characteristics, such as gestures, voice, typing rhythm, or gait, and certain other Personal Data.
Payment Method. When you use a credit card on the Platform, a third party that handles payments for us will receive your card information. To keep your financial data secure, we do not store credit card information on our servers.
Communications. If you contact us directly, we may receive additional Personal Data about you. For example, when you contact our Partner Support Team, we may receive the contents of a message or attachments that you may send to us, and other Personal Data you choose to provide.
Payment Information. To make sure businesses using the Platform get paid, we keep information about bank routing numbers, tax information, and any other payment information provided by you.
C. Personal Data We Collect from Third Parties
Third Party Partners. Once you register on the Platform, we may receive additional Personal Data about you, such as demographic data, payment information, or fraud detection information, from third party partners and combine it with other Personal Data that we have about you. We may receive Personal Data about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with Personal Data we already have about you. We may also receive Personal Data from other affiliated companies that are a part of our corporate group. This helps us to update, expand and analyze our records, confirm your identity, identify new prospects for marketing, and provide products and services that may be of interest to you.
Background Information. SMSVS works with third party partners to perform identity verification and criminal background checks on individuals using the Platform, and we may receive Personal Data from them, including publicly available Personal Data about your criminal history. We share certain of your Personal Data with these partners who help us by running background checks and identity verifications on you for security purposes and we also may share such data with clients that you are servicing or law enforcement authorities.
How We Use the Personal Data We Collect
SMSVS may access and use the Personal Data we collect as necessary (a) to provide and maintain the Platform; (b) to provide our services to you and our other clients; (c) to verify your identity; (d) to address and respond to service, security, and customer support issues; (e) to detect, prevent, or otherwise address fraud, security, unlawful, or technical issues; (f) as required by law; (g) to fulfill our contracts; (h) to improve and enhance the Platform; and (i) to provide analysis or valuable information back to you and our other clients.
Some specific examples of how we use the Personal Data are as follows:
Create and administer your account
Provide, improve, expand, and promote the Platform
Provide services to you and other clients
Confirm your identity and perform background checks
Send you updates and servicing information
Analyze how you use our websites and the Platform
Analyze the customer support services you provide on client programs (which may include screen recording, voice recording, viewing or listening while servicing)
Communicate with you, either directly or through one of our partners, including for marketing and promotional purposes
Send emails and text messages to individuals who have started the registration process for providing customer support services on the Platform regarding the status of their registration
Determine your eligibility to use the Platform
Analyze data, including through automated systems and machine learning, to understand what servicing opportunities you might be interested in
Notify you about servicing opportunities and service updates
Personalize the SMSVS experience for you
Call you or send you emails and text messages
Facilitate transactions and payments
Provide you with support
Conduct research and analysis and analyze data, including through automated systems and machine learning, to improve our services and your experience
Find and prevent fraud and other unlawful conduct
Respond to security, confidentiality and safety issues that may arise, and requests from government authorities
How We Share the Personal Data We Collect With Third Parties
Examples of how we may share Personal Data with service providers include:
Providing our services
Payment processing and fraud prevention
Verification of your identity
Providing customer support
Sending marketing communications
Conducting research and analysis
Providing cloud computing infrastructure
Clients. We will transfer Personal Data about you to clients if you are providing services for one of such client’s programs via the Platform.
Service Partners. We will share your Personal Data with the Service Partner you work for. We will also share your Personal Data with third party service partners (including other users of the Platform such as instructors or support resources) that are supporting you and your business as part of a client program you are servicing.
Third Party Services. The Platform may allow you to connect with other websites, products, or services that we don’t have control over. If you use these services, we will provide the third party with Personal Data about you to allow them to provide the service to you. We can’t speak to the privacy practices of these third parties, and we encourage you to read their privacy policies before deciding whether to use their services.
Other Sharing. We may share your Personal Data with third parties in the following cases:
While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets.
If a government authority requests Personal Data and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process.
With law enforcement officials, government authorities, or third parties if we think doing so is necessary to protect the rights, property, or safety of a client or its customers, SMSVS, other Service Partners or agents, or the public.
To comply with a legal requirement or process, including but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures, or to prevent fraud.
If you signed up for a promotion with a referral or promotion code, with your referrer to let them know about your redemption of or qualification for the promotion.
To provide Personal Data about the use of the Platform to potential business partners in aggregated or de-identified form that can’t reasonably be used to identify you.
Whenever you consent to the sharing.
We may need to communicate with you for a variety of different reasons, including:
Responding to your questions and requests. If you contact us with a problem or question, we will use your Personal Data to respond.
Sending you service and administrative emails and messages. We may contact you to inform you about changes in our services or the Platform, our offerings, and important service- related notices, such as client updates, security and fraud notices. These emails and messages are considered a necessary part of the services and you may not opt-out of them.
Sending emails about new products or other news about SMSVS that we think you’d like to hear about either from us or from our business partners. You can always opt out of these types of messages at any time by clicking the unsubscribe link at the bottom of each communication.
Conducting surveys. We may use the Personal Data gathered in the surveys to enhance and personalize our platform, services, and websites.
Offering referral programs and incentives.
We give you choices about the ways we collect, use, and share your Personal Data. SMSVS requests certain Personal Data from individuals registering to use the Platform to provide customer support and other services. If you do not provide the requested information in the registration process, we may be unable to complete your registration and allow you to provide customer support services. In instances other than the registration process, if you choose not to provide certain details, some of your experiences with us may be affected.
Email Subscriptions. You can always unsubscribe from our marketing and promotional emails but we will still send you service and administrative emails about your use of the Platform and servicing client programs. You can opt out of receiving marketing emails from SMSVS by clicking on the unsubscribe link at the bottom of any marketing email. To opt out of all other emails from SMSVS, email Admissions@smsvirtualsolutions.com. Please include your name, the name of your service partner, your email address, and your User/CSP ID.
Text Messages. When you register to use the Platform to provide customer support and other services, SMSVS will request your consent to send you text messages. You can opt out of receiving all texts from SMSVS by editing your contact data in your profile in the portal. Unselect the check box at the bottom left-hand side of the page that says “Check here to confirm your agreement to receive text messages from SMSVS” and save the change. After opting out of the text message feature, you will stop receiving text messages within 24 hours. If you are unable to login to the portal, please send an email to Admissions@smsvirtualsolutions.com withdrawing your consent to receive text messages. Please include your name, the name of your service partner, your phone number and your User/CSP ID.
We collect and store biometric information from Illinois residents. Your biometric information will be retained for the purpose of verifying your identity, for security purposes or to detect fraud. It will be destroyed when it is no longer needed to verify your identity or to detect fraud or within three years of your last interaction with SMSVS, whichever occurs first.
International Transfer of Personal Data
Data Privacy Framework
We commit to adhering to the EU-U.S. DPF and Swiss-U.S. DPF and applies these to all of your Personal Data we collect. SMSVS includes the following entities: SMS Virtual Solutions LLC.
You have a right to access and in certain circumstances, limit the use and disclosure, of your Personal Data under the EU-U.S. DPF and Swiss-U.S. DPF. You may contact us at Admissions@smsvirtualsolutions.com to further information about your rights. Within the scope of our authorization to do so, and in accordance with our commitments under the EU-U.S. DPF and Swiss-U.S. DPF, we will work with any third-party partners to provide you access to your Personal Data we hold on behalf of our partners or held by our partners on our behalf. We also will take reasonable steps to enable you, either directly or in connection with our third-party partners, to correct, amend, or delete Personal Data that is demonstrated to be inaccurate. We may disclose your Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We may subsequently transfer your Personal Data to a third parties acting on our behalf for processing as indicated in the International Transfer of Personal Data section above. In accordance with the EU-U.S. DPF and Swiss-U.S. DPF, we are liable for any processing of Personal Data by such third parties that is inconsistent with the EU-U.S. DPF and Swiss-U.S. DPF unless we were not responsible for the event giving rise to any alleged damage. For the types of third parties to which we disclose your Personal Data see above “How We Share the Personal Data We Collect With Third Parties.”. For the purposes for which we disclosure your Personal Data see “How We Use the Personal Data We Collect”.
Our compliance with the EU-U.S. DPF and Swiss-U.S. DPF is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we commit to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact us at Admissions@smsvirtualsolutions.com.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to International Centre for Dispute Resolution by the American Arbitration Association (“ICDR/AAA”), an alternative dispute resolution provider based in the United States .If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.icdr.org/dpf for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you.
In certain circumstances, we are obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that you have invoked binding arbitration by delivering notice to us and following the procedures and subject to conditions set forth in Annex I of Principles.
Data Security. We are committed to protecting your data. Even though we take reasonable precautions to protect your data, no security measures can be 100% secure and we cannot guarantee the security of your data. We recommend safeguarding your login and password, as this is one of the easiest ways you can manage the security of your own account – remember that if you lose control over your login or password, you may lose control over your Personal Data.
Data Retention. We will retain your Personal Data for as long as your account with us is active and then (a) pursuant to our records retention schedules and practices, (b) to comply with our legal obligations, (c) to resolve disputes, and (d) to enforce our agreements.
Children’s Privacy. We do not knowingly collect Personal Data from children under 18. If we find out that a child under 18 has given us Personal Data, we will take steps to delete that Personal Data. If you believe that a child under the age of 18 has given us Personal Data, please email us at Admissions@smsvirtualsolutions.com. For California residents, we do not knowingly collect information about children under the age of 13 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under the age of 13 has provided Personal Data through one of our websites, we will use reasonable efforts to remove that information from our databases.
Last Updated: October 27, 2023
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