SMS Privacy & Communications P

SMolicy (Summary Version)

SMS Text Messaging Privacy and Terms & Conditions - Private Fairway Holdings, LLC 

Valid Ocotber 1, 2026

To ensure all SMS communications comply with privacy standards, protect user data, and meet legal and industry requirements including TCPA, CTIA guidelines, and general best‑practice privacy principles.

1. Consent & Authorization

• SMS messages are sent only to individuals who have provided explicit, documented consent.

• Consent must clearly state the purpose of messaging (alerts, marketing, authentication, etc.).

• Users may withdraw consent at any time by replying STOP.

2. Data Collection & Use

• Only the minimum necessary data is collected: phone number, message metadata, and any user‑provided information.

• SMS data is used solely for the stated purpose at the time of consent.

• No SMS data is sold, rented, or shared with third parties except required service providers.

3. Data Security

• SMS data is stored using industry‑standard encryption at rest and in transit.

• Access is restricted to authorized personnel with a legitimate operational need.

• Systems handling SMS data undergo periodic security reviews.

4. Data Retention

• SMS logs and related personal data are retained only as long as necessary for operational, legal, or compliance purposes.

• Retention periods are documented and enforced through automated policies.

• Data is securely deleted when no longer required.

5. User Rights

• Users may request access to the data associated with their phone number.

• Users may request correction or deletion of their data where legally permissible.

• Opt‑out requests are honored immediately and logged for compliance.

6. Message Content Standards

• Messages must be accurate, relevant, and aligned with the purpose of consent.

• Sensitive personal information (PII, financial data, health details) must never be sent via SMS.

• Marketing messages must include clear identification of the sender.

7. Compliance

• All SMS operations comply with:

  • TCPA (Telephone Consumer Protection Act)

  • CTIA Messaging Principles & Best Practices

  • Applicable state privacy laws (e.g., CCPA/CPRA where relevant)

• Regular audits ensure ongoing compliance.

8. Opt‑Out & Support

• Users can opt out at any time by replying STOP.

• Additional commands such as HELP provide support contact information.

• Opt‑out status is immediately enforced across all systems.