This SMS Privacy Policy describes how we collect, use, store, disclose, and protect information associated with our SMS messaging program. By providing your mobile telephone number and opting in to receive text messages from us, you agree to the practices outlined in this policy. This SMS Privacy Policy is incorporated into our main Privacy Policy and Terms & Conditions.

1. Information We Collect

When you subscribe to our SMS program or interact with our messaging services, we may collect the following categories of information:

1.1 Personal Information

• Mobile phone number voluntarily submitted through our website, in-store sign-up devices, sign-up forms, or other enrollment channels.
• Contact details associated with your rewards account (such as name, if previously provided during enrollment).

1.2 SMS Interaction Data

• Date and time of your opt-in confirmation (SMS opt-in timestamp).
• Message delivery information (delivery status, read status, opt-out status).
• Program activity including:
  • Prize wheel entries
  • Points earned or redeemed
  • Rewards notifications
  • Account updates
  • Customer support requests

1.3 System & Compliance Logs

• STOP, HELP, START/UNSTOP commands
• Carrier-level logs required for compliance
• Technical logs used to maintain service quality and security

We do not collect or process sensitive categories of personal information (such as identification documents, financial account numbers, passwords, or health data) through SMS.

2. How We Use Your Information

Your information is used strictly for the operation, administration, and support of our SMS rewards program. This includes:

2.1 Program Communications

• Sending points updates, prize wheel results, reward confirmations, alerts, and program reminders.
• Notifying you of new rewards, special promotions (if applicable), and account-related messages.

2.2 Service Management

• Verifying opt-in consent and maintaining compliance with SMS regulations.
• Responding to HELP, STOP, or customer service requests via SMS.
• Managing your rewards profile and maintaining accurate account information.

2.3 Compliance, Security & Fraud Prevention

• Maintaining TCPA, CTIA, carrier, and A2P 10DLC compliance records.
• Monitoring for spam-like behavior or misuse of the messaging system.
• Protecting against unauthorized access and maintaining system integrity.

Your mobile number will never be sold, rented, or shared with unaffiliated third parties for marketing purposes.

3. Legal Basis for Processing (Where Applicable)

If required under applicable privacy laws (e.g., GDPR-style jurisdictions, even though CITB is U.S.-based), we may process your data under the following lawful bases:

• Consent: You voluntarily opt in to receive messages.
• Legitimate Interests: To operate a functional rewards program and respond to inquiries.
• Legal Obligations: To maintain records required by telecommunications and marketing regulations.

4. Data Sharing and Third-Party Service Providers

We may share SMS-related information only with trusted service providers necessary for SMS delivery and program operations. These include:

4.1 Twilio Inc.

Used for sending, receiving, and logging SMS messages as our designated messaging provider.

4.2 Mobile Network Operators

Used only for message routing and delivery.

4.3 Compliance & Security Providers

Third-party services that help ensure TCPA/CTIA compliance, fraud prevention, and message deliverability.

These parties are contractually required to use your information solely for the purposes of delivering and supporting SMS communications and may not use your information for unrelated advertising or sales.

We do not share SMS subscriber information with external marketers, brokers, or advertisers.

5. Data Retention

We retain SMS program data only for as long as reasonably necessary to:

• Maintain your rewards account
• Provide SMS notifications
• Verify opt-in consent
• Meet regulatory and carrier requirements
• Resolve disputes and support inquiries

Retention periods may vary based on statutory, regulatory, or operational requirements. When data is no longer needed, it is securely deleted, anonymized, or archived according to our data retention policy.

6. Your Choices and Opt-Out Rights

6.1 Opt-Out Via Text Message

You may unsubscribe from SMS communications at any time by texting:

• STOP — Immediately ends all recurring SMS messages.
• UNSTOP — Resubscribes you to SMS messages if you previously opted out.

Opt-outs are processed automatically and promptly.

6.2 Assistance Commands

• Text HELP to receive assistance or program information.
• Contact us directly if you prefer human support.

6.3 Impact of Opting Out

If you opt out, you will no longer receive:

• Points notifications
• Prize wheel updates
• Rewards alerts
• Program or account updates

Some non-SMS communications may still be sent via email if you previously opted into those channels.

7. Data Security

We implement industry-standard administrative, technical, and physical safeguards to protect your personal information, including:

• Encryption of data in transit and at rest
• Secure servers and access-controlled systems
• Regular monitoring for unauthorized access
• Compliance with CTIA guidelines and TCPA requirements
• Use of secure APIs and authentication controls

While we follow best practices, no transmission method is 100% secure, and we cannot guarantee absolute security.

8. Age Restrictions

• Our SMS program is intended for individuals 18 years and older.
• We do not knowingly collect information from minors.

9. Changes to This SMS Privacy Policy

We may update this SMS Privacy Policy from time to time to reflect changes in laws, regulations, or program features. Any updates will be posted on our website with a revised effective date. Continued participation in the SMS program after changes indicates acceptance of the updated policy.

10. Contact Information

If you have questions, concerns, or requests regarding this SMS Privacy Policy, SMS data practices, or your rights, you may contact us: