Tigo Privacy Policy

(A) This Notice

Summary – This Notice

This Notice explains how we Process Personal Data. This Notice may be amended or updated from time to time, so please check it regularly for updates.

This Notice is issued by each of the Controller entities listed in Section (P) below (together, “Tigo”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our products or services, personnel of corporate customers and vendors, applicants for employment, and visitors to our premises (together, “you”). Defined terms used in this Notice are explained in Section (S) below.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

For California Residents, there is additional information that can be found in our “CCPA Additional Privacy Disclosures” notice which can be found here.

For EU/UK Residents, there is additional information that can be found in our “EU/UK Additional Privacy Disclosures” notice which can be found here.

This Notice was last updated on January 2, 2024.

(B) Collection of Personal Data

Summary – Collection of Personal Data

We collect or obtain Personal Data: when those data are provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make Personal Data public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Apps; when you visit our Sites; when you register to use any of our Sites, Apps, products, or services; or when you interact with any third party content or advertising on a Site or in an App. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

• Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application) or data provided to us by a distributor through whom you have acquired any Tigo products or services.
• Data we obtain in person: We obtain Personal Data during meetings, at trade shows, during visits from sales or marketing representatives, or at events we attend.
• Collaborations: We obtain Personal Data when you collaborate with us in research or in an advisory/consultancy capacity.
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
• Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
• App data: We collect or obtain Personal Data when you download or use any of our Apps.
• Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
• Registration: We collect or obtain Personal Data when you use, or register to use, any of our Sites, Apps, products, or services.
• Content and advertising information: If you interact with any third party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
• Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

(C) Creation of Personal Data

Summary – Creation of Personal Data

We create Personal Data about you (e.g., records of your interactions with us).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us. We may also combine Personal Data from any of our Sites, Apps, products, or services, including where those data are collected from different devices or sources.

(D) Categories of Personal Data we Process

Summary – Categories of Personal Data we Process

We Process: your personal details (e.g., your name); your contact details (e.g., your address); your professional details (e.g., your CV); records of surveys or testing in which you have participated; demographic data (e.g., your age); visitor logs for our premises; records of your consents; payment details (e.g., your billing address); information about our Sites and Apps (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We Process the following categories of Personal Data about you:

• Personal details: given name(s); preferred name; and photograph.
• Contact details: correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
• Correspondence: records and copies of your correspondence if you contact us.
• Professional details: your CV; records of your expertise; professional history; practising details and qualification details; information about your experience; participation in meetings, seminars, advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities; and other professional skills.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Visitor logs: records of visits to our premises.
• Consent records: records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).
• Purchase details: records of purchases and prices; and consignee name, address, contact telephone number and email address.
• Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
• Data relating to hardware, Sites, and Apps: operational and diagnostic data relating to Tigo hardware; device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data; and other technical communications information (some of which may constitute Personal Data); registration details; username; password; security login details; usage and performance data; and aggregate statistical information.
• Employer details: where you interact with us in your capacity as an employee of a third party; and the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
• Cookie data: we collect information via cookies and similar technologies.
• Security information: your password(s); login attempt details; security settings; and other security-related information.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

(E) Sensitive Personal Data

Summary – Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

• Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
• Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
• Establishment, exercise or defence of legal claims: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims; or
• Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

(F) Purposes of Processing and legal bases for Processing

Summary – Purposes of Processing and legal bases for Processing

We Process Personal Data for the following purposes: providing our Sites, Apps, products, and services to you; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, Apps, products, and services; fraud prevention; establishment, exercise and defence of legal claims; and recruitment and job applications.

The purposes for which we Process the categories of Personal Data identified in Section (D) above, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

(G) Disclosure of Personal Data to third parties

Summary – Disclosure of Personal Data to third parties

We disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites or our Apps.

We disclose Personal Data to other entities within the Tigo group, for legitimate business purposes and the operation of our Sites, Apps, products, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:

• you and, where appropriate, your appointed representatives;
• third party distributors through whom you acquire any of our products or services;
• accountants, auditors, consultants, lawyers and other outside professional advisors to Tigo, subject to binding contractual obligations of confidentiality;
• third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• any relevant third party provider, where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

(H) Profiling

Summary – Profiling

Personal Data are subject to automated decision-making and Profiling.

We Process Personal Data for the purposes of automated decision-making and Profiling, which is carried out for the following purposes:

(I) International transfer of Personal Data

Summary – International transfer of Personal Data

We transfer Personal Data to recipients in other countries. Where we transfer Personal Data from the UK or the EEA to a recipient outside the UK or the EEA (as applicable) that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses or the UK equivalent (i.e., the UK International Data Transfer Agreement / UK addendum to the Standard Contractual Clauses).

Because of the international nature of our business, we transfer Personal Data within the Tigo group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses or the UK equivalent (i.e., the UK International Data Transfer Agreement / UK addendum to the Standard Contractual Clauses). You are entitled to request a copy of our Standard Contractual Clauses or the UK equivalent (i.e., the UK International Data Transfer Agreement / UK addendum to the Standard Contractual Clauses) using the contact details provided in Section (P) below.

Please note that when you transfer any Personal Data directly to any Tigo entity established outside the UK or the EEA (as applicable), we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.

(J) Data security

Summary – Data security

We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

(K) Data accuracy

Summary – Data accuracy

We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up-to-date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

(L) Data minimisation

Summary – Data minimisation

We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

(M) Data retention

Summary – Data retention

We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose.

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

(1) we will retain Personal Data in a form that permits identification only for as long as:

(a) we maintain an ongoing relationship with you (e.g., where you purchase Tigo products or services, or you are lawfully included in our mailing list and have not unsubscribed); or

(b) your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

plus:

(2) the duration of:

(a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and

(b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

and:

(3) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

(N) Your legal rights

Summary – Your legal rights

Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights.

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, products, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (i.e., in relation to the UK, the Information Commissioner’s Office (https://ico.org.uk/) or in relation to the EU, the Data Protection Authority for EU Member State in which you live, or in which you work, or in which the alleged infringement occurred (see the list here: https://edpb.europa.eu/about-edpb/about-edpb/members_en)).

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

• the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such Processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR / UK GDPR; and
• the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (P) below. Please note that:

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(O) Direct marketing

Summary – Direct marketing

We Process Personal Data to contact you with information regarding Sites, Apps, products, or services that may be of interest to you. You may unsubscribe for free at any time.

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, products, or services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, Apps, products, or services. If we provide Sites, Apps, products, or services to you, we may send or display information to you regarding our Sites, Apps, products, or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may unsubscribe from our promotional email list at any time by at https://www.tigoenergy.com/contact-support or by e-mailing us at [email protected] or at [email protected] or by clicking the «unsubscribe» link in our newsletters and emails. Please note that it may take up to 2 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, products, or services you have requested.

(P) Details of Controllers

Summary – Details of Controllers

There are several Tigo entities that act as Controllers for the purposes of this Privacy Notice.

For the purposes of this Notice, the relevant Controllers are:

Alternatively, you may contact us using our online: Contact Support.

Our Data Protection Officer is contactable using the details set out above.

(Q) Representatives

Summary – Representatives

We have appointed a Representative in accordance with the GDPR / Representatives in accordance with the GDPR and the UK GDPR.

Each of the controllers established outside the EEA and listed in Section (P) above has appointed Mirko Bindi located at Via Calamandrei 36, 52025 Montevarchi, Italy to be its representative for the purposes of Article 27 of the GDPR.

Each of the controllers established outside the UK and listed in Section (P) above has appointed Parminder Singh Panesar located at 27 Old Gloucester St, Holborn, London WC1N 3AX to be its representative for the purposes of Article 27 of the UK GDPR.

(R) Information for California Residents

Summary – Information for California Residents

This section provides additional disclosures required by the California Consumer Privacy Act, as amended (the “CCPA”).

Under the California Consumer Privacy Act (the “CCPA”), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents. California Residents are also afforded certain rights with regard to the Personal Information we collect about them that include the rights of access, deletion, correction, and to be free from discrimination. To view the disclosures required by the CCPA, and information describing the rights afforded to California Residents, click here.

(S) Definitions

• “App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means) including, without limitation, Tigo SMART.
• “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
• “CCPA” means the California Consumer Privacy Act, as amended by the California Privacy Rights Act.
• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• “EEA” means the European Economic Area.
• “GDPR” means the General Data Protection Regulation (EU) 2016/679.
• “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.
• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• “Relevant Personal Data” means Personal Data in respect of which we are the Controller.
• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.
• “Sensitive Personal Information” is a specific subset of Personal Information that includes certain government identifiers (such as social security numbers); an account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account; precise geolocation; contents of mail, email, and text messages; genetic data; biometric information Processed to identify a consumer; information concerning a consumer’s health, sex life, or sexual orientation; or information about racial or ethnic origin, religious or philosophical beliefs, or union membership.
• “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
• “Site” means any website operated, or maintained, by us or on our behalf.
• “UK GDPR” means the GDPR as it forms part of the laws applicable in the UK by virtue of section 3 of the European Union (Withdrawal) Act 2018 and the Data Protection Act 2018, and as applied and modified by Schedule 2 of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419) or as modified from time to time.
• “UK International Data Transfer Agreement” means the template transfer agreement adopted by the UK Information Commissioner’s Office on 21 March 2022.

(T) Text Messaging Terms and Privacy

Summary - Text Messaging

Text messaging is optional. Message frequency varies. Reply STOP to opt out or HELP for assistance. We do not share SMS opt-in information or consent records for third-party marketing.

Scope and message types

These provisions describe how Tigo Energy handles text messaging and the Personal Data associated with it. They apply to messages sent by Tigo Energy and by service providers acting on our behalf. Messages may relate to inquiries, customer support, account or service information, scheduling, and other communications you request or consent to receive. The applicable message types are described when you opt in or request a text-message interaction.

Your choice and consent

Participation in text messaging is optional. Tigo Energy obtains consent through the process identified for the relevant service or interaction, which may include a form, a phone call, an in-person conversation, or another clearly described opt-in method. Consent applies to the purposes and message types disclosed at that time. Providing a phone number for another purpose does not, by itself, constitute consent to receive marketing texts. We keep consent and preference records to manage your choices.

Message frequency and charges

Message frequency varies depending on the service, messaging program, and your interactions with us. Any program-specific frequency information is provided when you opt in. Message and data rates may apply under your mobile provider's plan. Tigo Energy does not charge a separate fee for sending or receiving these texts.

Opting out and changing your preferences

Reply STOP to opt out of the text-message conversation or messaging program associated with the sending number. We may send one confirmation of your opt-out, after which no further messages will be sent from that conversation or program unless you opt in again. You may also contact customer care to change your preferences or request help with other Tigo messaging programs. To resume messages, follow the applicable opt-in instructions. The promotional-email unsubscribe process in Section (O) does not apply to SMS messages.

Help and customer care

Reply HELP for assistance, or email [email protected] for customer care and messaging-preference requests. For questions about how we handle your Personal Data, contact [email protected].

SMS privacy and sharing restrictions

We use mobile numbers, message content, delivery records, consent records, and messaging preferences to provide the requested communications, deliver messages, assist you, and honor consent and opt-out choices. Service providers that deliver or support text messaging may process the information needed to provide those services on our behalf.

Mobile numbers, SMS opt-in information, and consent records will not be sold or shared with third parties or affiliates for marketing or promotional purposes.