Last modified: April 25th 2024

Introduction

Subprime Marketing Group ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website https://subprimemarketinggroup.com/ (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.

• In email, text, and other electronic messages between you and this Website.

• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party; or

• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at https://subprimemarketinggroup.com/contact-us

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, and any other identifier by which you may be contacted online or offline ("personal information");

• That is about you but individually does not identify you, and/or

• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

• Records and copies of your correspondence (including email addresses) if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.

• To provide you with information, products, or services that you request from us.

• To fulfill any other purpose for which you provide it.

• To provide you with notices about your account/subscription, including expiration and renewal notices.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to our Website or any products or services we offer or provide though it.

• To allow you to participate in interactive features on our Website.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the order form/registration form)/adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our user,, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

• To third parties to market their products or services to you if you have consented to/not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.

• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Website, we will transmit the contents of that email and your email address to the recipients.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply our terms of use or terms of service and/or other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to info@subprimemarketinggroup.com.

• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an email with your request to info@subprimemarketinggroup.com

• We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Accessing and Correcting Your Information

You may send us an email at info@subprimemarketinggroup.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Residents of certain states, such as California, Nevada, Colorado, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California, Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.

• Access and delete certain personal information.

• Data portability.

• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.

• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please contact us at info@subprimemarketinggroup.com

However, please know we do not currently sell data triggering that statute's opt-out requirements

RingCentral SMS/ MMS content policies

As a participating TCR CSP, RingCentral is dedicated to providing the highest quality of service, while working to eliminate spam, phishing, and fraudulent messages. To help ensure these goals are met, and in accordance with CTIA messaging guidelines, the Short Code Monitoring Handbook, T-Mobile’s Code of Conduct, and AT&T’s Code of Conduct the following policies apply to our SMS/ MMS solutions, whether sent via the RingCentral App, a third party provider, or via the API.

Additional policies, regulations, and laws may exist beyond those listed below. The following is not legal advice. It is strongly recommended you consult your own legal advisor for help understanding legal obligations you may have, given the kind of messaging you wish to send.

Enhanced Business SMS

Use of Enhanced Business SMS must comply with RingCentral's Terms of Service and Acceptable Use Policy.

RingCentral Enhanced Business SMS guidelines

• Send no more than 50 messages per originating number per minute
• If sending marketing, promotional or informational messages, capture written consent of recipients prior to sending your messages
• Do not use purchased lists or third party generated lead lists when sending SMS
• Provide clear opt-out instructions on informational, marketing, or promotional messages
• Avoid using link shorteners and non-branded domains for embedded links
• Complete required TCR registration prior to sending SMS messages

If you need to send more than 50 messages per originating number per minute, please evaluate utilizing our High Volume SMS solution which allows up to 60 messages per minute for long code numbers, and 180 messages per minute for toll-free numbers.

Automated messaging

Automated SMS messaging may be used on RingCentral's platform through RingCentral provided tools, third-party integrations, and RingCentral SMS APIs. Automated messaging must only be sent from numbers that have been linked to a TCR campaign designed for automated messaging (ie an "Automated" campaign type). Prior to sending any automated messages, you must have express and logged consent as outlined by the CTIA guidelines from the recipient to message them. Promotional messages (regardless of if automated) must have express, written, and logged consent. Automated messages must include opt-out language on each message (eg “Reply STOP to end”), and all opt-out requests must be honored.

Opt-in/ user consent

Before sending an SMS message to any number you must have their express consent to do so. It's important to note that implied consent is not considered sufficient for SMS outside of immediately responding to a received message, nor is purchasing a list of "users who have opted in to SMS." A user must actively ask to receive SMS messages from you. Remember, consent must be given for each campaign or message type you intend to send. Marketing or promotional messages require the recipients’ express prior written consent.

Examples of obtaining consent include using a web form where it is clearly explained that a user is opting into SMS messages, or by having them send a message to your number. It is highly recommended to use a double opt-in, confirming their consent via SMS and validating their number.

You must also log and track consent, and opt-ins and opt-outs. In certain cases carriers may request proof that an individual has opted in including an overview of how your opt-in/ opt-out process works.

Failure to ensure opt-in may result in your number or service being blocked or suspended by mobile carriers or RingCentral.

Opt-out

You must provide a clear way for users to opt out of your SMS messages, via text. The CTIA guidelines provide clear command keywords that must be honored for opt-out requests, including STOP and UNSUBSCRIBE.

Instructions for opt-ing out must be included on any informational or promotional messages.

Long-code and Toll-free SMS when used outside of our High Volume SMS solution do not automatically manage opt-outs, and you will need to manage and track opt-out requests when not using High Volume SMS. Similarly, you will need to manage opt-outs received through other methods, to avoid sending SMS to consumers that have opted out.

Prohibited campaigns

While SMS provides a great way to engage your opted-in customers, there are limitations and restrictions in terms of what types of messages may be sent, and to the content of the messages. The following campaigns (use cases) are strictly prohibited across all of RingCentral's SMS solutions:

• Loan and mortgage advertisements
• Credit repair offers
• Debt relief offers
• Debt collection attempts
• Work from home advertisements
• Secret shopper advertisements
• Political advertisements and messages
• Alcohol, tobacco, or firearms advertisements
• Pharmaceutical, vitamin, or other drug advertisements
• Campaigns that may be similar to the above

In addition, businesses that engage in the following activities are prohibited from using SMS, regardless of their message content, consent, or how they would otherwise use SMS:

• Companies that engage in indirect lending (or otherwise are providing loans not financed directly by them), short-term high-interest loans, payday loans, or student loans
• Companies that offer services for stocks, bonds, cryptocurrency, or other types of investment opportunities
• Companies that engage in or provide gambling or sweepstakes
• Companies that engage in credit repair, debt relief, debt collection, or tax relief services
• Companies that promote or provide work from home opportunities including but not limited to multi-level marketing opportunities
• Companies that promote, sell, or otherwise reference products or services related to alcohol, tobacco (including vape), firearms, or fireworks
• Companies that promote, sell, or otherwise reference substances defined as controlled substances under federal law, regardless of legality, including marijuana (cannabis)
• Companies that promote, sell, or otherwise reference Kratom or similar substances, regardless of legality
• Companies that buy, sell, or otherwise share SMS opt-in or phone numbers for the purpose of sending SMS with third-parties
• Companies that engage in third-party affiliate/lead generation, including the collection of information to be shared with loan providers, service providers, or for other lead generation purposes

Note: RingCentral is currently unable to offer exceptions to the above prohibited campaigns. Messages similar in nature may also be blocked by RingCentral or the carriers at their discretion. Some messages (e.g., an update on your loan application) may be blocked accidentally, in which case RingCentral recommends filing for an individual brand ID and a campaign specific to your messages.

Prohibited content

The following message content is also strictly prohibited and may result in your service being blocked or suspended by the carriers or RingCentral:

• Messages that engage in any illegal activity or otherwise violate our terms of service, including the acceptable use policy
• Messages that engage in or promote, pornographic or adult entertainment, regardless of legality
• Messages that contain text or references to violence, hate speech, or otherwise engaging in threatening, abusive, harassing, defamatory, libelous, deceptive or fraudulent behavior
• Messages that contain text or otherwise reference substances defined as controlled substances under federal law, regardless of legality, including marijuana (cannabis)
• Messages that contain third-party affiliate/lead generation links
• Messages that contain obfuscated links for the purpose of misleading the reader, or use links contrary to the expectation of the user based on the message text
• Messages that are structured to evade this policy or the policies of carriers (e.g. misspelling, uncommon capitalization, snowshoeing, etc.)

RingCentral reserves the right to add to this list at any time or determine messages are prohibited at its discretion.

Carrier fees and account restrictions

Accounts in violation of RingCentral or carrier rules and regulations may be subject to reduced deliverability of messages, additional campaign registration requirements and fees, suspension of service, or termination of service in addition to fines and other penalties passed through RingCentral by the carriers.

It is your responsibility to be aware of any additional restrictions or changes to policies, regulations, and laws when sending SMS messages, and to adhere to any and all policies related to the recipient number.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by updating this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

info@subprimemarketinggroup.com