Privacy Notice

Introduction

This Privacy Notice for The Stormy Butterfly Foundation ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you visit our website at https://www.trustlinemobile.com or any website of ours that links to this Privacy Notice, download and use our mobile application (TrustLine), or engage with us in other related ways, including any marketing or events.

Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@stormybutterfly.org.

Summary of Key Points

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent, and only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties, described below.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information, though no method of transmission or storage can be guaranteed 100% secure.

What are your rights? Depending on where you are located geographically, applicable privacy law may give you certain rights regarding your personal information. The easiest way to exercise your rights is by contacting us.

1. What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us. This may include:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Usernames
• Passwords
• Contact preferences
• Approved phone contacts
• Approved email contacts

We do not process sensitive information.

Payment data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by Wix. You may find their privacy notice at https://www.wix.com/about/privacy.

Application data. If you use our application(s), we may also collect geolocation information, mobile device access (such as your device's contacts), and mobile device data (device ID, model, manufacturer, operating system, browser type, carrier, and IP address), primarily to maintain the security and operation of our application(s), for troubleshooting, and for internal analytics and reporting.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services, such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and information about how and when you use our Services. We also collect information through cookies and similar technologies, described further in our Cookie Policy.

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. SMS and Mobile Messaging Privacy

TrustLine includes the TrustLine Conservator-Controlled Conversational Messaging Program, which allows protected persons to exchange conversational SMS messages with conservator-approved contacts. SMS messages are only enabled when the recipient has been approved by the protected person's conservator and has opted in to receive SMS messages through TrustLine.

When you use or interact with TrustLine SMS messaging features, we may collect and process mobile phone numbers, assigned TrustLine phone numbers, names associated with protected persons, conservators, and approved contacts, conservator-approved contact relationships, SMS opt-in and opt-out status, consent records and timestamps, message delivery status and metadata (including Twilio or carrier delivery identifiers), message content when needed to provide the service, HELP and STOP requests, and logs needed to operate, secure, troubleshoot, audit, and enforce the messaging program.

We use this information only to operate, support, secure, and improve TrustLine and its SMS messaging program: providing SMS messaging between protected persons and conservator-approved contacts, verifying opt-in, enforcing conservator-approved allow-lists, delivering messages, processing HELP and STOP requests, preventing unauthorized or abusive messaging, troubleshooting, support, audit logging, and compliance with applicable laws and carrier requirements.

We do not sell, rent, lease, or share mobile phone numbers, SMS message content, SMS opt-in data, SMS consent records, or SMS opt-out records with third parties or affiliates for their marketing or promotional purposes, and we do not use this information for third-party advertising.

We may share SMS and mobile information with service providers only as necessary to operate TrustLine and provide the SMS messaging program (telecommunications, SMS delivery, cloud hosting, authentication, customer support, and security providers). These service providers may process this information only on our behalf and are not permitted to use it for their own marketing or promotional purposes.

You may opt out of TrustLine SMS messages at any time by replying STOP to any TrustLine SMS message, and may request help by replying HELP or contacting us at info@stormybutterfly.org or (+1) 415-640-1084.

We retain SMS and mobile information for as long as reasonably necessary to provide the messaging service, maintain consent and opt-out records, comply with legal and carrier requirements, prevent abuse, resolve disputes, enforce our agreements, and maintain accurate audit records, after which it is deleted or anonymized unless we are required or permitted to retain it.

3. How Do We Process Your Information?

We process your personal information to facilitate account creation and authentication; deliver and facilitate delivery of the Services you request; respond to inquiries and offer support; fulfill and manage orders, payments, returns, and exchanges; enable user-to-user communications; protect our Services, including fraud monitoring and prevention; evaluate and improve our Services, products, marketing, and your experience; and comply with our legal obligations.

4. When and With Whom Do We Share Your Personal Information?

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with these third parties designed to safeguard your personal information; they may not use it for any purpose beyond what we instruct, and may not share it with any organization apart from us.

The third parties we may share personal information with are as follows:

For SMS and mobile messaging, providers such as Twilio may process mobile phone numbers, assigned TrustLine phone numbers, message metadata and content, delivery status, and opt-in/opt-out records only as necessary to provide SMS, voice, telecommunications, compliance, security, troubleshooting, and support services on our behalf, and are not permitted to use this data for their own marketing purposes.

We may also share your information in connection with a merger, sale of company assets, financing, or acquisition of all or a portion of our business.

5. Do We Use Cookies and Other Tracking Technologies?

We may use cookies and similar tracking technologies to gather information when you interact with our Services, and permit third parties and service providers to use online tracking technologies for analytics and advertising. SMS consent data, SMS opt-in and opt-out data, mobile phone numbers, and SMS message content are not used for third-party targeted advertising or shared with third parties for marketing purposes. See our Cookie Policy for details on how you can refuse certain cookies.

6. Do We Offer Artificial Intelligence-Based Products?

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies ("AI Products"), including AI bots. All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third parties.

7. How Long Do We Keep Your Information?

We keep your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice requires us to keep your personal information for longer than six (6) months past the termination of your account. When we have no ongoing legitimate business need to process your information, we delete or anonymize it, or, where that is not possible, securely isolate it from further processing until deletion is possible.

8. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect your personal information. However, no electronic transmission or storage technology can be guaranteed 100% secure, so we cannot promise that unauthorized third parties will never defeat our security. Any transmission of personal information to and from our Services is at your own risk.

9. Do We Collect Information From Minors?

We do not knowingly collect, solicit, or market to children under 18 years of age. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of a minor and consent to their use of the Services. If we learn that personal information from a user under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. Contact us at info@stormybutterfly.org if you become aware of any such data.

10. What Are Your Privacy Rights?

If we are relying on your consent to process your personal information, you have the right to withdraw that consent at any time by contacting us. You may review or change the information in your account, or terminate your account, at any time; upon termination we will deactivate or delete your account and information from our active databases, though we may retain some information to prevent fraud, troubleshoot problems, assist investigations, enforce our legal terms, or comply with legal requirements. Most browsers let you remove or reject cookies, though this could affect certain features of our Services.

11. Controls for Do-Not-Track Features

Because there is not yet a uniform technology standard for recognizing and implementing Do-Not-Track ("DNT") signals, we do not currently respond to DNT browser signals. We do recognize and honor Global Privacy Control (GPC) signals: when we detect a GPC signal from your browser, we treat it as a valid request to opt out of the sale or sharing of your personal information for targeted advertising under applicable state privacy laws, including the California Consumer Privacy Act (CCPA), and apply your preference automatically.

12. Do United States Residents Have Specific Privacy Rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you, correct inaccuracies, get a copy of, or delete your personal information, and withdraw your consent to our processing of it. These rights may be limited in some circumstances by applicable law.

In the past twelve (12) months, we have collected identifiers (contact details, IP address), personal information as defined in the California Customer Records statute, protected classification characteristics, and geolocation data. We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months, though we have disclosed those same categories to service providers for business purposes as described in Section 4 above.

Depending on your state of residence, your rights may include the right to know whether we are processing your data, access it, correct inaccuracies, request deletion, obtain a copy, non-discrimination for exercising your rights, and opt out of processing used for targeted advertising, sale, or certain profiling. To exercise these rights, contact us at info@stormybutterfly.org. We will honor opt-out preferences signaled through Global Privacy Control. If we decline to act on your request, you may appeal by emailing the same address; if your appeal is denied, you may submit a complaint to your state attorney general.

California residents may also request, once a year and free of charge, information about categories of personal information we disclosed to third parties for direct marketing purposes in the preceding calendar year, under California Civil Code Section 1798.83 (the "Shine the Light" law).

13. Do We Make Updates to This Notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date. If we make material changes, we may notify you by prominently posting a notice or directly sending you a notification.

14. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, email us at info@stormybutterfly.org or contact us by post at:

The Stormy Butterfly Foundation
1875 S Bascom Ave, Suite 2400
Campbell, CA 95008
United States

15. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To make such a request, contact us at info@stormybutterfly.org.