Privacy Policy
1. Last Updated Date: November 6, 2024
This Privacy Policy explains how we process your personal data, including how we collect, use, and process your data, when you visit our website, request information, or subscribe to and use our services, including the GoContact Call-Center Solution. In doing so, we comply with our legal obligations, as your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights. This Privacy Policy applies to Smith Rose Finley, PC (referred to as “SRF”). The last update on November 6, 2024, to provide additional disclosures about the collection, use, and sharing of information.
2. Personal Information
i. Personal Information
In this Policy, “Personal Information” means any information relating to an identified or identifiable individual. Personal Information includes, but is not limited to, your name, physical address, email address and telephone number.
ii. Personal Information Provided by You
When you purchase or inquire about our service, buy equipment, create an account with us, or request information, we may collect information including but not limited to your name, company name, address, and contact information, such as email address, phone number, credit, and payment information to service your account and act upon your feedback or issues.
iii. Personal Information Collected via Automated Means
As a customer of SRF and its affiliated brands, we may automatically collect information using the service including but not limited to IP address, geolocation information, calling records, voicemails and transcripts, and contact information used in call routing.
iv. Third Parties
If SRF obtains information, including Personal Information, from sources other than our Services or receive information from others, we will treat the combined information as Personal Information in accordance with this Policy.
v. SRF Use of Information
SRF may collect and use subscriber identifiable information for billing, provisioning of service, resolution of problems associated with service, 411 type directory services, 911 emergency service, demographic data, and to inform subscribers of new products or services that will enhance their SRF experience. SRF may use subscriber identifiable information to market new products and services to the subscriber and to any channel partner that may have knowledge of the subscriber's services with SRF.
4. Your European Union Privacy Rights
If you are EU resident, you have the right to access, rectify, or erase your personal information, as well as the right to restrict or object to certain processing activities. We are committed to keeping you informed about the data we collect, how it is used, and your rights in relation to your personal information. Our privacy policy is designed to empower you with the knowledge and control necessary to make informed decisions about your privacy. To make a request, please send an email firm@smithrose.com or a letter to SRF, 521 W. Beauregard Ave, San Angelo, Texas 76903, 325-653-6721. with “Request for EU Privacy Information” in the subject line or body of the email or letter.
5. California Consumer Privacy Act (CCPA)
a. Applicability
This section applies only to California consumers. For purposes of this section “Personal Information” has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers' Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell Personal Information. These rights apply to all residents of CA, regardless of whether you are a customer, business contact, or member of the workforce. As a California resident, you have a right not to receive discriminatory treatment for the exercise of your privacy rights.
b. Categories of Information We Collect
- Identifiers - Such as real name, alias, address, unique personal identifier, online identifier, Internet Protocol address, email address, or account name.
- Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). - A name, address, or telephone number.
- Commercial Information - Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Sensitive Personal Information - Account log-in, access code, passwords, credentials, precise geolocation, and contents of email and text messages.
- Internet Network Activity - Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
- Geolocation Data - Physical location or movements.
- Sensory Data - Audio, electronic, visual, or similar information.
c. Your Rights Under CCPA
As a California resident, you may ask businesses to disclose what personal information they have about you and what they do with that information. You can request that a business disclose to you:
- the categories and/or specific pieces of personal information they have collected about you,
- the categories of sources for that personal information,
- the purposes for which the business uses that information,
- the categories of third parties with whom the business discloses the information, and
- the categories of information that the business sells or discloses to third parties. You can make a request to know up to twice a year, free of charge.
d. Right to Opt-out
If a subscriber wishes not to receive specified communications or have certain information used for specific purposes, they may opt out by contacting us at SRF. Subscriber should notify SRF in writing, not to participate in direct marketing of new products and services from SRF then subscriber's information will not be used for the purpose of marketing new products. Users may email firm@smithrose.com to opt-of direct marketing communications or use the unsubscribe feature provided on all email communications. Please specify your preferences and include your name, email address, and relevant details. SRF will make every effort to process this request promptly. Please note that even if you opt out, you may still receive transactional communications related to our products or services.
e. Right to Correct
You may ask businesses to correct inaccurate information that they have about you.
f. Right to Limit Use
You can direct businesses to only use your sensitive personal information for limited purposes, such as providing you with the services you requested.
g. Right to Delete
You can request that businesses delete personal information they collected from you and tell their service providers to do the same, subject to certain exceptions (such as if the business is legally required to keep the information).
h. Exercising Your Rights (Compliance Cal. Civ. Code § 1798.83)
California residents also have the right to request information regarding third parties to whom the company has disclosed certain categories of personal information during the preceding year for the third parties' direct marketing purposes under California's “Shine the Light” law (Cal. Civ. Code § 1798.83). Personal information under this California law means “any information that when it was disclosed identified, described, or was able to be associated with an individual.” We do not disclose this type of personal information to third parties for their own purposes and we permit you to opt out of any disclosures of non-identifiable personal information. However, if you are a California resident and would like to inquire further submit a verifiable consumer request with “Request for California Privacy Information” in the subject line to us by either:
A. Emailing firm@smithrose.com
B. Smith Rose Finley, 521 W. Beauregard, San Angelo, Texas 76903
Response Time
We strive to address a verifiable consumer request within 45 days of receiving it. Should additional time be necessary, we will notify you in writing, specifying the reason for the extension. We will communicate all required or requested responses and other correspondences in writing or via email. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If applicable, the response we provide will also explain any reasons we cannot comply with a request.
Non-Discrimination
We pledge not to discriminate against you, or any other individual should you choose to exercise your CCPA rights. Subject only to CCPA allowances, SRF will not: (i) refuse you goods or services; (ii) apply differing prices or rates for goods or services; (iii) offer varied levels or qualities of goods or services; or (iv) imply that you might receive different prices, rates, levels, or qualities of goods or services.
Duration of Personal Information
The retention period for the information we gather about you varies based on the nature of the data. Following this timeframe, we will either delete or anonymize your information. In cases where deletion or anonymization is not immediately feasible, such as when information is stored in backup archives, we will securely store and isolate your data, preventing any additional use until deletion becomes viable.
6. Children's Privacy Policy
SRF does not sell products or services for purchase or use by children. SRF does not knowingly solicit or collect subscriber identifiable information from children or teenagers under the age of eighteen. SRF will not knowingly link to any third-party web site that solicits or collects subscriber identifiable information from minors. If you believe that a minor has personally disclosed information to SRF, contact SRF at firm@smithrose.com so that the information can be removed.
7. Security
SRF is committed to safeguarding the security of your information and has implemented robust security measures against unauthorized access, disclosure, and alteration of such information. Although SRF has invested in a variety of security features to ensure the privacy of subscriber information on its network, be aware that no data transmission over the internet or electronic storage method is entirely secure. SRF has implemented strict operations guidelines to ensure subscriber privacy is safeguarded. SRF will continue to revise policies and implement additional security features as new technologies become available. However, no information transmission over the Internet is 100% percent secure. SRF cannot guarantee in any way that information provided to SRF by subscriber may not be illegally obtained from SRF.
9. Unlawful Activity
SRF also may use subscriber identifiable information to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of service, the network integrity, that otherwise violate SRF's Service Agreements or activities that are or may be illegal.
10. Compliance with CIPA 632(a)
In accordance with California Information Privacy Act (CIPA) Section 632(a), SRF is committed to ensuring the protection and privacy of your personal information. We adhere to the requirements set forth in CIPA 632(a) to safeguard your data and uphold your privacy rights. SRF will not read, listen to or disclose to any third parties private e-mail, voice conversations, or other private communications that are transmitted using SRF services, except as required to ensure proper operation of services or as otherwise authorized by law.
i. Notice and Consent.
Before initiating a live chat session, you will see a consent link. SRF is providing notice to online users that by continuing to chat, you consent to this chat being recorded and stored in with SRF’s software vendor in accordance with our Privacy Policy. This step aims to ensure that users are given sufficient notice and are fully aware of and consent to any recording of their communications under CIPA.
ii. Chatbot Software Vendor
- SRF software chatbot vendor does not monitor or view the contents of Customer chats with its site visitors (unless and only to the extent expressly directed by the Customer to do so during customer success calls).
- They do not use any chats or the contents thereof for its own purposes, nor does it sell any Customer data to third parties.
- They do not share or sell any information with third parties.
- Our software chatbot vendor is the medium for communication. It is not communicating with site visitors or eavesdropping on chats. Our software chatbot vendor only has access to chats for customer and technical support purposes only.
- Contact. For any inquiries or concerns regarding our compliance with CIPA 632(a), please contact our Data Protection Officer at firm@smithrose.com.
11. Account Information
The subscriber is responsible for ensuring that the information on file with SRF is current and accurate. Subscribers may update the information they have on file by contacting our customer service department through phone or via our website at www.smithrsoe.com.
12. Changes to This Privacy Policy
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Services after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.
How to Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at:
A. Emailing firm@smithrose.com
Smith Rose Finley
521 W. Beauregard
San Angelo, Texas 76903