Privacy Policy

LiveContact's websites, mobile applications and messaging platform (our "Sites") are operated by LiveContact, LLC, a Delaware limited liability company ("LiveContact," "we," "us," or "our"), with offices located at Street Address, City, State ZIP.

This Privacy Policy ("Policy") explains how our service works, and how we collect, use, and disclose personal information. If you have questions or concerns about our privacy practices, please contact us using the contact information in Section 17, below.

Please read this Policy carefully. By accessing or using any of the Sites, you acknowledge that you have received and reviewed this Policy, and you consent to data processing by us as described herein. Your use of the Sites is also subject to our Terms of Service and Mobile Messaging Terms of Service (link). Certain processing activities, features, or communications may be subject to additional notices, choices, or consent requirements under applicable law.

Also, please note the following:

• Dispute Resolution: Section 15 ("Dispute Resolution") explains how we handle privacy-related concerns and disputes. By using the Sites you hereby agree to be bound by the terms of Section 15, herein.
• AI Notice: We use AI-enabled tools both to help generate contact cards and related content for our Customers, and to help us monitor, secure, and improve our systems, such as for fraud detection and product analytics, as described in Section 1(b), below. For information about the AI models we use and how we govern AI-enabled features, see Section VI of our Terms of Service. For a current list of our AI and other Service Providers, contact us at privacy@livecontact.com.

(a) Service Overview

LiveContact provides a software platform ("Platform") that enables businesses (each a "Customer") to: generate digital contact cards and profile pages; distribute contact information via QR codes, links, and embedded tools; collect contact information (including phone numbers and email addresses) from individuals; facilitate communications, including SMS, MMS, email, and other messaging channels, sent by Customers to individuals (each, a "Recipient"); and manage Customer engagement and contact records.

As explained in our Terms of Service, LiveContact is a technology platform. Communications sent through the Platform are sent (in each case) by the Customer (not LiveContact) and are transmitted via our Platform with the help of one or more third-party communications service providers we engage (each, a "Communications Service Provider"). In each case, our Customers are responsible for determining whether their communications comply with applicable law, and our Customers are responsible for obtaining and maintaining all required consents and permissions. LiveContact does not provide legal advice or independently determine whether a Customer's particular communication is lawful or authorized.

(b) AI Features

We use artificial intelligence in two distinct ways:

• AI Tools Which Help Create Contact Cards: Our Platform includes AI-assisted features ("AI Tools") that help Customers create, organize, summarize, or enrich Customer contact cards, Customer profile pages, and related content. When a Customer uses these features, certain information and data (such as publicly available content from a website that the Customer identifies to us, and also information that the Customer may type or upload directly, collectively "AI Inputs") are collected and sent to a third-party AI model, and the AI model then generates suggested content ("AI Output") for the Customer's review. These AI Outputs are limited to contact cards, profile pages, and related content.
• Inferred Information: Information which is identified, inferred, summarized, or generated through AI Tools does not, by itself, establish consent or authorization to contact any individual, or to take any other action.
• AI Tools; Training of AI Models: We do not train, fine-tune, or otherwise modify AI Tools, and we do not use this information, or any Customer's AI Output, to train any AI model. Section VI of our Terms of Service describes these AI Tools, and the Customer's obligation to review AI Output before using it, in more detail.
• Internal AI-Enabled Tools: We may also use AI-enabled tools internally to help us monitor, secure, and improve our systems, for example, to help detect and prevent fraud or abuse, to support customer support functions, and for product analytics. We do not use this internal AI processing to make decisions that produce legal or similarly significant effects concerning an individual without human involvement, and we do not use Personal Information collected for these internal purposes to train AI models made available to other companies.

We respect and care about your privacy and security, and we strive to meet the requirements of applicable law. When we collect personal data, we are committed to:

• Data minimization: We collect only data which is necessary for a business purpose;
• Purpose limitation: We process data only as instructed or authorized;
• Security by design: We implement reasonable technical and organizational safeguards; and
• Transparency: We strive to clearly describe our service, our role, and our privacy practices.

We do not use Recipient Data for our own independent marketing purposes, we do not use Customer Data or Recipient Data to train any AI model, and we do not sell Customer Data or Recipient Data to third parties.

This Policy describes both (i) Personal Information that LiveContact processes for its own purposes, for which LiveContact may act as a controller, covered business, or equivalent entity under applicable law, and (ii) Customer Data that LiveContact processes on behalf of Customers as a service provider, contractor, processor, or equivalent entity. Our role and responsibilities differ depending on the context, as described below.

If you are a Recipient who has received a communication from a Customer via our Sites (for example, an email or SMS message), please review that Customer's own privacy policy for information about how your data is handled and what rights may be available to you. This Policy also describes, in Section 3(c) below, the categories of Recipient Data we may process on a Customer's behalf, and our limited independent role when a Recipient makes an explicit platform-wide suppression request to LiveContact.

(a) Data We Collect, and For Which We Are the Controller / Covered Business

We collect certain data when we operate our Sites and provide services to our Customers, and when we do so, we act as the controller (or covered business, or equivalent term) with respect to that data. This data includes:

• Account Information (defined below) and AI Inputs provided by or collected from our Customers;
• Website usage and analytics data;
• Direct communications with us received from Customers, Recipients or others;
• De-identified or Aggregated data (see Section 7(f));
• Data provided to us by our Communications Service Providers which relate to our services; and
• Communications preferences of individuals who contact us directly.

Collectively, the foregoing is referred to as "LiveContact Data."

(c) Customer Data and Recipient Data (We are a Service Provider)

(c.1) Customer Data: We process certain personal and non-personal data and information provided by, and controlled by, our Customers, in order to provide our services to them. In this context, "Customer Data" means Personal Information submitted to or processed through the Sites by or on behalf of Customers. Customer Data includes:

• Contact information of Recipients designated by a Customer to receive communications via the Sites (e.g., name, phone number, email, title) ("Contact Records");
• Other personal information about Recipients added to the Sites by a Customer;
• Other non-personal information added to the Sites by a Customer;
• Communication records related to Recipients; and
• Recipient profile and engagement data.

(c.2) Recipient Data: The subset of Customer Data that identifies or relates to a Recipient is referred to as "Recipient Data." Except for limited processing that applicable law permits a service provider, contractor, or processor to perform for its own operational purposes, we process Customer Data, including Recipient Data, on behalf of and under the instructions of our Customers and subject to our agreements with them. As explained in our Terms of Service, Customers are responsible for:

• obtaining all consents and permissions required by applicable law before messaging a Recipient (including without limitation all Do Not Call (DNC) regulations), for the applicable channel and campaign purpose, and maintaining auditable records of that consent (including the certification required under our Mobile Messaging Terms);
• understanding that a Contact Record does not, by itself, establish messaging permission, and that information derived from our AI Tools does not establish consent;
• providing any notices required by applicable law to Recipients and other third parties;
• honoring opt-out requests processed through our Communications Service Providers, and not attempting to circumvent Recipient suppression;
• providing Recipients with access to applicable consumer-rights options;
• ensuring lawful use of the Sites by all Customer personnel;
• complying with all applicable privacy, marketing, communications (including the TCPA, CAN-SPAM Act, and CTIA guidelines, DNC laws and regulations), consumer protection, and related laws and industry standards;
• verifying the accuracy of Generated Content before it is published or sent; and
• responding to Recipient requests effectively and in a timely manner.

We strive to collect as little Personal Information as possible when we provide our services. This section describes the categories of information (personal and non-personal) that we may collect, or that we may have collected in the prior 12 months, for the purposes described in this Policy.

Two important terms used throughout this Policy:

• "Personal Information" refers to data or information that can be linked to an identified or identifiable person. In this Policy, Personal Information also includes "Sensitive Information." Under various laws, the term ‘Personal Information’ may also include other information depending on how it is used and whether it is linked with other information.
• "Sensitive Information" generally refers to certain kinds of personal information that receive additional protections or restrictions under applicable law (e.g., payment card information, or in limited circumstances, an account password).

(a) Account Information

If you create an account, you may be required to disclose certain account information, as described below ("Account Information"), which may include:

• Account registration information, such as name, email address, phone number, account credentials (including passwords, which we store using industry-standard security measures such as hashing), and account settings. We use Account registration information to administer and secure your account, to communicate with you, and as otherwise described in this Policy.
• Billing and transaction confirmation data. We partner with a third-party payment processor (one of our Service Providers, described below) to process payments on our Sites. When you make a payment through this Service Provider, we only receive confirmation that a payment was received, the amount, and the account for which it was received.

(b) Sensitive Information

The Sites are not designed for Customers or other users to submit Sensitive Information unless expressly permitted by LiveContact. Account credentials may constitute Sensitive Information under certain laws. In addition, because Customers control the information they submit to the Sites, Customer Data could include other information that applicable law treats as sensitive. Customers should not submit government identification numbers, precise geolocation, financial account numbers, health information, or other Sensitive Information unless the submission is expressly permitted under their agreement with LiveContact and is lawful. LiveContact does not intentionally solicit those categories of Sensitive Information for general use of the Sites.

(c) Device Information

We may automatically collect device information ("Device Information") regarding how you access and use our website(s), such as:

• The type of device you use;
• The date and time you access the website(s);
• The type of web browser you use, and the Internet Protocol address used;
• The sections within our websites that you access;
• The user language; and
• The operating system of your device.

(d) Interaction Information

"Interaction Information" may include:

• Our communications with you: If you receive an email, SMS, or other message from us directly (as opposed to a message from a Customer sent via our Sites), we may collect information you share in response, and may use tools to capture data related to when you respond, open our message, or click on any links or banners it contains.
• Your communications with us: These may include information you submit if you contact us directly for support or other purposes.
• Website interactions: How you interact with our website(s), links you click, and information you type into online forms on our Sites.
• System information collected when you visit our websites: Browser type, operating system, IP address, domain name, referring website, and/or a date/time stamp.

(e) No Biometric Information

LiveContact does not collect biometric information (as defined under applicable law) for user identification or any other purpose. You may be able to use certain features (e.g., facial recognition) available in third-party operating systems (e.g., Apple's iOS) to access our mobile applications, but we do not collect or store any biometric information from those third-party processes.

We collect Personal Information in the following ways, pursuant to applicable law:

• Directly from you, when you use our Sites, register for an account or create a profile, contact us, send support requests, sign up to receive communications, submit survey responses, or otherwise provide or request information.
• Through cookies or other marketing or service-management technologies, when you visit our website(s), open or click on emails we send, or interact with our advertisements.
• From our third-party partners, including those that help us provide the services you have requested.
• Other sources, including data analytics providers or publicly available sources.
• From our Customers, as described in Section 3(c), above.

We may use Personal Information for the following business purposes:

• To create and administer accounts for authorized users of Customers, and to facilitate and provide services.
• For everyday business purposes, such as account management, contract administration, Site management, corporate governance, and legal and regulatory reporting.
• To assist Customers in using and accessing our services and Sites, including responding to questions, operating the Sites, and performing our obligations.
• To respond to feedback or requests for support.
• To send marketing or informational communications to our Customers that promote LiveContact products, programs, or services (with consent, where required).
• To analyze, improve, and develop our Sites and services. For LiveContact Data, this may include general product development and analytics as described in this Policy. For Customer Data, we limit such processing to providing, securing, maintaining, supporting, and improving the services provided to our Customers, and to other purposes permitted by our agreements and applicable service-provider, contractor, or processor requirements, including through the internal AI-enabled tools described in Section 1(b).
• To comply with laws, regulations, and legal processes.
• To monitor compliance with our policies and applicable terms of service, for fraud prevention, to detect and address illegal activity, and to protect LiveContact, our authorized users, Recipients, and property.
• For customer and authorized user relationship management and administration.
• Where permitted, to create aggregated or de-identified data in accordance with applicable law, including for statistical, analytic, research, security, and service-improvement purposes. Where required by law, we will maintain such information in de-identified form and will not attempt to re-identify it.
• To monitor and improve the effectiveness and functionality of the Sites, personalize your experience, and troubleshoot problems, using Device Information, including with the help of third-party partners.
• To respond to requests for information or support from Recipients who have received messages from Customers via our Sites, including requests concerning Customer-specific opt-outs.
• To provide the Services to our Customers using Customer Data.

In addition to specific situations discussed elsewhere in this Policy, we may disclose, or have disclosed in the prior 12 months, the Personal Information listed above for the following business purposes, as permitted by applicable law:

(a) Disclosures to Service Providers We Engage to Provide Part of Our Services

LiveContact may disclose Personal Information (including LiveContact Data and Customer Data) to companies we engage to perform services on our behalf ("Service Providers"), such as cloud hosting partners, our AI model provider, and our Communications Service Providers (which handle message transmission and related compliance functions such as opt-out processing). Service Providers' access is strictly limited to the purpose of providing the relevant service, and in certain cases, a Service Provider's own privacy policy may also apply to your use of the Sites.

(b) Disclosures to Our Third-Party Professional Service Providers

We may disclose Personal Information to professional service providers, such as external auditors, attorneys, and accountants, based on our legitimate business interests and our obligations to comply with applicable law. These providers may use your Personal Information to provide services to us and to comply with their own legal and professional obligations.

(c) To Comply with Legal Obligations and to Respond to Authorities

We may disclose your Personal Information to satisfy applicable laws or regulations, and in response to legal process or an enforceable government or law enforcement request. We may also disclose Personal Information if reasonably necessary to monitor compliance with our policies and applicable terms of service, to detect, prevent, or address fraud, security, or technical issues, or to protect the rights, property, or safety of LiveContact, our authorized users, Recipients, or the public.

(d) Disclosures to Affiliated Companies, and to a Subsequent Owner or Operator

We may share Personal Information with parent, subsidiary, or affiliated entities. We may transfer Personal Information to a successor entity upon a merger, consolidation, or other corporate reorganization, to a purchaser of all or a portion of our assets, or in connection with a financing arrangement.

(e) Social Media Platforms and Networks

Some Sites may include links or tools made available by social media platforms and networks ("Platforms"), which may result in information being collected by those Platforms if you use them. Platforms' use of your information is not governed by this Policy, and use of any Platform is solely at your own risk.

(f) De-Identified or Aggregate Information

We may aggregate, deidentify and/or anonymize information in a way that ensures it is no longer identifiable to you or Recipients, and use or disclose that information at our discretion, in accordance with applicable law, including for statistical, analytic, and administrative purposes.

(g) No Sale or Sharing for Cross-Context Behavioral Advertising

LiveContact does not sell Personal Information or share Personal Information for cross-context behavioral advertising, as those terms are defined under applicable law, except as expressly disclosed in this Policy or with your consent where applicable. We may otherwise disclose Personal Information to Service Providers and other recipients for the business and operational purposes described in this Section 7. The terms "sell," "share," and "disclose" may have different meanings under applicable privacy laws and are not used interchangeably in this Policy.

(h) Mobile Messaging Services (SMS, MMS, Chat)

Except as expressly provided above in this Section 7, and except as necessary to send authorized communications via SMS, MMS, or chat: (1) we will not share mobile telephone numbers with third parties or affiliates for third-party marketing or promotional purposes; and (2) we will not share SMS/MMS opt-in/opt-out data or consent records with any third parties, unless required to administer our Sites or provide services to our Customers.

Customer-specific opt-out and suppression requests (such as an SMS "STOP" reply) are processed through our Communications Service Providers and reflected in the applicable messaging controls. An opt-out from one Customer does not automatically operate as a platform-wide opt-out from unrelated Customers unless the Recipient clearly makes a platform-wide request to LiveContact as described in Section 3(b). Our Customers' use of mobile messaging features is expressly subject to LiveContact's Mobile Messaging Terms and Conditions, available at link.

We process Personal Information for the purposes described in this Policy and as otherwise permitted or required by applicable U.S. law. Where a specific activity requires specific additional consent (e.g., certain messaging-related consents), we may seek that consent separately as appropriate; otherwise, our processing is based on the purposes and relationships described in this Policy and our applicable agreements.

The Sites are not directed to individuals under the age of 18 for purposes of creating or maintaining a LiveContact account, and individuals under 18 are not permitted to register for or directly use the Sites as account holders. Because Customers control the Recipient Data they submit or process through the Sites, LiveContact may process information concerning individuals under 18 on a Customer's behalf even though LiveContact does not knowingly solicit such information directly from minors.

If you believe an individual under 18 has impermissibly created an account or submitted Personal Information directly to LiveContact, please contact us. We will take commercially reasonable steps to investigate and, where appropriate, delete or restrict the information consistent with applicable law and our legal obligations.

Customers are responsible for ensuring that their collection and use of Recipient Data concerning minors, and any communications directed to minors, comply with applicable law and LiveContact's terms. If you believe a minor has received an improper Customer communication through the Sites, please contact the applicable Customer and, if appropriate, LiveContact. We may assist the Customer, restrict processing, or apply Customer-specific or platform-wide suppression where appropriate and consistent with the request and applicable law.

LiveContact may use cookies (small text files placed on your computer or device that help our Sites function) in connection with our websites, and we may analyze information derived from cookies for the purposes described in this Policy.

We differentiate between cookies that are essential for the technical features of the Sites and optional analytics or advertising cookies. Depending on your location and applicable law, you may be able to adjust your cookie preferences using our Cookie Banner under "Settings," or other options available on the relevant Sites. If you use a different device to access the same Sites, you may need to manage settings separately for each device.

You may also be able to limit cookie use through your browser settings, although that may affect certain Site functions.

This section describes rights that may be available to you under applicable U.S. state privacy laws (such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and comparable laws in other states), with respect to Personal Information that is LiveContact Data ("LiveContact Personal Information"). Your rights will vary depending on where you are located. For Personal Information that is Customer Data, please contact the applicable Customer to understand the rights that may be available to you. If we receive a rights request directly from a Recipient concerning Customer Data, we may refer the request to the applicable Customer and will assist the Customer as required by applicable law and our agreement with that Customer.

With respect to LiveContact Personal Information, you may have the following rights:

• Correction: You may have the right to request that we correct inaccurate or incomplete LiveContact Personal Information.
• Deletion: You may have the right to request that we delete your LiveContact Personal Information. If required by law, we will grant your request. When we delete LiveContact Personal Information, it will be removed from our active databases, though it may remain in archives where deletion is not practical, and we may retain information as needed to comply with legal obligations, resolve disputes, or enforce our agreements.
• Access / Right to Know: You may have the right to request access to the LiveContact Personal Information we hold about you, including the purposes of processing, the categories of recipients to whom it has been disclosed, its sources, and retention periods.
• Data Portability: In certain circumstances, you may have the right to receive the LiveContact Personal Information you provided to us in a structured, commonly used, machine-readable format, and to transmit it to another entity.
• Consent Withdrawal: Where our processing is based on your consent, you may withdraw it at any time; however, you may not be able to use the Sites or features for which you withdraw consent. Withdrawal does not affect the lawfulness of processing conducted before withdrawal.
• Opt-Out of Sale or Sharing, or Targeted Advertising: You may have the right to opt out of the sale or sharing of LiveContact Personal Information, or its use for targeted advertising. As described in Section 7, LiveContact does not sell or share Personal Information except as described in that Section.
• Limit Use of Sensitive Information: Depending on applicable law and the information involved, you may have rights to limit certain uses or disclosures of Sensitive Information. As described in Section 4(b), the Sites are not designed for general submission of Sensitive Information, although Customer Data may contain information that applicable law treats as sensitive.
• Non-Discrimination: We do not discriminate or retaliate against individuals who exercise the rights described in this Policy.
• Appeal: If we decline to act on your request, you may have the right to appeal our decision. We will provide instructions for submitting an appeal in our response to your request.
• Automated Decision-Making: We do not engage in automated decision-making, without human involvement, for decisions that produce legal or similarly significant effects concerning an individual.
• Recognized Opt-Out Preference Signals: LiveContact takes commercially reasonable measures to recognize opt-out preference signals (e.g., Global Privacy Control) on its website(s), where required by applicable law. Recognition of such a signal applies only to the specific device and browser that sends it.
• Promotional Emails: You may provide your email address so that we can send newsletters, surveys, offers, and other promotional materials. You can stop receiving these by following the unsubscribe instructions in our emails or by contacting us.
• Promotional Text Messages: If you receive a promotional text message from us directly (as opposed to a message from a Customer sent via our Sites), you can opt out of future messages by replying "STOP" (or as otherwise directed), or by contacting us.

Many of these rights are limited to certain jurisdictions and subject to exceptions. Your rights and our response will vary based on the circumstances of your request. We will respond within the time period required by applicable law, and may limit or deny a request where permitted or required by law, where we cannot adequately verify your identity, or where the applicable law does not apply to us. If we cannot provide the requested information or make the requested change, we will explain why.

If you designate an authorized agent to submit a request on your behalf, we will require verification that you authorized that agent, and we will use available information to verify your identity (and, where applicable, your agent's identity and authority). Every request must: (i) include sufficient information for us to reasonably verify you are the person about whom we collected Personal Information, or an authorized representative; and (ii) describe the request with enough detail for us to understand, evaluate, and respond to it.

To submit a request to exercise any of these rights, please use the contact information in Section 17 ("Contact Us").

We maintain reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, acquisition, disclosure, alteration, or destruction. No security program or online system can eliminate all risk, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality and security of your login credentials and for promptly notifying us if you believe your account has been compromised.

How long we retain Personal Information depends on the context and purposes for which it was collected. We generally retain Personal Information for as long as necessary to achieve the purposes for which it was collected or processed, unless a different retention period is required by applicable law.

We are not responsible for the privacy or security practices of any third-party website or service, including any linked to or referenced on the Sites. We may provide links to third-party websites solely as a convenience; such linking does not mean we endorse, are affiliated with, or make any representation about that third-party website. LiveContact neither reviews, controls, nor is responsible for third-party sites or their content. Any Personal Information you provide to a third-party site is governed by that site's own privacy policy, and you access such sites entirely at your own risk. We encourage you to review the privacy practices of any third-party website before providing Personal Information.

LiveContact is a Delaware limited liability company, with offices located within the United States. This Policy is designed to address U.S. legal requirements, and our Sites and Services are directed toward individuals located in the United States. Our servers and infrastructure are located in the United States. If you access the Sites from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, and you consent to that transfer. U.S. law may offer different protections for your information than the laws of your home jurisdiction. We will take reasonable steps to ensure that Personal Information is treated securely and in accordance with this Policy.

(a) Concerns Related to Our Privacy Practices: Written Notice and Good-Faith Resolution

If a claim, complaint, or dispute arises from the terms of this Policy or LiveContact's privacy practices (a "Privacy Claim"), you agree to first submit your Privacy Claim to us in writing, using the contact information in Section 17, before taking any other action. We will investigate each Privacy Claim in good faith and respond within a reasonable time, and will attempt in good faith to resolve it to your satisfaction.

(b) Binding Arbitration (For All Other Claims or Disputes)

Any claim, complaint, or dispute that does not qualify as a Privacy Claim, or any Privacy Claim not fully resolved under Section 15(a), will be considered a "Dispute" under Section XIV of our Terms of Service, and will be finally and exclusively resolved by binding arbitration in accordance with the terms of that Section XIV, including its class action waiver.

We may update and post revisions to this Policy from time to time. Changes are effective immediately upon posting of the revised Policy. We encourage you to review this page periodically. This Policy was last updated as of the effective date listed above.

If you have concerns or questions about our privacy practices, the terms of this Policy, or your Personal Information, please contact us at:

privacy@LiveContact.comLiveContact, LLCStreet AddressCity, State ZIP1-800 phone number

Privacy Rights: To exercise any individual rights you may have, please submit your privacy-related request by emailing us at privacy@LiveContact.com.