IMpower Solutions - Privacy Policy

Effective Date: December 10, 2025
Last Updated: December 10, 2025

This Privacy Policy describes how OwnerListens, Inc. d/b/a IMpower Solutions ("IMpower," "we," "us," or "our"), a Delaware corporation operating out of California, collects, uses, and discloses personal data.

This policy applies to:

• Customers: Businesses and entities that subscribe to our SaaS platform, messaging services, and APIs.
• Site Visitors: Individuals who visit our website (impower.solutions) or interact with our marketing.
• Message Recipients (Indirectly): Individuals who receive messages from our Customers via our platform. Important Note: In this context, we act as a "data processor" or "service provider." We process this data solely on behalf of our Customers, who are the "data controllers."

1. Information We Collect

We collect information in three main ways: (1) information you provide directly; (2) information collected automatically via our platform; and (3) information processed on behalf of our Customers.

A. Information You Provide (as a Customer or Visitor)

• Account Registration: Name, business email, phone number, company name, and job title when you sign up for an account or a demo.
• Billing Information: Credit card details or billing address. (Note: Payment card data is processed by our secure third-party payment processors; we do not store raw credit card numbers).
• Verification Data: Business Tax ID (EIN), incorporation documents, and authorized representative details required for 10DLC (The Campaign Registry), Toll-Free verification, or Meta (WhatsApp) business verification.
• Communications: Content of messages you send to our support team, employees, or via our "Contact Us" forms.

B. Information Collected Automatically

• Usage Data: Log files, IP addresses, browser type, operating system, and pages visited on our dashboard to help us improve platform security and performance.
• Cookies & Trackers: We use cookies to maintain your login session and analyze site traffic. You can control cookies through your browser settings.

C. Information Processed on Behalf of Customers (Message Data)

When our Customers use our Services to message third parties (consumers, employees, etc.), we process the following data on their behalf:

• Phone Numbers: Sender and recipient mobile numbers.
• Message Content: The body of SMS, MMS, WhatsApp, or other messages, which may include text, media, or links.
• Metadata: Timestamps, delivery receipts, and carrier routing information.

We do not own this Message Data. We process it only to deliver the Service in accordance with our Customer's instructions and our Terms of Use.

2. How We Use Your Information

We use the information we collect for the following business purposes:

• Service Delivery: To provision phone numbers, transmit messages (SMS/MMS/RCS/WhatsApp), and manage 10DLC/Toll-Free registrations with carriers.
• Billing & Administration: To invoice you, manage subscriptions, and verify business identity for compliance.
• Compliance & Safety: To detect and prevent spam, fraud, and abuse; to handle "STOP" and "HELP" requests; and to comply with carrier regulations (e.g., CTIA) and legal obligations.
• Support & Improvement: To troubleshoot technical issues, integrate with your chosen platforms (e.g., Slack, Zendesk), and improve our features.
• Communication: To send you service alerts, API updates, and (unless you opt out) marketing emails about our products.

3. Sharing and Disclosure

We do not sell personal data. We share data only as follows:

• Telecommunication Partners (Strictly Necessary): To deliver messages, we must share message content and phone numbers with downstream carriers (e.g., Verizon, AT&T), aggregators, and registries (e.g., The Campaign Registry for 10DLC).
• Service Providers: We use trusted third-party vendors for hosting, payment processing (e.g., Stripe), and customer support tools. They may access data only to perform services for us.
• Legal & Regulatory: We may disclose information if required by law, subpoena, or to protect the safety and security of our platform, users, or the public.
• Business Transfers: If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

4. International Data Transfers (GDPR/UK/Canada)

We operate primarily in the United States. If you are located in the EEA, UK, or Canada:

• Data Location: Your data will be processed in the U.S.
• Safeguards: We rely on Data Processing Addendums (DPAs) with Standard Contractual Clauses (SCCs) to validate data transfers.
• GDPR Rights: European users have rights to access, correct, or delete their personal data. To exercise these rights regarding your Account Data, contact us at [email protected].

Note on Message Data: If you are a recipient of a message sent by one of our Customers and wish to exercise your GDPR rights (e.g., "Right to be Forgotten"), please contact the business that messaged you directly. As a processor, we will assist them in fulfilling your request.

5. Data Retention

• Customer Account Data: Retained as long as your account is active and for a period thereafter to comply with tax/legal obligations.
• Message Logs: We retain message transmission logs for a limited period to ensure delivery, resolve disputes, and comply with carrier audit requirements.
• Suppression Lists: We retain phone numbers on our "Block/Stop" lists indefinitely to ensure we honor opt-out requests permanently.

6. Your Choices & Opt-Outs

• Marketing Emails: Click "Unsubscribe" in any marketing email.
• Messaging Opt-Out: If you receive a text from one of our Customers and wish to stop, reply STOP to that message. We will process this at the carrier level to block future messages from that number.
• Cookies: You can disable cookies in your browser settings, though some dashboard features may not function correctly.

7. Security

We use industry-standard technical and organizational measures to protect data, including encryption in transit (TLS) and at rest. However, no internet transmission is 100% secure. You are responsible for keeping your API keys and login credentials confidential.

8. Changes to this Policy

We may update this policy to reflect changes in our services or laws. Material changes will be notified via email or a dashboard notice.

9. Contact Us

If you have questions about this policy or our privacy practices:
IMpower Solutions
Attn: Privacy Officer
Email: [email protected]
Address: 887 Savory Drive, Sunnyvale, California, 94087, USA