Privacy Policy

• We collect contact information, business information, payment information and online activity data.
• Through the App we also process the texts, calls and contact details that our business customers exchange with the people who contact them, their leads. That data belongs to the business; we process it on the business's behalf.
• We use information to deliver our Services, to market to prospective customers, and to run our business.
• We share information with service providers, advertising partners, and as the law requires. App data is never shared with advertising partners, and the App contains no advertising or analytics SDKs.
• We do not sell personal information for money. We do share certain website information with advertising partners for cross-context behavioural advertising, and you can opt out at any time.
• We record our sales, onboarding and support calls. Calls placed inside a business's account are recorded only if that business has turned recording on; it is off by default.
• You have rights to access, delete, correct and limit how we use your information. Section 13 explains how to use them.

We do not knowingly collect precise geolocation, racial or ethnic origin, religious beliefs, sexual orientation, immigration status, genetic data, biometric data, health information, or information about children under 16.

The App does not collect your location, your address book, your phone's own SMS or call log, your browsing history, or health or financial information, and it contains no advertising, analytics or tracking SDKs. The microphone is used only during a call you place or answer in the App. The photo library is accessed only when you choose a photo to attach to a message.

• Directly from you, when you fill out a form, book a call, sign up, contact us or sign in to the App.
• From your device, through cookies, pixels and similar technologies on our Sites, and through the push-notification token your device issues if you allow notifications.
• From our business customers, when a business adds you as an owner or staff member, or when a business's leads contact it and their messages reach us through the business's number.
• From advertising partners such as Meta and Google, which deliver our advertising.
• From service providers, including our CRM and messaging platform, our payment processor and our telephony carrier.
• From publicly available sources, such as business directories and public records.

• To provide and operate the Services and the App: account creation, billing, support, delivering the business's texts and calls, push notifications, and metering usage for billing.
• Sales and marketing: responding to enquiries, following up on leads, sending promotional email and SMS where consented, and retargeting on advertising platforms. App data is not used for marketing.
• Analytics and improvement: understanding how the Sites and Services are used, diagnosing problems and developing features.
• Advertising: measuring ad performance, building lookalike audiences and retargeting visitors to our Sites. This counts as "sharing" under California law, see Section 7. It does not apply to the App.
• Quality assurance and training: reviewing recordings of our own sales, onboarding and support calls.
• Security and fraud prevention: detecting and preventing fraudulent or unauthorised activity, including logging every access to a business's account by our staff.
• Legal compliance: complying with law, court orders and regulatory requirements, including telecom messaging rules.
• Business operations: accounting, recordkeeping, audits and corporate transactions.

We will not use your sensitive personal information for purposes other than those permitted by California law without first offering you the right to limit that use.

We require service providers to use personal information only for the purposes we authorise, under contractual obligations of confidentiality and security.

Between a business and its leads. When you contact one of our business customers, your messages, calls and contact details are shown to the owner and staff of that business, and to the Delegated AI Inc staff assigned to that account. We process that information as a service provider to the business.

We do not sell personal information for money.

We do share the following categories collected on our Sites with advertising partners for cross-context behavioural advertising, which is treated as a "sale" or "sharing" under California, Colorado, Connecticut and other state laws:

• Identifiers, such as online identifiers and IP address
• Internet activity, such as pages visited and ads clicked
• Inferences

You can opt out at any time by emailing care@growthxl.ai with the subject line "Opt Out of Sale/Sharing", or by enabling a Global Privacy Control signal in your browser, which we honour automatically for residents of states that recognise universal opt-out signals.

We do not sell or share any information collected inside a client account, and we do not knowingly sell or share the personal information of consumers under 16.

We use cookies, pixels and similar technologies on our Sites to keep you logged in and remember preferences (essential), to measure traffic and performance (analytics), and to deliver and measure advertising. The App uses none of these: it stores only your session and preferences on your device, sends nothing to advertising or analytics providers, and does not track you across other companies' apps or websites.

You can manage cookies through your browser settings, through a Global Privacy Control signal, or through the industry opt-outs at optout.aboutads.info and optout.networkadvertising.org. We do not use session replay on our Sites.

The App is provided to businesses that are Delegated AI Inc customers, so their owners and staff can text and call their leads from the business's phone number. Accounts are created by us for our customers; there is no public sign-up.

• Who is responsible for what. For your own login and device data, Delegated AI Inc is the controller. For the business's leads and their conversations, the business is the controller and we act as its processor.
• Permissions. The App asks for the microphone during calls, notifications for new messages and calls, and the photo library only when you attach a photo. It does not request location, contacts or access to your phone's own SMS or call log.
• No tracking. The App does not track you across other companies' apps or websites and contains no advertising or third-party analytics.
• Staff access. Delegated AI Inc staff assigned to a business can open that account to provide support. Every such access is logged.
• Account deletion. Email care@growthxl.ai and we will complete your request within 30 days. Deleting your login does not delete the business's conversations, which belong to the business.
• Leads' choices. A lead who no longer wants texts from a business can reply STOP at any time, and it is honoured automatically.

You may request deletion at any time as described in Section 13. After deletion we may keep limited information needed to comply with legal obligations, resolve disputes, prevent fraud and enforce our agreements.

If you are a lead of one of our business customers and your request concerns the messages or calls you exchanged with that business, we will forward your request to that business or direct you to it, because the business controls that information.

Email care@growthxl.ai with what you would like. We will:

• Acknowledge your request within 10 business days.
• Respond within 45 days. If we need more time we will tell you, and may extend by a further 45 days.
• Handle the first request in any 12-month period at no charge.

Verification. To protect your information we will ask you to confirm details we already hold, such as your email address and our last interaction with you. We may ask for more verification where the request involves sensitive information.

Authorised agents. You may appoint an agent to make a request for you. We will require written, signed authorisation and will verify your identity.

Appeals. If we deny your request and you live in Virginia, Colorado, Connecticut, Texas or Oregon, you may appeal by emailing us with the subject line "Appeal". We will respond within 45 days, or 60 days for Colorado and Texas.

The Sites and Services are not directed to children under 16, and the App is a business tool intended for adults. We do not knowingly collect personal information from children under 16. If you believe we have, email us and we will delete it.

We use reasonable administrative, technical and physical safeguards, including encryption in transit, encryption at rest with our hosting providers, access controls, logging of staff access to customer accounts, and vendor due diligence. No method of transmission or storage is completely secure, so while we use commercially acceptable means to protect your data we cannot guarantee absolute security.

The Sites, Services and App are operated from the United States. If you access them from elsewhere, your information will be transferred to and processed in the United States, and by using them you consent to that transfer.

Our Sites link to third-party websites and services. This Policy does not apply to them, and we encourage you to read their privacy policies.

We may update this Policy from time to time. The date at the top reflects the most recent change. If we make material changes we will notify you by posting a notice on the Sites or in the App, or by email. We review this Policy at least once every 12 months.

Delegated AI Inc
Delegated AI Inc, 1130 Ogletown Road, Suite 2, #2749, Newark, DE 19711, USA
Email: care@growthxl.ai