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AVR reserves the right, in its sole discretion, to modify or change this Privacy Policy at any time with or without prior notice to you. You must review the current Privacy Policy on a regular basis. Your continued use of the AVR service following any changes to the Privacy Policy constitutes your full acceptance of those changes. If you have any questions, concerns, or comments about this Privacy Policy, please email us at Gary@avirtualreceptionist.com.

Information Collection / Opt-Out

AVR provides you (the AVR customer) the tools and resources to collect your subscribers' contact information on an opt-in basis. Subscribers, on the other hand, have the ability to opt out of your distribution lists easily and at any time. Subscribers can grant or revoke your ability to view and export their contact information by logging into the Subscription Management and unchecking the box labeled: "Allow access to my contact information."

Online Sign-up

AVR allows you to collect email addresses, instant message screen names, phone numbers, and other custom data when subscribers opt in to join your distribution list(s) via an online sign-up page powered by AVR. When joining a distribution list, we will ask subscribers for personal information such as their name, phone number, IM screen name, and email address. The information they provide and the information AVR obtains about them may be used to:

  • Provide subscribers with products and services they request.
  • To anticipate and resolve problems and conflicts with our products and services.
  • For verification and authentication purposes in regards to requests or changes of any personal information or data related.
  • For other purposes communicated to them at the time they provide or authorize the use of their information.

All subscribers have the ability to unsubscribe or change their personal subscription settings at any time. You should allow and inform your subscribers to unsubscribe by:

  • Email: Click the ‘Unsubscribe’ link located at the bottom of each email.
  • Mobile Text: Text STOP to the short code that they do not wish to receive messages from.
  • IM: Click the ‘Unsubscribe’ link located at the bottom of each instant message.
  • Voice Broadcasts: Follow the prompt, asking them to press 7 to unsubscribe from voice broadcast messages.

Your subscribers may also call the AVR Unsubscribe Hotline at 1-866-866-0009 to unsubscribe at any time.

Importing Contact Information

You agree to import, add, edit, access or otherwise use only lists for which all listed parties have opted in to receive correspondence from you ("Permission-Based Lists") in connection with your use of the service. You hereby covenant that you shall not use any other lists in connection with your use of the service. In the event that you import or add a subscriber with phone numbers, you must be able to provide tangible proof upon request that the subscriber being imported or added has given prior express written consent to be added to your lists and to receive solicitation messages from you. Written consent may be granted when a subscriber is clearly and fully notified of the collection of their contact information and agrees in writing that he or she may be contacted through their collected contact information. Prior express written consent can be obtained in hand written form or via email, website form, text message, or other methods in compliance with the E-SIGN Act. You will have to obtain prior express written consent from the recipient of your solicitation messages, even if you previously had a business relationship with the recipient. In addition, TCPA has revised a rule regarding text or voice solicitation messages. Click here for more information.

You should not assume a preexisting relationship to be a substitute for explicit permission to import corresponding contact information into AVR system. Nor should you send messages without explicit permission. For example, if your customer disclosed a mobile number in a normal course of business but did not specifically express permission to receive your message, you cannot send messages to the number. If it is discovered that you have been delivering any type of message to recipients who have not granted you permission, you will be held fully accountable for your actions and are subject to any and all legal actions that result from such violations including class action suits whether you use our standard user interface or API.

Mobile Keyword

In addition to Online Sign-up pages, you can also collect mobile phone numbers when subscribers text your mobile keyword (that you create) to AVR's shared short code. By texting your mobile keyword, subscribers are opting in their mobiles phone numbers to join your distribution list(s). Also, when subscribers text in your mobile keyword, they are giving prior express written consent so you can view and access their mobile numbers. This allows you to send solicitation messages to the subscribers. Subscribers can remove their mobile phone numbers from your database at any time by replying to any text message they receive from AVR with "STOP". They can also change permission for you to view (or export) their contact information by unchecking "Allow access to my contact information." box while they are signed into the Subscription Management page.

Sharing and Usage / Exporting

AVR does not share, sell, or rent any contact information with any party. You are not allowed to share your subscribers' contact info with any third party for any reason. However, AVR may use or disclose information, including your personal information and your subscribers' contact information, under the following very limited circumstances:

  • To provide you with products and services requested by you or your subscribers.
  • To anticipate and resolve problems and conflicts with our products and services.
  • For verification and authentication purposes in regards to requests or changes of any personal information or data related.
  • For other purposes communicated to you at the time you provide or authorize the use of your information.
  • To enforce our or your Terms of Use and Privacy Policy or other legal agreements.
  • To outsource any of the tasks referenced in our Terms of Use and Privacy Policy, such as customer service.
  • In response to a subpoena, court order, or other legal process.
  • To establish or exercise our legal rights or defend against legal claims.
  • To share with a company controlled by, or under common control with AVR for any purpose permitted by our Terms of Use or Privacy Policy.
  • When AVR believes such use or disclosure is (a) necessary in order to investigate, prevent, or take action regarding suspected illegal activities, fraud, or situations involving potential threats to the physical safety of any person, or (b) required by law.
  • In the event of a merger, acquisition, consolidation, divestiture, or bankruptcy of AVR.

NOTE: The AVR service is not intended for children under 13, and AVR does not knowingly collect information from children under the age of 13.

Privacy Policy for Subscribers and End Users

Updated May 31, 2018

AVR offers services enabling its users to send messages via multiple modes of communications - mobile text message, email, and pre-recorded voice message. This Privacy Policy is for those who received a message from a AVR user. AVR is dedicated to protecting your personal information and will make every reasonable effort to handle collected information appropriately.

If you believe you (the “Subscriber”) have received unwanted, unsolicited messages from the AVR system, please forward a copy of that email with your comments to support@trumpia.com and AVR will take an appropriate action. If you received an unwanted text message, or voice call, please call the AVR Unsubscribe Hotline at 1-866-866-0009.

Please note that the AVR service is not intended for children under 13, and AVR does not knowingly collect any personal information from children under the age of 13. Some AVR users may classify and rate their message content for recipients who are 21 years of age or older. Please observe content rating for intended audience before you sign up for any distribution list or mobile keyword.

AVR respects and is committed to the privacy of every user and subscriber. Accordingly, AVR endeavors to comply with all laws and regulations that apply to the gathering and use of personal information, including but not limited to US and European privacy laws whether local, national or regional.

Information Collection

Your personal contact information is collected by the AVR user on an opt-in basis and is provided to AVR in 3 ways:

1. A AVR user can collect your first name, last name, phone number, email address, and other custom data when you subscribe to a AVR user’s distribution list via an online sign-up page ("OSP").

2. A AVR user can also collect your mobile phone number when you willingly text the AVR user's mobile keyword to their designated short code. Certain SMS text features enable a AVR user to collect your name, email address, or other customized personal information by asking you to reply via SMS texts with specific information.

3. A AVR user may have previously collected your contact information on an opt-in basis outside of the AVR system. The AVR user has represented to AVR that your personal information was collected with your permission and you have consented to receive messages from the user.

You may manage your subscriptions and you may opt-out of receiving communications from AVR users at any time by following the directions in the next section of this Privacy Policy.

How Your Information is Used

Contact Information: When you sign up on an OSP or via a mobile keyword or have provided your personal information to a AVR user outside of the AVR system, you are subscribing to receive communications from a AVR user. By subscribing, you are giving explicit permission for this AVR user to send you messages via text message, email and/or voice broadcast.

Additional Information: You may choose to provide a AVR user with additional information such as your birthday or other personal information to help improve and personalize your experience. A AVR user may later personalize content, such as making suggestions or sending customized communications based on the additional personal information you have provided. You can manage or delete your personal information at any time by visiting your Contacts Dashboard. If you email us, we may keep your message, email address, and contact information to respond to your request.

Links: In order to operate our services, including our Smart Targeting and Auto Campaign features, we keep track of how you interact with links when they are included in communications sent by a AVR user. This includes links in text messages and emails a AVR user sends you.

Web Beacons: When a AVR user sends you messages, the message may include a web beacon to determine the number of people who open them. Web beacons collect only limited information, such as a cookie identifier, time and date of a page being viewed, and a description of the page on which the web beacon resides (the URL). Web beacons can be refused. If you do not wish to receive web beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software. When you click on a link included in a message sent by a AVR user, AVR or the AVR user may record this individual response to customize messages sent to you.

Cookies: A cookie is a small data file that is transferred to your computer or mobile device. Similarly to many other websites, we use cookies and similar technologies to collect additional website usage data and to improve our products and services, but we do not require cookies for most parts of our products and services such as receiving communications. We may use both session cookies and persistent cookies to better understand how you interact with our website, to monitor aggregate usage by our users and web traffic, and to customize and improve our products and services. Although most web browsers automatically accept cookies, some browsers’ settings can be modified to decline cookies or alert you when a website is attempting to place a cookie on your computer. However, some pages on our website may not function properly if you disable cookies. We do not support a “Do Not Track” browser option.

How to Unsubscribe From Distribution Lists, Update Your Information and Remove Your Data From AVR’s Records

You have the ability to unsubscribe from distribution lists, change your personal subscription settings or request the deletion of your personal information at any time.

To unsubscribe for:
  • Email: Click the ‘Unsubscribe’ link located at the bottom of each email. ‘Block’ link removes your contact information and additionally prevents the same list from adding you again.
  • Mobile Text Message: Text STOP to the short code that you do not wish to receive messages from. NOTE: Message and data rates may apply.
  • Voice Broadcasts: Follow the voice instruction/prompt when you receive a broadcast call. Press 7 to unsubscribe from voice broadcast messages.
  • You may also call the AVR Unsubscribe Hotline at 1-866-866-0009 to unsubscribe from distribution lists at any time.

You can change your communication preferences and manage your information on your Contacts Dashboard.

If you believe that your personal information was collected by a AVR user without your consent or you received an unsolicited message and would like to report spam, please click here or call 1-866-866-0009. When reporting the offending organization, please include the contact email address or short code that sent you the spam, the username of the sender, and the message or first few sentences of the message that you consider spam. AVR believes in a spam-free communication environment and has a no tolerance Anti-Spam Policy.

Information Sharing and Disclosure

AVR DOES NOT share your name or any personal information (including your name, email, or phone number) with third parties, except for the very owners of the OSP or the mobile keywords through which you volunteered your personal information (AVR users).

You have given the respective AVR user explicit permission to send messages to your contact information when you signed up for messages. If a AVR user added or imported your information without your permission, you can block the AVR user from adding or importing it again into his/her database residing in AVR.

AVR may use or disclose information about you, including your personal information, under the following circumstances:
  • To provide you with communications, products and services you request.
  • To anticipate and resolve problems and conflicts with our communications, products and services.
  • For verification and authentication purposes in regards to requests or changes of any personal information.
  • For other purposes communicated to you at the time you provide or authorize the use of your information.
  • To enforce our Terms of Use and Privacy Policy or other legal agreements.
  • In response to a subpoena, court order, or other legal process.
  • To establish or exercise our legal rights or defend against legal claims.
  • To share with a company controlled by, or under common control with AVR for any purpose permitted by our Terms of Use and Privacy Policy.
  • When AVR believes such use or disclosure is (a) necessary in order to investigate, prevent, or take action regarding suspected illegal activities, fraud, or situations involving potential threats to the physical safety of or any other harm for any person, or (b) required by law.
  • In the event of a merger, acquisition, consolidation, divestiture, or bankruptcy of AVR.

Security of Your Information

To help protect the privacy of data and information you disclose to AVR users, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal information to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

Data Storage and Retention

Your personal information is stored by AVR on its servers, and on the servers of the cloud-based communication services AVR provides, located in the United States. AVR retains data for the duration of the AVR user’s business relationship with AVR. For more information on where and how long your personal information is stored, and for more information on your rights of erasure and portability, please contact AVR’s Data Protection Officer at privacy@trumpia.com.

Your Privacy Rights

This Privacy Policy is intended to provide you with information about what personal information AVR users collect about you and how it is used. If you have any questions, please contact us at privacy@trumpia.com.

If you wish to confirm that AVR is processing your personal information, or to have access to the personal information that AVR may have about you, please contact us at privacy@trumpia.com.

Changes and Updates to the Privacy Policy

As our company’s services change from time to time, this Privacy Policy and our Terms of Use are expected to change as well. We reserve the right to amend the Privacy Policy and Terms of Use at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy and Terms of Use on this website. You should check our website periodically to review the current Privacy Policy and Terms of Use that are in effect and any changes that may have been made to them.

Company Contact Information

DoCircle, Inc. (a California corporation with a DBA of Trumpia)
2544 W. Woodland Drive, Anaheim, CA 92801
888-707-3030
support@trumpia.com

Data Protection Officer

Jihoon Koo
2544 W. Woodland Drive, Anaheim, CA 92801
415-484-4204
privacy@trumpia.com