SMS Privacy Policy

1 Introduction and Overview

Brioni Granite is a [PLACEHOLDER: brief company description, e.g., "premier granite fabrication and installation company serving residential and commercial clients across the greater St. Louis metropolitan area"]. We are committed to providing exceptional service and maintaining transparent, respectful communication with our customers and prospective clients.

As part of that commitment, Brioni Granite operates an SMS text messaging program that allows us to communicate important information — including appointment reminders, project updates, promotional offers, and customer service messages — directly to your mobile device. This SMS Privacy Policy ("Policy") describes:

• The types of personal information we collect when you enroll in our SMS program;
• How we use, protect, and share that information;
• Your rights and choices as a participant in our SMS program; and
• How to contact us with questions or requests.

Consent Requirement: Brioni Granite will only send text messages to individuals who have affirmatively provided their prior express written consent to receive such communications. We do not send unsolicited text messages. Your participation in our SMS program is entirely voluntary.

Legal Compliance: This Policy is designed to comply with the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227; the regulations promulgated by the Federal Communications Commission (FCC) thereunder; the CTIA Messaging Principles and Best Practices; and all applicable federal and state laws governing electronic communications and consumer privacy. By participating in our SMS program, you acknowledge that you have read, understood, and agreed to this Policy.

2 Information We Collect

When you opt in to Brioni Granite's SMS program, we collect certain personal information in order to operate the program effectively and lawfully. The categories of information we may collect include:

2.1 Enrollment Information

• Mobile Phone Number: The wireless phone number you provide at the time of opt-in. This is the primary identifier used to send you text messages.
• Opt-In Date and Time: The exact date and time at which you enrolled, recorded automatically to maintain a verifiable consent record.
• Opt-In Source: The channel through which you enrolled (e.g., web form submission, keyword text-in via short code or long code, in-person point-of-sale sign-up, verbal request recorded in writing, or other documented method).
• Consent Record: A record of the specific consent disclosure language you agreed to at the time of opt-in, retained for compliance purposes.

2.2 Message Interaction Data

• Delivery Status: Technical confirmation of whether messages were successfully delivered to your device, including timestamps of delivery attempts.
• Opt-Out and Help Requests: Records of any STOP, QUIT, CANCEL, END, or HELP keywords you text in reply, along with the date and time of such requests.
• Inbound Messages: Content of any text messages you send to us in response to our communications, to the extent necessary to fulfill your request or provide customer service.

2.3 Technical and Device Information

• Device Type and Carrier Information: Where technically available through our messaging platform and SMS aggregator, we may receive information about the type of device you are using and your wireless carrier. This information is used for technical compatibility and program administration purposes only.

2.4 Combination with Other Account Data

Information collected through our SMS program may be associated with and combined with other personal information we hold about you as a customer of Brioni Granite — such as your name, email address, service history, and account records — in order to personalize communications, improve our services, and maintain a complete customer relationship record. Any such combined data will be treated in accordance with both this Policy and our General Privacy Policy.

3 How We Obtain Consent (Opt-In)

3.1 Explicit Written Consent Requirement

Brioni Granite requires prior express written consent before sending any marketing or promotional text messages, consistent with the TCPA and FCC regulations. This means you must affirmatively and knowingly agree to receive text messages before we will send them to you. Consent is never assumed, implied from a prior business relationship alone, or inferred from silence.

At the point of opt-in, we always disclose: (a) that you are agreeing to receive recurring automated text messages from Brioni Granite; (b) that message and data rates may apply; (c) how to opt out; and (d) how to obtain assistance.

3.2 Methods of Opt-In

You may enroll in our SMS program through any of the following channels:

• Keyword Text-In: Text a designated keyword (e.g., [PLACEHOLDER: Keyword, e.g., "JOIN" or "BRIONI"]) to our short code or long code number ([PLACEHOLDER: Short Code or Long Code Number]). By sending the keyword, you are providing your express written consent to receive text messages from Brioni Granite.
• Web Form: Complete an online opt-in form on our website at [PLACEHOLDER: URL], where you enter your mobile phone number and check a clearly labeled consent checkbox acknowledging this Policy and agreeing to receive text messages.
• In-Person Sign-Up: Complete a written or digital opt-in form at our place of business, point of sale, trade show, or other in-person event, providing your mobile number and signing or initialing an explicit consent disclosure.
• Other Documented Methods: Any other enrollment method in which affirmative consent is documented in writing prior to any message being sent.

3.3 Consent Is Not a Condition of Purchase

3.4 Double Opt-In Procedures

Where technically feasible and required by applicable carrier or industry guidelines, Brioni Granite may employ a double opt-in process. After you submit your initial opt-in, you will receive a confirmatory text message asking you to reply with a keyword (e.g., "YES") to confirm your enrollment. Your enrollment will not be activated until this confirmation is received. The double opt-in confirmation message itself does not constitute a marketing message.

3.5 Retention of Consent Records

Brioni Granite retains records of your consent — including the opt-in method, the disclosure language presented, the date and time of opt-in, and any confirmatory reply — for the duration of your enrollment in the SMS program and for a period of not less than [PLACEHOLDER: e.g., five (5) years] thereafter, or as otherwise required by applicable law, whichever is longer. These records are maintained to demonstrate compliance with the TCPA and applicable regulations.

4 Types of Messages We Send

Brioni Granite sends text messages in the following categories. All message content will be relevant to your relationship with Brioni Granite and will not include content unrelated to our business or your account.

Brioni Granite will not use its SMS program to send messages on behalf of unrelated third parties, and we will not send content that is irrelevant to our products, services, or your customer relationship with us.

5 Message Frequency

The number of text messages you receive from Brioni Granite will vary based on your account activity, the stage of your project, your engagement with our services, and our promotional calendar.

• Promotional Messages: For customers enrolled in our general marketing SMS list, we typically send up to 4–6 promotional text messages per month under normal operating conditions.
• Transactional Messages: Transactional messages are sent as triggered by your project milestones, appointment schedule, order status, or other actions, and are not subject to the promotional frequency limit above. The number of transactional messages you receive will vary depending on the scope and activity of your engagement with Brioni Granite.
• Customer Service Messages: Customer service messages are sent in direct response to your requests and are limited to what is reasonably necessary to address your inquiry.
• Peak Promotional Periods: During high-activity promotional periods — such as seasonal sales events, holiday promotions, or special limited-time offers — the frequency of promotional messages may temporarily increase beyond the typical monthly range. We will make reasonable efforts to ensure the total volume of messages remains relevant and non-excessive.

You may opt out of receiving promotional messages at any time without affecting transactional or customer service communications, or you may opt out of all SMS communications entirely. See Section 6 for opt-out instructions.

6 Opt-Out Instructions

6.1 Opt-Out via Text Reply

Simply reply STOP (or QUIT, CANCEL, END, UNSUBSCRIBE) to any text message sent from Brioni Granite's short code or long code number. No additional information is required. Upon receipt of your opt-out request, you will receive one final confirmatory text message acknowledging that you have been removed from our SMS program and confirming that no further promotional or marketing messages will be sent. This final confirmation message is the last message you will receive.

6.2 Additional Opt-Out Channels

In addition to the text reply opt-out, you may request removal from our SMS program through any of the following channels:

• Email: Send a written opt-out request to [PLACEHOLDER: Privacy or Customer Service Email Address, e.g., privacy@brionigranite.com], including your full name and the mobile phone number you wish to remove.
• Phone: Call our customer service line at [PLACEHOLDER: Phone Number] and request to be removed from our SMS list.
• Written Request: Mail a written opt-out request to our mailing address listed in Section 14 of this Policy.

6.3 Processing Timeframe

Brioni Granite will process all opt-out requests within 10 business days of receipt. During that processing period, you may receive one or more previously scheduled messages before the opt-out takes full effect.

6.4 Effect of Opt-Out

Opting out of our SMS program will not affect:

• Any existing contractual obligations between you and Brioni Granite;
• Any ongoing or previously placed orders, projects, or services;
• Your ability to purchase products or services from Brioni Granite in the future; or
• Communications we may send through other channels (e.g., email, postal mail) unless you also opt out of those separately.

7 Help and Support

7.1 Text HELP for Assistance

If you have questions about our SMS program or need assistance, reply HELP to any text message you receive from Brioni Granite. You will receive an automated response containing contact information and a brief description of the program and your opt-out options.

7.2 Customer Service Contact Information

7.3 General Privacy Policy

For information about our broader privacy practices beyond SMS communications, please visit our General Privacy Policy at: [PLACEHOLDER: URL to General Privacy Policy page].

8 Costs and Carrier Information

8.1 Message and Data Rates

You are solely responsible for any fees charged by your wireless carrier in connection with text messages sent or received as part of our SMS program. We recommend reviewing your wireless service plan or contacting your carrier if you are uncertain about applicable rates.

8.2 Carrier Liability Disclaimer

Brioni Granite is not responsible for any fees, charges, or costs imposed by your wireless carrier in connection with your participation in our SMS program. Wireless carriers are not liable for delayed or undelivered messages. Message delivery is subject to the availability of network services, and Brioni Granite cannot guarantee the delivery of any specific message at any particular time.

8.3 Supported Carriers

Brioni Granite's SMS program is supported by all major U.S. wireless carriers, including but not limited to AT&T, T-Mobile, Verizon, and other national and regional carriers. However, not all carriers or wireless service plans may support SMS messaging features used in our program. Supported carriers are subject to change. Brioni Granite is not responsible for any inability to deliver messages that results from carrier limitations, restrictions, or unsupported service plans.

9 Data Security

Brioni Granite takes the security of your personal information seriously. We have implemented reasonable and appropriate administrative, technical, and physical safeguards designed to protect your SMS-related data from unauthorized access, use, disclosure, alteration, and destruction.

9.1 Administrative Safeguards

• Internal privacy and data security policies governing the handling of personal information;
• Employee training on data privacy obligations and information security best practices;
• Designated personnel responsible for overseeing compliance with this Policy and applicable law; and
• Vendor due diligence procedures for all third-party service providers who access personal data on our behalf.

9.2 Technical Safeguards

• Encryption of personal data during transmission using industry-standard protocols (e.g., TLS/SSL) where applicable;
• Encryption of stored personal data where technically feasible and appropriate to the sensitivity of the data;
• Secure access controls and authentication requirements for systems containing personal information; and
• Regular review and updating of technical security measures in response to evolving threats.

9.3 Physical Safeguards

• Physical access controls to facilities and equipment where personal data is stored or processed;
• Secure disposal of records containing personal information in accordance with applicable retention schedules; and
• Access restrictions limiting the number of employees who can physically access personal data records.

9.4 Access Controls

Access to your personal SMS data is limited to those Brioni Granite employees, contractors, and authorized service providers who need access to perform their job functions or to operate the SMS program on our behalf. All personnel with access to personal data are subject to confidentiality obligations.

9.5 Incident Response

Brioni Granite maintains an incident response plan to address actual or suspected security breaches involving personal information. In the event of a breach that affects your personal data, we are committed to notifying affected individuals and applicable regulatory authorities as required by applicable law and in a timely manner.

9.6 Limitation of Security Guarantees

No data transmission over the internet or wireless network, and no data storage system, can be guaranteed to be 100% secure. While we strive to protect your personal information using the safeguards described above, we cannot warrant or guarantee the absolute security of any information you transmit to us or that we store on your behalf. If you believe your personal information has been compromised, please contact us immediately using the contact information in Section 14.

10 Third-Party Sharing and Disclosure

10.1 Permitted Disclosures

Notwithstanding the above commitment, Brioni Granite may share your SMS-related personal information in the following limited and permitted circumstances:

• Service Providers and Technology Partners: We may share your personal information with third-party vendors, messaging aggregators, cloud infrastructure providers, customer relationship management platforms, and other technology partners who assist us in operating our SMS program and delivering text messages on our behalf. All such service providers are:
  • Bound by written confidentiality agreements and data processing terms;
  • Prohibited from using your personal information for any purpose other than providing services to Brioni Granite; and
  • Required to implement appropriate security measures to protect your data.
• Legal Compliance: We may disclose your personal information when required to do so by law, regulation, legal process, or governmental request, including in response to a valid subpoena, court order, or request from a law enforcement agency or regulatory authority. We will make reasonable efforts to notify you of such disclosures to the extent permitted by law.
• Protection of Rights: We may disclose personal information when we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Brioni Granite, our customers, or the public; to prevent fraud or illegal activity; or to enforce our Terms of Service or other agreements.
• Business Transfers: In the event of a merger, acquisition, reorganization, sale of substantially all of our assets, or other business transfer, your personal information — including SMS enrollment data — may be transferred to the successor entity. We will provide notice of such a transfer on our website and, where feasible, via SMS or email prior to the transfer occurring, and the successor will be required to honor the commitments in this Policy or provide you with the opportunity to opt out.

10.2 No Sale of Personal Information

Brioni Granite does not, and will not, sell your mobile phone number, SMS opt-in data, or any other personal information collected through our SMS program to any third party in exchange for monetary or other valuable consideration, consistent with the CTIA Messaging Principles and Best Practices and applicable state privacy laws.

11 Customer Rights

As a participant in Brioni Granite's SMS program, you have the following rights with respect to your personal information. We are committed to honoring these rights in a timely and transparent manner.

11.1 How to Exercise Your Rights

To submit a request to access, correct, or delete your personal information, please contact us using any of the following methods:

• Email: [PLACEHOLDER: Privacy Inquiries Email, e.g., privacy@brionigranite.com] with the subject line "Privacy Rights Request – SMS"
• Phone: [PLACEHOLDER: Customer Service Phone Number]
• Mail: [PLACEHOLDER: Mailing Address], Attn: Privacy Officer

To verify your identity, we may ask you to provide your name, the mobile phone number associated with your SMS enrollment, and sufficient additional information to confirm your identity before processing your request. We will not use verification information for any purpose other than confirming your identity.

11.2 Response Timeframe

Brioni Granite will acknowledge receipt of your request within 5 business days and will respond substantively within 30 calendar days of receipt. If additional time is required to fulfill a complex request, we will notify you of the extension and the expected completion date.

12 Retention of Data

12.1 Consent Records

Brioni Granite retains records of your SMS opt-in consent — including the consent disclosure language, opt-in method, date, and time — for the duration of your active enrollment in our SMS program and for a minimum of [PLACEHOLDER: e.g., five (5) years] following the termination of your enrollment or the end of our customer relationship with you, whichever is later. This retention period supports our legal compliance obligations under the TCPA and applicable FCC regulations.

12.2 Message Logs

Logs of text messages sent to and received from you — including delivery status records and opt-out requests — are retained for [PLACEHOLDER: e.g., two (2) years] from the date the message was sent or received, or for such longer period as required by applicable law. Message logs are used for program administration, compliance verification, dispute resolution, and customer service purposes.

12.3 Deletion Upon Request

Upon receiving a verifiable request for deletion of your personal SMS data, Brioni Granite will delete or de-identify your information within a reasonable time, to the extent such deletion is permitted by applicable law. Certain data — particularly TCPA consent records and records required for legal compliance, tax, or regulatory purposes — may be retained for the full periods described above even after a deletion request.

12.4 Secure Disposal

When personal information is no longer required for the purposes described in this Policy and retention periods have expired, Brioni Granite will dispose of such information in a secure manner, including by electronic deletion, overwriting, degaussing, or physical destruction of paper records, as appropriate to the medium.

13 Changes to This Policy

13.1 Right to Update

Brioni Granite reserves the right to modify, update, or replace this SMS Privacy Policy at any time, in our sole discretion. Changes may be made to reflect updates to our SMS practices, changes in applicable law or industry standards, or new features or services we offer.

13.2 Notification of Changes

When we update this Policy, we will:

• Post the revised Policy on our website at [PLACEHOLDER: URL] with a new "Effective Date" and "Last Updated" date at the top of the document;
• For material changes that significantly affect your rights or the manner in which we use your personal information, provide advance notice via SMS message and/or email to the extent feasible, prior to the changes taking effect; and
• Make the prior version of the Policy available upon request for a reasonable period of time following any update.

13.3 Acceptance of Updated Policy

Your continued receipt and non-rejection of text messages from Brioni Granite following the posting of an updated Policy constitutes your acceptance of the changes. If you do not agree to the terms of an updated Policy, you may opt out of our SMS program at any time using the methods described in Section 6. We encourage you to review this Policy periodically to stay informed of how we are protecting your information.

14 Contact Information

If you have any questions, concerns, or requests regarding this SMS Privacy Policy or our handling of your personal information, please contact us using the information below.

For privacy-specific requests (access, correction, deletion of SMS data), please direct your inquiry to our Privacy Officer at the email address above and include "Privacy Rights Request – SMS" in the subject line.