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Privacy Policy

Version 2

Effective Date of Enrollment: August 12, 2026

IMPORTANT — PLEASE READ CAREFULLY

Your privacy matters to us. This Privacy Policy explains how Wringer.ai, Inc. ("Wringer.ai," "We," "Us," or "Our") collects, uses, stores, and shares personal information about visitors to the Wringer.ai website at wringer.ai (the "Site") and users of the Wringer Portal (collectively, the "Services"). This Privacy Policy also explains your rights in relation to your personal information and how to contact Us.

This Privacy Policy applies to personal information that We collect about you in your capacity as a Site visitor, Account holder, or authorized user of the Wringer Portal. It does not cover Consumer personal information that Clients submit to the Platform as Lead records. Wringer.ai processes Consumer Lead data as a service provider on behalf of Clients, and Our handling of such data is governed by the Terms of Service, not by this Privacy Policy. As described in the Terms of Service, that processing includes transmitting Consumer telephone numbers to third-party data providers for number validation, suppression, and contactability scoring at the Client's direction. Clients are solely responsible for providing privacy notices to, and obtaining any required consent from, the Consumers whose data they submit. Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in Our Terms of Service.

By accessing or using the Services, you agree to the practices described in this Privacy Policy. Your use of the Services is also governed by Our Terms of Service.

You must be at least 18 years old to use the Services.

1. Contact Information

If you have any questions or concerns regarding your privacy rights, this Privacy Policy, or Our data practices, you may contact Us at legal@wringer.ai.

2. Personal Information We Collect

We collect personal information from the following sources:

2.1 Information You Provide Directly

  • Account Registration: When you register for an Account on the Wringer Portal, We collect your email address. You may optionally provide additional profile information, such as your name and company name, through your user profile after registration.

  • Billing Information: When you configure billing or payment methods, We collect billing email addresses and payment method details (processed by Our third-party payment processor — We do not store full credit card numbers).

  • Business Verification Information: When you provision a telephone number or enable text messaging, We collect business-entity information required by telecommunication carriers, messaging aggregators, and industry registries to verify your business and register your messaging campaigns. This includes your legal entity name, any assumed or trade names you use, your employer identification number or other business registration number, entity type and jurisdiction of formation, business address, business telephone number, website, the name and title of an authorized representative, sample message content, and evidence of how you obtain consumer opt-in.

  • Customer Support: When you contact Us or request support, We collect the information you submit, including your name, email address, and the content of your communications.

2.2 Information Collected Automatically

When you interact with the Services, We automatically collect:

  • Usage Data: Information about how you access and use the Wringer Portal, including pages visited, features used, and actions taken.

  • Device and Connection Data: IP address, browser type, operating system, and device identifiers.

  • Session Data: Login timestamps, session duration, and user agent information. This information is captured at the time of account activity (including policy acceptance) for security and audit purposes.

  • Cookies and Tracking Technologies. We use cookies and similar technologies in three categories: (i) strictly necessary cookies required for Platform operation, including authentication, session management, security, and fraud prevention; (ii) functional cookies that remember your preferences and settings; and (iii) analytics cookies that help Us diagnose issues, measure performance, and improve Platform features. Some cookies are set by third-party service providers that support Platform operation (such as security, anti-bot, and content delivery services), and are subject to those providers' own policies. We do not use cookies for cross-context behavioral advertising or third-party marketing. You may configure your browser to refuse or delete cookies at any time; however, blocking strictly necessary cookies will prevent the Wringer Portal from functioning correctly.

  • Browser Privacy Signals. The Services honor the Global Privacy Control (GPC) signal and the Do Not Track (DNT) browser setting. Because We do not sell your personal information or use it for cross-context behavioral advertising, enabling these signals does not affect Our collection of information necessary to operate the Platform (such as session and security cookies). Where Applicable Law requires these signals to be treated as opt-out requests, We will treat them accordingly.

2.3 Information From Third Parties

We receive information about you from the following third-party services:

  • Payment Processor: Our third-party payment processor returns transaction statuses, tokenized payment method references, and related billing information when you fund your Account or update payment methods.

  • Carriers, Messaging Aggregators, and Registries: When We submit your Business Verification Information for number provisioning or campaign registration, these parties return verification and registration status, brand and campaign identifiers, assigned throughput or trust ratings, and the reasons for any rejection, suspension, or revocation.

3. How We Use Your Information

We use the personal information We collect to:

  • Provide and operate the Wringer Portal, including authenticating you, maintaining your Account, and enabling you to access Platform features.

  • Process payments, including charging your payment method for manual top-ups and auto-recharge transactions, and managing your prepay Account balance.

  • Send transactional communications, including billing notifications, auto-recharge confirmations, payment failure alerts, policy update notices, and password reset emails.

  • Maintain security and audit trails, including recording IP addresses and user agent information at the time of consent acceptance and other significant account actions.

  • Provide customer support and respond to inquiries.

  • Provision and register telephone numbers and messaging campaigns, including submitting your Business Verification Information to carriers, messaging aggregators, and industry registries, and maintaining that registration while your Account is active.

  • Calculate Account performance metrics used to determine the fees applicable to your Account, as described in the Terms of Service.

  • Improve the Services, including analyzing usage patterns, debugging errors, and developing new features.

  • Comply with legal obligations, including responding to lawful requests from law enforcement or regulatory authorities.

  • Detect and prevent fraud, security incidents, and other malicious or illegal activity.

4. How We Share Your Information

We may share your personal information in the following circumstances:

  • Service Providers: We share information with third-party service providers who assist in operating the Services, including Our payment processor, email delivery service, and cloud infrastructure providers. These providers are contractually obligated to use your information only for the purposes of providing services to Us.

  • Carriers, Messaging Aggregators, and Registries: We share your Business Verification Information with telecommunications carriers, messaging aggregators, and industry registries in order to provision telephone numbers and register messaging campaigns for your Account. These recipients use the information to verify your business, prevent fraud, and enforce their own messaging policies, under their own terms and privacy practices, which We do not control.

  • Affiliates: We may share information with Our parent, subsidiary, and affiliated companies to operate and support your Account, to provide integrated lead-sourcing and platform services where you use both, to calculate the Account performance metrics described in Section 3, and for internal analytics, fraud prevention, and administration.

  • Legal Requirements: We may disclose information when required by law, court order, or governmental authority, or when We believe disclosure is necessary to protect Our rights, your safety, or the safety of others.

  • Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. In the event of insolvency proceedings, personal information may be disposed of in a transaction approved by the court.

We do not sell your personal information to third parties for their own marketing purposes.

5. Data Retention

  • Active Accounts: We retain your personal information for as long as your Account remains active and as needed to provide the Services.

  • After Termination: Following Account termination, We retain personal information for a reasonable period as necessary to comply with legal obligations, resolve disputes, enforce agreements, and maintain audit trails.

  • Inactive Accounts: For accounts that have been inactive for more than twelve (12) consecutive months, We may delete or anonymize associated personal information. However, We retain Business Verification Information and registration records for applicable campaigns and numbers for so long as the associated telephone number or messaging registration remains assigned to Us, and We retain security, consent acceptance, and audit records for the period necessary to comply with legal obligations, respond to regulatory inquiries, and defend claims.

  • De-identified Data: We may retain de-identified, aggregated usage data indefinitely for analytics and Platform improvement purposes.

6. Data Security

We implement commercially reasonable technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption in transit and access controls.

However, no method of transmission over the Internet or method of electronic storage is fully secure. While We strive to protect your information, We cannot guarantee absolute security. You acknowledge that there are inherent security and privacy limitations of the Internet that are beyond Our control.

Breach Notification. In the event of a data breach affecting your personal information, We will notify you and the appropriate regulatory authorities where required by Applicable Law, without undue delay and in any event within the time periods required by Applicable Law. Such notification will include a description of the nature of the breach, the categories of personal information affected, the measures taken or proposed to address the breach, and any steps you may take to mitigate potential harm.

7. Transfer, Processing, and Storage

Your personal information may be transferred to, processed, and stored in the United States or other jurisdictions where data protection laws may differ from those of your jurisdiction. We take reasonable steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy regardless of where it is processed. Your use of the Services following the posting of this Privacy Policy constitutes your agreement to such transfers.

8. Third-Party Links

The Services may contain links to third-party websites or services. We are not responsible for the privacy practices or content of any third party. This Privacy Policy applies only to information collected by Us through the Services. We encourage you to review the privacy policies of any third-party websites or services you visit.

9. Children

The Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from anyone under 13 years of age. Consistent with the Children's Online Privacy Protection Act ("COPPA"), if We become aware that a child under 13 has provided Us with personal information, We will promptly delete such information. If you believe a child under 13 has provided Us with personal information, please contact Us at legal@wringer.ai.

10. Your Rights

Depending on your jurisdiction, you may have the right to:

  • Access the personal information We hold about you.

  • Correct inaccurate or incomplete personal information.

  • Delete your personal information, subject to legal retention requirements.

  • Restrict or object to certain processing of your personal information.

  • Data portability — receive your personal information in a structured, machine-readable format.

To exercise any of these rights, contact Us at legal@wringer.ai. We may need to verify your identity before responding. We will respond to verified requests within forty-five (45) days of receipt. If We need additional time, We may extend the response period by up to an additional forty-five (45) days, and We will notify you of the extension and the reason for it within the initial 45-day period.

11. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with additional rights regarding your personal information, including the right to know what personal information We collect, the right to delete, and the right to opt out of the sale of personal information. We do not sell personal information. To exercise your California privacy rights, contact Us at legal@wringer.ai.

12. Changes to This Privacy Policy and Continued Use

We may update this Privacy Policy from time to time. When We make material changes, We will notify you via email at the address associated with your Account. Material changes take effect thirty (30) days after email notice. Where a change materially expands the categories of personal information We collect or the parties with whom We share it, We may condition access to the affected feature on your affirmative acceptance. Your continued use of the Services after receiving notice of an updated Privacy Policy constitutes acceptance of those changes. If you do not agree to the updated Privacy Policy, you must discontinue use of the Services and terminate your Account in accordance with the Terms of Service.

We encourage you to review this Privacy Policy periodically for any updates.

For questions about this Privacy Policy, contact Wringer.ai at legal@wringer.ai.