Privacy Policy

Effective Date: [DATE]
Last Updated: [DATE]

1. INTRODUCTION

[COMPANY NAME] and its affiliated companies held under Vanterra Foundation Solutions (collectively, “Company,” “we,” “our,” or “us“) respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website [WEBSITE URL] (the “Site“), engage our services, or otherwise interact with us.

IMPORTANT NOTICE: We use advanced visitor identification technologies that may identify you and collect your information even before you submit a form on our website. Please review Section 3 carefully.

This Policy applies to residents of all U.S. states where we operate. Residents of California, Colorado, Connecticut, Utah, Virginia, Nevada, Illinois, and other states with comprehensive privacy laws have additional rights described in Section 10.

2. INFORMATION WE COLLECT

2.1 Information You Provide

• Contact Information: Name, email address, phone number, physical address
• Service Information: Details about your property, service needs, scheduling preferences
• Payment Information: Processed through third-party providers only (we do not store payment card details)
• Communications: Contents of emails, chat messages, or other communications with us
• Photos and Recordings: Images of your property, recorded service visits (with consent)
• Employment Information: Job applications sent to HR (limited to application purposes)

2.2 Information Collected Automatically

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent, clicks, referring sites, session duration
• Location Data: Approximate location based on IP address
• Cookies and Tracking: See Section 4 for detailed information

2.3 Information from Third Parties

• Identity Resolution Services: We use Customers.ai and similar services that may identify you using:
  • IP address matching
  • Device fingerprinting
  • Cross-site tracking
  • Data broker information
  • Public records matching
• Marketing Partners: Demographic and interest data
• Public Records: Property ownership and value information
• Social Data: Publicly available social media information

3. VISITOR IDENTIFICATION TECHNOLOGY DISCLOSURE

IMPORTANT NOTICE

We use advanced visitor identification technologies including but not limited to:

• Customers.ai – Identifies visitors using IP matching and device fingerprinting
• CallRail – Tracks phone calls and matches to web visitors
• ServiceTitan – Links service history with online behavior

These technologies can identify you even if you:

• Don’t fill out any forms
• Use private/incognito browsing mode
• Clear your cookies regularly
• Visit from different devices
• Use different email addresses

What We May Learn About You Without Your Direct Input:

• Name, email, phone number, physical address
• Company/employer information
• Social media profiles
• Household income estimates
• Property ownership records
• Family composition
• Purchase history from data brokers

Your Rights Regarding Identification:

• Request deletion of identified data: [PRIVACY EMAIL]
• Opt-out of identification (limited effectiveness): Use VPN + privacy-focused browser + tracking blockers
• File complaint with your state Attorney General if you believe your rights are violated
• Request list of data brokers we use: [PRIVACY EMAIL]

We use this identification data ONLY for: ✓ Improving marketing effectiveness and relevance ✓ Personalizing your website experience ✓ Pre-filling forms to save you time ✓ Better understanding our customer base ✗ NOT for automated decisions affecting you legally or significantly ✗ NOT for sale to third parties for their independent use ✗ NOT for discriminatory purposes

Future Technologies Notice

As technology evolves, we may adopt new methods of data collection and analysis including but not limited to:

• Artificial intelligence and machine learning for service optimization
• Advanced identity resolution and data enrichment services
• Behavioral analytics and predictive modeling
• Voice analytics and sentiment analysis (with consent)
• Internet of Things (IoT) device integration
• Augmented reality for service visualization
• Blockchain for service verification

Any new technology implementation will comply with applicable laws and this policy’s core commitment to not sell personal data to third parties for their independent marketing purposes.

4. COOKIES AND TRACKING TECHNOLOGIES

We use the following tracking technologies:

Essential Cookies (Required for site function)

• Session management
• Security tokens
• Load balancing

Analytics & Performance

• Google Analytics 4 (GA4): Site usage analysis and user behavior
• Google Tag Manager: Conversion tracking and event monitoring
• CallRail: Call attribution and tracking
• ServiceTitan: Service performance metrics
• Microsoft Clarity: Session recordings and heatmaps

Marketing & Advertising

• Google Ads: Search and display advertising, remarketing
• Facebook/Meta Pixel: Social media advertising and lookalike audiences
• Microsoft/Bing Ads: Search advertising
• Mailchimp/Klaviyo: Email marketing tracking
• Avoca: Call management and tracking

Your Cookie Controls

Most browsers allow you to:

• Block all cookies
• Block third-party cookies only
• Clear cookies when closing browser
• Receive notification when cookie is set

Opt-Out Links:

• Google Ads Settings: https://adssettings.google.com
• Facebook Ad Preferences: https://www.facebook.com/ads/preferences
• Google Analytics Opt-Out: https://tools.google.com/dlpage/gaoptout
• Network Advertising Initiative: https://optout.networkadvertising.org
• Digital Advertising Alliance: https://optout.aboutads.info

Note: Disabling cookies may limit Site functionality including form submissions and content personalization.

5. HOW WE USE YOUR INFORMATION

5.1 Primary Uses

• Provide, schedule, and complete inspections and services
• Process service requests and manage appointments
• Send service-related communications (confirmations, updates, warranties)
• Process payments and financing applications
• Improve our services and customer experience
• Comply with legal obligations and warranties
• Protect against fraud and security threats
• Train employees and improve service quality

5.2 Marketing Communications

With appropriate consent, we may contact you via:

• Email: Service updates, promotions, newsletters (via Mailchimp, Klaviyo)
• SMS/Text: Appointment reminders, service updates, promotional offers
• Phone Calls: Follow-ups, service opportunities, customer surveys
• Direct Mail: Seasonal promotions, service reminders
• Digital Ads: Retargeted advertisements across web and social media

5.3 SMS/Text Messaging Program Details

By providing your phone number, you consent to receive:

• Appointment confirmations and reminders
• Service updates and completion notifications
• Weather-related service alerts
• Promotional offers and seasonal tips
• Customer satisfaction surveys

Program Terms:

• Message frequency varies (typically 1-2 per appointment plus occasional marketing)
• Message and data rates may apply
• Reply STOP to opt-out, HELP for assistance
• Consent is not a condition of purchase
• We will not share your phone number with third parties for their marketing

5.4 Cross-Company Data Use Within Vanterra

We may share your information across our family of companies to:

• Provide services when another brand serves your area better
• Coordinate multi-service projects
• Improve overall customer experience
• Ensure warranty coverage across brands
• Prevent fraud and maintain security

This is NOT a sale of data but operational coordination within commonly-owned companies.

6. RECORDING DISCLOSURE AND CONSENT

6.1 Multi-State Call Recording Compliance

We record all inbound and outbound calls for quality assurance, training, and dispute resolution purposes.

Two-Party Consent States (Illinois, California, Connecticut, Florida, Maryland, Massachusetts, Michigan, Montana, New Hampshire, Pennsylvania, Washington):

• Explicit consent obtained via automated message
• You may decline recording and request non-recorded communication
• By continuing the call after notice, you consent to recording

One-Party Consent States (All others):

• Recording notice provided as courtesy
• Calls may be recorded without explicit consent

6.2 In-Person Service Recording

Our technicians may audio record portions of service visits for:

• Quality assurance and training
• Documentation accuracy
• Dispute resolution
• Warranty claim verification

Consent Protocol:

• Advance notice in appointment confirmation
• Signage on service vehicles/equipment
• Tablet/device notification
• Verbal notice from technician if requested

To Opt-Out: Notify us before appointment at [PHONE NUMBER] or inform technician upon arrival.

6.3 Property Photography

We photograph properties for:

• Service documentation (before/during/after)
• Warranty records
• Training materials
• Marketing (with separate written consent only)

Commercial Use: We will NEVER use your property photos for marketing without your separate written consent.

7. HOW WE SHARE YOUR INFORMATION

7.1 Service Providers (Operational necessity only)

• ServiceTitan: CRM and service management
• Avoca: Call management and AI assistance
• Payment Processors: Secure payment handling
• Email/SMS Platforms: Mailchimp, Klaviyo, Twilio
• Cloud Storage: AWS, Google Cloud
• Analytics Providers: Google, Microsoft, CallRail
• Financing Partners: Third-party financing companies

All service providers are contractually required to:

• Protect your information
• Use data only for specified purposes
• Not sell or misuse your data
• Delete data upon termination

7.2 CRITICAL COMMITMENT

We do NOT sell, rent, or share consumer phone numbers or any personal information with third parties for their independent marketing purposes. Phone numbers and personal data are shared with operational partners only as necessary to deliver our services. Any vendor with access to your information is contractually prohibited from using it for any purpose other than providing services to us.

7.3 Legal Disclosures

We may disclose information when required by:

• Court order or subpoena
• Government investigation
• Law enforcement request with proper authority
• Legal obligation or regulatory requirement

7.4 Business Transfers

If we sell, merge, or transfer any part of our business, your information may transfer to the successor entity, who must honor this Privacy Policy’s commitments.

7.5 Protection of Rights

We may share information to:

• Protect safety of any person
• Investigate fraud or security threats
• Enforce our agreements and policies
• Defend against legal claims

8. DATA RETENTION AND DELETION

8.1 Retention Periods

• Customer Service Records: 7 years from last service (warranty/legal requirements)
• Prospect/Lead Data: 7 years from last interaction
• Call Recordings: 7 years from recording date
• Service Visit Recordings: 7 years from service date
• Property Photos: 7 years for service documentation, indefinitely if consent for marketing use
• Marketing Suppression Lists: Indefinitely (to honor opt-outs)
• Financial Records: 7 years (tax/legal requirements)
• Website Analytics: 26 months

8.2 Deletion Requests

How to Request Deletion:

• Email: [PRIVACY EMAIL]
• Phone: [PRIVACY PHONE]
• Mail: [PRIVACY MAILING ADDRESS]

Process:

• Identity verification required
• Response within 45 days
• Confirmation of deletion provided
• Some data retained if legally required

Data We Cannot Delete:

• Transaction records required for warranties
• Tax and financial records
• Legal hold information
• Opt-out/suppression records

9. DATA SECURITY AND BREACH NOTIFICATION

9.1 Security Measures

We implement industry-standard security including:

• SSL/TLS encryption for data transmission
• Encrypted data storage at rest
• Multi-factor authentication for system access
• Regular security audits and penetration testing
• Employee background checks and training
• Physical security at data centers
• Incident response planning
• Cyber insurance coverage

9.2 Data Breach Notification Protocol

In the event of a breach affecting your personal information:

Notification Timeline:

• Within 72 hours of discovery (or as required by state law, whichever is sooner)

Notification Methods:

• Email to last known address
• Prominent website notice
• Phone call for sensitive data breaches
• Written mail if required by law

Information Provided:

• Nature and date of breach
• Types of information affected
• Steps we’ve taken in response
• Recommended protective actions
• Dedicated hotline number
• Identity protection services (if appropriate)

No Security Guarantee: While we take extensive precautions, no system is 100% secure. You acknowledge the inherent risks in data transmission and storage.

10. YOUR PRIVACY RIGHTS

10.1 Rights for All Users

Regardless of location, you may:

• Access your personal information
• Correct inaccurate information
• Opt-out of marketing communications
• Request data deletion (subject to legal requirements)
• Opt-out of cookie tracking
• Lodge complaints with regulators

10.2 California Residents (CCPA/CPRA)

Your Rights:

• Know what personal information we collect, use, share, or sell
• Delete personal information (with exceptions)
• Opt-out of sale/sharing of personal information
• Correct inaccurate personal information
• Limit use of sensitive personal information
• Data portability
• Non-discrimination for exercising rights

Shine the Light: Request list of third parties receiving your data for their direct marketing.

10.3 Colorado Residents (CPA)

Your Rights (Effective July 1, 2023):

• Access your personal data
• Correct inaccuracies
• Delete personal data
• Data portability
• Opt-out of:
  • Sale of personal data
  • Targeted advertising
  • Profiling with legal/significant effects

Appeal Process: If we deny your request, you may appeal within 30 days to [PRIVACY EMAIL].

10.4 Connecticut Residents (CTDPA)

Your Rights (Effective July 1, 2023):

• Confirm processing and access data
• Correct inaccuracies
• Delete personal data
• Data portability
• Opt-out of:
  • Sale of personal data
  • Targeted advertising
  • Profiling with significant effects

10.5 Illinois Residents

Special Notices:

• Recording Consent: Illinois requires all-party consent for recordings. Your consent is obtained before any recording.
• BIPA Compliance: We do NOT currently collect biometric identifiers. If this changes, we will obtain written consent first.
• Right to Deletion: Enhanced deletion rights under Illinois law.

10.6 Nevada Residents

You may opt-out of the sale of covered information under NRS 603A.340 by emailing [PRIVACY EMAIL].

10.7 Utah Residents (UCPA)

Your Rights (Effective December 31, 2023):

• Access and confirm processing
• Delete personal data
• Data portability
• Opt-out of:
  • Sale of personal data
  • Targeted advertising

10.8 Virginia Residents (VCDPA)

Your Rights (Effective January 1, 2023):

• Access personal data
• Correct inaccuracies
• Delete personal data
• Data portability
• Opt-out of:
  • Sale of personal data
  • Targeted advertising
  • Profiling for decisions with significant effects

10.9 How to Exercise Your Rights

Submit Requests Via:

• Email: [PRIVACY EMAIL]
• Phone: [PRIVACY PHONE]
• Online Form: [PRIVACY REQUEST FORM URL]
• Mail: [PRIVACY MAILING ADDRESS]

Verification Process:

• Government ID may be required
• Account information verification
• Signed declaration under penalty of perjury (California)

Authorized Agents:

• Written authorization required
• Direct verification with you still required
• Power of attorney may be accepted

Response Timeline:

• Acknowledgment: 10 days
• Completion: 45 days (may extend 45 additional days with notice)

11. ILLINOIS BIOMETRIC INFORMATION PRIVACY ACT (BIPA) NOTICE

We do NOT currently collect biometric identifiers including:

• Fingerprints
• Facial geometry/recognition
• Voiceprints
• Retina/iris scans
• Hand/gait patterns

If this changes in the future:

• We will obtain written consent first
• We will publish retention and destruction schedules
• We will not sell or profit from biometric data
• We will not disclose without consent or legal requirement
• This notice will be updated with specific protocols

12. CHILDREN’S PRIVACY

Our services are not directed to individuals under 18. We do not knowingly collect information from children under 18.

If you believe we have collected information from a child:

• Contact us immediately at [PRIVACY EMAIL]
• We will promptly delete the information
• We will review our collection practices

Parents/guardians may request deletion of any child’s information.

13. THIRD-PARTY LINKS AND SERVICES

Our Site may contain links to third-party websites. We are not responsible for their privacy practices.

Third-Party Services May Include:

• Social media platforms
• Review sites (Google, Yelp, BBB)
• Financing partners
• Insurance providers
• Industry associations

Please review their privacy policies before providing information.

14. INTERNATIONAL DATA TRANSFERS

We operate in the United States. Information is processed and stored in the US, where privacy laws may differ from your jurisdiction. By using our services, you consent to transfer and processing in the US.

15. DO NOT TRACK SIGNALS

We do not currently respond to browser “Do Not Track” signals. However, you may:

• Opt-out via methods in Section 10
• Use privacy-focused browsers
• Install tracking blockers
• Adjust cookie settings

16. CHANGES TO THIS PRIVACY POLICY

We may update this Policy periodically. Changes are effective when posted.

Notification of Material Changes:

• Email to customers
• Prominent website notice
• App notification (if applicable)

Review the “Last Updated” date to see when last revised.

17. ACCESSIBILITY

This Privacy Policy is available in alternative formats:

• Large print
• Audio recording
• Plain language summary

Request alternative formats at [ACCESSIBILITY EMAIL].

18. CONTACT INFORMATION

For Privacy Questions: [COMPANY NAME]
Attn: Privacy Officer
[MAILING ADDRESS]
[CITY, STATE ZIP]

Email: [PRIVACY EMAIL]
Phone: [PRIVACY PHONE]
Online Form: [PRIVACY FORM URL]

For Marketing Opt-Outs: Email: [UNSUBSCRIBE EMAIL]
Phone: [UNSUBSCRIBE PHONE]
Text: Reply STOP to any message

For Media Inquiries: [MEDIA EMAIL]

For Legal Service: [LEGAL SERVICE ADDRESS]