SMS Privacy Policy

This SMS Privacy Policy ("Policy") explains how Dodi USA LLC ("we," "us," "our," or "Dodi USA") collects, uses, protects, and shares your personal information when you opt into our SMS messaging program. This Policy is in compliance with the Telephone Consumer Protection Act (TCPA), CTIA Messaging Principles and Best Practices, and A2P 10DLC registration requirements.

By opting into our SMS messaging service, you agree to the terms outlined in this Privacy Policy.

1. Information We Collect

1.1 Personal Information

When you opt into our SMS messaging program, we collect the following information:

• Mobile Phone Number: Your 10-digit mobile phone number
• Name: Your first and last name (if provided)
• Consent Data: Records of when and how you provided consent to receive SMS messages, including the method of opt-in (web form submission, keyword, or other)
• Inquiry Details: Information about your investment inquiry or portfolio consultation request
• Meeting Preferences: Your preferred meeting date and time

1.2 Technical Information

We may automatically collect certain technical information, including:

• Message delivery status and timestamps
• Mobile carrier information
• Device type and operating system (when applicable)
• IP address (when collected via web form)

2. How You Opt-In

You can opt into our SMS messaging program through the following method:

2.1 What Consent Means

By opting in, you:

• Authorize Dodi USA LLC to send you SMS messages related to your inquiry
• Acknowledge that message and data rates may apply based on your mobile carrier plan
• Understand that consent is not a condition of purchase or service
• Agree to receive messages from our SMS-enabled phone number(s)

3. How We Use Your Information

We use the personal information collected through our SMS program for the following purposes:

3.1 Primary Use Cases

• Meeting Confirmations: To confirm your scheduled meeting date and time
• Inquiry Responses: To acknowledge receipt of your investment inquiry
• Appointment Reminders: To send reminders about upcoming consultations
• Rescheduling: To facilitate meeting rescheduling requests
• Service Communications: To provide information about your portfolio consultation

3.2 Message Frequency

You can expect to receive approximately 1-3 messages per inquiry, including:

• Initial confirmation message (1 message)
• Meeting reminder (1 message, if applicable)
• Follow-up or rescheduling messages (as needed)

Estimated Monthly Volume: We send approximately 10,000 messages per month across all clients.

4. How We Protect Your Information

We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect it:

• Secure Transmission: All SMS messages are transmitted through secure, encrypted channels via our messaging service provider (Twilio)
• Access Controls: Only authorized Dodi USA LLC staff members have access to your mobile phone number and related information
• Data Minimization: We only collect and retain information necessary to provide our SMS service
• Regular Audits: We conduct regular security audits to ensure compliance with industry standards
• Third-Party Security: Our messaging service provider (Twilio) maintains SOC 2 Type II certification and complies with industry security standards

5. Information Sharing and Disclosure

5.1 No Third-Party Marketing

5.2 Service Providers

We may share your information with trusted service providers who assist us in operating our SMS program:

• Twilio: Our SMS messaging platform provider. Twilio processes messages on our behalf and is contractually obligated to protect your information. Learn more at Twilio's Privacy Policy.

5.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, subpoenas, or government agencies).

6. Your Rights and Choices

6.1 Opt-Out Instructions

6.2 Help and Support

For assistance, reply "HELP" to any message, and you will receive information about our SMS program and how to contact us.

6.3 Data Access and Deletion

You have the right to:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information from our systems
• Portability: Request a copy of your data in a portable format

To exercise these rights, contact us using the information provided in Section 12.

6.4 Do Not Call Registry

If you are on the National Do Not Call Registry, we will not send you promotional SMS messages unless you have provided express written consent to do so through our opt-in process.

7. Message and Data Rates

Message and data rates may apply based on your mobile carrier's plan. Standard messaging rates from your wireless carrier will apply to all SMS messages sent and received. Please contact your mobile carrier for details about your messaging plan and associated costs.

Supported Carriers: Our SMS service is available on all major U.S. carriers, including AT&T, T-Mobile, Verizon, Sprint, and others.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Active Subscribers: We retain your information while you are subscribed to our SMS service
• Opt-Out Records: We maintain opt-out records to ensure we honor your preferences and comply with regulations
• Consent Records: We retain records of your consent for compliance and legal purposes (typically 4-7 years)
• Deletion Requests: Upon request, we will delete your personal information within 30 days, except where retention is required by law

9. Children's Privacy

Our SMS messaging service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are under 18, please do not opt into our SMS program or provide any personal information.

If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

10. Changes to This Privacy Policy

We may update this SMS Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the "Last Updated" date at the top of this Policy
• Post the revised Policy on our website at https://dodiusa.com/sms-privacy-policy
• Notify active SMS subscribers of material changes via text message (if required by law)

Your continued participation in our SMS program after changes are posted constitutes your acceptance of the revised Policy.

11. Compliance and Regulatory Information

This SMS Privacy Policy complies with:

• Telephone Consumer Protection Act (TCPA)
• CTIA Messaging Principles and Best Practices
• A2P 10DLC Registration Requirements (via The Campaign Registry)
• FCC Regulations for commercial text messaging
• State Privacy Laws (including CCPA, where applicable)