Privacy policy | SMS Bridge

Template for review. This document was prepared for review by qualified counsel in each market where it is used. It is not legal advice.

This is a template prepared for review by qualified counsel. It is not legal advice. It must be reviewed and adapted by a licensed lawyer before publication, and re-reviewed whenever the product, its data flows, or the regulatory map change.

Effective date: 31 August 2026 Last reviewed: August 31, 2026

Ino Tek Plus Holding [Registered Canadian business address, Fort McMurray, Alberta, Canada] Contact: info@inotekplus.com Business line +1 (780) 215 1111 is a voice line for company operations and is never used to collect or process personal data under this policy.

1. Who this policy covers

This policy describes how Ino Tek Plus Holding ("we," "us") collects, uses, discloses, and protects personal information in connection with SMS Bridge, a business texting system for field service companies. SMS Bridge can be deployed in two modes:

Self hosted deployment: the customer runs SMS Bridge on its own server, under its own control. In this mode, the customer is the data controller (GDPR/UK GDPR terminology) or the organization (PIPEDA/CCPA terminology) responsible for the personal information of its own customers and employees. We act as a processor/service provider only with respect to any optional hosted services the customer chooses to use, for example: software updates delivered over the internet, our AI classification API if the customer opts into cloud based classification rather than a fully local model, and any support access we are granted.
Hosted deployment: where we operate the server infrastructure on the customer's behalf, we act as a processor/service provider for the customer's end customer and employee data, and the customer remains the controller/business for that data. We are the controller for account and billing information about the customer itself.

This policy is written for the customer (the field service business) and, where relevant, for that customer's end customers and employees whose messages pass through SMS Bridge.

2. Categories of data we process

Category	Examples	Source
Account and billing data	Company name, admin names, admin emails, billing address, payment method token	Customer, at signup
Message content	The text of inbound and outbound SMS between the customer's company number and its end customers, including message metadata (timestamp, direction, associated job or contact record)	Customer's own texting activity through the app
Contact records	End customer name, phone number, job history, notes entered by staff	Customer's staff, entered into the app or synced from the customer's own CRM
Employee/user data	Staff names, phone numbers or device identifiers used to log into the app, role, assignment history, login and access logs	Customer, as employer, provisioning staff accounts
AI classification outputs	A label or score attached to a message (for example: "complaint," "billing question," "routine"), generated by our classifier reading message content, used to decide gating and escalation	Generated automatically from message content, see Section 3
Technical and diagnostic data	IP addresses, device and browser information, server logs, error reports	Automatically collected by the app and, in hosted deployments, our infrastructure

3. Message content is processed for classification, stated plainly

SMS Bridge's core feature, "the Company Gate," works by reading the content of inbound and outbound messages and classifying them, for example to detect that an inbound message is a complaint about the assigned technician so it can be held from that technician's device and escalated to the office, or to determine that an outbound message from a former assignee on a closed job should queue for admin release. This means:

Message content is read by an automated system (and, in self hosted deployments with cloud classification enabled, may be sent to our classification service) for the purpose of deciding how the message should be routed.
The classification result, not necessarily the raw message, is what determines gating.
Where the customer enables an AI auto responder, message content may also be used to generate an automated reply, which is disclosed to the end customer as coming from an automated system in jurisdictions that require it, including the European Union under Article 50 of the EU AI Act, in force since August 2, 2026 (see cookies_and_web.md for detail and sourcing).
Customers running a fully local, self hosted classification model keep message content on their own server at all times; no message content leaves the customer's infrastructure in that configuration. Verified against the shipped product on 31 August 2026: message classification currently runs through a hosted model provider in the United States by default, in every deployment. A fully local classification build, in which no message content leaves the customer's own server, is available on request and is not the default. Any written attestation of local only processing must name the build it describes.

4. Purposes of processing

Operating the core texting, gating, and classification features of SMS Bridge.
Account administration, billing, and customer support.
Security, fraud prevention, and abuse monitoring (for example detecting a compromised admin account).
Service improvement, using aggregated or de-identified usage statistics where possible.
Legal compliance, including responding to lawful requests from authorities.

We do not sell personal information. We do not use customer message content to train models that serve other customers without a separate, explicit, opt-in agreement; Verified on 31 August 2026: no model training of any kind is performed on customer message content, aggregated or otherwise. Message content is sent to the classification provider to classify a single message and is not retained by us for training.

5. Retention

Message content and contact records: retained for the life of the account. Verified on 31 August 2026: the product applies no automatic deletion. Nothing ages out on its own, and the oldest records in the reference deployment date from February 2021. Deletion happens when the customer asks for it or closes the account. A customer that needs a shorter retention period should tell us in writing and we will apply it.
Billing and account records: retained per Canadian tax and corporate record-keeping obligations (generally a minimum of six years under Canadian federal and Alberta requirements for business records; I have not independently verified the exact current statutory minimum for this product's specific record types, needs counsel).
Technical and diagnostic logs: verified on 31 August 2026, application logs rotate daily and seven days are kept, after which they are deleted. The in product audit log, which records who read a held message and when, is part of the customer's account record and is kept for the life of the account, because its purpose is to be there when someone asks what happened.
On account termination, see terms_of_service.md, Section on Data Export on Exit, for the data return and deletion timeline.

6. Sub-processors

See dpa_and_subprocessors.md for the current sub-processor list structure. At minimum, a hosted deployment or the carrier API gateway will involve:

A carrier API provider (for example Telnyx) for A2P/10DLC message delivery, when the customer uses the carrier gateway rather than the Android handset relay.
Cloud infrastructure providers for hosted deployments.
Payment processing providers for billing.

The Android handset relay gateway does not send message content through a third party carrier API; it relays through the customer's own SIM and mobile network operator, the same as a normal consumer phone.

7. International transfer

Where personal information is transferred out of the jurisdiction where it was collected (for example, a UK customer's data processed on infrastructure located outside the UK), we rely on appropriate safeguards, which may include Standard Contractual Clauses (EU), the UK International Data Transfer Addendum, or an assessment that the destination provides adequate protection. Self hosted deployments where the customer's server remains in its home country generally avoid this question entirely for message content, because we do not receive it.

8. Data subject / individual rights

Depending on the applicable law, an individual (an end customer texting the company, or an employee of the customer) may have rights to:

Access a copy of their personal information (GDPR Art. 15, PIPEDA Principle 9, CCPA right to know).
Correct inaccurate personal information (GDPR Art. 16, CCPA right to correct).
Delete personal information, subject to exceptions such as legal retention obligations (GDPR Art. 17, CCPA right to delete).
Object to or restrict certain processing (GDPR Art. 18/21).
Data portability (GDPR Art. 20).
Opt out of sale or sharing of personal information, if applicable; we do not sell personal information, so this right is generally not triggered, but customers should still be able to submit the request (CCPA/CPRA).

Because the customer is generally the controller/business for its own end customer and employee data, requests from an individual should generally be directed to the customer first. Where we act as controller (for example, for our own customer account holders) or where a customer asks us to help fulfill a request in a hosted deployment, contact info@inotekplus.com.

9. Security

We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including encryption in transit, access controls, and audit logging. Current technical controls, verified on 31 August 2026: TLS for all traffic in transit, with HTTP Strict Transport Security enforced; passwords stored as bcrypt hashes; sessions issued as short lived signed tokens with separate refresh tokens; login attempts rate limited by source address; role based access control, with messages held at the gate readable by management roles only; every read of a held message written to an audit log; records separated by tenant at the query layer. Hosting is OVH Canada, Beauharnois and Montreal, Quebec. The database is not separately encrypted at rest beyond the protections of the host operating system and database account controls, and we state that plainly rather than implying more. We do not currently publish an incident response service level; incidents are handled directly by the operator of the system.

10. Children's data

SMS Bridge is a business to business product for field service companies and their staff and customers. It is not directed at children, and we do not knowingly collect personal information from children through the product.

11. Changes to this policy

We will post updates here with a new effective date and, where changes are material, provide notice to customer administrators.

12. Contact

Ino Tek Plus Holding, Fort McMurray, Alberta, Canada. info@inotekplus.com. inotekplus.com.

Reminder: this document is a template, not a finished legal instrument. Do not publish it without review by qualified counsel in each jurisdiction where SMS Bridge is sold, and without engineering confirmation of the specific defaults flagged above as "I don't know."