Legal Document

Privacy Policy

Last Updated: February 20, 2026

Introduction

Rank Capture Grow LLC, operating as Willow CSR ("Willow CSR," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered customer service platform and related services (the "Services").

By using our Services, you consent to the data practices described in this policy.

This Privacy Policy applies to:

  • Subscribers: Businesses that use Willow CSR to manage customer communications
  • End Users: Customers who interact with businesses through the Willow CSR platform

SMS Privacy

THIS SECTION IS CRITICAL FOR A2P 10DLC COMPLIANCE

When you provide your mobile phone number to a business using Willow CSR services, or when you communicate with a business via SMS through our platform, the following applies:

No Sharing of Mobile Information

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

How SMS Data Is Used

Your phone number and SMS communications are used solely to:

  • Facilitate communication between you and the business you are contacting
  • Provide automated responses to your service inquiries
  • Coordinate appointment scheduling (when applicable)
  • Send follow-up messages related to your specific request

What We Do NOT Do With SMS Data

  • We do NOT sell your phone number to third parties
  • We do NOT rent or trade your SMS opt-in data
  • We do NOT use your number for marketing unrelated to your inquiry
  • We do NOT share your consent data with affiliates for promotional purposes
  • We do NOT transfer your consent to other businesses

SMS Opt-Out

You may opt out of receiving SMS messages at any time by replying with any of the following keywords:

STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT

Upon receipt of your opt-out request:

  • All SMS communication ceases immediately
  • A confirmation message is sent acknowledging the opt-out
  • Your phone number is added to our suppression list permanently
  • Opt-out records are permanent and platform-wide per provisioned number. Account deletion, re-registration, or number reassignment does not reset suppression status. Suppression persists for the lifetime of the platform.

Message and data rates may apply based on your mobile carrier plan.

Information We Collect

Information Provided by Subscribers (Businesses)

  • Account Data: Business name, owner name, email address, phone number, physical address
  • Payment Data: Payment card type, last 4 digits (full card data processed by Stripe)
  • Business Verification: Government ID, business registration, EIN documentation
  • Service Configuration: Business hours, service areas, qualification rules, notification preferences

Information Provided by End Users (Customers)

  • Contact Data: Phone number (when calling or texting a business)
  • Communication Data: SMS message content, voicemail recordings, service request details
  • Voluntary Information: Name, address, photos, and other details provided during conversation

Voice Interaction Consent: By interacting with Willow via voice (including pressing DTMF keys), End Users consent to the recording of the interaction for the purposes of verifying SMS opt-in consent and ensuring service quality. This recording is necessary to comply with A2P 10DLC carrier requirements and TCPA regulations.

Information Collected Automatically

  • Call Metadata: Time, duration, caller ID, consent method (numeric_dtmf), DTMF digit pressed
  • SMS Metadata: Timestamps, delivery status, opt-in/opt-out status
  • Device Information: Carrier, general location by area code
  • Usage Data: Number of messages sent/received, response times, interaction patterns

How We Use Your Information

For Subscribers (Businesses)

We use Subscriber information to:

  • Provide, operate, and maintain the Services
  • Process transactions and billing
  • Register and maintain A2P 10DLC campaign compliance
  • Send administrative information and service updates
  • Respond to inquiries and provide support
  • Monitor and analyze usage patterns
  • Enforce our Terms of Service
  • Comply with legal obligations

For End Users (Customers)

We use End User information to:

  • Facilitate communication between you and the business you contacted
  • Provide missed call notifications and text-back services
  • Enable businesses to respond to your service inquiries
  • Maintain records of communications for service quality
  • Verify and document consent for compliance purposes
  • Comply with legal obligations

Consent Records and Retention

What We Log

For A2P 10DLC compliance, we maintain detailed consent records including:

  • Timestamp of consent (UTC)
  • Phone number (normalized E.164 format; encrypted at rest)
  • Consent method (numeric_dtmf)
  • DTMF digit pressed
  • Business identifier
  • Call SID (Twilio)

Retention Periods

  • Consent Records: 5 years from date of consent
  • SMS Message Content: 2 years (aligned with TCPA statute of limitations)
  • Call Recordings: 2 years
  • Account Data: Duration of account + 1 year
  • Opt-Out Records: Permanent (suppression list maintained indefinitely)

Note: Opt-out and STOP requests are cross-referenced in our permanent suppression list, ensuring compliance verification even after message content retention expires.

You may request deletion of your data by contacting us at info@rankcapturegrow.com, subject to our legal retention requirements.

Information Sharing

We may share your information in the following limited circumstances:

With Businesses (for End Users)

Your contact information and message content is shared with the specific business you are attempting to reach.

Service Providers

We use trusted third-party service providers to operate our platform:

  • Twilio: Telecommunications (voice and SMS)
  • Stripe: Payment processing
  • Supabase: Database and infrastructure
  • Vercel: Website hosting

These providers are contractually obligated to protect your information and may only use it to provide services to us.

Compliance and Regulatory Bodies

To maintain A2P 10DLC messaging capability, Rank Capture Grow LLC may submit Subscriber business information — including business name, address, EIN, and contact details — to The Campaign Registry (TCR), mobile carriers, and upstream telecommunications providers for the purpose of brand registration, campaign vetting, and maintaining vetted compliance status. This sharing is required for the operation of the Services and is limited to information necessary for carrier compliance.

Legal Requirements

We may disclose your information when required by law, subpoena, court order, government or regulatory request, or for protection of our legal rights.

Business Transfers

In connection with a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will provide notice before your information becomes subject to a different privacy policy.

What We Never Do

We do NOT sell or share your personal information to third parties for their marketing purposes or for cross-contextual behavioral advertising.

We do NOT sell, share, or disclose SMS opt-in data or consent information with any third party for marketing or promotional purposes.

Data Security

We implement appropriate technical and organizational measures to protect your information, including:

  • Encryption in transit (TLS 1.2+)
  • Encryption at rest (AES-256)
  • Access controls and authentication
  • Regular security monitoring
  • Secure data centers

However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

Your Rights

All Users

  • Opt-Out of SMS: Reply STOP to any message
  • Access: Request information about what data we hold
  • Correction: Request correction of inaccurate information
  • Deletion: Request deletion of your information (subject to legal retention requirements)

California Residents

Under the California Privacy Rights Act (CPRA), California residents have additional rights including: right to know what personal information is collected; right to opt-out of the sale or sharing of personal information (Note: We do not sell or share personal information for cross-contextual behavioral advertising); right to limit the use of sensitive personal information; right to correct inaccurate personal information; right to delete personal information; and right to non-discrimination for exercising privacy rights.

To exercise these rights, contact us at info@rankcapturegrow.com.

Nevada Residents

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to info@rankcapturegrow.com. We do not currently sell your personal information as defined under Nevada law.

Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will take steps to delete such information promptly.

Third-Party Services

Our Services may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to those third parties. Our telecommunications services are provided through Twilio, subject to their privacy policy.

Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will provide notice via email to Subscribers and prominent notice on our website.

Contact Us

General Support
Email: info@rankcapturegrow.com
Website: willowcsr.com

Registered Agent / Legal
Rank Capture Grow LLC, operating as Willow CSR
201 Rue Beauregard, Ste. 202
Lafayette, LA 70508

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