Privacy Policy

Last updated: January 20, 2023

ConvertAble, LLC (“ConvertAble,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how ConvertAble collects, uses, discloses, and secures (“processes”) information about individuals that constitutes personal information under applicable data protection and privacy laws (hereinafter, “Personal Information”) through (“Website”), our computer or mobile applications, our electronic communications, including email and text messages, and other websites and services that we provide that are controlled by us and display this Privacy Policy (collectively, the “Service”).

Please read this Privacy Policy Carefully to understand how we handle your Personal Information. If you do not agree to this Privacy Policy, please do not use the Service.

ConvertAble’s Roles and Responsibilities

This Privacy Policy applies to the extent ConvertAble process Personal Information as a data controller or business, such that ConvertAble controls how and why Personal Information is processed.

This Privacy Policy does not apply to the extent ConvertAble processes Personal Information as a data processor or service provider, such as on our Customers’ (as that term is defined below) websites or applications, which may have their own terms and privacy policies. If your Personal Information has been submitted to us by or on behalf of a Customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the Customer directly. Because we may only access a Customer’s data upon instruction from that Customer, if you wish to make your request directly to us, please provide to us the name of the Customer who submitted your Personal Information to us. If we are able to verify the Customer, we will refer your request to that Customer and support them as needed in responding to your request within a reasonable timeframe.

If you are an employee, officer, or other agent of the Customer, our use of your Personal Information may be governed by ConvertAble’s agreement with the Customer.

Personal Information We Collect

ConvertAble collects information from and about users of our Service in a variety of ways. We act as a service provider to organizations (“Customers”) who want to engage with individual consumers (“Customer Consumers”) through the Service. In providing the Service to our Customers, we collect and obtain information about Customer Consumers to, among other services, deliver commercial text messages to Customer Consumers’ mobile phones that can also be used to make payments. In this capacity, ConvertAble acts as a data processor. We also collect information from Customers, Customer Consumers and other individuals when they visit our Website or register to use our Services.

Information You Provide. We collect information you provide when you use the Service or otherwise communicate with us.

If you are an agent, officer, or other employee of a Customer or an individual using services controlled or managed by ConvertAble (“ConvertAble Consumers”), we will collect the Personal Information you provide when you register for and contract to use the Service.

If you are a ConvertAble Consumer, we collect various Personal Information that you provide when you use the Service, for example, when you:

  • Send messages via the Service, we will collect any information included in those messages;

  • Interact with content on one of our websites and submit your email address, phone number, and/or any additional information that you choose to provide;

  • Contact us with questions or for customer service, we will collect contact information such as your name, email address, and phone number, and any information you provide in connection with your question; and

  • Participate in a contest, sweepstakes, research study, or email survey, we will collect basic contact information and any other information you provide in connection with these activities.

Personal Information about Customer Consumers that Customers Provide to Us. Customers may provide us with information about their Consumers through the Service or offline for inclusion in the Service. Such information may include Customer Consumers’ name, email address, and telephone number. Our Customers are responsible for providing notice and obtaining appropriate consents necessary for us to process this Personal Information.

Personal Information We Automatically Collect. Like most online services, we may automatically receive and store certain Personal Information about you through your browser or device. As discussed further below, we and our service providers may use a variety of technologies, including cookies, to assist in collecting this information.

  • Device Information. We collect technical information associated with the device(s) you use to access our Service, including information related to your browser and operating system, IP address (the Internet address of your computer), unique device identifiers, and other information such as your device type.

  • Usage Information. We collect a variety of information to better understand use of our Service. This may include the webpage that you were visiting before accessing our Service, the pages or features of our Service you use, how much time you spend there, date and time of use, and information about your usage preferences.

  • Transaction Information. We also collect information to help us verify transactions completed using our Service. This may include the names and email addresses of parties to a transaction, subject line, history of actions that individuals take on a transaction (e.g., reviewing and approving transactions, providing payment method details) and Personal Information, such as name, email address, IP address, and authentication methods.

Personal Information We Collect from Social Media and Other Content Platforms. When you “like” or “follow” us on Facebook, Instagram, Twitter, LinkedIn, or other social media sites, we may collect some Personal Information including your name, e-mail address, and any comments or content you post relevant that is to us. We also collect your Personal Information if you sign up for one of our promotions or submit information to us through social media sites.

Personal Information We Collect from Others. We may also receive Personal Information about you from service providers, advertisers, business partners, and other third parties that we work with. We may combine this information with other information we received about you through the Service.

How We Use Your Personal Information

We, or our service providers, use your Personal Information for various business and operational purposes:

  • Administer your account, including to verify your information and to collect payments;

  • Provide, manage, support, and improve our Service;

  • Respond to your requests for information and provide you with more effective and efficient customer service;

  • Conduct internal business operations in support of our Service, such as auditing, detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, resolving crashes, invoicing and accounting, sales and marketing, analytics, and research and development;

  • Contact you regarding ConvertAble and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you (in accordance with any privacy preferences you have expressed to us);

  • Customize content, preferences, and advertising on the Service, across the Internet and elsewhere;

  • Comply with applicable laws, regulations, and other legal processes and procedures;

  • Establish, exercise, or defend our legal rights; and

  • For any other purpose with your consent.

Legal Basis for Use of Your Personal Information

The legal basis for using your Personal Information as set out in this Privacy Policy are as follows:

  • Where use of your Personal Information is necessary to perform our obligations under a contract with you (eg., to comply with: the terms of service for use of our Service which you accept by browsing the websites/registering; and/or our contract to provide our Service to you);

  • Where use of your Personal Information is necessary for our legitimate interests or the legitimate interests of others (in each case provided such interests are not overridden by your privacy interests), such as the following: to provide security for our website and applications; operate our business and our Service; make and receive payments; validate payment transactions completed using our Service; to establish and defend our legal rights; or prevent fraud and to know the customer to whom we are providing our Service);

  • Where required by legal or regulatory obligations, such as the following: to assist with investigations, complaints, regulatory requests, litigation, arbitration, mediation or requests from individuals or to comply with court orders; or

  • Where we have obtained your consent.

Cookies and Similar Technologies

To collect the information in the “Personal Information We Collect” section above, we and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. We use these technologies in order to offer you a more personalized experience in the future (e.g. send personalized text messages such as shopping cart reminders), by understanding and remembering your particular browsing preferences.

  • A web server log is a file where website activity is stored.

  • A cookie is a small text file that is placed on your computer or mobile device when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Service you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.

  • Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads, and/or emails that are designed to: (i) collect usage information like ad impressions or clicks and email open rates; (ii) measure popularity of the Service and associated advertising; and (iii) access user cookies.
    As we adopt additional technologies, we may also gather information through other methods and technologies.

Please note that you can change your settings to notify you when certain cookies are being set or updated, or to block certain cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including flash cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Service and that ConvertAble does not control the choices that are available through above third party offerings.

For more information on the cookies we use and the purposes for which we use them, please refer to our Cookies Notice. By continuing to use our websites and/or our Service, you are agreeing to our use of cookies as described in our Cookies Notice.

Online Analytics and Interest-Based Advertising

Analytics. We may use third-party analytics services (such as those of Google Analytics) on our Service to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your Personal Information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Interest-Based Advertising. When you use the Service, ConvertAble may use the information collected from you in order to display advertising to you on other websites, such as Facebook or Google about products, services, and related features that we think may be of interest to you to improve and personalize your use of the Service. This type of advertising is called retargeting. These ads may be personalized based on various factors such as the features you are using, demographic and geographic data, and other information that we collect about you. This advertising may be based on your current activity or your activity over time and may be tailored to your interests.

In order to provide this interest-based advertising, we may use third party service providers who, on our behalf, may place cookies or other tracking technologies, such as cookies and SDKs on your computer browser, mobile phone applications, or other devices to collect information about your use of the Service in order to provide interest-based advertising to you both on the Service and on other websites.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated third-parties. As described below, these providers may offer you a way to opt-out of the collection of information that is used for our interest-based advertising to you. We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each non-affiliated third-party, not us.

If you are interested in more information about interest-based advertising and how you can generally control cookies and other tracking technologies from being put on your device to deliver such advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s (DAA’s) Consumer Opt-Out link, or TrustArc’s Advertising Choices Page. To opt out of the display of interest-based advertising from Google, please visit the Google Ads Settings page. Facebook also offers settings that may control what information Facebook uses about you or your device activity for advertising purposes. For more information, you will need to log in to Facebook via the Sign In link and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app).

Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising even if you opt-out as described above. In that case, the advertising will just not be based on your interests.

Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, because of the changing state of technology and indecision within the industry regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals.

Learn more about Do Not Track.

How We Share Your Personal Information

We may share, transfer, or disclose your information to the following parties:

  • Service Providers. We may share Personal Information with third parties who provide services to us, such as analytics, payments processing, web site management, information technology, security and other similar services. When you make a payment to another user within our Services, we share your payment method details with the third-party payment processor selected by you or the other user.

  • Customers with Which You Engage. If you use the Services to engage with a Customer, we may share your Personal Information with that particular Customer.

  • Related Entities. We may share your Personal Information with our affiliates (entities that control or are under the control of ConvertAble) for business purposes. We will require these entities to comply with the terms of this Privacy Policy with regard to their use of your Personal Information.

  • State, Federal, and International Courts and Regulatory and Government Authorities. We may disclose your Personal Information as we believe to be necessary or appropriate to: (i) comply with applicable law and legal processes; (ii) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iii) enforce our Terms of Use; (iv) protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and (v) allow us to pursue available remedies or limit the damages that we may sustain.

  • Prospective Purchasers, Assignees and other Parties Involved in Corporate Transactions. We reserve the right to transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, diligence, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

  • Other Third Parties as Authorized by You. We may also share or disclose your Personal Information when you have authorized us to do so or at your direction.

From time to time, we may share aggregate or de-identified information about use of the Service and individuals. We may share or disclose such aggregate or de-identified information with any third party, including advertisers, promotional partners, and sponsors.

Protection of Personal Information

We maintain reasonable physical, technical, administrative, and organizational security measures that are designed to protect your Personal Information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. These measures are commensurate with the sensitivity of the information that we maintain about you. While we strive to protect your Personal Information against unauthorized use or disclosure, we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. ​

Retention of Personal Information

We retain your Personal Information for as long as your account is active or as needed to comply with applicable legal obligations. We will also retain and use your Personal Information as necessary to resolve disputes, protect ConvertAble and our users, and enforce our agreements. Upon request, we will provide you with more information on the exact retention periods applying to your Personal Information in each case.

Third Party Links and Features

The Service may contain links to third-party services (e.g., social media sites like Facebook and Twitter) and third-party plug-ins (e.g., the Facebook “like” button and the Twitter “follow” button). These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through these third-party links and features, nor any association with their operators. If you choose to use these sites or features, you may disclose your Personal Information not just to those third parties, but also to their users and the public more generally depending on how their services function. ConvertAble does not control these third parties and is not responsible for the content or data practices of such third-party websites or services. Any information you provide to third parties on their websites or services is covered under their privacy and data collection policies, and is not covered by this Privacy Policy. We urge you to review the privacy and security policies of these third parties before interacting with their services.

Children’s Privacy

The Service is intended for general audiences and not for children under the age of 13. If we become aware that we have collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without legally valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

Your Rights and Choices

We respect your right to make choices about the ways we collect, use, and disclose your Personal Information.

Your Legal Rights. Depending on the laws of your local jurisdiction, you may have certain rights and choices with respect to your Personal Information. For example, under local laws, you may be able to ask us to:

  • provide access to and/or a copy of certain Personal Information we hold about you;

  • prevent the processing of your Personal Information for direct-marketing purposes (including any direct marketing processing based on profiling);

  • update or rectify Personal Information which is out of date or incorrect;

  • delete certain Personal Information which we are holding about you;

  • oppose, cancel, or restrict the way that we process and disclose certain of your Personal Information;

  • transfer your Personal Information to a third-party provider of services; or

  • revoke your consent for the processing of your Personal Information.

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain Personal Information may be exempt from such requests in some circumstances, which may include if we need to keep processing your Personal Information for our legitimate interests, to comply with a legal obligation, or if you are a resident of a country or state that does not provide the rights you have requested. We will let you know where this is the case or if certain rights don’t apply in your country or state of residence. We may request you provide us with information necessary to verify your identity before responding to your request as required or permitted by applicable law. If you consider that we have processed Personal Information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with a competent data protection authority.

Marketing Communications. You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, and promotions that might appeal to your interests by contacting us using the information below:

  • You can opt-out of receiving further promotional emails from us by following the unsubscribe instructions provided in the promotional email you receive from us or by contacting us directly at the email address listed below.

  • Our Customers may send you emails or text messages using our services. If you would like to opt-out of receiving such further communications, you need to exercise your rights with our Customers by, for example, unsubscribing to Customer emails or by responding to an ConvertAble generated text message from our Customers with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT.

Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

Information for California Residents and California Notice at Collection

This section applies only to “Personal Information” about California residents, as that term is defined in the California Consumer Privacy Act (“CCPA”), and it supplements the information in the rest of our Privacy Policy. Data about individuals who are not residents of California may be handled differently and is not subject to the same California rights described below. In addition, this section does not apply to Personal Information we collect in the following circumstances:

  • From employees or job applicants in their capacity as employees or job applicants;

  • Personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services; and

  • Information that we process as a service provider on behalf of other businesses, such as our Customers. Where we are acting as a service provider to a Customer, if you wish to exercise any rights that may be available to you, you should direct your request to our Customer, who is the party responsible for receiving, assessing, and responding to your requests.

CCPA Categories of California Personal Information We Collect

Throughout this Privacy Policy, including in the “Information We Collect” section, we discuss in detail the specific pieces of Personal Information we collect about individuals. Under the CCPA, we are also required to provide you with the CCPA “categories” of Personal Information we collect. The categories we collect are:

  • Identifiers, including Personal Information as defined in California consumer records law (such as name, address, phone number, email address);

  • Commercial information (such as transaction data); and

  • Internet or other network or device activity (such as browsing history or IP address, including the city and state based on IP address).

Sources of Personal Information

We collect these categories of Personal Information as described in the Information We Collect section, which include the following sources: from you when you use our Services; through your use of our website and social media pages; our service providers and business partners; and publicly available sources.

How We Use and Disclose These Categories of Personal Information

We and our service providers may use (and in the past 12 months have used) all of the Personal Information we collect for the business purposes described in this Privacy Policy, and in accordance with our disclosures in the “How We Use Your Personal Information.” Each of the categories of Personal Information listed above is shared in accordance with the “How We Share Your Personal Information” sections above and may be disclosed to the following: ConvertAble’s service providers and agents; ConvertAble’s related entities; state, federal, and international courts and regulatory and government authorities; prospective purchasers, assignees, and other parties involved in corporate transactions, and other third parties with which that you have authorized us to share your Personal Information.

Sale of Personal Information

The CCPA also provides California residents with the right to opt out of the “sale” of Personal Information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not sell Personal Information. However, if you choose to limit the use of cookies and tracking technologies through your use of our website, please review the information in the “Online Analytics and Interest-Based Marketing” section.

Please note that we also do not knowingly sell the Personal Information of minors under 16 years of age without legally required affirmative authorization.

Your California Privacy Rights

If you are a California resident, the CCPA allows you to make certain requests about your Personal Information. Specifically, the CCPA allows you to request us to:

  • Inform you about the categories of Personal Information we collect or disclose about you; the categories of sources of such Personal Information; the business or commercial purpose for collecting your Personal Information; and the categories of third parties with whom we share/disclose Personal Information.

  • Provide access to and/or a copy of certain Personal Information we hold about you.

  • Delete certain Personal Information we have collected from you. If you choose to exercise this right, please note that we may retain your Personal Information as permitted under applicable law, including but not limited to the following purposes: to provide goods or services within the context of our relationship with you; to detect security incidents or other fraudulent or illegal activity; and to comply with ConvertAble's legal and regulatory obligations.

If you choose to exercise any of these rights, you will not be discriminated against or receive discriminatory treatment. You also may have the right to receive information about the financial incentives that we offer to you (if any).

When you seek to exercise your rights, we will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum and depending on the sensitivity of the Personal Information you are requesting and the type of request you are making, verifying your name, phone number, email address, and other account information. If we are unable to verify your request, we will notify you and request additional information. If we do not receive this information, we will close your request due to our inability to verify your identity.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. Authorized agents will be required to provide proof of their authority to act on your behalf. If an authorized representative submits a request on your behalf, we will contact you to confirm their representation. If we are unable to verify your identity, or confirm that you have authorized the request, we may not be able to respond to your request in full.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us by the following methods:


Attn: Privacy Dept.
701 Market Street, #111-133
St. Augustine, FL 32095

When seeking to exercise your rights, please provide your email address, phone number, and any other information that may be relevant to your request. You may be required to additional identifying information as a security precaution to assist us in preventing the unauthorized disclosure of your Personal Information.

California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of Personal Information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your Personal Information with third parties for their own direct marketing purposes.

Information for Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident and you have purchased products from us, you may submit a request to opt out of any potential future sales under Nevada law by email to Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Information for International Users

ConvertAble is based in the United States and, regardless of where you use our Service, the information collected as part of that use will be transferred to and maintained on servers located in the United States. By using our Service, you consent to this collection, transfer, storage, and processing of Personal Information in the United States.

In addition, the processing described above may involve overseas storage and other overseas transfer, including in or to countries or territories where the laws may provide a different level of data protection. Without limiting the foregoing, your Personal Information will be disclosed by us to our affiliated entities and vendors which conduct operational, technology and customer service functions in various jurisdictions, including the United States of America, and other countries where we operate. When Personal Information is transferred to such countries or territories not recognized under applicable law as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms as required under applicable law (such as the EU Standard Contractual Clauses) to ensure Personal Information remains protected. You can obtain a copy of the relevant data transfer mechanism we have put in place to protect personal data by contacting us as described below.

Privacy Policy Updates

We may update this Privacy Policy from time to time to reflect changes in the law, our data collection and use practices, the features of our Service, or advances in technology. We will make the revised Privacy Policy accessible through use of the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Last Updated” date included at the beginning of this Privacy Policy. If we make a material change to the Privacy Policy, you will be provided notice in accordance with legal requirements. Your use of this Service following any such change constitutes your agreement that all information collected from or about you after the revised Privacy Policy is posted will be subject to the terms of the revised Privacy Policy.

Contact Us

If you have any questions or comments about this Privacy Policy, our privacy practices or if you would like to exercise your rights and choices, please contact our Data Protection Officer at:, or by writing to us at: ConvertAble, Attn: Privacy Dept., 701 Market Street, #111-133, St. Augustine, FL 32095.