Rivvia Sales, LLC
Privacy Policy

Effective Date: January 1, 2025
Last Updated: December 21, 2025

 

Rivvia Sales, LLC (“Rivvia,” “we,” “our,” or “us”) is committed to protecting the privacy, confidentiality, and security of individuals who visit RivviaSales.com (the “Site”), submit applications, participate in recruiting or onboarding activities, communicate with Rivvia, or otherwise engage with Rivvia as independent contractor prospects, applicants, contractors, or users.

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This Privacy Policy describes, in detail, the categories of information we collect, the purposes for which we collect and use such information, how and with whom information may be shared, how long information is retained, the safeguards we use to protect information, and the rights and choices available to individuals with respect to their personal information.

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This Privacy Policy is intentionally drafted to align fully and consistently with Rivvia’s:

• SMS/Text Messaging Policy

• Telephone Consumer Protection Act (TCPA) Policy

• Terms of Use

• Applicable federal, state, and carrier privacy, communications, and data-protection requirements

 

Where personal information is collected or processed in connection with SMS, MMS, AI-assisted messaging, automated communications, or recruiting workflows, this Privacy Policy should be read together with the SMS/Text Messaging Policy. In the event of a conflict, the SMS-specific provisions govern the handling of SMS-related data.

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By accessing or using the Site, submitting information, applying for opportunities, communicating with Rivvia, or otherwise participating in any recruiting, onboarding, or communication process administered by Rivvia, you acknowledge that you have read and understand this Privacy Policy and agree to the collection, use, and processing of your information as described herein, to the extent permitted by law.

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1. Definitions

For purposes of this Privacy Policy, the following definitions apply and are intended to be interpreted consistently with applicable privacy, consumer-protection, telecommunications, and employment-related laws.

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1.1 “Personal Information”

“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable individual. Personal Information may include, without limitation, names, contact information, identifiers, online identifiers, application data, communication records, and other information described in this Policy.

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1.2 “Sensitive Information”

“Sensitive Information” means a subset of Personal Information that is afforded heightened protection under applicable law. This may include, where legally collected and processed:

• Government-issued identification information

• Background check or screening results

• Identity verification data

• Information protected under federal or state privacy or consumer-protection laws

Rivvia collects and processes Sensitive Information only where permitted by law, disclosed in advance, and reasonably necessary for legitimate recruiting, compliance, or operational purposes.

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1.3 “Recruitment Data”

“Recruitment Data” means Personal Information collected, generated, or processed for purposes of evaluating, engaging, qualifying, onboarding, training, managing, or communicating with independent contractor candidates, applicants, or prospects. Recruitment Data may include application responses, interview notes, assessments, communications, scheduling data, and onboarding status.

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1.4 “Processing” or “Process”

“Processing” or “Process” means any operation or set of operations performed on Personal Information, whether by automated or manual means, including but not limited to collecting, recording, organizing, structuring, storing, using, accessing, transmitting, sharing, analyzing, retaining, securing, or deleting information.

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1.5 “SMS Data”

“SMS Data” means Personal Information collected or processed in connection with Rivvia’s SMS or MMS text messaging programs, including:

• Mobile telephone numbers

• Message content and interaction history

• Consent, opt-in, and opt-out records

• Message timestamps and delivery metadata

• Preference and suppression list data

SMS Data is governed by this Privacy Policy and Rivvia’s SMS/Text Messaging Policy.

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1.6 “AI-Assisted Systems” or “Automated Systems”

“AI-Assisted Systems” or “Automated Systems” means software tools, algorithms, virtual assistants, chatbots, or automated workflows that may be used by Rivvia to support communications, recruiting operations, scheduling, or internal efficiency. Such systems operate under defined rules, human oversight, and compliance controls and do not override consent, opt-out, or legal requirements.

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1.7 “Service Provider” or “Vendor”

“Service Provider” or “Vendor” means a third party that processes Personal Information on Rivvia’s behalf for business, operational, compliance, or technical purposes, such as messaging platforms, hosting providers, recruiting systems, analytics tools, or background screening providers, subject to contractual confidentiality and data-protection obligations.

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1.8 “You” or “User”

“You” or “User” means any individual who accesses the Site, submits information, communicates with Rivvia, participates in recruiting or onboarding activities, or otherwise interacts with Rivvia through any channel.

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2. Scope & Applicability

This Privacy Policy governs the collection, use, processing, storage, disclosure, and protection of Personal Information by Rivvia Sales, LLC in connection with its website, recruiting operations, communications programs, and related services. This Policy applies to all Personal Information processed by Rivvia, regardless of the method of collection or the technology used.

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2.1 Covered Platforms and Channels

This Privacy Policy applies to Personal Information collected through or in connection with:

• RivviaSales.com and any subdomains, landing pages, or web-based portals operated by Rivvia

• Online application, recruiting, and registration forms

• SMS and MMS text messaging programs

• Email communications

• Voice calls, call recordings, call transcriptions, and voicemail interactions, where permitted by law

• AI-assisted virtual agents, chatbots, and automated messaging systems

• Orientation, training, onboarding, and operational communications

• Customer support, helpdesk, and compliance-related interactions

• Authorized third-party platforms and tools used on Rivvia’s behalf

This Policy applies whether interactions occur through desktop, mobile, or other devices.

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2.2 Covered Individuals

This Privacy Policy applies to Personal Information relating to:

• Website visitors

• Independent contractor prospects

• Applicants and candidates

• Independent contractors and trainees

• Individuals who communicate with Rivvia through SMS, email, voice, or chat

• Individuals whose information is submitted by them directly or through authorized third-party sources

For avoidance of doubt, this Privacy Policy does not create an employment relationship and does not alter the independent contractor nature of opportunities described by Rivvia.

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2.3 Relationship to SMS/Text Messaging Policy

Personal Information collected or processed in connection with Rivvia’s SMS and MMS messaging programs is governed by this Privacy Policy and Rivvia’s SMS/Text Messaging Policy.

In the event of any inconsistency or conflict between this Privacy Policy and the SMS/Text Messaging Policy with respect to SMS-related data, the SMS/Text Messaging Policy controls.

This dual-policy structure is intended to ensure:

• Clear disclosure of SMS-specific practices

• Compliance with TCPA, FCC, and carrier requirements

• Transparent handling of consent, opt-out, and message metadata

 

2.4 Relationship to Other Rivvia Policies

This Privacy Policy operates in conjunction with Rivvia’s:

• Terms of Use

• TCPA Policy

• Recruiting Policies and Disclosures

• Non-Discrimination and Equal Opportunity Policies

Each policy governs a specific aspect of Rivvia’s operations. This Privacy Policy governs privacy and data-handling practices and does not supersede contractual terms or legally required disclosures.

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2.5 Geographic Scope

This Privacy Policy applies to individuals located in the United States. Rivvia’s services and recruiting programs are directed to U.S. residents only, and Rivvia does not intentionally target or solicit individuals located outside the United States.

Where state-specific privacy laws apply, Rivvia complies with such laws and provides additional rights or disclosures as required.

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2.6 Applicability Across Technologies

This Privacy Policy applies regardless of whether Personal Information is processed:

• Manually by Rivvia personnel

• Through automated or AI-assisted systems

• Via third-party service providers or platforms

The use of automation, artificial intelligence, or similar technologies does not reduce Rivvia’s responsibility to protect Personal Information or comply with applicable law.

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2.7 Changes in Scope

Rivvia may expand or modify the scope of its services, technologies, or communication channels over time. When such changes materially affect privacy practices, Rivvia will update this Privacy Policy and provide notice as required by law.

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3. Categories of Personal Information Collected

Rivvia Sales, LLC collects Personal Information that is reasonably necessary to operate its website, administer recruiting and onboarding activities, communicate with individuals, comply with legal and regulatory obligations, and maintain operational integrity. The categories of Personal Information collected may vary depending on how an individual interacts with Rivvia and the stage of engagement.

Rivvia does not collect Personal Information indiscriminately and applies data-minimization principles to limit collection to legitimate business and compliance purposes.

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3.1 Identifiers and Contact Information

Rivvia may collect basic identifying and contact information, including:

• First and last name

• Email address

• Mobile telephone number

• Mailing address or general location (e.g., city and state)

• Online identifiers such as IP address or device identifiers

This information is used to identify individuals, facilitate communications, and manage recruiting and operational workflows.

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3.2 Recruiting and Application Information

In connection with recruiting and independent contractor evaluation, Rivvia may collect information voluntarily provided by individuals, including:

• Application submissions and form responses

• Work history, sales experience, or qualifications

• Statements of interest or availability

• Territory preferences or travel availability

• Training or onboarding status

Recruiting and application information is used solely for evaluating suitability, coordinating onboarding, and managing recruiting pipelines.

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3.3 Communications Information

Rivvia collects information related to communications between individuals and Rivvia, including:

• SMS and MMS message content and interaction history

• Email correspondence

• Chat or AI-assistant interactions

• Support requests and responses

• Voice call recordings, transcriptions, or voicemail content where permitted by law and disclosed in advance

Communications information is used for operational support, compliance verification, quality assurance, and dispute resolution.

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3.4 SMS-Specific Information (Alignment With SMS Policy)

In connection with Rivvia’s SMS/Text Messaging Program, Rivvia may collect and maintain:

• Mobile telephone numbers

• Opt-in and consent records, including date, time, method, and disclosure language

• Opt-out and suppression list records

• Message delivery status and timestamps

• HELP requests and support interactions

SMS-specific information is governed by this Privacy Policy and Rivvia’s SMS/Text Messaging Policy and is maintained to demonstrate TCPA and carrier compliance.

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3.5 Consent, Preference, and Compliance Records

Rivvia maintains records related to consent and compliance, including:

• Express consent records for SMS and other communications

• Preference and communication settings

• Opt-out, revocation, and do-not-contact records

• Acknowledgments of policies or disclosures

These records are used to enforce individual choices, honor legal requirements, and support audit and litigation defense.

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3.6 Technical, Device, and Usage Information

When individuals interact with Rivvia’s website or systems, Rivvia may automatically collect technical information, including:

• IP address and approximate geolocation

• Browser type and operating system

• Device type and settings

• Pages viewed, session duration, and interaction timestamps

• Error logs, performance data, and security events

This information is used for system security, analytics, troubleshooting, and improving functionality.

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3.7 Information Collected Through AI-Assisted or Automated Systems

Where AI-assisted tools, chatbots, or automated workflows are used, Rivvia may collect and process:

• Inputs provided by individuals during interactions

• Contextual information necessary to route or respond to inquiries

• Interaction metadata and system logs

AI-assisted systems operate under defined rules and human oversight and do not collect information beyond what is necessary to fulfill their operational purpose.

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3.8 Information From Third-Party Sources

Rivvia may receive Personal Information from authorized third-party sources, including:

• Background screening or identity verification providers (where permitted by law)

• Recruiting platforms or referral partners where individuals have opted in

• Publicly available or professional networking information voluntarily made available by individuals

Information obtained from third parties is handled in accordance with this Privacy Policy and applicable law.

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3.9 Sensitive Personal Information

Rivvia may collect limited categories of Sensitive Personal Information only where legally permitted, disclosed in advance, and reasonably necessary, such as:

• Government-issued identification for compliance or verification

• Background check results where required or authorized

Rivvia does not knowingly collect sensitive personal information through SMS programs and does not use such information for marketing purposes.

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3.10 Information We Do Not Intentionally Collect

Rivvia does not intentionally collect:

• Social Security numbers through public website forms

• Financial account or payment card information through SMS

• Biometric identifiers

• Personal information of individuals under the age of 18

If such information is inadvertently received, Rivvia takes reasonable steps to limit retention and protect the data.

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4. Sources of Personal Information

Rivvia Sales, LLC collects Personal Information from a variety of sources in order to operate its website, administer recruiting and onboarding activities, communicate with individuals, and comply with legal and regulatory obligations. The sources of Personal Information vary depending on how an individual interacts with Rivvia and the nature of the relationship.

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Rivvia does not obtain Personal Information from unauthorized or deceptive sources and does not engage in the purchase of bulk contact lists for SMS or recruiting purposes.

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4.1 Information Provided Directly by You

Rivvia collects Personal Information that individuals voluntarily provide, including when they:

• Visit or interact with RivviaSales.com

• Complete online application, recruiting, or registration forms

• Submit inquiries or requests for information

• Communicate with Rivvia via SMS, email, voice calls, or chat

• Participate in interviews, orientations, or training sessions

• Interact with AI-assisted virtual agents or automated systems

Information provided directly by individuals is used for the purposes described at the time of collection and as further outlined in this Privacy Policy.

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4.2 Information Collected Through Automated Technologies

When individuals access or use Rivvia’s website or systems, Rivvia may automatically collect certain information through technical and analytical means, including:

• Cookies, pixels, and similar tracking technologies

• Server logs and security monitoring tools

• Website analytics platforms

• Device, browser, and usage metadata

This information is collected to support system functionality, security, analytics, and performance optimization.

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4.3 Information Collected Through SMS and Communication Systems

In connection with Rivvia’s SMS, email, and voice communication programs, Rivvia may collect Personal Information from:

• SMS opt-in and opt-out interactions

• Message replies, HELP requests, or support inquiries

• Call recordings or transcriptions where legally permitted and disclosed

• Messaging platform delivery and interaction logs

Such information is collected to facilitate communications, enforce consent preferences, and demonstrate compliance with TCPA and carrier requirements.

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4.4 Information Collected Through AI-Assisted or Automated Systems

Rivvia may collect Personal Information through AI-assisted tools, chatbots, or automated workflows when individuals interact with such systems. This may include:

• Inputs provided by the individual during interactions

• Contextual information required to route or respond to requests

• Interaction timestamps and system logs

AI-assisted systems operate under defined rules and human oversight and do not independently collect information beyond what is necessary to fulfill their operational purpose.

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4.5 Information from Third-Party Service Providers

Rivvia may receive Personal Information from authorized third-party service providers acting on Rivvia’s behalf, including:

• Recruiting platforms or applicant-tracking systems

• Background screening or identity verification providers, where permitted by law

• Messaging, voice, or email service providers

• Cloud hosting, analytics, or IT support vendors

All such providers are contractually required to process Personal Information only for Rivvia’s authorized purposes and to maintain appropriate confidentiality and security safeguards.

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4.6 Information from Referral or Lead Sources

Where individuals have affirmatively opted in, Rivvia may receive Personal Information from referral partners, lead sources, or recruiting networks. Rivvia requires that such sources obtain lawful consent prior to sharing information and does not accept information obtained through unlawful or deceptive means.

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4.7 Information from Public or Professional Sources

Rivvia may collect limited Personal Information from publicly available or professional sources, such as professional networking platforms, where individuals have made such information publicly available. Such information is used in accordance with applicable law and this Privacy Policy.

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4.8 Information We Do Not Accept or Use as Sources

Rivvia does not knowingly obtain Personal Information from:

• Purchased or scraped SMS or email lists

• Data brokers for SMS messaging purposes

• Unauthorized third-party sources lacking lawful consent

If Rivvia becomes aware that Personal Information has been obtained from an impermissible source, reasonable steps will be taken to cease use and remediate as appropriate.

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5. Purposes for Processing Personal Information

Rivvia Sales, LLC processes Personal Information only for legitimate, disclosed, and lawful business purposes consistent with the context in which the information was collected, applicable privacy laws, and Rivvia’s operational needs. Personal Information is not processed for purposes that are incompatible with the original reason for collection without additional notice or consent where required by law.

Rivvia applies purpose-limitation and data-minimization principles to ensure Personal Information is used appropriately and proportionately.

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5.1 Recruiting, Evaluation, and Independent Contractor Engagement

Rivvia processes Personal Information to support recruiting and independent contractor engagement activities, including to:

• Review and evaluate applications and expressions of interest

• Assess qualifications, experience, and availability

• Communicate regarding opportunities, next steps, and requirements

• Schedule interviews, orientations, or training sessions

• Manage recruiting pipelines, candidate status, and onboarding workflows

Personal Information processed for recruiting purposes is used solely to evaluate suitability and manage engagement and is not used for unrelated marketing purposes.

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5.2 Communications and Relationship Management

Rivvia processes Personal Information to communicate with individuals through lawful and authorized channels, including:

• SMS and MMS text messages

• Email communications

• Voice calls and voicemail, where permitted by law

• AI-assisted chat or messaging systems

Communications may include recruiting updates, onboarding instructions, scheduling notices, training reminders, compliance communications, and responses to user-initiated inquiries. All communications are subject to consent, opt-out, and timing controls described in Rivvia’s SMS/Text Messaging Policy and TCPA Policy.

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5.3 Consent Management and Compliance Enforcement

Rivvia processes Personal Information to establish, document, and enforce consent and communication preferences, including to:

• Obtain and record express consent for SMS and other communications

• Honor opt-out, revocation, and suppression requests

• Maintain do-not-contact and preference lists

• Demonstrate compliance with TCPA, FCC rules, and carrier requirements

These processing activities are critical to Rivvia’s legal compliance and audit readiness.

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5.4 Operation of SMS, Email, and Messaging Programs

Personal Information is processed to operate Rivvia’s messaging programs in a compliant and functional manner, including to:

• Deliver authorized messages

• Track message delivery and interaction status

• Respond to HELP or support requests

• Manage message frequency, timing, and routing

Messaging-related processing is limited to the scope disclosed at the time of consent and governed by Rivvia’s SMS/Text Messaging Policy.

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5.5 AI-Assisted and Automated Processing

Rivvia may process Personal Information through AI-assisted or automated systems for purposes such as:

• Routing inquiries and scheduling communications

• Generating standardized informational responses

• Supporting recruiting operations and internal efficiency

• Providing timely support through chat or messaging interfaces

AI-assisted processing is conducted under human oversight, does not override consent or opt-out controls, and does not involve independent decision-making related to hiring, compensation, or eligibility.

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5.6 Website Operations, Analytics, and Performance Improvement

Rivvia processes Personal Information to operate, secure, and improve its website and systems, including to:

• Monitor site usage and performance

• Diagnose technical issues and prevent fraud

• Improve functionality, navigation, and user experience

• Maintain system security and integrity

Analytics and usage data are used in aggregate where possible and are not used to make decisions with legal or similarly significant effects on individuals.

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5.7 Security, Fraud Prevention, and Risk Management

Personal Information may be processed to:

• Detect, prevent, and respond to security incidents

• Protect Rivvia’s systems, users, and data

• Prevent misuse, fraud, or unauthorized access

• Enforce policies and investigate violations

These activities are necessary to maintain operational security and protect both Rivvia and individuals.

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5.8 Legal, Regulatory, and Compliance Obligations

Rivvia processes Personal Information as necessary to comply with applicable laws and regulations, including to:

• Satisfy recordkeeping and reporting obligations

• Respond to lawful requests, subpoenas, or investigations

• Defend against claims, disputes, or audits

• Enforce contractual rights and obligations

Processing for legal and compliance purposes may continue even where an individual withdraws consent, to the extent permitted or required by law.

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5.9 Internal Business Operations and Administration

Rivvia may process Personal Information for internal business purposes, such as:

• Training and quality assurance

• Internal reporting and analytics

• Operational planning and management

• Improving recruiting and onboarding processes

Internal processing is conducted in a manner consistent with this Privacy Policy and applicable law.

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5.10 No Incompatible or Undisclosed Uses

Rivvia does not process Personal Information for purposes that are materially different, unrelated, or incompatible with the purposes described in this Privacy Policy without providing notice or obtaining consent where required by law.

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6. SMS-Specific Privacy Practices (Alignment With SMS/Text Messaging Policy)

This Section governs the collection, use, storage, protection, and disclosure of Personal Information processed in connection with Rivvia Sales, LLC’s SMS and MMS text messaging programs (“SMS Data”). These practices are designed to align fully with Rivvia’s SMS/Text Messaging Policy, TCPA Policy, and applicable federal, state, and carrier requirements.

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6.1 Scope of SMS Data

SMS Data includes, but is not limited to:

• Mobile telephone numbers

• SMS and MMS message content

• Message timestamps and delivery status

• Consent, opt-in, and opt-out records

• HELP requests and support interactions

• Suppression list and do-not-text records

• Messaging platform metadata and audit logs

SMS Data is treated as sensitive operational data due to heightened regulatory and carrier scrutiny.

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6.2 Lawful Basis for SMS Processing

Rivvia processes SMS Data only where a lawful basis exists, including:

• Express consent provided by the recipient

• User-initiated inquiries requiring SMS responses

• Other limited circumstances permitted by applicable law

SMS Data is never processed based on implied consent, silence, or pre-checked opt-ins.

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6.3 Purpose Limitation for SMS Data

SMS Data is processed solely for purposes disclosed at the time of consent and described in Rivvia’s SMS/Text Messaging Policy, including:

• Recruiting communications and follow-ups

• Application status updates

• Onboarding and training notifications

• Scheduling confirmations and reminders

• Operational and support communications

• Compliance, audit, and recordkeeping purposes

Rivvia does not use SMS Data for third-party marketing, advertising, list resale, or unrelated promotional activity.

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6.4 Consent Recordkeeping and Verification

Rivvia maintains detailed consent records associated with SMS Data, including:

• Date and time consent was obtained

• Method of consent (web form, written, verbal, etc.)

• Disclosure language presented at opt-in

• Mobile number to which consent applies

• Source or campaign associated with the consent

These records are maintained to demonstrate compliance with the TCPA, FCC rules, and carrier audit requirements.

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6.5 Opt-Out and Suppression Enforcement

SMS Data includes records of opt-out and revocation events. Rivvia enforces opt-out requests by:

• Immediately placing numbers on suppression lists

• Preventing further SMS messages to opted-out numbers

• Enforcing suppression across all systems and campaigns

Opt-out data is retained to ensure continued compliance and prevent accidental re-messaging.

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6.6 AI-Assisted Messaging and SMS Data Controls

Where AI-assisted or automated messaging systems are used in connection with SMS communications, such systems are configured to:

• Access only SMS Data associated with valid consent

• Respect opt-out and suppression lists without exception

• Operate within defined content and purpose boundaries

• Log interactions for compliance and audit purposes

AI-assisted systems do not override consent controls, do not independently determine eligibility, and do not reuse SMS Data outside authorized purposes.

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6.7 SMS Data Sharing Restrictions

Rivvia does not sell, rent, license, or otherwise disclose SMS Data to third parties for their independent use.

SMS Data may be shared only with:

• Authorized messaging platforms or aggregators acting on Rivvia’s behalf

• Service providers supporting compliance, auditing, or technical delivery

• Legal or regulatory authorities where required by law

All recipients of SMS Data are subject to contractual confidentiality and data-protection obligations.

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6.8 Security of SMS Data

Rivvia applies enhanced safeguards to SMS Data, including:

• Access controls limiting SMS Data to authorized personnel and systems

• Secure messaging platform configurations

• Monitoring for unauthorized access or misuse

• Internal compliance reviews and audits

These safeguards are designed to protect SMS Data from unauthorized access, disclosure, or misuse.

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6.9 Retention of SMS Data

SMS Data is retained only as long as reasonably necessary to:

• Operate Rivvia’s SMS programs

• Enforce consent and opt-out preferences

• Demonstrate compliance with TCPA and carrier rules

• Defend against claims, complaints, or audits

Retention periods may extend beyond active participation where required for compliance or legal defense.

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6.10 No Sale or Cross-Context Use of SMS Data

Rivvia does not sell SMS Data and does not use SMS Data for cross-context behavioral advertising or profiling.

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6.11 Relationship to General Privacy Practices

This Section applies specifically to SMS Data. Where a conflict exists between this Section and other portions of this Privacy Policy regarding SMS Data, this Section controls.

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7. Data Sharing & Disclosure

Rivvia Sales, LLC does not sell, rent, or trade Personal Information. Personal Information is shared only as necessary to operate Rivvia’s services, comply with legal obligations, and support recruiting and communications activities.

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7.1 Service Providers

Rivvia may share Personal Information with authorized service providers and vendors that perform services on Rivvia’s behalf, including:

• SMS, voice, and email messaging platforms

• Recruiting and applicant tracking systems

• Cloud hosting, analytics, and IT service providers

• Background screening or identity verification providers, where permitted by law

Service providers are contractually required to use Personal Information only for Rivvia’s authorized purposes and to maintain appropriate confidentiality and security safeguards.

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7.2 Legal and Regulatory Disclosure

Rivvia may disclose Personal Information when required to do so by law, regulation, subpoena, court order, or other lawful governmental request, or when necessary to protect Rivvia’s rights, safety, or property.

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7.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or a portion of Rivvia’s business or assets, Personal Information may be transferred as part of the transaction, subject to applicable law and appropriate confidentiality protections.

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8. Data Retention & Deletion

Rivvia retains Personal Information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including recruiting, communications, compliance, and operational needs.

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8.1 Retention Criteria

Retention periods may vary based on:

• The nature of the information collected

• The purpose for which it is processed

• Legal, regulatory, or contractual requirements

• The need to maintain compliance or defend against claims

Consent and opt-out records related to SMS communications may be retained longer to demonstrate TCPA and carrier compliance.

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8.2 Deletion and Disposal

When Personal Information is no longer required, Rivvia takes reasonable steps to delete, anonymize, or securely dispose of the information in accordance with applicable law and internal procedures.

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9. Data Security

Rivvia implements commercially reasonable administrative, technical, and organizational measures designed to protect Personal Information from unauthorized access, use, disclosure, alteration, or destruction.

Security measures may include:

• Access controls and role-based permissions

• Secure system configurations and vendor controls

• Monitoring for unauthorized activity or misuse

• Internal reviews of security and compliance practices

While no system can be guaranteed to be completely secure, Rivvia works to maintain safeguards appropriate to the sensitivity of the information processed.

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10.  MESSAGING & A2P 10DLC DATA

When you opt in to receive text messages from Rivvia Sales, we collect and 
process:

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Data Collected:
- Mobile phone number
- Opt-in date, time, and method
- Message delivery status and timestamps
- Carrier information
- Device type (if available through carrier data)
- Opt-out requests and preferences

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How We Use This Data:
- Deliver requested SMS communications
- Maintain compliance with TCPA and carrier requirements
- Track delivery success and optimize messaging campaigns
- Honor opt-out requests
- Respond to support inquiries
- Comply with legal obligations and audit requirements

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Data Sharing:
Your mobile messaging data is shared only with:
- Our messaging service provider [INSERT NAME] (as a service processor)
- Wireless carriers (for message delivery only)
- Law enforcement or regulators (when legally required)

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We DO NOT:
- Sell mobile phone numbers to third parties
- Share data for unrelated marketing purposes
- Use messaging data for purposes beyond stated consent

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Data Retention:
- Consent records: Minimum 4 years (TCPA requirement)
- Opt-out records: Retained indefinitely
- Message logs: Per carrier and compliance requirements
- Inactive numbers: Removed from active campaigns after 12 months of no 
  engagement (unless opted out sooner)

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Your Rights:
- Request a copy of your consent record
- Opt out at any time (reply STOP)
- Request deletion of data (subject to legal retention requirements)
- Update your mobile number on file

For messaging privacy questions: support@rivviasales.com

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