EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles)

SmartTouch Interactive (“STI”) is committed to protecting the privacy of individuals and maintaining compliance with applicable data protection laws, including the EU-U.S. Data Privacy Framework (DPF) Principles. This Privacy Policy outlines our practices for handling personal data collected, used, and transferred in connection with our services. STI adheres to the EU-U.S. Data Privacy Framework (DPF) Principles as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. You can learn more about the DPF program and view our certification at the U.S. Department of Commerce’s DPF website: https://www.dataprivacyframework.gov. SmartTouch Interactive is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

https://smarttouchinteractive.com/wp-content/uploads/2025/10/SmartTouch-Terms-Conditions-DPF-Final.pdf

Data Analysis

Collection: We collect personal data from clients and their customers, including identifiers (e.g., name, email, phone, address, IP), marketing preferences, and interaction data. Use: Data is processed for CRM, marketing automation, campaign reporting, and customer relationship management. Transfer: Data may be shared with trusted service providers (sub-processors) under contract, limited to purposes consistent with this Policy.

The email address you provide for order processing, will only be used to send you information and updates pertaining to your order.

If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information, etc.

Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

Notice to Customers

a. Individuals are notified at the time of data collection regarding what personal data is collected, why it is collected, and how it will be used.

b. Notices are reviewed for accuracy and provided at registration forms, client campaigns, and onboarding processes.

c. STI may also be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

d. The Privacy Policy is publicly available on our website at www.smarttouchinteractive.com/privacy.

Opt-Out/Opt-In

Individuals may opt-out of receiving marketing communications at any time by using unsubscribe links or contacting privacy@smarttouchinteractive.com. Where sensitive data (e.g., health, financial, or children’s data) is collected, opt-in consent will be obtained before processing. STI maintains an internal suppression system to respect opt-out/opt-in choices across all campaigns.

Onward Transfer

All onward transfers of personal data to third parties are governed by written contracts requiring compliance with DPF Principles. STI remains liable for the processing of personal data it transfers to third parties acting on its behalf.

Access Rights

Individuals may request access to their personal information, as well as correction, amendment, or deletion of inaccurate or unlawfully processed data. Requests should be submitted to privacy@smarttouchinteractive.com, and responses will be provided within 30 days.

Security

STI implements technical and organizational measures, including encryption, role-based access controls, secure backups and firewalls, regular audits, and employee training, to protect personal information.

Data Integrity and Purpose Limitation

Personal data is processed only for purposes disclosed at collection and consistent with the DPF Principles. STI ensures that data is accurate, complete, current, and reliable for its intended use.

Enforcement and Dispute Resolution

a. Individuals may raise privacy concerns by contacting our Customer Service Department at support@smarttouchinteractive.com. In compliance with the EU-U.S. DPF, SmartTouch Interactive commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF to ANA DPF Dispute Resolution, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit ANA DPF Dispute Resolution for more information or to file a complaint. The services of ANA DPF Dispute Resolution are provided at no cost to you. https://www.ana.net/content/show/id/accountability-dpf-consumers

b. STI may also be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

c. If unresolved, individuals may seek binding arbitration under the DPF. https:// www.ana.net/content/show/id/accountability-dpf-consumers

d. National security-related complaints may be directed to the U.S. Department of State Ombudsperson.

Assessment

STI conducts annual compliance reviews through internal self-assessment procedures. These reviews verify compliance with this Privacy Policy, complaint handling, and alignment with DPF Principles. Independent audits may be conducted when appropriate.

Training

All employees receive general training on this Privacy Policy and their responsibilities under DPF. Employees with access to personal data receive enhanced training on data handling, security protocols, and complaint resolution. Employee policies are updated regularly to reflect evolving privacy obligations.

Contact Information

For questions, concerns, or requests related to this Privacy Policy, please contact:

SmartTouch Interactive – Privacy Office
8500 Shoal Creek Building 4 Suite 100
Austin, Texas 78757
Email: support@smarttouchinteractive.com
Phone: +1 512-582-5900 Leads