Effective Date:
October
1, 2024

At
Havrilla Commercial Investment Group,

("we," "us," or "our"), we value your privacy and are committed to protecting your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information in connection with our A2P messaging services.

1. Information We CollectWe may collect the following types of information in connection with A2P messaging:•
Personal Information: This includes, but is not limited to, your phone number, name, and any other information you voluntarily provide.•
Message Content: We may collect the content of the messages exchanged through our platform.•

Usage Data: We may collect data regarding your use of our A2P messaging services, including timestamps, message delivery status, and interaction with messages.

How We Use Your InformationWe use the information we collect for the following purposes:•
To send messages and notifications you have requested or consented to.•

To improve our services, including troubleshooting, analytics, and enhancing user experience.•

To ensure compliance with applicable laws and regulations.•
To prevent fraud, abuse, or misuse of our services.3.

How We Share Your InformationWe do not sell or rent your personal information to third parties.

However, we may share your information in the following circumstances:•
With service providers who assist in the operation of our messaging platform.•
With regulatory authorities, if required by law, to comply with legal obligations.•

With other third parties in the event of a merger, acquisition, or similar corporate transaction, where your information may be transferred as part of the transaction.4.

Data SecurityWe take reasonable precautions to protect your information from unauthorized access, loss, misuse, or alteration. However, no data transmission or storage system can be guaranteed to be 100% secure, and we cannot ensure the absolute security of your data.5.

Your Rights and ChoicesYou have the right to:•
Opt-out of receiving messages at any time by following the instructions provided in the message.•

Access, update, or delete your personal information, subject to applicable laws and regulations.

To exercise your rights or if you have any questions about our data practices, please contact us at
Havrilla Commercial Investment Group.6.

Third-Party ServicesOur services may contain links to third-party websites or services.

This Privacy Policy does not apply to third-party websites, and we encourage you to review their privacy policies.7.

International Data TransfersIf you are located outside of
the United States of America,
please be aware that your information may be transferred to, stored, and processed in
the United States of America
or other jurisdictions where our servers are located.

By using our services, you consent to such transfers.8. Changes to This Privacy PolicyWe may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated policy on our website or sending you a notice via our messaging services.9.

Contact UsIf you have any questions about this Privacy Policy or our practices, please contact us at:Havrilla Commercial Investment Group

1174
Limeridge
Drive, Concord, CA
94521

[email protected](920)
289-3638By using our A2P messaging services, you acknowledge that you have read and understood this Privacy Policy.