1. Introduction

Toolbelt (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, SMS messaging services, and related services (collectively, the “Service”).

Please read this Privacy Policy carefully. By using the Service, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

2.1 Information You Provide

Data TypeExamplesPurpose
Account InformationName, email address, phone number, passwordCreate and manage your account
Business InformationBusiness name, address, industry, EINSet up your business profile
Identity InformationLast 4 digits of SSN, date of birthVerify your identity for payments
Payment InformationBank account details, routing numbersProcess payments and payouts
SMS/Phone InformationMobile phone number, text message contentProvide AI-powered appointment scheduling via SMS

2.2 Information Collected Automatically

Data TypeExamplesPurpose
Device InformationDevice type, operating system, unique device IDImprove app performance
Usage DataFeatures used, time spent, actions takenImprove our Service
Log DataIP address, access times, app crashesSecurity and troubleshooting
SMS MetadataMessage timestamps, delivery status, opt-in/opt-out statusManage SMS communications and compliance

2.3 Information from Third Parties

We receive information from third-party services you connect to your account, including financial institutions through Plaid (see Section 3).

3. Plaid Technologies

We use Plaid Inc. (“Plaid”) to connect your bank accounts to our Service. When you link your bank account, you will be directed to Plaid’s interface to provide your credentials.

What Plaid Collects:

By using Plaid, you authorize Plaid to collect and share the following information from your financial institution:

Plaid’s Privacy Policy:

Plaid’s use of your data is governed by their privacy policy, available at: https://plaid.com/legal/#end-user-privacy-policy

Your Control:

You can disconnect your bank account at any time through the app settings or by contacting us.

4. SMS/Text Messaging Services

Toolbelt provides AI-powered appointment scheduling and booking management via SMS text messaging. This section describes how we handle data related to our SMS services.

4.1 How SMS Services Work

When a customer texts a business phone number managed through Toolbelt, an AI assistant responds to help schedule, reschedule, or cancel appointments. Messages are processed through Twilio, our SMS service provider, and our AI systems to generate appropriate responses.

4.2 SMS Data We Collect

Data TypeExamplesPurpose
Phone NumbersCustomer and business mobile/phone numbersDeliver and receive SMS messages
Message ContentText of inbound and outbound messagesProcess appointment requests and generate AI responses
Conversation MetadataTimestamps, delivery status, message countTrack conversation state and ensure delivery
Opt-In/Opt-Out StatusSTOP, START, HELP keyword responsesManage consent and comply with TCPA regulations
AI-Detected IntentBooking intent, service preferences, scheduling dataImprove AI responses and complete bookings

4.3 How We Use SMS Data

4.4 SMS Data Sharing

We do not sell, share, or use SMS data (including phone numbers and message content) for advertising or marketing purposes. SMS data is only shared with:

We do not share SMS opt-in/opt-out data or consent status with any third parties for their own marketing purposes.

4.5 SMS Consent and Opt-Out

Customers initiate SMS communication by voluntarily texting the business phone number. By sending the first message, customers consent to receive AI-generated appointment scheduling responses.

Opt-Out:

Opt-In:

Help:

Message and data rates may apply. Message frequency varies based on your interaction with the scheduling assistant.

4.6 SMS Data Retention

Data TypeRetention Period
SMS Conversation HistoryDuration of business account + 1 year
Message ContentDuration of business account + 1 year
Opt-Out RecordsIndefinitely (required for compliance)
AI Conversation ContextDuration of active conversation

5. How We Use Your Information

PurposeDescription
Provide ServicesProcess payments, payouts, transactions, and AI-powered SMS scheduling
Verify IdentityConfirm you are who you say you are (KYC compliance)
Prevent FraudDetect and prevent fraudulent transactions
CommunicateSend receipts, notifications, appointment confirmations, and support messages
Improve ServiceAnalyze usage to improve features and user experience
Legal ComplianceMeet legal and regulatory requirements including TCPA

6. How We Share Your Information

We do not sell your personal information. We may share your information with:

6.1 Service Providers

ProviderPurposeData Shared
PlaidBank account connectionsBank credentials, account info
StripePayment processingPayment details, transaction info
Firebase / Google CloudData storage and authenticationAccount data, usage data
TwilioSMS message deliveryPhone numbers, message content
AnthropicAI-powered conversation processingMessage content (anonymized)

6.2 Legal Requirements

We may disclose your information if required to:

6.3 Business Transfers

If Toolbelt is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

6.4 With Your Consent

We may share your information for other purposes with your explicit consent.

7. Data Security

Security MeasureDescription
Encryption in TransitAll data transmitted using TLS 1.2 or higher
Encryption at RestAll stored data encrypted using AES-256
Access ControlsLimited access based on role and necessity
Multi-Factor AuthenticationRequired for all administrative access
MonitoringContinuous monitoring for unauthorized access
SMS SecurityTwilio webhook signature validation on all inbound messages

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

8. Data Retention

Data TypeRetention Period
Account InformationDuration of account + 2 years
Transaction Records7 years (legal requirement)
Bank Account TokensUntil you disconnect the account
Usage Data1 year
SMS Conversation HistoryDuration of business account + 1 year
SMS Opt-Out RecordsIndefinitely (compliance requirement)

After the retention period, data is securely deleted or anonymized.

9. Your Rights and Choices

9.1 Access

You can request a copy of the personal information we hold about you.

9.2 Correction

You can update or correct your account information at any time through the app.

9.3 Deletion

You can request deletion of your account and personal information. Note that some data may be retained for legal compliance.

9.4 Disconnect Bank Accounts

You can disconnect linked bank accounts at any time through:

9.5 SMS Opt-Out

You can stop receiving SMS messages at any time by replying STOP to any message. See Section 4.5 for full details on SMS consent management.

9.6 Opt-Out of Communications

You can opt out of promotional communications by:

9.7 Do Not Track

Our app does not currently respond to “Do Not Track” signals.

10. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

RightDescription
Right to KnowRequest what personal information we collect, use, and share
Right to DeleteRequest deletion of your personal information
Right to Opt-OutOpt out of the sale of personal information (we do not sell your data)
Right to Non-DiscriminationWe will not discriminate against you for exercising your rights

To exercise these rights, contact us at privacy@toolbelt.com.

11. Children’s Privacy

Our Service is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn we have collected information from a child under 18, we will delete it promptly.

12. International Data Transfers

Your information may be transferred to and processed in the United States, where our servers are located. By using our Service, you consent to this transfer.

13. Third-Party Links

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by:

Your continued use of the Service after changes constitutes acceptance of the updated policy.

15. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

ToolBelt
Email: davidperez@toolbelt.com
Mail: 111 Fenner Rd, Newton, NJ 07860
Privacy Contact: David Perez, Founder & CEO

16. Consent

By using Toolbelt, you consent to: