SSC Privacy Policy

SMART SYSTEMS CONSTRUCTION LLC PRIVACY POLICY

Effective Date: August 16, 2026 State of Tennessee | A2P 10DLC & TCPA Compliant | TIPA Compliant

Smart Systems Construction ("Company," "we," "us," or "our"), a construction company operating in the State of Tennessee, is committed to protecting the privacy and security of your personal information. This Privacy Policy ("Policy") governs the collection, use, disclosure, retention, and protection of personal data — including mobile and SMS communications — in connection with our services, website, and business operations. This Policy is designed to comply with applicable federal and state law, including the Telephone Consumer Protection Act (TCPA), Federal Communications Commission (FCC) regulations, A2P 10DLC carrier registration requirements, the Tennessee Information Protection Act (TIPA), Tenn. Code Ann. § 47-18-3201 et seq. (effective July 1, 2025), the Tennessee Telephone Solicitation Act, and the Tennessee Identity Theft Deterrence Act. By using our services, visiting our website, or submitting your contact information to Smart Systems Construction through any channel, you acknowledge that you have read and understood this Privacy Policy and agree to its terms. If you do not agree to this Policy, please do not use our services or submit personal information to us. TABLE OF CONTENTS ● 1. Information We Collect ● 2. SMS / Text Messaging Communications & A2P 10DLC Consent ● 3. How We Use Your Information ● 4. Disclosure of Information / Third-Party Sharing ● 5. Data Security ● 6. Data Retention ● 7. Your Rights as a Consumer ● 8. Tennessee-Specific Considerations ● 9. Cookies & Website Tracking ● 10. Children's Privacy ● 11. Changes to This Policy ● 12. Contact Us 1. Information We Collect Smart Systems Construction collects personal information through multiple channels, including our website contact forms, telephone calls, in-person meetings, signed contracts, and digital opt-in forms. The categories of personal information we collect include, but are not limited to, the following: 1.1 Contact Information ● Full legal name ● Mailing and billing address ● Email address ● Telephone number and/or mobile phone number 1.2 Project Information ● Property address and location details ● Scope of work, project specifications, and service history ● Project photographs and inspection documentation ● Homeowner's insurance information, claim numbers, and adjuster contact details (where applicable) 1.3 Communication Data ● SMS and text message content sent to or received from our messaging platform ● Inbound and outbound call logs, including call duration and timestamps ● Email correspondence ● Notes from in-person or virtual consultations 1.4 Usage Data ● Website browsing behavior, pages visited, and time spent on pages ● Internet Protocol (IP) address ● Browser type, version, and operating system ● Cookies, web beacons, and tracking pixels (see Section 9) ● Referral source (e.g., search engine, advertisement, or social media link) 1.5 Financial Information ● Payment method type (e.g., credit card, check, ACH) — we do not collect or store full payment card numbers ● Billing address ● Transaction history, invoice records, and payment confirmation data 1.6 Consent Records ● SMS and communications opt-in timestamps ● IP address recorded at the time of consent submission ● Opt-in source and collection channel (e.g., website form, signed paper form, verbal consent) ● Opt-out timestamps, method of opt-out, and confirmation records DATA COLLECTION CHANNELS Personal information is collected via: (a) website contact and estimate request forms; (b) inbound and outbound telephone calls; (c) in-person consultations and site inspections; (d) signed service contracts and project agreements; and (e) digital and paper opt-in consent forms. 2. SMS / Text Messaging Communications & A2P 10DLC Consent This section governs Smart Systems Construction's SMS text messaging program and is provided in full compliance with the Telephone Consumer Protection Act (TCPA), FCC regulations, CTIA Messaging Principles and Best Practices, and A2P 10DLC carrier registration requirements. Please read this section carefully before providing your mobile phone number to us. 2.1 SMS Program Description Smart Systems Construction uses Roof-r as its SMS/text messaging platform to facilitate business-related communications with customers and prospective customers. We operate as an Application-to-Person (A2P) messaging sender on 10-digit long code (10DLC) phone numbers that are formally registered with The Campaign Registry (TCR) in accordance with wireless carrier requirements. Message types transmitted through our SMS program include, but are not limited to: ● Appointment confirmations and scheduling reminders ● Project status updates and milestone notifications ● Estimate delivery and follow-up communications ● Payment reminders and invoice notifications ● Customer service replies and support communications ● Promotional messages (only where separate express written consent has been obtained) 2.2 How We Obtain Your Consent (Opt-In) Smart Systems Construction obtains SMS consent only through explicit, affirmative, and verifiable opt-in actions by the consumer. We do not use implied consent, pre-checked consent boxes, or consent inherited from third parties. Consent is always specific to Smart Systems Construction and the described message types. Approved opt-in methods include: 1. Website Contact Form: A dedicated, clearly labeled SMS consent checkbox presented at the point of data collection on our website contact and estimate forms. 2. Written or Signed Consent Form: A paper or electronic consent form provided during in-person consultations or contract execution, containing explicit consent language. 3. Verbal Consent: Verbal consent obtained during telephone calls, documented by company staff with a timestamped notation in the customer's record. The following consent language (or equivalent) is presented to consumers at the point of opt-in collection: "By checking this box, you consent to receive text messages from Smart Systems Construction at the phone number provided, including appointment reminders, project updates, frequency varies. Reply STOP and service-related messages. Message and data rates may apply. Message to opt out at any time. Reply HELP for assistance." All consent records are stored and include: (a) the opt-in timestamp; (b) the IP address at the time of consent submission (for web-based opt-ins); and (c) the method and channel through which consent was collected. Consent to receive SMS communications is specific to Smart Systems Construction and is not shared with, sold to, or transferred to any third party for their independent marketing use. 2.3 Message Frequency & Costs ● Message frequency varies based on project stage, service activity, and individual communication needs. There is no fixed number of messages per month. ● Standard message and data rates may apply to SMS communications, as determined by your individual mobile carrier plan. Smart Systems Construction does not impose any additional charge for SMS communications. ● We do not send unsolicited bulk promotional messages. Service related messages are sent only in connection with active or pending projects and customer inquiries. 2.4 Opt-Out Procedures You may revoke your consent to receive SMS messages from Smart Systems Construction at any time using any of the following methods: 4. Reply STOP: Reply STOP to any text message sent by Smart Systems Construction. Upon receipt of a STOP reply, we will send one (1) final confirmation message acknowledging your opt-out request and will immediately cease all further SMS communications to that mobile number. 5. Email Request: Send a written opt-out request to our privacy email address at brett.smart@ssbuildco.org. 6. Telephone Request: Call our office at (629) 462-4657 during business hours and request to be removed from our SMS contact list. Opt-out requests are processed within ten (10) business days in accordance with CTIA guidelines. Submission of a STOP reply is processed immediately at the platform level. Opting out of SMS communications does not affect other communication channels, including email and telephone, unless a separate opt-out is also requested for those channels. Opt-out records are retained for a minimum of four (4) years in accordance with the TCPA statute of limitations. 2.5 Re-Opt-In After Opt-Out If you have previously opted out of SMS communications and wish to resume receiving text messages from Smart Systems Construction, you may re-subscribe by: ● Replying START or YES to our SMS number; or ● Re-submitting a completed consent form through our website or in person. Re-opt-in constitutes a new, independent consent event and will be recorded accordingly. 2.6 HELP Response Replying HELP to any text message from Smart Systems Construction will trigger the following automated response: "Smart Systems Construction: For help, call (629) 462-4657 or email brett.smart@ssbuildco.org. Reply STOP to unsubscribe." 2.7 Non-Sharing of SMS Opt-In Data CARRIER-REQUIRED DISCLOSURE Mobile information (including phone numbers and SMS opt-in data) collected by Smart Systems Construction will not be sold, shared, rented, released, or traded to third parties or affiliates for marketing or promotional purposes. Roof-r, our contracted SMS platform provider, receives mobile phone numbers and associated message data solely for the limited purpose of transmitting text messages on behalf of Smart Systems Construction. Roof-r's access to and use of this data is governed by data processing agreements that restrict use to service delivery only and prohibit independent use of consumer data for marketing, resale, or any other purpose. 3. How We Use Your Information Smart Systems Construction uses the personal information we collect for the following purposes: 7. Project Scheduling and Management: To schedule, coordinate, and manage roofing, construction, and related services, including site visits, inspections, and installations. 8. Communications: To send appointment reminders, project status updates, estimates, invoices, and other service-related communications via phone, email, and SMS (where consent has been obtained). 9. Payment Processing: To process payments, manage billing accounts, and maintain accurate financial records. 10.Customer Service: To respond to inquiries, address complaints, resolve disputes, and provide general customer support. 11.Promotional Communications: To send marketing or promotional communications, including special offers — only where separate, express written consent has been obtained and only through channels for which consent was given. 12.Legal Compliance: To comply with applicable federal and state laws, regulations, court orders, and lawful government requests. 13.Website and Service Improvement: To analyze website usage, diagnose technical issues, and improve the functionality, content, and user experience of our website and services. 14.Internal Business Operations: For internal analytics, business planning, quality assurance, and operational recordkeeping purposes. 15.Safety and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, unauthorized access, and other potentially illegal or harmful activities. We do not use personal information for purposes that are incompatible with those disclosed in this Policy without providing prior notice and, where required, obtaining additional consent. 4. Disclosure of Information / Third-Party Sharing Smart Systems Construction does not sell personal information. We share personal information only in the following limited circumstances: 4.1 Service Providers We share personal information with third-party vendors and service providers who perform services on our behalf, including but not limited to: ● Roof-r — SMS/text messaging platform (see Section 2.7 for non sharing disclosure) ● Payment processors and financial institutions ● Project scheduling and customer relationship management (CRM) software providers ● Website hosting and analytics providers ● Cloud storage and data backup providers All service providers are vetted for data security practices and are bound by written data processing agreements or contractual confidentiality obligations that restrict their use of personal information to the specific services performed on our behalf. Service providers are prohibited from using personal data for their own independent marketing or other purposes. 4.2 Legal and Regulatory Disclosures We may disclose personal information to law enforcement agencies, regulatory bodies, courts, or other government authorities where required by applicable law, regulation, legal process (e.g., subpoena or court order), or where necessary to protect the rights, property, or safety of Smart Systems Construction, our customers, or the public. 4.3 Professional Advisors We may share personal information with attorneys, accountants, auditors, and other professional advisors, subject to legally binding confidentiality obligations, in connection with legal advice, audits, or professional services. 4.4 Anonymized and Aggregated Data We may share anonymized, aggregated data that does not identify any individual consumer with business partners or for industry analytics purposes. Such data is not considered personal information and is not subject to the protections described in this Policy. 4.5 Business Transfers In the event of a merger, acquisition, asset sale, corporate restructuring, or other business transfer involving Smart Systems Construction, personal data may be transferred as part of the transaction. In such circumstances, we will provide advance notice of the transfer, the identity of the acquiring entity, and any material changes to this Policy through our website or by direct notification to affected individuals. 5. Data Security Smart Systems Construction implements industry-standard administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. Our security measures include, but are not limited to: ● Encrypted Data Transmission: All data transmitted between your browser and our website is encrypted using Secure Sockets Layer / Transport Layer Security (SSL/TLS) technology. ● Access Controls: Role-based access controls limit access to personal information to only those employees and contractors who have a legitimate business need to access it. ● Secure Password Protocols: Employees are required to use strong, unique passwords and multi-factor authentication where supported for systems containing personal information. ● Encrypted Data Storage: Sensitive personal information is stored using encryption at rest where technically feasible. ● Employee Training: Company personnel with access to personal information receive regular training on data privacy obligations, security protocols, and the requirements of this Policy. ● Security Audits: We conduct periodic reviews of our data security practices and update them as necessary to address emerging threats. 5.1 Data Breach Notification In the event of a data breach that compromises the personal information of Tennessee residents, Smart Systems Construction will notify affected individuals and the Tennessee Attorney General's Office in accordance with Tenn. Code Ann. § 47-18-2107 (Tennessee Identity Theft Deterrence Act / data breach notification law). Notification will be provided in the most expedient time possible and without unreasonable delay, subject to the needs of law enforcement. 5.2 Limitation of Liability While we employ the security measures described above, no method of electronic data transmission or storage is 100% secure. Smart Systems Construction cannot guarantee the absolute security of your personal information. You transmit information to us at your own risk. If you have reason to believe that your personal information has been compromised in connection with our services, please contact us immediately using the information in Section 12. 6. Data Retention Smart Systems Construction retains personal information only for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, and to resolve disputes. The following retention schedules apply: Data Category Retention Period Basis Contact and project data Duration of customer relationship plus 7 years Construction warranty obligations; IRS and tax record requirements SMS opt-in and opt-out records Minimum 4 years TCPA statute of limitations (47 U.S.C. § 227) Website analytics data 24 months Business analytics; website improvement Payment and billing records As required by IRS and financial audit requirements IRS Publication 583; applicable tax and audit regulations Employee and contractor records As required by applicable employment and tax laws Federal and state labor law compliance Data Category Retention Period Basis Data breach notification records Minimum 5 years Tenn. Code Ann. § 47-18 2107 compliance Upon receipt of a verified consumer deletion request submitted in accordance with Section 7, personal information will be deleted or anonymized within forty-five (45) days, unless retention is required by applicable law, is necessary to complete a pending transaction, or is needed to resolve a dispute or enforce our legal rights. Where deletion is not possible due to legal obligations, we will inform the requesting individual of the basis for retention. 7. Your Rights as a Consumer 7.1 Federal Rights Under the TCPA Under the Telephone Consumer Protection Act (47 U.S.C. § 227) and applicable FCC regulations, you have the following rights with respect to SMS and telephone communications: ● Right to Opt Out of SMS: You may revoke consent to receive text messages from Smart Systems Construction at any time. See Section 2.4 for opt-out procedures. ● Right to Revoke Consent: You may revoke consent for marketing calls and texts through any reasonable means, including replying STOP, sending a written request, or calling our office. 7.2 Tennessee Consumer Rights Under TIPA The Tennessee Information Protection Act (TIPA), Tenn. Code Ann. § 47-18-3201 et seq., effective July 1, 2025, establishes data privacy rights for qualifying Tennessee residents. TIPA's full applicability thresholds — which include minimum annual revenue and data volume thresholds — may or may not apply to Smart Systems Construction depending on current business metrics. However, as a matter of good-faith compliance and our commitment to consumer privacy, Smart Systems Construction voluntarily extends the following rights to all Tennessee residents regardless of whether the statutory thresholds apply: ● Right to Access: You have the right to confirm whether Smart Systems Construction processes your personal data and, if so, to receive a copy of the personal data we hold about you. ● Right to Correction: You have the right to request correction of inaccurate personal data we hold about you. ● Right to Deletion: You have the right to request deletion of personal data we hold about you, subject to applicable legal retention obligations and other lawful exceptions. ● Right to Data Portability: You have the right to receive a copy of your personal data in a portable, structured, and machine-readable format, to the extent technically feasible. ● Right to Opt-Out of Sale: Smart Systems Construction does not sell personal data. No opt-out of sale is required or necessary. ● Right to Opt-Out of Targeted Advertising: You have the right to opt out of any use of your personal data for targeted advertising purposes. See Section 9 for information on cookies and tracking technologies. ● Right to Appeal: If Smart Systems Construction denies a rights request, you may submit a written appeal to us within a reasonable period. If the appeal is also denied, you may file a complaint with the Tennessee Attorney General's Office. 7.3 How to Exercise Your Rights To submit a consumer rights request, please contact us using the following methods: ● Email: brett.smart@ssbuildco.org ● Mail: Smart Systems Construction, 604 West Street, Murfreesboro, TN 37130 Please clearly identify yourself, describe the right you wish to exercise, and provide sufficient information to allow us to verify your identity. Smart Systems Construction will respond to verified requests within forty-five (45) days of receipt. If additional time is needed, we will notify you within the initial 45-day period and may extend the response period by an additional forty-five (45) days with appropriate notice. We will not discriminate against you for exercising your rights under this Policy. 8. Tennessee-Specific Considerations 8.1 Tennessee Telephone Solicitation Act Tenn. Code Ann. § 47-18-1501 et seq. Smart Systems Construction complies with Tennessee's state "mini-TCPA." We obtain prior express consent before sending any SMS promotional messages to Tennessee residents. Such consent is obtained directly from the individual consumer and is specific to Smart Systems Construction. Consent is not shared with, purchased from, or transferred from third-party lead generators or data brokers. All promotional SMS communications identify Smart Systems Construction as the sender and include opt-out instructions. 8.2 Tennessee Identity Theft Deterrence Act Tenn. Code Ann. § 47-18-2107. Smart Systems Construction maintains written data breach notification procedures in compliance with Tennessee's breach notification law. In the event of a security breach involving Tennessee residents' personal information, we will provide timely notification to affected individuals and to the Tennessee Attorney General's Office as required by statute. 8.3 Tennessee Consumer Protection Act Tenn. Code Ann. § 47-18-101 et seq. Smart Systems Construction does not engage in deceptive, unfair, or misleading trade practices in connection with the collection of personal data or the administration of SMS communications. All disclosures related to our data practices are provided clearly and conspicuously in accordance with the Tennessee Consumer Protection Act. 8.4 Tennessee Information Protection Act (TIPA) Tenn. Code Ann. § 47-18-3201 et seq. (Effective July 1, 2025.) Smart Systems Construction acknowledges the enactment of TIPA and voluntarily extends its consumer rights protections to all Tennessee consumers as described in Section 7.2 of this Policy, regardless of whether the statutory applicability thresholds are met. We are committed to maintaining data practices consistent with TIPA's requirements as our business grows. 8.5 Governing Law and Dispute Resolution This Privacy Policy and any disputes arising out of or relating to this Policy or the collection, use, or disclosure of personal information by Smart Systems Construction shall be governed by and construed in accordance with the laws of the State of Tennessee, without regard to conflict of law principles. Any disputes that cannot be resolved informally shall be resolved in the courts of Rutherford County, Tennessee, or as otherwise mutually agreed by the parties in writing. 9. Cookies & Website Tracking Smart Systems Construction uses cookies, web beacons, pixel tags, and similar tracking technologies on our website to enhance functionality, analyze usage patterns, and deliver relevant content. The following categories of tracking technologies may be employed: Cookie Type Purpose Consent Required Essential Cookies Required for core website functionality (e.g., form submission, session management). Cannot be disabled without impairing site function. No (technically necessary) Analytics Cookies Collect aggregate data on website usage (e.g., Google Analytics or similar). Used to understand how visitors interact with our site and to improve content and navigation. Recommended Marketing / Advertising Cookies Track browsing activity across websites to deliver targeted advertisements. Used only where express consent has been obtained. Yes Users may control and manage cookies through their browser settings. Most browsers allow you to refuse, delete, or receive notification of cookies. Please note that disabling certain cookies may affect the functionality of our website. Refer to your browser's help documentation for instructions on managing cookie preferences. We do not currently respond to Do Not Track (DNT) browser signals, as there is no uniform industry standard for the interpretation and implementation of DNT signals at this time. We will update this Policy if our practices change. 10. Children's Privacy Our services are directed exclusively to adults and are not intended for use by children under the age of thirteen (13). Smart Systems Construction does not knowingly collect, solicit, or retain personal information from children under 13 years of age. Our website is not designed to attract children, and we do not market our services to minors. If we become aware that we have inadvertently collected personal information from a child under 13, we will take prompt steps to delete such information from our records. If you are a parent or guardian and you believe your child has provided personal information to us, please contact us immediately using the information in Section 12 and we will take appropriate corrective action. 11. Changes to This Policy Smart Systems Construction reserves the right to update, modify, or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, business operations, or industry standards. The following procedures apply to Policy changes: ● Minor Updates: Non-material changes (such as clarifications, formatting corrections, or minor additions) will be posted on our website with an updated Effective Date. ● Material Changes: Changes that materially affect your rights or the way we collect, use, or share personal information will be communicated through prominent website notice, email notification, or SMS notification (where you have consented to receive such communications), at least thirty (30) days prior to the effective date of the change where practicable. ● Continued Use as Acceptance: Your continued use of our services or website following the posting of any updated Privacy Policy constitutes your acknowledgment of the changes and your agreement to be bound by the updated terms. If you do not agree to a revised Policy, you should cease use of our services and contact us to request deletion of your personal information. ● Effective Date: The "Effective Date" displayed at the top of this document will be updated with each revision to reflect the date the revised Policy takes effect. We encourage you to review this Privacy Policy periodically to stay informed of our current data practices. 12. Contact Us For questions, concerns, or requests regarding this Privacy Policy, your personal information, or your consumer rights, please contact Smart Systems Construction using the following information: Privacy Inquiries — Smart Systems Construction Company Name Smart Systems Construction Mailing Address 604 West Street Murfreesboro, Tennessee 37130 Phone Number (629) 462-4657 Privacy Email Address brett.smart@ssbuildco.org Website www.ssbuildco.org When submitting a privacy request by email or mail, please include your full name, contact information, and a clear description of your request or concern. We will acknowledge receipt of your inquiry within five (5) business days and respond fully within the timeframes described in Section 7.3. This Privacy Policy is provided for informational purposes and does not constitute legal advice. Smart Systems Construction recommends consulting qualified legal counsel to ensure ongoing compliance with all applicable federal and state laws, including the TCPA, FCC regulations, A2P 10DLC carrier requirements, and the Tennessee Information Protection Act (TIPA).

Effective Date: August 16, 2026 | Smart Systems Construction LLC