Last updated: October 16, 2024
This Privacy Policy includes important information about your personal data and we encourage you to read it carefully.
Contiguity offers a suite of communication services—including text messaging, iMessage, WhatsApp, email, and voice calls—alongside identity verification, fraud detection, and cloud-based solutions like databases. Our services cater to a broad range of clients, from individual hobbyists to enterprises of all sizes, including small businesses and Fortune 500 companies.
This Privacy Policy (“Policy”) describes the Personal Data we collect, how we use and share it, along with details on how you can reach out to us with privacy-related inquiries. Additionally, the Policy outlines your rights as a data subject and choices you have, including the right to object to certain usages of your Personal Data by us.
In this Policy, “Contiguity”, “we”, “our,” or “us” refers to Contiguity LLC, which is responsible for the collection, use, and handling of Personal Data as described in this document.
“Personal Data” refers to any information associated with an identified or identifiable individual, which can include data that you provide to us, and we collect about you during your interaction with our Services (such as device information, IP address, etc.).
“Services” refer to the products and services provided by Contiguity under the Contiguity Services Agreement and the Contiguity Consumer Terms of Service. This may include devices and applications provided by Contiguity. Our “Services” are services that we provide to entities (“Contiguity’s Customers”, “Contiguity Customer”, “Customer”) that directly and indirectly provide us with “End User” Personal Data in connection with their own operations and activities. “Sites” refer to contiguity.co, and other Contiguity websites, apps, and online services. Collectively, we refer to Contiguity, Services, and Sites as “Services.”
Partners refer to telecommunications, cloud providers, and other third-party service providers that Contiguity engages, including those utilized for identity verification purposes, in order to deliver our Services.
Depending on the context, “you” might be an Contiguity Customer, End User, or Visitor:
When interacting with a Contiguity Customer—such as receiving messages from a Contiguity Customer or signing up for their services and verifying your identity through Contiguity Identity—you are considered an End User.
You are a Contiguity Customer if you hold a Contiguity account and use the Services, such as sending text messages to your recipients or prompting them to verify their identities.
If you engage with Contiguity by visiting our website without logging into a Contiguity account, or your interaction does not otherwise classify you as an End User, you are considered a Visitor. For example, you are a Visitor when exploring Contiguity’s services and considering becoming a Contiguity Customer.
In this Policy, “Communications Data” refers to the data that Contiguity collects and utilizes to facilitate the communications you initiate. For instance, Communications Data may include details such as the subject line of an email, the contents of the email, the recipient’s email address, the time the email was sent, and any fraud analysis conducted on its contents.
Similarly, “Verification Data” refers to the data collected and used by Contiguity to conduct identity verifications that you request. Verification Data may include, and is not limited to, images of an individual’s identity document (front and back), their name, address, date of birth or age, the document’s issue and expiry dates, the issuing country, the type of document, and facial images (“selfies”) of the individual. This data may also undergo various analyses, including assessments of whether the document is counterfeit, whether the identity document is supported, whether the document’s information is correct, if the document’s information matches information you had already provided to the Contiguity Customer, among other checks.
Depending on the activity, Contiguity assumes the role of a “data controller” and/or “data processor” (or “service provider”) based on the activity.
The collection and use of your Personal Data by Contiguity depends on whether you are an End User, a Contiguity Customer, or a Visitor, and the specific Service being used. For instance:
If you are registering for Contiguity Enterprise as a Contiguity Customer, we may collect your company details, contact information, and billing data in order to set up and manage your account, provide customer support, and facilitate payment processing. Then, Contiguity may store your Communications Data.
When you are verifying your identity through Contiguity Identity as an End User, we collect, process, and store Verification Data, such as your identity document and facial images (“selfies”).
If you are browsing our website as a Visitor, we collect information such as your IP address, browser type, and usage data through cookies and other tracking technologies to understand how you interact with our website and to enhance your browsing experience.
Contiguity provides a range of Services to Contiguity’s Customers, including communications such as Text (SMS), Email, Calls, Identity verification (ensuring individuals are who they claim to be), and Database services. When acting as a service provider—also referred to as a data processor—for a Contiguity Customer, we process End User Personal Data in accordance with our agreement with the Contiguity Customer and follow their lawful instructions. For example, this may occur when we verify your identity on behalf of a Contiguity Customer as part of their service sign-up process, or when a Contiguity Customer uses our platform to send you text messages, emails, or other communications.
Contiguity Customers are responsible for ensuring that the privacy rights of their End Users are respected, including obtaining necessary consents and providing appropriate disclosures regarding their own data collection and usage practices related to their products and services. If you are an End User, please review the privacy policy of the Contiguity Customer you are engaging with for information on their specific privacy practices, choices, and data controls.
Communications Data. If you’re an End User receiving communications, sending communications to, interacting with Message Intents, opening / clicking tracked links in emails, or otherwise interacting with a Contiguity Customer, we receive and process your Communications Data.
Identity/Verification Information. Contiguity provides a verification and fraud prevention Service that Contiguity’s Customers can use to verify Personal Data about you, such as your authorization to use a particular payment method or if you are over the age of majority. During the process, you’d be asked to share with us certain Personal Data (like your government ID and selfie for biometric verification, and Personal Data you input. To protect against fraud and determine if somebody is trying to impersonate you, we may cross-verify this data with information about you that we’ve collected from other Contiguity Customers, Partners, business affiliates, identity verification services, publicly available sources, and other third party service providers / sources.
To deliver our Services to Contiguity Customers, we use and share End Users’ Personal Data with those Customers. Where permitted, we also use End Users’ Personal Data for Contiguity’s own purposes, such as enhancing security, improving our Services, and preventing fraud, loss, and other potential harms, as detailed below.
Communications Services. We use your Communications Data to provide communication-related Services to Contiguity Customers, such as sending and receiving messages, ensuring regulatory compliance (e.g., GDPR, TCPA), and training our fraud detection systems to differentiate between legitimate and harmful communications. Additionally, we may use your Personal Data to enhance and optimize our Services.
Identity/Verification Services. We process Personal Data related to your identity, including information you provide directly and data from our service providers, to conduct identity verifications on behalf of Contiguity or a Contiguity Customer you are interacting with. This helps prevent fraud and bolsters security. For instance, if you submit a selfie alongside your identity document, we may employ biometric technology to assess whether the images match and verify your identity.
Fraud Detection and Loss Prevention. We utilize Personal Data collected across our Services to identify and prevent losses for Contiguity, our Customers, and our Partners. As part of our fraud prevention-related Services, we may share your Personal Data (including Communications Data) with Contiguity Customers and Partners to help them assess the risk of fraud or loss in relation to your identity or actions.
Sharing with Contiguity Customers (and Their Authorized Third Parties). We share End Users’ Personal Data with their respective Contiguity Customers and third parties authorized by those Customers.
Contiguity Customers may further share your Personal Data with third-party service providers outside of Contiguity. For more details on how your Personal Data is handled, refer to the Contiguity Customer’s privacy policy.
Advertising by Contiguity Customers. If you begin interacting with a Contiguity Customer but do not complete your interaction (i.e, only begin a Support Conversation using Message Intents, or partially verify your identity), the Customer may still receive your Personal Data in connection with our Services. The Contiguity Customer may then use this information to market or advertise their products and services to you, subject to the terms of their privacy policy. Please consult the Contiguity Customer’s privacy policy for more information on how they use your Personal Data for marketing purposes and your rights to opt out.
The Contiguity Customers you choose to do business with may further share your Personal Data with third parties (like additional third party service providers other than Contiguity). Please review the Contiguity Customer’s privacy policy for more information.
We collect, use, and share the Personal Data of Visitors.
When you browse our Sites, we receive your Personal Data, either provided directly by you or collected through our use of cookies and similar technologies. If you opt to complete a form on the Site or third party websites where our advertisements are displayed (like LinkedIn or Facebook), we collect the information you included in the form. This may include your contact information and other information pertaining to your questions about our Services. We may also associate a location with your visit.
Personalization. We use the data we collect from cookies and similar technologies about you to measure user engagement with the content on the Sites, improve relevancy and navigation, customize your user experience (such as language preference and region-specific content), and curate content about Contiguity and our Services that’s tailored to you. For instance, as not all of our Services are available globally, we may customize our responses based on your region.
Advertising. Where allowed by applicable law, we use and share Visitors’ Personal Data with third parties so we can advertise and market our Services. Subject to applicable law, including any consent requirements, we may advertise through interest-based advertising and track the efficacy of such ads. We do not transfer your Personal Data to third parties in exchange for payment. However, we may provide your data to third party partners, like advertising partners, analytics providers, and social networks, who assist us in advertising our Services.
Engagement. As you interact with our Sites, we use the information we collect about and through your devices to provide opportunities for further interactions, such as discussions about Services or interactions with chatbots, to address your questions.
We collect, use, and share Personal Data from our Customers to provide our Services.
Registration and Contact Information. When you register as a Contiguity Customer, we collect your name, contact details, and/or login credentials. If you register for or attend an event organized by Contiguity, or sign up to receive communications from us, we collect your registration and profile information. We may also collect Personal Data from third-party data providers to market and communicate with you. In some instances, we may associate location information with you to better tailor our Services to your needs.
Identification Information. As a Contiguity Customer, we may require your contact information (such as your name, postal address, phone number, and email address) to fulfill regulatory requirements, verify your identity, and prevent fraud. We may collect additional Personal Data, such as government-issued identity documents and associated identifiers, from you or third-party sources, such as credit bureaus or through the Services we provide. You may also choose to provide us with banking information for billing or payment purposes.
We primarily use the Personal Data of Contiguity’s Customers to provide the Services you request. Below are the typical ways we use and share this data:
Providing Services. We use and share Contiguity Customers’ Personal Data to facilitate the Services you have requested. In some instances, we may need to submit your Personal Data to government authorities to comply with regulatory requirements, such as complying with subpoenas or submitting your information to telecommunications providers.
We also share Contiguity Customers’ Personal Data with parties specifically authorized by you, such as companies providing payment processing or third-party apps integrated with Contiguity’s platform. Common examples include:
The use of your Personal Data by a third party authorized by you is governed by that third party’s privacy policy. Please consult their privacy policy for further details.
Fraud Detection and Loss Prevention. We use Contiguity Customers’ Personal Data to detect and mitigate risks associated with fraudulent activities, which could cause losses to Contiguity, Contiguity’s Customers, and our Partners. We may collect and use data from third-party sources, such as credit bureaus, or analyze patterns of misuse through our Services to prevent fraud and monitor for terms of service violations. Contiguity may share your Personal Data with our Partners and third-party service providers to verify the information provided and identify potential risks. Additionally, we use and share Personal Data to conduct due diligence and perform sanctions screening, in compliance with applicable laws.
Advertising and Marketing. Where permitted by law, we use and share Contiguity Customers’ Personal Data with third parties to advertise and promote our Services. This includes interest-based advertising and the tracking of ad performance. While we do not sell your Personal Data in exchange for payment, we may share it with advertising partners, analytics providers, and social media platforms that assist us in advertising Contiguity’s Services. We may also use your Personal Data, including your activity on Contiguity’s platform, to evaluate your eligibility for new Services or to promote existing offerings.
Contiguity will never access or use data you hold in Contiguity Base (a NoSQL database solution) or Contiguity Drive (file storage).
Contiguity may only access your data with your consent to provide support, when you request it (via the API or the dashboard), or to mitigate fraud and abuse (i.e, checking if your files on Drive host malware).
Contiguity is committed to the principle that privacy is a fundamental human right. We do not sell or disclose personally identifiable information to third parties without a legitimate reason or your explicit consent. Contiguity may use your data to deliver our Services, enhance and improve those Services, advertise to you, and communicate with you. While these are common uses, this list is not exhaustive, and there may be other legitimate purposes for which your data is used as part of our operations. However, we remain transparent and committed to ensuring your data is handled responsibly and in accordance with applicable privacy laws.
We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical, and administrative measures designed to protect the Personal Data covered by this Policy from unauthorized access, destruction, loss, alteration, or misuse. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
We encourage you to assist us in protecting your Personal Data. If you hold a Contiguity account, you can do so by using a strong password, safeguarding your password against unauthorized use, and avoiding using identical login credentials you use for other services or accounts for your Contiguity account. If you suspect that your interaction with us is no longer secure (for instance, you believe that your Contiguity account’s security has been compromised), please contact us immediately.
We retain your Personal Data for as long as we continue to provide the Services to you or our Customers, or for a period in which we reasonably foresee continuing to provide the Services. Even after we stop providing Services directly to you or to a Customer that you’re doing business with, and even after you close your Contiguity account or complete an interaction with a Customer, we may continue to retain your Personal Data to:
In cases where we keep your Personal Data, we do so in accordance with any limitation periods and record retention obligations imposed by applicable law.
As a global business, it’s sometimes necessary for us to transfer your Personal Data to countries other than your own, including the United States. These countries might have data protection regulations that are different from those in your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from officials, such as law enforcement or security authorities.
We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective the latter of when we post the revised Policy on the Services or otherwise provide notice of the update as required by law.
We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our website and, if you are an End User or Customer, by contacting you through your Contiguity Dashboard, email address and/or the physical address listed in your Contiguity account.
The laws of the state of Florida will govern this Policy, without giving effect to its conflict of law principles.
If you have any questions or complaints about this Policy, please contact us. If you are an End User (i.e., an individual doing business or interacting with a Contiguity Customer), please refer to the privacy policy or notice of the Contiguity Customer for information regarding their privacy practices, choices and controls, or contact the Contiguity Customer directly.