Our SMS texting provider requires an accessible privacy policy to use their services. This policy must be visible on your website or included in client-facing documents such as engagement letters. When registering your SMS line, we will ask you to provide a copy of this privacy policy.
This guide is part of the overall SMS messaging setup process for Liscio, ensuring compliance and proper registration.
A compliant Privacy Policy must clearly describe how consumer data will be used and shared (if applicable) and provide information on how consumers can contact the message sender. To support successful campaign registration and vetting, ensure your Privacy Policy includes the following key points:
Consent
When a campaign is being vetted, the language presented in a sender's Privacy Policy is heavily scrutinized to ensure the message sender doesn't improperly claim to have the consumer’s consent to share end-user data with third parties for marketing purposes. While it's permissible for a business to share end-user data essential for business operations, the fundamental practice of sharing data to sell consumer information (leads) to third parties is prohibited and will be rejected.
Privacy Policies are reviewed during vetting to ensure consumer data isn't transferred among various organizations. To successfully address these requirements, we recommend adopting and including a process in the Privacy Policy that demonstrates senders will refrain from sharing information consumer data.
Example: "Mobile information will not be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties."
Opt-out instructions
Message senders are required to acknowledge the consumer's right to opt out of a messaging campaign to ensure that message recipients’ consent remains intact. The Privacy Policy must also include instructions on how to opt out of future communications.
Example: “If you wish to be removed from receiving future communications, you can opt out by texting STOP, QUIT, END, REVOKE, OPT OUT, CANCEL, or UNSUBSCRIBE.”
Our SMS vendor strongly recommends creating a personalized Privacy Policy with accompanying SMS disclosures, as discussed above. The examples provided are for guidance and can be adapted to suit your specific needs. Please note that Liscio Support is unable to assist with implementing these into your website or provide legal advice for editing your Privacy Policy.
Alternatives for Firms Without Websites
If your firm does not have a website, you can still meet registration requirements by providing a PDF document that includes your Privacy Policy and Terms & Conditions. This document must be accessible via a web link or browser.
Submission of Legal Company Information
To register your firm for SMS messaging, you must provide official company details, including:
Your firm’s Legal Company Name, Doing Business As (DBA) name (if applicable), Employer Identification Number (EIN), and Company Address
Alternatively, submit a scanned copy of your SS-4 Letter from the IRS.