Privacy Policy

Effective Date: May 21, 2026

Introduction

True Aluminum, Inc. ("Company," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect information collected from users of our A2P (Application-to-Person) SMS text messaging services and our website at https://truealuminum.com. This Policy is designed to comply with applicable Florida and United States federal privacy laws, including the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227; the CAN-SPAM Act; the California Consumer Privacy Act (CCPA), to the extent applicable; and carrier requirements established by AT&T, Verizon, T-Mobile, and other U.S. telecommunications carriers.

By providing your mobile phone number and consenting to receive SMS messages from True Aluminum, Inc., you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy in its entirety. If you do not agree with any term of this Policy, please do not provide your mobile phone number or consent to receive SMS messages.

1. Information We Collect

1.1 Personal Information Provided Directly by You

When you provide your information through our Website, landing pages, in-person at a service location, or through any other interaction with our business, we may collect:

• Full name
• Email address
• Physical / service address
• Mobile phone number
• Information provided in estimate requests, service inquiries, or feedback forms
• Consent records, including date, time, and method of SMS opt-in

1.2 Information Collected Through the SMS Program

Through your participation in our A2P SMS program, we may also collect:

• Mobile phone number (mandatory for program participation)
• Date and time of SMS opt-in consent
• Consent method (e.g., web form checkbox, verbal, SMS reply)
• Message history and content of communications sent and received
• CSAT survey responses submitted via SMS
• Record of opt-out requests and their effective dates

1.3 Automatically Collected Information

When you access our Website or interact with our SMS messages, we may automatically collect:

• Device type, operating system, and browser information
• IP address and general geographic location (city/region level)
• SMS message open rates and delivery status (where technically available)
• Website navigation data, pages visited, and time on site
• Referring URL or source of SMS consent

2. How We Use Your Information

2.1 SMS Messaging Purposes

• Sending appointment reminders, scheduling confirmations, and service notifications
• Delivering estimate requests, follow-ups, and project-related communications
• Sending emergency service notifications and urgent alerts
• Transmitting promotional offers, seasonal campaigns, and service announcements
• Sending and receiving customer satisfaction surveys (CSAT) after completed services
• Sending post-project follow-up communications, including Net Promoter Score (NPS) requests, qualitative feedback requests about completed work, and invitations to leave public reviews
• Responding to your inquiries and providing customer support via SMS
• Managing your SMS opt-in and opt-out preferences
• Maintaining compliance records as required by federal and state law
• Detecting and preventing fraud, unauthorized access, or misuse of the SMS program

2.2 Website and Service Improvement Purposes

• Improving our Website functionality and user experience
• Analyzing service demand, customer preferences, and marketing effectiveness
• Personalizing your experience with our communications
• Complying with legal obligations, including record-keeping requirements

3. SMS Service Provider, GHL

Our A2P SMS messaging services are delivered through GHL ("Service Provider"), a third-party SMS gateway, marketing automation, and business communications platform. By consenting to receive SMS messages from True Aluminum, Inc., you acknowledge and agree that your mobile information will be processed by GHL in accordance with its terms of service and privacy policy.

True Aluminum, Inc. remains the sole data controller for your personal information as it relates to our SMS program. GHL processes your information solely as a service provider acting on our instructions and is not authorized to use your data for its own purposes. GHL is contractually obligated to maintain appropriate technical and organizational security measures to protect your information.

4. Consent and Mobile Number, How We Collect It

4.1 Opt-In Consent Methodology

• Web Form Opt-In: You provide your mobile phone number through a web form, landing page, or checkout process on our Website, and check or confirm an SMS consent checkbox.
• In-Person Opt-In: You provide your mobile phone number verbally or in writing at a physical service location, trade show, or promotional event.
• Keyword Opt-In: You send a specific keyword (e.g., "INFO" or "YES") to our SMS number, thereby expressly consenting to receive messages.
• CRM / Service Record Opt-In: You provide your mobile phone number during a service appointment or estimate request and consent to SMS follow-up communications.

4.2 Consent Records

We maintain electronic records of all SMS opt-in consents, including: the mobile phone number provided; the date and time of consent; the method by which consent was obtained; the IP address or device identifier at the time of opt-in (for web-based consents); and the specific version of this Policy accepted at the time of consent. These records are retained for a minimum of four (4) years in accordance with TCPA record-keeping requirements.

4.3 No Pre-Checked Consent Boxes

We do not use pre-checked consent boxes or automatic opt-ins. Your consent must be affirmatively provided. You are not required to consent to receive marketing or promotional messages as a condition of purchasing any goods or services from us.

5. Message Frequency and Categorization

Messages sent through our SMS program are classified into two categories:

Transactional / Service Messages: Appointment reminders, scheduling confirmations, service updates, project notifications, estimate requests, emergency service alerts, payment reminders. These messages are sent based on your active service relationship with us and do not require separate marketing consent.

Marketing / Promotional Messages: Special offers, seasonal promotions, service announcements, customer surveys (CSAT), service area expansions, and community updates. These messages require your explicit marketing consent.

Message frequency varies based on your service activity. During periods of active service, you may receive multiple messages per week. We do not guarantee a specific number of messages. All messages are sent from our designated sender number: +1 656-236-0628.

6. SMS Opt-Out and Unsubscription

You may withdraw your consent to receive SMS messages at any time, without cost:

• Reply "STOP" to any text message received from +1 656-236-0628.
• Reply "UNSUBSCRIBE" to any text message received from +1 656-236-0628.
• Call us at (863) 804-6021 during business hours and request removal.
• Send an email to [email protected] with "SMS Opt-Out" in the subject line.

Upon receipt of your opt-out request, we will send a confirmation text within 24 hours. You will cease to receive marketing and promotional SMS messages within that period. Transactional/service messages related to an active service may continue until your service relationship with us ends.

7. Information Sharing and Third-Party Disclosure

7.1 Information We Do NOT Share, Including SMS Opt-In Data

We do not sell, rent, or trade your personal information, including your mobile phone number and SMS opt-in data, to third parties for marketing or promotional purposes under any circumstances. SMS opt-in data and consent information collected through our SMS program will not be shared with any third party under any circumstances, except for our authorized SMS service provider (GHL) solely for the purpose of delivering SMS messages on our behalf.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Your mobile information, text-message consent information, and opt-out status will not be sold or shared with third parties or affiliates for their own marketing or promotional purposes. We may share this information only with service providers that help us deliver text messages, or as required by law.

7.2 Service Providers and Subcontractors

• GHL, SMS gateway and A2P messaging platform
• Customer service and support platforms integrated with our CRM
• Payment processing providers (for billing-related communications)
• Website analytics and marketing automation tools
• Survey, feedback, and review-request platforms (including RealWork Labs)
• Advertising, conversion-measurement, and call-tracking vendors
• Legal, accounting, and compliance advisors

All third-party service providers are contractually required to use your personal information solely for the purpose of providing services to us and to maintain appropriate data security measures.

7.3 A2P 10DLC and Carrier Disclosure

Our SMS program operates under the A2P 10DLC (10-Digit Long Code) framework approved by U.S. telecommunications carriers. As required by carriers, certain campaign and brand registration information is submitted to carrier-approved registries through our SMS service provider. This registration does not include the content of your personal messages.

7.4 Legal Compliance and Law Enforcement

We may disclose your personal information if required to do so by law, court order, subpoena, or other legal process; to comply with federal or state regulatory requirements; to protect the rights, property, or safety of True Aluminum, Inc., our customers, or the public; or to cooperate with law enforcement agencies.

8. Surveys, NPS, and Review Requests

After a completed service appointment, True Aluminum, Inc. may contact you by phone, SMS/MMS, or email to request that you complete a satisfaction survey (CSAT), provide a Net Promoter Score (NPS) or other rating, share qualitative feedback about the work performed, or leave a review on public platforms (such as online review or social media sites). By consenting to receive these communications, you expressly consent to receive these survey and review requests.

• SMS survey messages are sent from our designated sender number: +1 656-236-0628.
• Survey responses, NPS scores, and qualitative feedback are collected through third-party survey and review-request platforms (including RealWork Labs) integrated with our systems.
• Participation in surveys, feedback requests, and public reviews is entirely voluntary. Declining to participate will not affect your ability to receive services from us.
• Survey and feedback responses are retained for a minimum of two (2) years for quality assurance purposes.
• Responses may be used in aggregate and anonymized form to improve our services.
• Your survey responses will not be shared with third parties for marketing purposes.
• Where you choose to leave a public review, the content you submit to a third-party review platform is governed by that platform's own privacy practices.

9. Data Retention

• SMS opt-in consent records, minimum 4 years from date of consent
• SMS message history (content), minimum 4 years from date of each message
• CSAT survey responses, minimum 2 years from date of submission
• Customer service communications, minimum 3 years from date of communication
• Website analytics data, minimum 1 year from date of collection
• Billing and payment records, minimum 7 years (tax and financial law)

When your data is no longer needed for the purposes described in this Policy, we will securely delete or anonymize it in accordance with applicable data protection laws.

10. Data Security

• Encryption of data in transit (TLS/SSL) for all web communications
• Role-based access controls limiting data access to authorized personnel only
• Regular security assessments and monitoring of our systems and SMS platform
• Vendor due diligence to ensure GHL and other service providers maintain adequate security measures
• Secure storage of consent records and message history with restricted access

Despite these measures, no method of electronic transmission or storage over the internet is 100% secure. If you become aware of a data breach involving your personal information, please contact us immediately at (863) 804-6021 or [email protected].

11. Your Rights

11.1 Rights Under Applicable Federal and State Law

• Request access to the personal information we hold about you
• Request correction of inaccurate or outdated information
• Request deletion of your personal information, subject to applicable legal retention requirements
• Opt out of marketing and promotional SMS messages at any time by replying "STOP"
• File a complaint with the FCC at 1-888-CALL-FCC or https://www.fcc.gov/complaints
• File a complaint with the Florida Attorney General's Office regarding privacy violations

11.2 How to Exercise Your Rights

To exercise any of the rights described in this section, contact us at: Phone: (863) 804-6021 | Email: [email protected] | Address: 4000 N Frontage Rd, Plant City, FL 33565. We will respond to verifiable consumer requests within thirty (30) days of receipt.

12. Children's Privacy

Our services are not directed to, and we do not knowingly collect personal information from, individuals under the age of eighteen (18). If we become aware that a minor has provided us with personal information, we will take immediate steps to delete such information from our records and terminate their participation in the SMS program. If you believe a minor has provided us with personal information, please contact us at [email protected].

13. CCPA, California Consumer Privacy Act

To the extent the California Consumer Privacy Act (CCPA), Cal. Civ. Code § 1798.100 et seq., (as amended by the CPRA) applies to our data practices:

• Categories of personal information collected: identifiers (name, phone number, email, IP address), commercial information (service history), and internet activity information.
• Sources of personal information: directly from you, automatically through website and SMS interactions, and from our SMS service provider (GHL).
• Business purposes for collection: delivering SMS communications, customer service, service improvement, legal compliance, and fraud prevention.
• We do not sell personal information. We share data with service providers (GHL) as described in Section 7.
• California residents have the right to request deletion, correction, or access to their data. To exercise these rights, contact us at [email protected].

14. Cookies and Tracking Technology

Our Website uses cookies and similar tracking technologies to improve your browsing experience, analyze site traffic, and understand how visitors interact with our Website. We may use the following types of tracking technologies:

• Essential Cookies: Required for basic site functionality. These cookies do not collect personal information.
• Analytics Cookies: Used to understand how visitors navigate and use our Website (e.g., Google Analytics).
• Marketing/Advertising Cookies: Used to deliver relevant advertisements and track campaign performance.
• SMS/Communication Tracking: Information about how you interact with SMS messages we send, including delivery status and open rates where technically available.

These technologies may be operated by third parties that collect information across different websites over time. Examples of tools we may use include Google Analytics (to understand Website traffic and usage), Google Ads and the Meta Pixel (to measure advertising and conversion performance and deliver ads), call-tracking tools such as dynamic phone numbers (to attribute calls and leads to marketing sources), and chat and messaging tools (to support customer communications).

You may control or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of our Website. We do not use cookies to collect personal information beyond what is described in this Policy. See our Cookie Policy for full details.

14.1 Global Privacy Control (GPC) and Do Not Track

Some browsers or extensions support the Global Privacy Control ("GPC") signal. Where required by applicable law, we will process GPC signals as a request to opt out of certain processing (such as certain types of "sharing" for targeted advertising under state law). Honoring GPC may be limited by technical constraints and may not apply to cookies necessary to operate the Website. Because there is no common industry standard for interpreting "Do Not Track" (DNT) signals, the Website may not respond to all DNT signals; you can use the other controls described in this section to manage cookies and tracking.

15. Links to Third-Party Websites

Our Website and SMS messages may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices or content of any third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

16. Changes to This Policy

We may update this Policy from time to time to reflect changes in our data practices, SMS program, or applicable law. Any changes will be posted on this page with an updated "Effective Date." Continued participation in the SMS program after any modification constitutes your acceptance of the revised Policy.

17. Contact Information

For questions, concerns, or complaints regarding this Privacy Policy, contact us:

• Company: True Aluminum, Inc.
• Address: 4000 N Frontage Rd, Plant City, FL 33565
• Phone: (863) 804-6021
• SMS Sender Number: +1 656-236-0628
• Email: [email protected]
• Website: https://truealuminum.com