At Nalley, DBA EZ Messenger, DBA Dustin Nalley, and DBA EZ Affiliate ("we," "us," "our"), we are committed to protecting your privacy. This Privacy Policy applies to all of our websites (under the main domain and subdomains) and our subscription services ("Subscription Service").

This Privacy Policy governs our data collection, processing, and usage practices. It also describes your choices regarding the use, access, and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use our websites or the Subscription Service.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification.

While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically.

1. Information We Collect About You

- Personal and Contact Information: This includes your name, age, telephone number, postal address, email address, username, and social media username(s). We may collect this information when you interact with us, including via our customer care team.

- Communications: Details (and copies) of your communications and interactions with us via our customer care team or otherwise, including by email, telephone (voice recordings), post, and online via webchat or social media channels.

- Identity Verification: Copies of documents you provide to prove your identity (including driving license and passport) when there is a legal reason to request this from you.

- Transaction Details: Payments from you for subscription or purchase of our services.

- Financial Information: Your payment card information (processed by PayPal or Stripe) when you make a purchase or subscribe to our services.

- Technical Information: Information about your device or browser when you use our app or website, including geolocation data, IP address, device ID, browser type and version, and time zone setting.

We may also receive personal data directly from you or from various third parties and public sources, including social media channels (if you interact with us through those channels) or other third parties.

Registration:

How: We use your personal and contact information to register you as a new client. Why: Necessary for the performance of a contract with you.

Accessing Services:

How: We use the personal and contact information provided by you and the transaction details about your purchases, to provide our services to you. Why: Necessary for the performance of a contract with you.

Communications:

How: We use the personal and contact information provided by you, copies of your communications with us, and transaction details, to manage our relationship with you. Why: Necessary for the performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how clients use our services).

Staff Training:

How: We may use copies of your communications with us (including voice recordings) to train our staff.Why: Necessary for our legitimate interests (to ensure that we are able to provide the best service to you).

Market Research:

How: We may use the personal and contact information you have provided to ask you to take part in market research or a survey.Why: Necessary for our legitimate interests (to assess and improve our services and business).

Technical Issues:

How: If you contact us about an issue, we may use technical information and personal and contact information to administer and protect our business and website.Why: Necessary for our legitimate interests (for running Nalley, LLC., the provision of administration and IT services, security, and fraud prevention). Necessary to comply with a legal obligation.

Experience:

How: We use information about your use of our website, technical information about your device, personal and contact information, and other relevant information to deliver relevant content and manage delivery. Why: Necessary for our legitimate interests (to ensure that you are shown relevant content based on your use of our app or website).

Advertising Effectiveness:

How: We use information about your use of our app or website and, in some circumstances, personal and contact information about you, to measure the effectiveness of advertising.Why: Necessary for our legitimate interests (to determine how effective advertising is in order to improve advertising, its relevance, and to fulfill contracts with our marketing partners).

Analytics:

How: We use information about your use of our app or website and technical information, including about your device or location, to optimize our service.Why: Necessary for our legitimate interests (to measure interactions with our website, to define types of clients that use our services, and to inform our marketing strategy).

Publicity and Testimonials:

How: We may use your personal and contact information, communications, testimonials, and screenshots for marketing and publicity purposes. This includes publicly distributing testimonials, screenshots, and other client experiences for marketing purposes.Why: Necessary for our legitimate interests (to promote our services). Your consent.

Regulatory Compliance:

How: We may use your personal and contact information, financial information, information about transactions, and technical information to comply with legal obligations.Why: Necessary to comply with a legal obligation.

Fraud Prevention:

How: We may use your personal and contact information, financial information, information about transactions, and technical information for fraud prevention.Why: Necessary to comply with a legal obligation. Necessary for our legitimate interests (to ensure that transactions and interactions are not fraudulent).

Queries:

How: We may use your personal and contact information, financial information, information about transactions, and technical information to deal with any requests, complaints, or queries from you.Why: Necessary to comply with a legal obligation. Necessary for our legitimate interests (to respond to you and to deal with any request you may have). We use your personal data to create aggregated data sets. You are not identifiable from aggregated data, which is not considered personal data. However, if we combine or connect aggregated data with your personal data, we treat the combined data as personal data used in accordance with this

Privacy Policy.

3. How We Use Your Personal Data for Marketing

We send marketing communications through various channels, such as newsletters, email notifications, and other communications you request or consent to receive. You may opt-out at any time by:

- Clicking 'unsubscribe' or updating preferences in any email communication we send.

- Contacting us in writing. Emailing us at [email protected].

4. How We Share Your Data with Third Parties

We may share your personal data with:

- Banks and Payment Providers: To set up and/or obtain payment of any amounts due to us.

- IT System Providers: To provide software for account setup, communication, and hosting.

- Social Media Platforms: For fulfilling services and targeted advertising.

- Survey Companies and Market Research Agencies: To undertake surveys and analyze results.

- Digital Analytics Companies: For website analytics and reporting.

- Professional Advisers: For consultancy, banking, legal, insurance, and accounting services.

- Regulatory Authorities: As part of investigations or legal purposes.

- Auditors: To audit systems and transactions for efficiency or regulatory compliance.

5. How We Protect Your Data

We have implemented measures to protect your personal data:

- Encryption: Our entire site uses HTTPS rather than HTTP, encrypting all information sent and received.

- Third-Party Requirements: Third parties must have appropriate measures to protect your data.

- International Transfers: Your data may be processed outside the EEA, with appropriate safeguards in place.

6. How Long We Keep Your Personal Data

We keep your personal data as long as necessary to fulfill the purposes for which we collected it, including legal, accounting, or reporting requirements. After the retention period, your data will be deleted or anonymized.

7. Your Rights

You have the right to:

- Ask us not to use your personal data for marketing.

- Request access to personal information held about you.

- Ask for rectification of inaccurate or incomplete data.

- Withdraw consent for consent-based processing.

- Request deletion of your data.Request restriction of processing in certain circumstances.

- Request data portability in certain circumstances.

8. Contact Us

If you have any questions about our Privacy Policy or wish to exercise your rights, please contact our Data Protection Officer:

Data Protection Officer

Dustin Nalley

Nalley, LLC.

[email protected]

9. Cookies

We use cookies and similar technologies to recognize your browser and device. We allow third parties to use cookies, pixels, and ad tags while you browse our website and app, collecting information about your usage.

Here's how and why we use them:

Strictly Necessary Cookies: Required for the operation of our website and app.

Performance Cookies: Collect information about how you use our website or app, helping us improve functionality.

Functionality Cookies: Identify whether you are logged into our portals and remember your preferences.

Advertising Cookies and Pixels: Placed by media partners for targeted advertising.

You can manage or delete cookies in your browser settings. For more information about cookies, how to opt out, and the steps you can take to protect your privacy on the internet, visit your online choices

Consent for Publicity and Testimonials

By using our services, you consent to our use of your testimonials, communications, and screenshots of client experiences for marketing purposes. If you have any concerns or wish to withdraw your consent, please contact us at

[email protected]

Changes to this Privacy Policy

Any changes that we may make to our Privacy Policy in the future will be posted on this website. Where appropriate, we will notify you of the changes periodically.