Capitalized words have the meanings defined below. These definitions apply whether the terms appear in singular or plural form.
Hold Time Media delivers SMS messages to individuals who are on hold with a Business Partner that has licensed the Hold Time Media platform. While on hold, End-Users hear a pre-recorded interactive voice (IVR) prompt that describes the program before any message is sent — including that one text message containing a game link will be sent to their mobile number, that message and data rates may apply, how to get help (reply HELP) and how to opt out (reply STOP), and where to find these Terms and this Privacy Policy.
Consent is express and opt-in. To receive the message, the End-User presses 1 on their phone keypad (or says "yes") in direct response to the prompt. This keypress is an affirmative opt-in given by the recipient, in real time, over the same call. Only after the End-User presses 1 do we send exactly one SMS message — to that End-User's own phone number (their caller ID) — containing the game link. If the End-User does not press 1, no message is sent. Each opt-in results in exactly one SMS message; the Service does not send recurring, scheduled, or broadcast messages, and phone numbers are never uploaded, purchased, or submitted by any third party.
Every SMS includes opt-out instructions. End-Users may reply STOP at any time to unsubscribe and will receive a single confirmation message. Standard message and data rates may apply. Business Partners are responsible for ensuring their use of the Hold Time Media platform complies with applicable laws, including the Telephone Consumer Protection Act (TCPA) and any applicable state regulations governing SMS communications.
Depending on how the Service is configured by a Business Partner, we may collect the following personally identifiable information:
Usage Data is collected automatically when an End-User interacts with the Service. This may include:
We do not collect Social Security numbers, financial account numbers, credit card information, biometric data, health or medical information, or protected classification characteristics such as race, religion, or sexual orientation.
The Company uses collected data for the following purposes:
We do not use End-User data for third-party advertising or sell End-User personal information to data brokers.
No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties. We do not sell, rent, or share End-User mobile phone numbers with any third parties. Mobile phone numbers are used solely to deliver the single opt-in SMS and to honor opt-out (STOP) and help (HELP) requests.
Aggregate and anonymized usage data may be shared with the Business Partner that deployed the Hold Time Media experience. Individually identifiable data is only shared as required to deliver the Service or as authorized by the End-User.
We work with third-party Service Providers to operate the Service. These providers process data only to perform services on our behalf and may not use it for their own purposes. They include:
In the event of a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your data becomes subject to a different Privacy Policy.
We may disclose your Personal Data if required by law or in response to valid requests by public authorities, including courts and government agencies.
Hold Time Media is registered under the A2P 10DLC framework as required by U.S. mobile carriers. All SMS communications sent through the Service:
We retain Personal Data only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.
Mobile phone numbers used for SMS delivery are retained only for the duration of the hold session and any applicable opt-out record keeping required by law. Usage Data is generally stored for no longer than 24 months unless a longer period is required by law.
We implement commercially reasonable technical and organizational measures to protect your data, including encrypted data transmission, access controls, and regular security reviews.
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.
The Service is not directed at individuals under the age of 13. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and believe your child has provided us with Personal Data, please contact us immediately and we will take steps to remove that information from our systems.
If you are located in the European Economic Area (EEA), you have the following rights under GDPR:
To exercise any of these rights, please contact us using the information in Section 13. You also have the right to lodge a complaint with your local data protection authority.
If you are a California resident, you have the following rights under CCPA/CPRA:
We do not sell personal information as that term is commonly understood. We do not share personal information with third parties for their direct marketing purposes.
To submit a verifiable consumer request, contact us using the information in Section 13. We will respond within 45 days of receipt.
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy at www.holdtimemedia.com/privacy and updating the "Last Updated" date at the top of this document. Continued use of the Service after changes are posted constitutes your acceptance of the revised policy.
If you have questions, requests, or concerns about this Privacy Policy or our data practices, please contact us: