01Who we are
Placeholders in brackets (e.g. [COMPANY LEGAL NAME]) must be filled in with the company's details before launch. This document is a starting template and should be reviewed by a lawyer.
This Privacy Policy explains how Noir SMS, operated by [COMPANY LEGAL NAME], [REGISTERED ADDRESS] ("we", "us"), handles personal information when you visit noirsms.com or use our services. For the purposes of UK data protection law, we are the data controller.
Contact for privacy matters: [PRIVACY EMAIL]. [If required: UK representative: [UK REPRESENTATIVE NAME AND ADDRESS].]
02Information we collect
| Category | Examples | Source |
|---|---|---|
| Account details | First and last name, email, hashed password, referral code, how you heard about us | You |
| Transactions | Top-ups, balance, numbers purchased, service and country chosen, refunds | You and our systems |
| SMS content | Messages received on numbers you rent, including verification codes | Third-party services sending the SMS |
| Payment details | Payment status and the last 4 digits / card brand. Full card numbers are handled only by our payment processor | Payment processor |
| Technical data | IP address, browser, device, approximate location derived from IP, log-in times, security logs | Your device |
| Support | Messages you send us | You |
| Cookies | Essential cookies; analytics and marketing cookies only with your consent | Your device |
We do not ask for your personal phone number, and we do not knowingly collect information from anyone under 18.
03How we use it and our legal bases
- To provide the service (create your account, deliver numbers and SMS, manage your balance and refunds): performance of our contract with you.
- To keep the service secure and prevent fraud and abuse, including enforcing our Acceptable Use Policy: our legitimate interests and legal obligations.
- To process payments and keep accounting records: contract and legal obligation.
- To answer support requests and send service messages (e.g. receipts, security alerts, changes to our terms): contract and legitimate interests.
- To measure and improve the site and send marketing: your consent, which you can withdraw at any time.
05International transfers
Our providers may process data in the United States, Canada, the United Kingdom, the European Union and other countries. When data leaves the UK, we use recognized safeguards such as the UK International Data Transfer Addendum or adequacy regulations.
06How long we keep it
- Account data: while your account is open and up to [24] months after it is closed.
- SMS history: available in your account while it is open; you can ask us to delete it at any time.
- Transaction and tax records: as long as the law requires (usually 6 to 7 years).
- Security logs: up to [12] months.
07Your rights
Depending on where you live, you may have the right to access, correct, delete or export your personal information, to object to or restrict certain processing, and to withdraw consent at any time.
United Kingdom
Under UK GDPR you also have the right to complain to the Information Commissioner's Office (ico.org.uk).
Canada
Under PIPEDA and applicable provincial laws, you can access and correct your information and complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca).
United States
Residents of California and other states with privacy laws may request to know, delete or correct their information and opt out of the sale or sharing of personal information (we do not sell or share it). We will not discriminate against you for exercising these rights, and we honor Global Privacy Control signals as an opt-out.
To exercise any right, email [PRIVACY EMAIL]. We may need to verify your identity before acting on a request.
09Security
We use encryption in transit, hashed passwords, access controls and optional two-factor authentication. No system is 100% secure, so please use a strong, unique password.
10Changes and contact
We may update this policy and will show the new "last updated" date here; material changes will be notified by email or in the dashboard. Questions: [PRIVACY EMAIL].