PRIVACY POLICY

The American Customer Works Company ("ACW," "we," "us," or "our") respects your privacy and is committed to protecting the personal and business information entrusted to us. This Privacy Policy explains how we collect, process, store, and safeguard your data when you interact with our website, our client command portals, our market intelligence platform (Prospector), and our telephony systems—including calling or texting our toll-free line (1-877-462-2901).

1. Information We Collect

We collect information necessary to deliver market intelligence, operate client portals, process payments, and provide customer support. The categories of data we collect include:

• Account & Registration Data: Name, business email address, company name, primary website URL, industry sector, target geographic scope, and administrative credentials submitted during onboarding or account setup.
• Billing & Payment Information: Payment card details and billing addresses are collected and processed securely by our third-party payment processor, Stripe. We do not store raw credit card numbers on our servers.
• Customer-Configured SMTP Credentials: If you elect to connect outbound email accounts for outreach dispatch, your SMTP server credentials (server address, port, username, password) are saved securely on encrypted storage partitions solely to execute your configured dispatches.
• Public Market Intelligence & OSINT: Prospector harvests publicly available business information from open web sources, public commercial registries, corporate websites, and public discussion forums (e.g., company names, executive titles, public business email addresses, phone numbers, and public problem statements).
• Telephony & Inbound Communications: Caller ID, call duration, DTMF keypad selections, voicemail audio recordings, and automated Speech-to-Text (STT) transcripts generated when you dial or text 1-877-462-2901.
• Technical & Session Data: IP addresses, browser types, request timestamps, and sliding session tokens (`vanguard_portal_token`) used to maintain secure portal access.

2. How We Use Your Information

We use collected information strictly to operate, maintain, and improve our services, including:

• Provisioning client command portals and managing lead pipelines;
• Analyzing public market demand signals and evaluating prospect fit using artificial intelligence;
• Processing subscription billing and managing account status via Stripe;
• Delivering transactional customer support, requested callbacks, and platform notifications;
• Monitoring system health, preventing security threats, and auditing platform performance.

3. Mobile Information Sharing & Consent

Text messaging opt-in data, phone numbers, and consent records are used exclusively to deliver transactional customer support, requested platform updates, and demo notifications from 1-877-462-2901.

4. Third-Party Service Providers

We do not sell, rent, or trade your personal or business data. We share data only with trusted third-party infrastructure providers necessary to operate the Service:

• Payment Processing: Stripe (for credit card processing and subscription billing);
• Telephony & TeXML Services: Telnyx (for toll-free voice, IVR, and SMS routing);
• Cloud AI Operations: OpenAI (for cloud AI reasoning, where prompt payloads undergo PII redaction prior to processing).

5. AI Processing & Anonymization

Prospector integrates artificial intelligence and machine learning models for market signal evaluation and pitch drafting. To protect privacy:

• Cloud LLM requests pass through a automated PII airlock that redacts sensitive personal identifiers (personal handles, individual phone numbers) before cloud processing;
• Local sovereign models (Qwen / Llama-Server) run directly on our air-gapped server infrastructure for local evaluation;
• We do not permit third-party AI providers to use your private account data or email credentials to train public AI models.

6. Cookies & Session Management

We use secure, HTTP-only cookies (`vanguard_portal_token`) with an 8-day sliding renewal window to maintain your authenticated session across your company’s vanity subdomain. These cookies are strictly necessary for portal navigation and security. We do not use third-party tracking cookies or advertising ad-tech pixels on our client portals. On public ACW pages, a separate first-party browser identifier, valid for up to 30 days, helps us associate outreach links with page loads and subsequent visits in the same browser. We record page paths, timestamps, limited browser information and indications of automated requests for up to 90 days. These observations do not establish that an email was read or identify the person viewing a forwarded link. This measurement does not record page interactions or conversions, and honors Do Not Track and Global Privacy Control signals.

7. Data Security & Encryption

We employ commercial-grade physical, technical, and administrative safeguards to protect your data, including:

• AES-256 encrypted storage partitions for database ledgers and client assets;
• HTTPS / SSL transport layer security across all web gateways and API endpoints;
• Sandboxed, air-gapped execution environments for sub-agent routines;
• Restricted LAN-only access boundaries for sensitive system configuration interfaces.

8. Data Retention & Deletion

We retain account and operational data for as long as your account remains active. For deactivated, paused, or cancelled accounts, operational lead data, scraped caches, AI traces, and staged tasks are automatically and permanently purged after 365 days of continuous inactivity. Basic accounting records and subscription transaction histories are retained in accordance with federal tax and accounting requirements.

9. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: