01
Who is responsible
100 Technology LLC, registered in the State of Delaware, United States, operates the THOG messaging platform and the a2p100tech.com website, and is responsible for the personal data described in this policy. Privacy questions and rights requests may be sent to [email protected].
This policy covers two different relationships. For your account, enquiries and website use we act as a controller. For the messages you send through the platform, including recipient phone numbers and message content, we act as a processor on your instructions, and you are the controller of that data.
02
Data we collect
Account and enquiry data you give us:
- name, company name and country of registration;
- work email address and phone number;
- a one-way hash of your password, never the password itself;
- your recorded acceptance of our terms and your messaging-consent choice;
- expected monthly volume, use case, shortlisted destinations and enquiry notes.
Traffic data generated when you use the platform:
- recipient mobile numbers, sender identity, message content and encoding;
- submission and delivery timestamps, segment counts, operator and MCC;
- delivery status and failure codes returned by operators.
Technical data collected automatically: IP address, browser and device type, pages viewed, API request metadata and security logs. We do not store card numbers or bank credentials on this website.
03
How we use data
We use personal data to:
- create, verify and secure your account;
- respond to enquiries and prepare rate cards and routing proposals;
- route, deliver, report on and bill for your messaging traffic;
- prepare sender identity, brand, campaign and template registrations with regulators, registries and operators;
- detect fraud, abuse and unauthorised access, and protect route quality;
- comply with legal, regulatory and operator obligations; and
- improve the platform and the website.
Where you tick the messaging-consent box at registration, we may send you account verification, service and occasional product messages by SMS and email at the details you provided. Message and data rates may apply. You may withdraw that consent at any time by contacting [email protected] or by following the opt-out instruction in a message. We may still send messages strictly necessary to operate your account or complete an open request.
04
Legal grounds for processing
Depending on where you are located, we rely on: performance of a contract with you or steps taken before entering one; compliance with legal obligations; our legitimate interests in operating, securing and improving a messaging network and in preventing abuse; and your consent where consent is required, such as for optional marketing messages. Where we rely on consent you may withdraw it at any time without affecting processing already carried out.
05
Recipient data and your responsibilities
When you send a message, you supply the recipient's phone number and the content. We process that data solely to deliver the message, produce delivery receipts, bill you, and meet legal or operator obligations. We do not use your recipient data to market our own services and we do not sell it.
As the controller of that data you are responsible for holding a valid legal basis and documented consent where required, for providing recipients with your own privacy notice, and for handling their rights requests. Our Terms of Service set out these obligations in full.
06
When data is shared
We share only the data necessary, with:
- mobile network operators, aggregators and interconnect partners, to deliver messages;
- regulators, registries and vetting providers, where a market requires sender identity, brand or campaign registration;
- hosting, infrastructure, security and monitoring providers;
- payment, banking, accounting and professional advisers;
- authorities where we are legally compelled, and to a successor entity in a merger or acquisition.
We do not sell personal data and we do not share it for third-party advertising.
07
International transfers
Message delivery is inherently cross-border: to reach a handset, a message and its destination number must be passed to operators in the destination country. Your data may therefore be processed in the United States, in the destination market, and in the locations of our service providers. Where transfers are subject to European, United Kingdom or similar transfer rules, we rely on appropriate safeguards such as standard contractual clauses, together with technical and organisational measures suited to the transfer.
08
Security
Passwords are stored using a salted one-way key derivation function and are never recorded in plain text. Session cookies are HTTP-only and are marked secure in production. Transport to and from the platform is encrypted with TLS, webhooks are signed, and access to production data is restricted to personnel who need it. No internet service can guarantee absolute security, but we maintain safeguards appropriate to the sensitivity of the data and review them regularly.
09
Retention
Account records are retained while your account is active and for the period afterwards required by tax, accounting and contractual obligations. Enquiry correspondence is retained while it is needed to answer you and to evidence the commercial relationship.
Message metadata needed for billing, dispute resolution and regulatory reporting is retained for the period required by law and operator agreements. Message content is retained only for the short operational window needed to deliver, retry and troubleshoot a message, after which it is deleted or de-identified.
10
Your rights
Subject to your location and to legal limits, you may ask us to access, correct, delete or port your personal data, to restrict or object to certain processing, or to withdraw consent. Residents of California and comparable jurisdictions may also request disclosure of the categories of data collected and may opt out of any sale or sharing of personal data; we do not sell or share personal data as those terms are defined.
Send requests to [email protected]. We may need to verify your identity, and we may retain data where law requires. If a request concerns data we process on a customer's behalf, we will refer you to that customer. You may also complain to your local supervisory authority.
11
Cookies and local storage
We use a strictly necessary session cookie to keep you signed in, and browser local storage to remember the destination shortlist you build on this device. Both are required for the features they support and neither is used for advertising. We do not currently use third-party advertising or cross-site tracking cookies. Clearing site data removes the shortlist and signs you out.
12
Children
The THOG platform is a business service and is not directed to children. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, contact [email protected] and we will delete it.
13
Changes to this policy
We update this policy when our services, providers or legal obligations change. The date shown alongside this page identifies the current version. Material changes are announced on the website or sent to the contact details on your account. Continued use after the effective date constitutes acceptance of the updated policy.