1. Who This Policy Covers

This Privacy Policy explains how MyBuildr, a product and service of MyPortal Virtual Assistants Corp. / MyPortal Marketing ("MyBuildr," "we," "us," "our"), collects, uses, shares, and protects information in connection with the MyBuildr platform (the "Service"). It applies to two distinct groups of people, and we've tried to be clear about which section applies to which:

• 
  Customers — the small business owners and their staff who sign up for and use MyBuildr directly.
• End Users — the customers, leads, patients, or website visitors of our Customers, whose data passes through MyBuildr's tools (for example, someone who chats with a Customer's AI chat widget, receives a review-request text, or calls a Customer's AI voice receptionist).

Where our Customers are the ones deciding what data about their own End Users is collected and why, MyBuildr acts as a data processor/service provider on the Customer's behalf for that End User data, and the Customer remains responsible for having the appropriate legal basis and consent to collect and use it. This Policy describes both our own practices as a business and the processing we do on our Customers' behalf.

2. Information We Collect

From Customers directly: account information (name, business name, email, phone, billing address); payment information (processed by our third-party payment processor — we do not store full card numbers); business details you provide or connect (services offered, hours, location, brand voice, logo, photos, Google Business Profile access, social media account access, ad account access); and usage data (how you interact with the MyBuildr dashboard).

From or about End Users, on behalf of our Customers: contact information (name, phone number, email) submitted through a Customer's website, chat widget, or provided by the Customer's own customer list; message content exchanged with the AI chat widget or AI voice receptionist, including call recordings and transcripts where enabled; appointment and booking information; review and feedback content; and website analytics (pages visited, general location, device type) for Customers' sites built on MyBuildr.

3. How We Use Information

We use the information described above to: provide, operate, and maintain the Service, including building and hosting your website, managing your local listings, and running the CRM, email, SMS, chat, and voice features; train and run the AI tools that generate website copy, ad creative, email content, chat responses, and voice responses in your specific brand voice; detect proactive marketing opportunities (for example, identifying a slow period and drafting a promotional campaign) as described in our Terms and Conditions; process payments and manage your subscription; provide customer support and respond to your requests; and improve the Service, including improving our AI models using aggregated or de-identified data where feasible.

We do not sell Customer or End User personal information to third parties for their own independent marketing purposes.

4. AI Processing Disclosure

MyBuildr's AI tools process business information and, where applicable, End User messages and call content in order to generate website content, respond to chat and voice inquiries, draft marketing communications, and take certain automated actions. This processing may involve sending data to third-party AI model providers (see Section 5) solely to generate the requested output; those providers are contractually restricted from using your data to train their own general-purpose models except where required by their standard terms, which we review before integrating any such provider.

If you interact with a MyBuildr Customer's AI chat widget or AI voice receptionist as an End User, you should assume your message or call may be processed by AI systems, and, where legally required, we and/or our Customers will disclose that you are interacting with an AI at the start of that interaction.

5. Sharing and Third-Party Services

We share information with the following categories of third parties, only as necessary to provide the Service:

• 
  Payment processors, to handle subscription billing securely.
• Meta and Google, when you enable MyBuildr Ads, to create and manage advertising campaigns on your connected ad accounts.
• Our SMS/voice infrastructure providers (including Twilio and our AI voice/chat technology partner, ID Privacy AI, who power the MyBuildr Chat and MyBuildr Voice features), to send text messages, place and receive calls, and process AI conversations.
• Google, for Google Business Profile and local listings synchronization.
• Social media platforms you connect, to publish and manage content on your behalf.
• Cloud hosting and infrastructure providers, to store and run the Service.
• Our own personnel and contracted specialists, where you subscribe to Managed Services, so they can manage the relevant tools on your behalf.
• Legal and regulatory authorities, where required by law, or to protect the rights, property, or safety of MyBuildr, our Customers, or others.

A current list of material subprocessors is available on request.

6. Call Recording and Voice AI

Where a Customer enables MyBuildr Voice (our AI phone receptionist), calls to that Customer's business line may be recorded and transcribed for the purposes of answering the call, booking appointments, providing the Customer a record of the interaction, and improving the AI's accuracy. Where required by law, callers will be informed at the start of the call that they are speaking with an AI system and, where applicable, that the call may be recorded. Our Customers are responsible for configuring these disclosures correctly for the jurisdictions in which they operate.

7. SMS/Text Messaging Program

Where a Customer uses MyBuildr to send text messages to its End Users, for example automated review-request messages sent shortly after a completed appointment or service visit, the following applies specifically to that SMS program:

Consent. End Users are enrolled through their Customer's own opt-in process, such as a checkbox or verbal request at the time of check-in, intake, or visit, and enrollment is always optional. Consent to receive text messages is never a condition of purchasing goods or services, receiving treatment, or maintaining a customer relationship with the Customer.

No sharing for marketing. Mobile phone numbers and SMS opt-in information collected for this program are not shared with third parties for their own marketing or promotional purposes. They are used only to deliver the messages the End User has agreed to receive, and are shared only with the infrastructure providers named in Section 5 (such as Twilio) solely to transmit those messages.

Frequency and charges. Message frequency varies by Customer and use case but is typically limited, for example one message per completed visit for a review-request program. Message and data rates may apply, depending on the End User's mobile carrier and plan.

Opt-out and help. End Users may opt out of a specific SMS program at any time by replying STOP to any message in that program, and may reply HELP for support. Carriers are not liable for delayed or undelivered messages.

8. Data Retention

We retain Customer account information for as long as the account is active and for a reasonable period afterward to comply with legal, accounting, and dispute-resolution obligations. We retain End User data (messages, call recordings/transcripts, booking records) for as long as the relevant Customer's account is active, unless the Customer deletes it sooner or a shorter period is required by law. When a Customer's account is closed, we will delete or de-identify associated End User data within a commercially reasonable period, except where retention is required by law or for legitimate business records (such as billing history).

9. Your Rights and Choices

Depending on your location, you may have rights to access, correct, delete, or receive a copy of your personal information, and to opt out of certain uses. Customers can manage most of this directly within the MyBuildr dashboard or by contacting us. End Users who wish to exercise privacy rights regarding data held by a specific MyBuildr Customer should generally contact that Customer directly, since the Customer controls the underlying data; where the request instead needs to come to us, we will assist and route the request to the relevant Customer as appropriate.

End Users can always opt out of a specific SMS program by replying STOP to a message in that program (see Section 7), and out of promotional email by using the unsubscribe link included in every message, as required by law.

10. Data Security

We use industry-standard administrative, technical, and physical safeguards designed to protect information processed through the Service, including encryption in transit, access controls, and vendor security review for the third parties listed in Section 5. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

11. International Data Transfers

MyBuildr and its service providers may process and store information in countries other than where you or your End Users are located, including Canada, the United States, and the Philippines (where our product and support teams operate). Where required, we rely on appropriate safeguards for such transfers.

12. Children's Privacy

The Service is intended for business use by adults and is not directed at children. We do not knowingly collect personal information from children under 13 (or the relevant age of digital consent in your jurisdiction). If we learn we have inadvertently collected such information, we will delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify active Customers of material changes by email or in-app notice at least 14 days before they take effect, and will update the "Last updated" date above.

14. Contact Us

• Questions about this Privacy Policy or requests regarding your personal information can be sent to support@myportalmarketing.com.
  
  Email: privacy@mybuildr.co
  
• Mail: 48 Webb Circle, Haliburton, Ontario K0M1S0, Canada