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SMS / Messaging Terms & Conditions

Version 1.0  |  Effective Date: March 27, 2026

1. Program Overview

Program Name: HoopFrog Account Verification & Security SMS

Company: HoopFrog Inc., 3-11 Bellerose Drive, Suite 312, St. Albert, AB T8N 5C9, Canada

SMS Phone Number: +1 (587) 805-1506

Service Provider: Twilio Inc. (San Francisco, CA, USA)

HoopFrog, operated by HoopFrog Inc., uses SMS text messaging for the following purposes:

• Phone Verification: A one-time code sent to verify your phone number during account registration
• Two-Factor Authentication (2FA): A one-time code sent to verify your identity when you log in from an untrusted device
• Identity Verification: A one-time code sent to confirm your identity when you submit a Data Subject Access Request (DSAR) or other privacy rights request

2. Consent and Opt-In

By providing your mobile phone number during account registration, enabling SMS-based two-factor authentication (2FA), or requesting identity verification via SMS, you expressly consent to receive automated transactional SMS text messages from HoopFrog (operated by HoopFrog Inc.) at the phone number you provide. This consent is not a condition of purchasing any goods or services.

You may be asked to confirm your consent by entering a verification code sent to your phone. This double opt-in process serves as your prior express consent under applicable law.

3. Message Types and Frequency

Message Type	Trigger	Estimated Frequency
Phone verification code	Account registration	1 message per registration
2FA login code	Login from untrusted device	Varies; typically 1–5 per month
DSAR identity verification	Privacy rights request	Rare; 1 message per request

Message frequency varies. You will only receive messages when you initiate an action that requires SMS verification. We do not send marketing, promotional, or recurring campaign messages via SMS. All messages are transactional and user-initiated.

4. Message and Data Rates

5. How to Opt Out and Get Help

Opt-Out (STOP)

You may opt out of receiving SMS messages at any time by:

• Replying STOP to any message from +1 (587) 805-1506
• Disabling SMS 2FA in your HoopFrog account settings (Settings > Security > Two-Factor Authentication)
• Contacting us at support@hoopfrog.com

After opting out, you will receive one final confirmation message: “You have been unsubscribed from HoopFrog SMS messages. No more messages will be sent. Reply HELP for help or contact support@hoopfrog.com.”

Note: If you opt out of SMS messages, you will no longer be able to use SMS-based phone verification or 2FA. You may switch to authenticator app (TOTP) based 2FA as an alternative.

Help (HELP)

For assistance, reply HELP to any message from +1 (587) 805-1506, or contact:

• Email: support@hoopfrog.com
• Privacy Officer: privacy@hoopfrog.com
• Mail: HoopFrog Inc., 3-11 Bellerose Drive, Suite 312, St. Albert, AB T8N 5C9, Canada

6. Carrier Disclaimer

Carriers (including but not limited to AT&T, Verizon, T-Mobile, Sprint, Rogers, Bell, Telus, Vodafone, Optus, Telstra, Spark NZ, Claro, Vivo, Telcel, and all other mobile carriers) are not liable for delayed or undelivered messages. Message delivery is subject to effective transmission from your network operator and is not guaranteed.

SMS messaging is available on most major carriers. Supported carriers vary by region. If your carrier does not support SMS from our number, please contact support@hoopfrog.com for alternative verification methods.

7. Privacy and Data Protection

Your phone number is personal data. We take its protection seriously. For full details, see our Privacy Policy.

7.1 Data Collection and Storage

• Your phone number is encrypted at rest using AES-256-GCM encryption
• A SHA-256 hash of your phone number is stored separately for lookup and deduplication purposes
• Phone numbers are never displayed to other users or shared for marketing purposes
• SMS message content and delivery logs are retained for 90 days for security auditing, then permanently deleted

7.2 Data Processor

SMS messages are transmitted via Twilio Inc. (101 Spear Street, San Francisco, CA 94105, USA), which acts as a data processor on our behalf. Twilio processes your phone number solely to deliver SMS messages and is bound by a Data Processing Agreement (DPA) with HoopFrog Inc. Twilio’s privacy practices are described in their Privacy Policy.

7.3 Data Retention

• Phone number (encrypted): Retained while your account is active, plus 30 days after account deletion
• Phone number hash: Retained for 90 days after account deletion (for anti-fraud purposes), then permanently deleted
• SMS delivery logs: 90 days, then permanently deleted
• Verification codes: Expire after 10 minutes and are not stored after use

8. United States, TCPA Compliance

For users in the United States, this section provides disclosures required by the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, and regulations of the Federal Communications Commission (FCC).

• By providing your phone number, you give prior express consent to receive automated transactional SMS text messages from HoopFrog Inc. (doing business as HoopFrog) at the number you provide
• Consent is not required as a condition of purchasing any goods or services
• Messages are sent using an automated telephone dialing system (via Twilio)
• Message frequency varies (see Section 3 above)
• Message and data rates may apply
• Text STOP to cancel; text HELP for help
• You may revoke consent at any time by replying STOP or contacting support@hoopfrog.com

9. Canada, CASL and CRTC Compliance

For users in Canada, this section addresses compliance with Canada’s Anti-Spam Legislation (CASL, S.C. 2010, c. 23) and Canadian Radio-television and Telecommunications Commission (CRTC) requirements.

• Sender identification: Messages are sent by HoopFrog Inc. (doing business as HoopFrog), 3-11 Bellerose Drive, Suite 312, St. Albert, AB T8N 5C9, Canada
• Express consent: You provide express consent to receive transactional electronic messages when you supply your phone number for verification or 2FA
• Unsubscribe mechanism: Reply STOP to any message, disable SMS 2FA in settings, or email support@hoopfrog.com
• Contact information: support@hoopfrog.com | +1 (587) 805-1506
• These messages are transactional in nature (account verification and security) and are exempt from certain CASL consent requirements under Section 6(6) of CASL. We obtain express consent nonetheless to exceed minimum compliance

10. CTIA Short Code Compliance Disclosures

11. European Union and United Kingdom, GDPR / UK GDPR

For users in the European Economic Area (EEA) and the United Kingdom, the following applies under the General Data Protection Regulation (EU) 2016/679 and UK GDPR:

• Legal basis for processing: Your phone number is processed on the basis of your explicit consent (Article 6(1)(a) GDPR), given when you provide your phone number for verification or enable SMS 2FA. For security-related processing (fraud prevention), we may also rely on legitimate interest (Article 6(1)(f) GDPR)
• Data processor: Twilio Inc. (USA) acts as a data processor under a Data Processing Agreement that includes Standard Contractual Clauses (SCCs) for international data transfers
• Retention period: Phone numbers are retained while your account is active, plus 30 days after deletion. SMS logs are retained for 90 days
• Right to withdraw consent: You may withdraw your consent at any time by replying STOP, disabling SMS 2FA, or contacting privacy@hoopfrog.com. Withdrawal does not affect the lawfulness of processing before withdrawal
• Right to erasure: You may request deletion of your phone number by contacting privacy@hoopfrog.com or using the account deletion feature in Settings
• Right to lodge a complaint: You have the right to lodge a complaint with your local Data Protection Authority
• International transfer: Your phone number is transferred to Twilio (USA) and stored in Canada. These transfers are governed by Standard Contractual Clauses and Canada’s adequacy decision by the European Commission

12. Australia and New Zealand

Australia, Privacy Act 1988

• Collection notice: We collect your phone number for the purpose of account verification and security authentication, as described in this document
• Purpose limitation: Your phone number will only be used for the transactional SMS purposes described in Section 3 and will not be used for direct marketing
• Cross-border disclosure: Your phone number may be disclosed to Twilio Inc. in the United States for the purpose of delivering SMS messages. HoopFrog Inc. takes reasonable steps to ensure Twilio complies with the Australian Privacy Principles (APPs)
• Access and correction: Under APPs 12 and 13, you have the right to request access to and correction of your phone number by contacting privacy@hoopfrog.com
• Complaints: You may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au

New Zealand, Privacy Act 2020

• Collection notice: We collect your phone number directly from you for account verification and security purposes
• Purpose limitation: Your phone number is used solely for the SMS verification purposes described in Section 3
• Cross-border disclosure: Your phone number is disclosed to Twilio Inc. (USA) and stored by HoopFrog Inc. (Canada). We take reasonable steps to ensure comparable privacy protections are in place via contractual agreements
• Access and correction: Under Information Privacy Principles 6 and 7, you have the right to request access to and correction of your personal information by contacting privacy@hoopfrog.com
• Complaints: You may lodge a complaint with the Office of the Privacy Commissioner at privacy.org.nz

13. Mexico, LFPDPPP

For users in Mexico, the following applies under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP):

• Consent: By providing your phone number, you grant express consent for its collection and processing for the purpose of account verification and security authentication
• Purpose of processing: Your phone number is processed solely for account registration verification, two-factor authentication, and identity verification for privacy rights requests
• Transfer notice: Your phone number is transferred to Twilio Inc. (USA) for SMS delivery and stored by HoopFrog Inc. (Canada). These transfers are made with your consent and in compliance with LFPDPPP Articles 36–37
• ARCO rights: You may exercise your rights of Access, Rectification, Cancellation, and Opposition by contacting privacy@hoopfrog.com. We will respond within 20 business days
• Supervisory authority: INAI, inai.org.mx

14. Brazil, LGPD

For users in Brazil, the following applies under the Lei Geral de Proteção de Dados (LGPD, Law No. 13,709/2018):

• Legal basis: Your phone number is processed on the basis of your explicit consent (Article 7, I of the LGPD), provided when you supply your phone number for verification or enable SMS 2FA
• Purpose limitation: Your phone number is used exclusively for the transactional SMS purposes described in Section 3 (account verification, 2FA, and identity verification)
• Data subject rights: You have the right to confirmation of processing, access, correction, anonymisation, portability, deletion, information about sharing, and revocation of consent. Contact privacy@hoopfrog.com to exercise these rights. We will respond within 15 days per the LGPD
• International transfer: Your phone number is transferred to Twilio Inc. (USA) and stored in Canada. Canada’s PIPEDA provides a comparable level of protection to the LGPD, in accordance with LGPD Article 33
• Supervisory authority: ANPD, gov.br/anpd

15. Changes to These SMS Terms

We may update these SMS Terms from time to time. If we make material changes, we will notify you via in-app notification at least 30 days before the changes take effect. The current version is always available at /sms-terms.

16. Related Policies

• Privacy Policy
• Terms of Service
• Cookie Policy

17. Contact Information

• General Support: support@hoopfrog.com
• Privacy Officer: privacy@hoopfrog.com
• Legal: legal@hoopfrog.com
• Mailing Address: HoopFrog Inc., 3-11 Bellerose Drive, Suite 312, St. Albert, AB T8N 5C9, Canada
• SMS Phone Number: +1 (587) 805-1506

HoopFrog Inc., Federal Corporation No. 1467452-9 | Alberta Registration CAN 2126911664