Effective Date: May 19, 2025

**IMPORTANT DISCLAIMER:** This is a sample Privacy Policy provided for illustrative purposes. AB Services Elite strongly advises you to consult with qualified legal counsel to ensure your Privacy Policy is compliant with all applicable laws, regulations, and specific operational practices of your service. This sample does not constitute legal advice.**

AB Services Elite ("we," "us," or "our") is committed to protecting the privacy of individuals who use our professional messaging service (the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information. By registering for and using our Service, you consent to the practices described in this Privacy Policy.

1. Information We Collect

We collect the following categories of personal information directly from you when you register for our Service:

• Identity Data: This includes your full name, username (if applicable), and other identifiers you may use.
• Contact Data: This includes your email address and phone number, which we use for communication and account management.
• Connection Data: Information related to your inmate connections, such as their name and correctional ID, which you provide to facilitate messaging.
• Transaction Data: Details about payments to and from you and other details of products and services (e.g., credits) you have purchased from us. We use third-party payment processors and do not store your full credit card details.
• Message Content: The content of messages you send and receive through the Service. As a messaging platform, we necessarily process and store this content to deliver your messages and, if applicable and disclosed (e.g., for partner facilities with review enabled), for review by authorized personnel.

2. How We Collect Your Information

We collect your personal information primarily through the following method:

• Direct Interactions: You provide us with your personal information when you register for an account, update your profile, add connections, purchase credits, fill out forms within the Service, or communicate with us directly via email or other channels.
• Automated Technologies or Interactions: As you interact with our Service, we may automatically collect Technical Data about your equipment, Browse actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies (e.g., Firebase Analytics). This includes IP address, browser type, operating system, access times, and pages viewed.

3. Purposes for Which We Use Your Information

We use your personal information for the following specific purposes:

• Service Provision: To register you as a new user, enable the core functionality of our Service, which is to facilitate the sending and receiving of messages between you and your inmate connections. This includes managing your account, processing transactions (like credit purchases), and ensuring the proper delivery and handling of messages according to service features (e.g., routing through partner facilities if applicable).
• Communication: To communicate with you regarding your account, updates to our Service, important notices (including security alerts), and changes to our terms or privacy policy.
• Customer Support: To provide you with support and assistance when you encounter issues or have questions about our Service.
• Service Improvement: To analyze usage patterns and trends to improve and optimize the functionality, security, and user experience of our Service. This may involve using anonymized and aggregated data for analytical purposes.
• Security and Fraud Prevention: To maintain the security and integrity of our Service, including monitoring for and preventing fraudulent or unauthorized activities, and to enforce our terms and conditions.
• Legal Compliance: To comply with applicable legal and regulatory obligations, legal processes, or governmental requests.

4. Legal Basis for Processing Personal Information

Our legal basis for processing your personal information typically includes:

• Contractual Necessity: Processing is necessary for the performance of the contract (our Terms of Service) we have with you to provide the Service.
• Legitimate Interests: Processing is necessary for our legitimate interests in operating, maintaining, and improving our Service, providing customer support, ensuring security, preventing fraud, and for administrative or legal purposes, provided that such interests are not overridden by your rights and fundamental freedoms.
• Consent: In some specific situations, we may rely on your consent to process your personal information (e.g., for certain types of cookies or direct marketing communications, if applicable). Where we rely on consent, you have the right to withdraw it at any time.
• Legal Obligation: Processing may be necessary for compliance with a legal obligation to which we are subject.

5. Disclosure of Your Information

We are committed to maintaining your privacy. We do not sell your personal information. We may share your personal information with third parties only in the following limited circumstances:

• Service Providers: We may share your information with third-party vendors, consultants, and other service providers who need access to such information to carry out work on our behalf (e.g., payment processors, cloud hosting providers like Google Firebase, analytics providers, email service providers). These providers are contractually obligated to safeguard your information and are restricted from using your personal information for any other purpose.
• Correctional Facilities and Partner Entities: To facilitate communication with an inmate, your identifying information (such as your name, email, and phone number as registered with our Service) and the content of your messages will necessarily be shared with and accessible by the relevant correctional facility where your inmate connection is housed, and any partnered entities (e.g., "Partner Facilities" using our platform) authorized by that facility to manage or review communications. This is essential for the delivery of messages and for compliance with the facility's rules, security protocols, and applicable regulations. Such facilities or partners may have their own policies regarding message review, monitoring, and record-keeping.
• Legal Requirements and Protection of Rights: We may disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with a legal obligation, subpoena, court order, or other legal process; (b) protect and defend our rights or property; (c) prevent or investigate possible wrongdoing in connection with the Service; (d) protect the personal safety of users of the Service or the public; or (e) protect against legal liability.
• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, your personal information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Service of any change in ownership or uses of your personal information.

6. Data Security

We have implemented administrative, technical, and physical security measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. For example, user passwords are hashed, and communications with our Service may be encrypted using SSL/TLS technology. We utilize Google Firebase for backend services, which provides its own robust security infrastructure.

While we strive to protect your personal information, please understand that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

7. Data Retention

We will retain your personal information for as long as your account is active or as needed to provide you the Service and to fulfill the purposes for which it was collected. This includes retention necessary for complying with our legal obligations (e.g., record-keeping for correctional facilities if required), resolving disputes, and enforcing our agreements. When your account is terminated, we will take steps to delete or anonymize your personal information from our active systems in accordance with our data retention policies and applicable law. Message content may be retained for longer periods as required by correctional facility policies or legal obligations. Anonymized or aggregated data may be retained indefinitely for analytical and service improvement purposes.

8. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information. These may include:

• Right to Access: You may have the right to request access to the personal information we hold about you and to receive a copy of that information.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you. You can typically update your account information through your dashboard settings.
• Right to Erasure (Deletion): In certain circumstances, you may have the right to request the deletion of your personal information, subject to certain exceptions (e.g., legal obligations, ongoing service provision).
• Right to Restriction of Processing: You may have the right to request that we restrict the processing of your personal information under certain conditions.
• Right to Data Portability: Where applicable, you may have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Right to Object: You may have the right to object to the processing of your personal information in certain circumstances (e.g., for direct marketing, though we currently do not engage in direct marketing with your core service data).
• Managing Your Information: You can review and change your personal information by logging into the Service and visiting your account profile page.

To exercise any of these rights, please contact us using the information provided in Section 13 ("Contact Us"). We will respond to your request within a reasonable timeframe and in accordance with applicable law. We may require you to verify your identity before responding to your requests.

9. Children's Privacy

Our Service is not directed to, and we do not knowingly collect personal information from, children under the age of 13 (or the relevant minimum age in your jurisdiction). If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us. If we become aware that we have collected personal information from a child under the applicable age limit without verification of parental consent, we will take steps to remove that information from our servers.

10. International Data Transfers

Your information, including personal data, may be processed and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. We currently process and store data primarily in the United States, leveraging Google Firebase infrastructure. If you are located outside the United States and choose to use our Service, you consent to the transfer of your information to the United States and its processing there. We will take appropriate safeguards to ensure your personal information remains protected in accordance with this Privacy Policy and applicable law.

11. Disclaimer Regarding Legal Disputes

By registering for and using the services of AB Services Elite, you acknowledge and agree that you voluntarily waive, to the fullest extent permitted by applicable law, any right to initiate or participate in any class action lawsuit or class-wide arbitration against AB Services Elite arising from or related to your use of our services or this Privacy Policy. You further agree that any dispute resolution proceedings will be conducted only on an individual basis. You understand and agree that your primary remedy for any dissatisfaction or issue with our services is to terminate your account and discontinue using the Service. This clause is intended to govern the relationship between you and AB Services Elite regarding legal disputes related to the Service and should be read in conjunction with our full Terms of Service.

12. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, service offerings, or legal and regulatory requirements. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. We may also notify you through other means, such as by email or a notice on our Service, prior to the change becoming effective. We encourage you to review this Privacy Policy periodically for any changes. Your continued use of the Service after any modifications to this Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

13. Contact Us

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

AB Services Elite | Connect
Email: info@abserviceselite.com