Mobile Messaging (SMS) Policy
CONTENTS
1. Purpose
2. Scope
3. Lawful Basis
4. Collection Requirements (Trade Shows and Events)
7.Data Minimization and Retention
10. Compliance and Enforcement
Appendix A - Customer-Facing SMS Consent Language
Appendix B - Listing of Transtech Group and Affiliated Companies
1. PURPOSE
The purpose of this Policy is to establish governance requirements for the collection, use, processing, storage, and transmission of mobile phone numbers for SMS or text message communications. This Policy ensures compliance with applicable data protection and electronic communications laws, including but not limited to the GDPR, UK GDPR, ePrivacy Directive, PECR, TCPA, and other relevant regulations.
2. SCOPE
This Policy applies to all Transtech Group, LLC. (Appendix B) business units that collect or process mobile phone numbers; all SMS communications including marketing, promotional, informational, and service-related messages; all employees, contractors, and third parties acting on behalf of the Company; and mobile numbers collected at trade shows, events, website forms, partner programs, or direct outreach. Mobile phone numbers constitute personal data and shall be handled in accordance with the Company’s Privacy Policy and Information Security Policy.
3. Lawful Basis
Marketing SMS communications shall be sent only where valid prior consent has been obtained unless otherwise permitted by applicable law. Consent must be freely given, specific, informed, unambiguous, and documented. Consent shall not be inferred from badge scanning alone, provision of a business card, general event attendance, or pre-checked boxes. Where reliance on legitimate interest is considered for non-marketing communications, a documented Legitimate Interest Assessment (LIA) must be completed and approved by the Privacy function.
4. Collection Requirements (Trade Shows and Events)
Individuals must be provided with clear and transparent notice at the time their mobile number is collected. Notice shall include the identity of the Company, purpose of SMS communications, message frequency statement, notice that message and data rates may apply, opt-out instructions, and reference to the Company’s Privacy Policy. Records of consent shall be retained by the department (Marketing) manager responsible for messaging.
5. Permitted Use
SMS communications shall be limited to the purposes disclosed at the time of consent. SMS shall not be used to transmit sensitive personal data, confidential corporate information, authentication credentials, or passwords. Use of mobile numbers for materially different purposes requires renewed consent.
6. Opt-Out and Withdrawal
All marketing SMS messages shall contain clear opt-out instructions. Withdrawal of consent shall be honored without undue delay. Opted-out numbers not be used for further SMS marketing communications.
7. Data Minimization and Retention
The Company shall collect only the minimum personal data necessary to fulfill the stated purpose. Mobile phone numbers shall not be retained longer than necessary and retention shall follow the Company’s Data Retention Policy.
8. Third-Party Processors
SMS service providers shall be subject to a written Data Processing Agreement (DPA). Third parties shall implement appropriate technical and organizational security measures. International transfers shall comply with applicable cross-border transfer mechanisms.
9. Security Controls
Mobile phone numbers shall be stored only in Company-approved systems. Access shall be role-based and limited to authorized personnel. Unauthorized extraction, export, or sharing of mobile numbers is prohibited.
10. Compliance and Enforcement
Non-compliance with this Policy may result in disciplinary action, up to and including termination of employment or contract. The Privacy function shall conduct periodic audits to ensure compliance.
Appendix A - Customer Facing SMS Consent Language
.Short-Form Consent:
By providing your mobile number and selecting this option, you agree to receive text messages from TransTech Group & Affiliates about products, services, and events. Message frequency varies. Message and data rates may apply. Reply STOP to unsubscribe. See our Privacy Policy at [URL].
Extended Consent:
By providing your mobile phone number, you consent to receive marketing text messages from Transtech Group / Affiliates regarding products, services, and events. You may withdraw consent at any time by replying to STOP. Your personal data will be processed in accordance with our Privacy Policy.
Appendix B - Listing of TransTech Group and affiliated companies
Transtech Group, LLC.
Trans-Tech Energy, LLC.
Transtech Fabrication, LLC
Bendel Tank & Heat Exchanger, LLC.
Metalforms, LLC.
Metalforms Italia S.r.l.
ESI Acquisition Entity, LLC.
KL Distribution, LLC.
4Energyneering Solutions, LLC.
ESI Seller, Inc
ESI Acquisition Canada, Inc.
Energyneering Solutions Canada, LTD
Transtech Group International, Inc.
Maddox Industrial Holdings, LLC
Maddox Industrial, LLC
Transtech Cryogenics, Inc.
CTR of the Carolinas, Inc.