Infrastructure SMS Notifications – Privacy Policy

Last updated: November 23, 2025

1. Scope of this Policy

This SMS Infrastructure Notifications Privacy Policy (the “Policy”) explains how Cohesive Database Synoptics (“we,” “us,” or “our”) collects, uses, discloses, and protects personal information in connection with our SMS text messaging program for infrastructure-related notifications.

This Policy applies specifically to SMS messages sent to employees and contractors relating to the monitoring, operation, security, and maintenance of our systems and services (the “SMS Program”). It does not govern other forms of communication we may use (such as email or collaboration platforms), which may be subject to additional or separate policies.

2. Who We Are and How to Contact Us

Cohesive Database Synoptics is a provider of custom cloud software systems and developer tooling solutions.

If you have questions about this Policy or how we handle personal information in connection with the SMS Program, you may contact us at:

• Email: privacy@codatsy.com
• Mailing Address: 625 Kenmoor Ave SE Ste 350 Grand Rapids, Michigan 49546

3. Information We Collect

In connection with the SMS Program, we may collect and process the following categories of information:

Identification and contact information

• Name
• Mobile phone number
• Role or relationship with us (e.g., employee, contractor, team or department)

SMS and technical information

• Message content (limited to infrastructure-related communications)
• Message timestamps (sent, delivered, failed)
• Delivery status and error codes
• Phone number type and carrier information, where available
• Log records associated with sending and receiving messages

We collect this information from internal HR, IT, or contractor records you provide or that are maintained as part of your relationship with us, from information you provide directly, and from technical systems used to send and track SMS messages.

We do not intentionally collect more personal data than is reasonably necessary to operate the SMS Program.

4. How We Use Your Information

We use personal information collected in connection with the SMS Program for the following purposes:

Infrastructure and operational communications

• Sending infrastructure-related alerts, including:
  • System and service performance alerts
  • Outage and incident notifications
  • Maintenance windows and change notices
  • Security or policy-related notifications
• Communicating time-sensitive information relevant to your role, responsibilities, or on-call status.

Program administration and compliance

• Managing subscription lists and ensuring messages reach the correct recipients.
• Recording and honoring opt-in and opt-out preferences as required by law and carrier rules.
• Monitoring the effectiveness and reliability of message delivery (for example, delivery success rates and failures).

Legal, security, and compliance purposes

• Complying with applicable laws, regulations, and carrier requirements.
• Supporting internal audits, incident response, security investigations, and compliance reviews.
• Protecting our rights, property, systems, and the safety of our personnel and third parties.

We do not use personal information collected through the SMS Program for advertising, general consumer marketing, or the marketing of third-party products or services.

5. Legal Basis for Processing (Where Applicable)

Where applicable law requires a legal basis, we may rely on your consent where it is required for sending SMS communications. In other cases, we may process your information as necessary for the performance of your role, contract, or engagement, or as necessary for our legitimate interests, including maintaining secure and reliable infrastructure and communicating operational and security-related information, provided those interests are not overridden by your rights and interests.

If you have questions about the legal basis that applies in your case, you may contact us using the details above.

6. How We Share Your Information

We do not sell your personal information or your phone number. We do not share your mobile number, opt-in data, or SMS consent with third parties for their own marketing or promotional purposes.

We may share information collected via the SMS Program only with the following categories of recipients:

Service providers and telecommunications carriers

• Messaging platforms and underlying carriers that transmit and deliver SMS messages on our behalf.
• These providers are permitted to use your information only as necessary to provide services to us and are subject to appropriate confidentiality and security obligations.

Affiliates and internal recipients

• Our affiliated entities, if any, and internal teams or functions such as IT, security, HR, and compliance that need access to the information to operate the SMS Program and perform their job duties.

Legal and regulatory recipients

• Law enforcement authorities, regulators, courts, or other third parties, where we believe disclosure is required by law or reasonably necessary to:
  • Comply with a legal obligation or lawful request,
  • Protect our rights, property, or safety, or that of our personnel or others, or
  • Detect, investigate, or prevent security incidents, fraud, or abuse.

Standard 10DLC statement: Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties.

7. Opt-In and Opt-Out

Opt-In

Participation in the SMS Program may occur through internal onboarding processes, HR or IT records, or operational requirements tied to your role, such as on-call responsibilities or incident response duties, and through your explicit consent or request to receive infrastructure notifications at a specific mobile number.

By providing your mobile number for the SMS Program, or by accepting a role where SMS notifications are part of the operational communication methods, you acknowledge and consent, where required by law, to the use of your number for the purposes described in this Policy.

Opt-Out and Updates

You may opt out of receiving SMS messages for the SMS Program at any time by replying STOP to any SMS message we send through the SMS Program, where supported by the system, or by contacting us at the email provided above and requesting that your number be removed or changed.

After we receive your opt-out request, we will take reasonable steps to stop sending SMS messages to that number, except where messages are required by law or strictly necessary for critical security or operational notices that cannot be reasonably delivered through alternative channels.

If you opt out of SMS notifications, we may still deliver comparable notifications via other channels, such as email, incident management systems, or collaboration tools, where appropriate and consistent with your role and our internal policies.

You are responsible for keeping your contact information accurate and up to date. To update your mobile number or communication preferences for the SMS Program, please contact us at the email provided above or follow your internal HR or IT procedures.

8. Data Retention

We retain personal information collected in connection with the SMS Program only for as long as necessary to operate and administer the SMS Program, maintain appropriate operational, security, and audit records, comply with legal, regulatory, and carrier requirements, and resolve disputes and enforce our agreements.

After the relevant retention period has expired, we will delete or anonymize the information within a reasonable time, in accordance with our data retention and deletion practices.

9. Data Security

We implement reasonable and appropriate technical and organizational measures designed to protect personal information processed in connection with the SMS Program against unauthorized access, disclosure, alteration, or destruction. These measures may include access controls, logging, encryption in transit where appropriate, and other safeguards.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. However, we continually review and update our security measures in light of evolving risks and practices.

10. International Data Transfers (If Applicable)

Depending on where you are located, your information may be processed and stored in a country that may have different data protection laws than the country in which you reside or work.

Where required by law, we take steps to ensure that appropriate safeguards are in place for such international transfers, such as standard contractual clauses or equivalent mechanisms, or reliance on other lawful bases permitted by applicable law.

If you would like more information about cross-border transfers or the safeguards we use, you may contact us at the email address provided above.

11. Your Rights (Where Applicable)

Depending on your location and applicable law, you may have certain rights in relation to your personal information, which may include the right to access the personal information we hold about you, the right to request correction of inaccurate or incomplete information, the right to request deletion of your personal information subject to certain legal or operational exceptions, the right to object to or request restriction of certain processing, and the right to withdraw consent where processing is based on consent, without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us at the email provided above. We may need to verify your identity before responding to your request and may be unable to fully comply where we are legally required or permitted to retain certain information, for example, to maintain audit logs or comply with legal obligations.

12. Changes to This Policy

We may update or revise this Policy from time to time. When we do, we will update the “Last updated” date at the top of this Policy. Material changes may be communicated through internal channels or other reasonable means.

Your continued use of the SMS Program after any changes to this Policy have become effective will constitute your acknowledgment of the updated Policy.