1. Introduction

Shutr Enterprises LLC (referred to as "Shutr," "we," "us," or "our") respects your privacy and is committed to protecting it. This policy outlines how we collect, process, and use your data as an authorized agency on the GoHighLevel (GHL) platform.

2. Important Information and Who We Are

2.1 Role and Relationship

Shutr operates as an authorized agency on the GoHighLevel platform and acts as both:
• A data controller for information we collect directly from you.

• A data processor for information processed through GoHighLevel’s infrastructure.

2.2 Platform Provider

Our services are delivered through GoHighLevel’s platform. While we maintain this privacy policy, you may also be subject to GoHighLevel’s privacy policies when using their platform infrastructure.

3. The Data We Collect

3.1 Information You Provide

We collect the following data when you interact with our services:

• Identity Data: Name, title, company name

• Contact Data: Email address, phone numbers, addresses

• Business Data: Business registration details

•Technical Data: Login credentials, access logs

• Marketing Data: Communication preferences

• Client Data: Your client data is stored inside the GHL platform

• Creative Work: Any assets you share with us (such as photos, videos, or marketing materials) to support your business are treated as confidential.

No third party sharing or selling. We do not sell, rent or share any of your data or mobile opt-ins with third parties for their own marketing or commercial use. The only time we may share your mobile numbers or personal information is with trusted sub-processors and service providers (like SMS delivery platforms) under obligation to protect and limit the usage of that data. We will not disclose, distribute or use your mobile opt-in data for any purpose other than those described in this policy, unless required by law or your explicit authorization. To opt-out, end users can opt out of text messages at any time and upon receiving an opt-out request (for example: replying with "STOP"), we immediately suppress their number from further communication, except for any legally permitted confirmations or notices.

3.2 Agency Access and Development Support

To provide services effectively, Shutr maintains administrative access to client accounts for:

• Technical support & troubleshooting

• Platform optimization & maintenance

• Implementation of custom features

• Performance monitoring

• Emergency technical interventions

This access is:

• Limited to authorized personnel

• Used only when necessary for support, maintenance, or requested changes

• Subject to strict internal security protocols

• Governed by consent under Shutr’s Terms of Service and Privacy Policy

3.3 Automatically Collected Information

We may collect data automatically, including:

• Usage Data: How you use our services

• Technical Data: IP address, browser type, device information

• Analytics Data: Service usage patterns

3.4 Third-Party Sources

We may receive additional data from:

• GoHighLevel platform

• Public databases

• Marketing partners

• Service providers

4. How We Use Your Information

4.1 Primary Uses

We use your data for:

• Providing services

• Account management

• Customer support

• Technical issue resolution

• Service optimization

• Communication & notifications

4.2 Administrative Access Usage

Our access to client accounts is strictly limited to:

• Performing requested changes

• Maintaining system performance

• Resolving technical issues

• All administrative activity is logged and monitored to ensure compliance with privacy standards.

4.3 Marketing & Communications

When you or your customers provide a mobile number and opt in to receive text (SMS) communications from us, we collect and store that mobile opt-in data for the sole purpose of:

• Send service updates

• Send review requests

• Share relevant business opportunities

• Deliver newsletters and updates

4.4 Legal Bases for Processing

We process data under the following legal bases:

• Contract performance (fulfilling our services)

• Legal obligations (complying with regulations)

• Legitimate business interests (service optimization)

• Consent (where required)

4.5 Payment Processing

All payments are processed through Shutr Enterprises LLC via Stripe.

This setup:

• Ensures secure payment processing

• Complies with financial regulations

• Does not affect service delivery or support

5. Data Sharing & Disclosure

5.1 Service Providers

We may share data with:

• GoHighLevel (primary platform provider)

• Hosting providers

• Analytics services

• Communication services

• Payment processors (Stripe)

5.2 Legal Requirements

We may disclose your data to:

• Comply with laws and regulations

• Respond to legal requests

• Protect our rights

• Facilitate business transfers (e.g., mergers, acquisitions)

6. International Transfers

6.1 Data Location

• Primary data processing occurs in the United States

• Payment processing occurs via Stripe

• Some data may be processed in other regions via GoHighLevel’s infrastructure

• We ensure appropriate safeguards for international transfers where applicable.

7. Data Security

7.1 Security Measures

We implement:

• Encryption (in transit and at rest)Strict access controls

• Regular security assessments

• Incident response procedures

7.2 Data Breach Procedures

In the event of a data breach, we will:

• Notify affected users

• Coordinate with GoHighLevel on platform-related incidents

• Comply with regulatory reporting requirements

8. Data Retention

8.1 Retention Periods

We retain data for:

• Active accounts: Duration of service

• Terminated accounts: Data is permanently deleted within 30 days of account termination

• Legal requirements: Certain records may be retained for tax purposes

9. Your Legal Rights

9.1 Your Rights

You have the right to:

• Access your data

• Correct inaccurate data

• Request deletion

• Object to processing

• Request data portability

• Withdraw consent for marketing

9.2 CCPA Compliance

Since we operate in the United States, we comply with the California Consumer Privacy Act (CCPA) for applicable clients.

10. Business Transfers

If Shutr undergoes a merger, acquisition, or sale, your personal information may be transferred to the new entity under the same privacy conditions.

11. Cookies & Tracking

11.1 Cookie Usage

We use cookies and similar technologies for:

• Essential platform functionality

• Analytics and performance tracking

• Improving user experience

• Marketing (with consent)

12. Changes to This Policy

We may update this policy periodically. Significant changes will be announced through:

• Email notifications

• Platform updates

• Website notices

13. Contact Us

For privacy-related inquiries, contact us at:

Email: [email protected]

By using our services, you acknowledge this privacy policy and consent to the described practices.