Employee Messaging Privacy Policy

Zekelman Employee Messaging Privacy Policy

Effective Date: March 26, 2026

This Employee Messaging Program Privacy Policy explains how Zekelman Industries and its affiliates and related entities (collectively, “we,” “our,” or “us”) processes personal information in relation to its employee text message program (the “Messaging Service“). We use this Messaging Service to send operational, equipment, and safety alerts to current employees.

1. Personal Information We Collect

We may obtain personal information from and about you in various ways, including information you directly provide when you use the Messaging Service. We may collect the following:

1. Communications Usage Data (Metadata)

  • Phone numbers involved (source and destination)
  • Routing information
  • Date, time, and duration of the communication
  • Type of communication (e.g., SMS, voice call)
  • Status of the message or call (delivered, failed, etc.)
  • Error data 
  • Communications Traffic records

2. Device and Network Information

  • IP address and device information (when interacting with Twilio’s portal or APIs)
  • General location information (such as city or town, but not precise geolocation)
  • Device type, operating system, browser type, etc.

3. Customer Proprietary Network Information (CPNI) (for US voice services)

  • Number of calls
  • Call destinations
  • Call locations
  • Type and configuration of service
  • Note: CPNI does not include names, addresses, or the content of calls.

4. Security Identifiers

  • Unique security IDs (SIDs) and API tokens for each account and resource.

5. Support and Feedback Data

  • If you interact with our third-party support provider, the phone number or email used, and the content of the interaction, may be stored.

2. How We Use Personal Information

We use and retain personal information about you for the following purposes related to the Messaging Service:

  • Communication, including sending you alerts.
  • Operate the Messaging Service, including delivering, analyzing, maintaining, and supporting the Messaging Service.
  • Enhance the Messaging Service, including enhancing Messaging Service features and customizing and personalizing your Messaging Service experiences.

3. How We Disclose Personal Information

We may disclose your Personal Information for the purposes described above to the following parties:

  • Our Affiliates and Other Brands for our business purposes.
  • Agents, Vendors, and Service Providers that assist us in providing the Messaging Service.
  • Government Entities, Professional Advisors, and Other Parties to protect our operations and our or others’ rights, privacy, safety, or property; enforce our terms and conditions; comply with law or legal process; respond to requests from public and government authorities; and allow us to pursue available remedies or limit the damages that we may sustain.
  • Parties to Transactions as part of or during any negotiations of any merger, acquisition, reorganization, restructuring, divestiture, dissolution, or other sale or transfer where a party assumes control over all or part of our business or assets.

Mobile information and SMS opt-in consent will not be shared with or sold to any third parties or affiliates for marketing or promotional purposes.

4. Safeguards

We take reasonable measures to protect personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and online digital storage are not completely secure and we do not guarantee the security of your personal information collected through the Messaging Service.

Opt-Out: You may revoke your consent to receive these text messages at any time by replying ‘STOP’ to any message or by contacting the Help Desk.

Retention:  We retain your personal information only as long as necessary for the purposes described above or as required by law.

Access, Correction and Deletion: You may have the right to access, correct, or delete your personal information, subject to applicable law. Please contact the Help Desk for more information.

International Transfers:  If your personal information is transferred outside your country, we will ensure appropriate safeguards are in place as required by applicable law.

5. Contact Us

For questions about the Messaging Service please contact the Help Desk at helpdesk@zekelman.com.