Privacy Policy

1. Scope

This Privacy Policy applies to personal information collected through the Services and in related communications with us. It applies to Inside Community Members, Outside Community Members, profile visitors, payers, support contacts, and other users.

This Privacy Policy does not govern independent correctional facilities, telecommunications providers, payment processors, websites, applications, or other third parties. Their privacy practices are governed by their own policies.

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2. Age Requirement

The Services are intended only for persons eighteen (18) years of age or older. We do not knowingly permit minors to create or use accounts. If we learn that personal information was collected from a person under eighteen in violation of our requirements, we may delete or restrict the information and account as appropriate.

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3. Categories of Personal Information We Collect

The information we collect depends on how you use the Services.

3.1 Account and Identity Information

We may collect:

• name, nickname, username, and account identifiers;
• email address, telephone number, mailing or billing address;
• password, personal identification number, verification code, and authentication information;
• date of birth or age confirmation where needed;
• identity, account, eligibility, or fraud-verification information;
• account status, user type, permissions, and preferences; and
• information supplied when an Outside Member creates or manages an Inside Member's profile or account.

3.2 Inside-Member and Profile Information

We may collect:

• Inside Member name and correctional or institutional identifier;
• facility, jurisdiction, location, or related information where provided or available;
• assigned telephone number and area-code preference;
• biography, interests, connection goals, profile image, public posts, and life updates;
• connection, contact, invitation, and profile-visibility information;
• subscription, trial, and Voice Connection status; and
• other information submitted for profile creation, management, verification, or support.

3.3 Communications and User Content

We collect and store content transmitted through or submitted to the Services, including:

• text messages;
• voice messages, audio submitted through voice-message features, and voice-message transcripts where transcription is enabled;
• profiles, photographs, comments, posts, and life updates;
• support messages and requests;
• Stacy prompts, questions, requests, generated responses, drafts, summaries, and recommendations;
• information users ask Stacy to locate, explain, remember, or use;
• recommendation history, recommendation settings, user feedback, reports, complaints, and moderation records; and
• related metadata, including sender, recipient, date, time, status, delivery information, and connection context.

We do not record the audio of ordinary telephone calls through the Voice Connection service. We may collect and retain call metadata, such as participating telephone numbers or account identifiers, date, time, duration, direction, status, technical events, and cost or usage information.

Correctional facilities, telecommunications providers, or other third parties may independently monitor or record calls under their own policies and applicable law.

3.4 Payment, Transaction, and Connection Credit Information

We may collect:

• transaction amount, date, status, recipient, and purpose;
• subscription, renewal, cancellation, refund, and trial information;
• Connection Credit funding and usage activity;
• billing address and payment-method details provided to our payment processors;
• limited payment-method information returned by a processor, such as card brand, expiration date, or last four digits;
• chargeback, dispute, reversal, fraud, and refund information; and
• receipts, transaction references, and related support records.

Payment processors generally collect and process full payment credentials directly. We do not intentionally store full payment-card numbers or card security codes unless expressly disclosed and permitted.

3.5 Device, Network, and Usage Information

We may automatically collect:

• Internet Protocol address;
• browser, operating system, device type, and device identifiers;
• pages, screens, links, features, and content viewed or used;
• access dates and times;
• referring and exit pages;
• cookie, pixel, analytics, and similar technology information;
• approximate location inferred from an IP address;
• application logs, crash data, error records, and performance information; and
• security, authentication, and fraud signals.

3.6 Support and Administrative Information

We may collect support requests, case history, internal notes, communications, investigation records, account changes, moderation actions, and administrator audit logs.

3.7 Sensitive Information You Choose to Provide

Messages, voice messages, profiles, calls, posts, life updates, or Stacy interactions may contain sensitive information, including information about health, disability, mental health, substance-use recovery, relationships, religious beliefs, legal matters, finances, sexual life, victim status, or other personal circumstances.

Do not submit sensitive information unless you understand that it may be processed as described in this Privacy Policy and may be subject to monitoring or disclosure by facilities, providers, or lawful authorities.

Where information qualifies as sensitive personal information, consumer health data, or another specially protected category under applicable law, we will process it as required by that law.

3.8 Inferences and Recommendations

We may create inferences, summaries, classifications, predictions, and recommendations from information available through the Services, including relationship context, interests, communication patterns, account activity, and prior interactions. These may be used to personalise the Services, support Stacy, detect risk, and improve user experience.

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4. Sources of Personal Information

We may collect personal information:

• directly from you;
• from another authorised user who creates, manages, funds, or interacts with an account or profile;
• from Inside Members and Outside Members with whom you communicate;
• from correctional facilities, telecommunications providers, payment processors, identity or fraud-prevention providers, and other service providers;
• from public records or publicly available sources where lawful;
• automatically from devices, browsers, cookies, logs, and analytics technologies; and
• through our own analysis, moderation, AI systems, and account operations.

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5. How We Use Personal Information

We may use personal information to:

• create, authenticate, administer, and secure accounts;
• provide calling, messaging, profiles, posts, life updates, community exploration, funding, subscriptions, support, and related features;
• identify and connect authorised users and contacts;
• process payments, subscriptions, Connection Credits, cancellations, refunds, disputes, and chargebacks;
• provide, personalise, and improve Stacy and other AI-assisted features;
• generate drafts, summaries, recommendations, reminders, profile updates, and user guidance;
• operate, test, evaluate, secure, troubleshoot, and improve Stacy, recommendation logic, platform features, products, and services;
• communicate about accounts, transactions, security, service changes, support, and marketing where permitted;
• conduct analytics, research, troubleshooting, quality assurance, and product development;
• maintain records and respond to requests;
• monitor and moderate content and communications where permitted;
• detect, prevent, investigate, and respond to fraud, abuse, exploitation, harassment, prohibited contact, payment misuse, security incidents, and unlawful activity;
• enforce our Terms and policies;
• comply with legal obligations and lawful requests;
• establish, exercise, or defend legal claims;
• protect users, victims, facilities, service providers, Stay Connected Plus, and the public; and
• complete a merger, financing, acquisition, reorganisation, sale, bankruptcy, or other business transaction.

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6. Stacy and Artificial-Intelligence Services

6.1 What Stacy Is

Stacy is an AI-powered assistant used to help operate and support features of the Services. Depending on the feature and the user's permissions and settings, Stacy may help users draft or edit messages, generate conversation ideas, provide profile suggestions, create summaries, identify meaningful updates, generate recommendations, assist with navigation, and support interactions through the Voice Connection and interactive voice response (IVR) system.

AI-generated responses, summaries, drafts, suggestions, and recommendations may occasionally be inaccurate, incomplete, outdated, or inappropriate for a user's circumstances. Stacy is intended to assist users and does not replace human judgment. Stacy does not provide legal, medical, mental-health, psychological, financial, emergency, or other professional advice. Users remain responsible for reviewing AI-generated content and for decisions or actions taken based on it.

6.2 Information Stacy May Process

When an AI-assisted feature is enabled and the information is available to the feature under the user's permissions and settings, Stacy may process:

• user account and profile information;
• profile updates and profile-completion information;
• interests, goals, connection preferences, and stated communication preferences;
• accessibility preferences and supported accommodation settings;
• text messages;
• voice messages and voice-message transcripts where transcription is enabled;
• posts, comments, and life updates;
• connection activity and authorised shared activity between connected users;
• questions, instructions, and requests submitted to Stacy;
• previous Stacy conversations and relevant conversation context;
• recommendation history, recommendation status, and recommendation feedback;
• user feedback, reports, corrections, and dismissals;
• platform interactions, feature usage, and navigation activity;
• call metadata, such as participants, date, time, duration, direction, and status, but not the audio of ordinary Voice Connection telephone calls; and
• technical, security, fraud, and service-performance information.

Stacy is not intended to process every category of information held by Stay Connected Plus. Processing is limited to information reasonably relevant to the enabled feature, the user's request, platform operation, safety, fraud prevention, security, legal compliance, and the purposes described below.

6.3 Why We Use Information With Stacy

We may use the information described above to:

• personalise Stacy and maintain relevant conversation continuity;
• improve message drafting, message editing, tone suggestions, and clarity assistance;
• generate conversation suggestions and conversation starters;
• generate connection recommendations;
• generate life-event reminders and life-update suggestions;
• generate relationship insights and summaries;
• provide profile suggestions and profile-management assistance;
• improve IVR interactions and voice-based navigation;
• help users find and use platform features;
• detect duplicate, repetitive, outdated, or already dismissed recommendations;
• detect meaningful changes that may support a relevant recommendation;
• reduce repetitive AI processing and improve platform performance;
• evaluate the usefulness, safety, and quality of Stacy outputs;
• detect, investigate, and prevent abuse, exploitation, prohibited contact, security threats, payment fraud, and other fraud;
• maintain security, system integrity, records, and auditability;
• troubleshoot errors and provide customer support; and
• comply with legal obligations, lawful requests, dispute-resolution requirements, and enforcement of our policies.

Stay Connected Plus does not use customer content to train proprietary foundation models or general-purpose AI models because Stay Connected Plus does not operate its own general-purpose model-training programme. We may evaluate outputs, recommendation performance, system safety, feature quality, and user feedback to improve how the Services use approved AI tools and recommendation logic, but this is not training a general-purpose AI model on customer content.

6.4 Personalised Stacy Recommendations and Opt-Out

Where permitted by applicable law, Personalised Stacy Recommendations may be enabled by default. Users may turn personalised recommendation processing off and may turn it back on later.

Outside Members may manage the setting through Account Settings and Privacy Settings, or may contact support@myscplus.com. Inside Members may manage the setting through available IVR Settings, an available voice command, or a support request through the Voice Connection system or support@myscplus.com.

When Personalised Stacy Recommendations are turned off:

• future processing for new personalised recommendations should stop after the preference is applied;
• basic account, calling, text-message, voice-message, profile, support, and other non-personalised communication features may continue to operate;
• previously generated recommendations may remain visible until the user removes them, they expire, or they are cleared through ordinary system operation;
• recommendation history, settings records, messages, voice messages, account records, fraud records, security logs, and other information may remain stored for legitimate operational, security, legal, regulatory, dispute-resolution, recordkeeping, and fraud-prevention purposes; and
• processing necessary to provide a specific AI feature that the user affirmatively requests may still occur for that request, even when background personalised recommendations are off.

Turning recommendations off does not automatically delete an account, messages, voice messages, recommendation records, or other records. Account deletion and legally available privacy requests are handled separately under Section 14.

Additional user-controllable settings may include AI-generated conversation suggestions, life-event recommendations, recommendation notifications, email recommendation notifications, push recommendation notifications, voice recommendation announcements, and life-event announcements. Availability may differ between Outside Members and Inside Members and may change as features are introduced, modified, or discontinued.

6.5 Automated Processing and Human Judgment

The Services use automated processing to generate recommendations, message suggestions, message edits, profile suggestions, summaries, conversation ideas, reminders, navigation assistance, and other personalised assistance. These outputs are intended to assist users. They are not final determinations about a person's legal rights, medical condition, financial eligibility, correctional status, or access to an essential service, and they do not replace independent judgment.

6.6 Approved AI Providers

Approved AI and technology providers may process information on our behalf to provide model access, transcription, storage, hosting, safety, security, or related technical services. We select and configure providers under contractual, technical, and organisational protections where applicable.

A provider may retain information temporarily when reasonably necessary to deliver, secure, troubleshoot, or monitor the contracted service, subject to the provider agreement, our configuration, and applicable law. Stay Connected Plus does not authorise AI providers to use customer content to train their own general-purpose models. If a provider's terms or configuration would permit such training, we will not intentionally submit customer content under that configuration without first providing any notice or obtaining any consent required by applicable law.

6.7 Sensitive Information

Stacy may process sensitive information when a user voluntarily includes it in a message, voice message, transcript, profile, post, comment, life update, support request, or Stacy conversation. This may include information about health, disability, mental health, religious or philosophical beliefs, political opinions, sexual orientation or sexual life, criminal-justice circumstances, victim status, finances, or information concerning minors mentioned by an adult user.

Stay Connected Plus is not a healthcare provider, legal service, financial adviser, or emergency service. Users should avoid providing sensitive information that is not necessary for the requested feature. Where sensitive information is processed, we use access controls, authentication, logging, monitoring, provider restrictions, user settings, and other safeguards designed to limit processing to authorised purposes and personnel. Rights or consent requirements imposed by applicable sensitive-data or consumer-health-data law will apply where required.

6.8 Cross-User Privacy

We do not intentionally use one user's private information to personalise an unrelated user's experience. Information may be used across connected users only where reasonably necessary to operate an authorised shared feature, such as messaging, invitations, shared life updates, shared relationship summaries, or recommendations relating to an established connection, and only within applicable permissions, visibility choices, connection status, and privacy settings.

6.9 Recommendation Controls and Operational Safeguards

We maintain or require administrative and technical controls designed to support recommendation privacy, including, where applicable:

• recording consent, acknowledgement, or the version of the Terms and Privacy Policy accepted by a user;
• logging changes to recommendation and privacy settings;
• allowing authorised customer-support personnel to confirm a user's current recommendation settings;
• preventing background personalised-recommendation jobs from processing users whose applicable setting is off;
• removing closed or deleted users from active recommendation queues when appropriate;
• clearing or expiring cached recommendation summaries when appropriate;
• retaining recommendation records only as described in this Privacy Policy; and
• enforcing role-based and connection-based access controls for recommendation data.

These controls may be implemented differently across web, IVR, support, and administrative systems.

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7. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients for the purposes described in this Policy.

7.1 Telecommunications and Communications Providers

We may disclose information to telephone, messaging, voice, network, and communications providers to route, deliver, support, troubleshoot, secure, and bill for communications.

7.2 Correctional Facilities and Related Systems

Information may be disclosed to or accessible by correctional facilities, departments, facility contractors, or related systems when necessary for access, verification, approval, monitoring, safety, compliance, or service delivery.

7.3 Payment Processors and Financial-Service Providers

We disclose transaction and account information to payment processors, banks, card networks, fraud-prevention providers, and related parties to process payments, refunds, disputes, chargebacks, and verification.

7.4 Hosting, Cloud, Technology, and AI Providers

We may disclose information to vendors that provide hosting, storage, databases, security, analytics, communications, customer support, software, development, AI processing, transcription, and technical services. Approved AI providers act on our behalf under applicable contractual and technical restrictions. We do not authorise those providers to use customer content to train their own general-purpose models.

7.5 Professional Advisers

We may disclose information to lawyers, accountants, auditors, insurers, consultants, and other professional advisers.

7.6 Other Users and the Public

We disclose information as directed by users and as needed to provide connections and communications. Public profile content, public posts, public images, and public life updates may be visible to users or the public.

7.7 Safety, Legal, and Enforcement Disclosures

We may preserve or disclose information to correctional facilities, law enforcement, courts, regulators, governmental agencies, victims, emergency responders, or other parties when we believe disclosure is reasonably necessary to:

• comply with law, legal process, or lawful requests;
• enforce our Terms or policies;
• investigate fraud, abuse, exploitation, threats, prohibited contact, or unlawful activity;
• protect rights, property, safety, users, victims, Stay Connected Plus, or the public; or
• respond to an emergency.

7.8 Business Transactions

We may disclose or transfer information in connection with a merger, acquisition, financing, reorganisation, bankruptcy, sale of assets, change of control, or similar transaction.

7.9 With Consent or Direction

We may disclose information with your consent or at your direction.

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8. Sale and Sharing of Personal Information

Stay Connected Plus does not currently sell personal information for money and does not currently share personal information for cross-context behavioural advertising as those terms are defined by applicable U.S. state privacy laws.

We may use service providers and contractors to process information on our behalf. Those disclosures are not intended to constitute a sale when governed by appropriate contractual restrictions.

Our practices may change. Before beginning a practice that constitutes a sale or regulated sharing under applicable law, we will update this Privacy Policy and provide any notice, consent, opt-out mechanism, or other rights required by law.

We do not knowingly sell or share personal information of persons under eighteen.

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9. Cookies and Similar Technologies

We and our service providers may use cookies, pixels, software development kits, local storage, logs, and similar technologies to:

• operate and secure the Services;
• remember preferences and sessions;
• understand usage and performance;
• diagnose errors;
• prevent fraud;
• measure communications or campaigns; and
• improve functionality.

Browser and device settings may allow you to limit some technologies. Disabling necessary cookies may prevent parts of the Services from working.

Where required, we will provide consent or preference controls. If we later engage in regulated sale or sharing, we will honour legally required opt-out signals, including applicable Global Privacy Control signals.

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10. Public Information and Visibility Choices

Information designated as public may be viewed, copied, shared, indexed, or retained by others. This may include profile names, photographs, biographies, interests, connection goals, public posts, and public life updates.

Use available visibility settings carefully. Removal from our Services does not guarantee removal from copies, screenshots, search-engine caches, facility records, or third-party systems.

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11. Communications Privacy and Correctional Monitoring

Communications involving incarcerated persons may be monitored, reviewed, restricted, delayed, blocked, recorded by third parties, or disclosed under facility policies, provider practices, court orders, law, or safety procedures.

Do not use the Services for privileged, confidential, emergency, medical, legal, or safety-critical communications unless you have independently confirmed that the communication method is appropriate and protected.

Stay Connected Plus does not record ordinary telephone-call audio, but we retain call metadata. Voice messages and other audio intentionally submitted as content are stored as part of the Services.

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12. Data Retention

We retain personal information for periods reasonably necessary for the purposes described in this Privacy Policy. Retention depends on the type of information, account status, operational need, legal and regulatory requirements, safety and security needs, dispute-resolution requirements, fraud-prevention needs, contractual obligations, and technical constraints. We do not describe information as being retained forever.

Retention may include:

• Active account data: retained while an account is active and as reasonably necessary to provide, administer, secure, personalise, and support the Services;
• Closed or deleted account data: retained after closure or deletion where reasonably necessary for legal compliance, billing, refunds, chargebacks, disputes, fraud prevention, safety, policy enforcement, audits, records, and system integrity;
• Message history: text messages, related metadata, and relevant status records may be retained to provide conversation history, continuity, safety, moderation, support, fraud prevention, and dispute resolution;
• Voice messages and transcripts: retained while reasonably necessary to provide playback, transcription, continuity, moderation, safety, support, fraud prevention, and dispute resolution;
• Recommendation records: generated recommendations, status, dismissal or completion history, user feedback, and recommendation settings may be retained to prevent duplication, maintain continuity, respect user preferences, measure feature performance, and resolve complaints;
• Stacy conversations: retained for continuity, support, records, safety, fraud prevention, quality evaluation, and the operational purposes described in Section 6, but not to train a Stay Connected Plus proprietary general-purpose AI model;
• Security and system logs: retained to authenticate users, detect threats, investigate incidents, maintain auditability, troubleshoot errors, and protect system integrity;
• Fraud and abuse investigations: retained for as long as reasonably necessary to investigate, prevent recurrence, support chargebacks or disputes, protect users, and comply with law;
• Legal holds and regulatory records: retained for the period required by a legal hold, court order, subpoena, investigation, legal claim, recordkeeping rule, or other legal obligation; and
• Backup copies: retained until overwritten, isolated, or deleted through ordinary backup and disaster-recovery cycles, subject to legal holds and technical constraints.

After applicable retention needs end, information may be deleted, anonymised, de-identified, aggregated, or otherwise disposed of in accordance with our procedures and applicable law. Deletion from active systems may not result in immediate deletion from backups, security archives, fraud files, or records that must be retained for lawful purposes.

Turning Personalised Stacy Recommendations off does not by itself change these retention rules. Account deletion does not require deletion of information that we are permitted or required to retain.

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13. Data Security

We use administrative, technical, and organisational safeguards designed to protect personal information against unauthorised access, use, alteration, disclosure, loss, or destruction. Depending on the system and information involved, safeguards may include:

• encryption in transit and, where appropriate, encryption or equivalent protections for stored information;
• authentication controls, credential protections, and account-verification procedures;
• role-based, need-to-know, connection-based, and administrative access controls;
• security monitoring, fraud detection, abuse detection, and anomaly detection;
• system, access, preference-change, and administrative logging;
• provider due diligence and contractual restrictions;
• software, infrastructure, and vulnerability-management controls;
• employee and contractor confidentiality and administrative controls; and
• incident response, backup, recovery, and service-continuity procedures.

No system is completely secure. You are responsible for safeguarding your password, PIN, devices, account access, and authentication information and for promptly notifying us of suspected unauthorised use.

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14. Your Privacy Choices and Rights

14.1 Account and Platform Controls

Depending on the account type, feature availability, and applicable law, users may:

• view account and profile information where available;
• correct or update profile information;
• update communication, notification, accessibility, and privacy preferences;
• turn Personalised Stacy Recommendations and related recommendation settings on or off as described in Section 6.4;
• manage public-profile visibility and audience settings where available;
• request account cancellation or deletion where applicable; and
• contact privacy@myscplus.com for privacy support.

Outside Members may access available controls through Account Settings and Privacy Settings. Inside Members may use available IVR Settings, voice commands, or customer support. Some information cannot be changed directly because it is needed for identity, payment, security, fraud prevention, facility requirements, legal compliance, or record integrity.

14.2 Rights Required by Applicable Law

Privacy rights vary by location. Stay Connected Plus honours the rights available to users under applicable law and may provide additional account controls where available. Where applicable law grants a right, an eligible person may be entitled to request access, correction, deletion, portability or export, information about processing, withdrawal of consent, or an opt-out of certain sale, sharing, targeted advertising, or profiling practices.

Submit a privacy request to privacy@myscplus.com or by mail using the contact information in Section 22. Describe the request, the account or information involved, and the jurisdiction in which you reside.

We may verify identity and authority before processing a request. We may deny, limit, or charge for a request where permitted, including when we cannot verify identity, an exception applies, the request is excessive, or retaining information is necessary for security, fraud prevention, legal compliance, transactions, disputes, safety, exercise of legal rights, or other permitted purposes.

We will not unlawfully discriminate against a person for exercising an applicable privacy right. Authorised agents may submit requests where permitted by law and subject to verification.

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15. California Privacy Notice

If the California Consumer Privacy Act, as amended, applies to Stay Connected Plus and your information, California residents may have rights described above, including rights to know, access, correct, delete, opt out of sale or sharing, limit certain uses of sensitive personal information, and be free from unlawful discrimination.

During the twelve months before the Effective Date, we may have collected the categories described in Section 3 and disclosed them for business purposes to the recipient categories described in Section 7.

We do not currently sell personal information or share it for cross-context behavioural advertising. If that changes, we will provide legally required notices and opt-out mechanisms.

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16. Consumer Health and Sensitive Data

Users may voluntarily communicate information that could qualify as consumer health data or sensitive data under state law. Stay Connected Plus is not a healthcare provider and the Services are not intended for medical diagnosis or treatment.

Where applicable law grants rights concerning consumer health or sensitive data, requests may be submitted to privacy@myscplus.com. We will not sell consumer health data without any authorisation required by applicable law.

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17. Automated Processing and Profiling

We use automated systems, including Stacy, to generate content, recommendations, summaries, risk indicators, moderation signals, and personalised experiences. These systems may analyse communications, profiles, activity, and other permitted data.

We do not intend to use automated processing to make decisions that produce legal or similarly significant effects without human involvement, except as permitted by law. Where applicable law provides rights relating to qualifying profiling, you may submit a request to privacy@myscplus.com.

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18. Marketing Communications

We may send service-related communications that are necessary for accounts, security, transactions, support, or legal notices.

Where permitted, we may also send promotional emails, texts, or other communications. You may unsubscribe from promotional emails through the message's unsubscribe mechanism or contact support@myscplus.com. Opting out of marketing does not stop necessary service communications.

Message and data rates may apply.

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19. Do Not Track

Some browsers offer "Do Not Track" signals. Because no uniform standard applies to all such signals, we do not currently respond to them except where required by law. We will process legally recognised opt-out preference signals when applicable.

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20. International Access

The Services are operated from the United States. If you access the Services from another country, personal information may be transferred to, processed in, and stored in the United States or other countries where service providers operate. Those countries may have different data-protection laws.

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21. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in law, technology, Services, or practices. We will post the updated policy and revise the "Last Updated" date.

If a change is material, we may provide additional notice. Changes apply prospectively from the effective date, unless law requires otherwise.

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22. Contact Us

Stay Connected Plus, LLC

P.O. Box 220

Venango, PA 16440

Privacy requests and questions: privacy@myscplus.com

General support: support@myscplus.com

Legal notices: legal@myscplus.com

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