Ontarget Systems, LLC (OTS)

Programmed SMS Privacy Policy

Last Updated: March 25, 2026

Effective Date: October 1, 2026

OTS Program: OTS serves lenders which finance construction projects. Its primary purpose is to

assess progress and facilitate disbursement of loan proceeds. The service provided includes

several onsite reviews for each project. The OTS SMS program compares each project against the

average times between site visits and messages the project’s representative whenever an onsite

review appears due.

Additionally, to improve efficiency, OTS queries projects in the vicinity of any project agreeing to an

onsite review with the intent of completing more than one review per trip.

OTS collects and controls all messaging data. The company determines the purpose for collecting

SMS data and how the data are processed.

SMS data collected by OTS are limited to the following:

Consent data:
   The Project Identification Number assigned by OTS.

   Mobile telephone number for messaging the project.

   Message response date and time.

   Opt-out date if applicable.

   Notes recording the fact that a message was sent.

   Appointment date.

   Acceptance or rejection of the suggested onsite review.

Consent information:

   The Project Identification Number assigned by OTS.

   The mobile telephone number for messaging the project.

   Opt-In Timestamp.

   Opt-In Method.

   Whether disclosure of potential costs was shown in the offer email.

   Links to Ontarget Systems Terms of Service and Privacy Policy.

   Confirmation of acceptance.

   Acceptance sender’s email address.

   Consent text.

   Opt-out date if applicable.

Collected data is used only for scheduling onsite reviews. Accepted appointments and requests for

“HELP” are transferred to office staff for review and further coordination as necessary. Collected

data is retained in OTS encrypted files and is never sold to anyone. Data is not shared outside

Ontarget Systems except with Twilio, our communications provider. Twilio provides secure

transmission and storage as part of their platform.

Twilio acts as a service provider on behalf of Ontarget Systems and processes data only to deliver

SMS services. Twilio may store or transmit data in accordance with their Binding Corporate Rules

and Data Protection Addendum.

SMS data is retained for one year after opt-out or project completion and includes the items listed

above. Projects may request deletion of the data after opt-out if the request is made in writing,

signed by the project’s SMS recipient, and mailed to Ontarget Systems at the address below.

Each project has the right to withdraw consent at any time by replying to Ontarget Systems SMS

with the word “STOP”. Similarly, projects requiring assistance with SMS may reply to any Ontarget

Systems SMS with the word “HELP”. Projects also may withdraw consent or request assistance by

email to construction@ontargetsys.com or by telephone to (207) 623-9240.

Ontarget Systems, LLC

133 Neck Road, Suite 1

West Gardiner, ME 04345

Telephone: 207-623-9240

Email: construction@ontargetsys.com

Consent Capture:

OTS uses two primary methods of soliciting consent to send programmed SMS (short

message service) (also known as text messages) to recipients: email and voice (telephone).

Recipients must use explicit language to accept OTS SMS.

OTS records the date and time of the recipient’s response, the source (email or voice), the

email address of the respondent, the specific response and the telephone number to be used for

SMS.

The first SMS sent to each respondent is confirmation of acceptance. If the recipient has

elected to forego OTS SMS, an acknowledgement of the opt out action is emailed. Similarly, a HELP

response is acknowledged by email.

Data Usage:

Collected Data:

Messages are sent based on the average time between OSRs. Generally, the project will

receive no more than five messages per month

Routine messaging also may result in opt-out action. Any message containing “STOP”

immediately generates programmed blocks to future messaging. The opt-out message is

acknowledged by SMS.

Routine messaging may generate a “HELP” response. Such requests are acknowledged by

SMS and followed up by telephone contact.

Privacy Policy and Terms of Service:

Emails offering OTS SMS services include links to our Privacy Policy and Terms of Service.

Collected data through programmed SMS including the consent process are used entirely

within OTS for the purpose of scheduling OSRs. Data are not distributed or sold for any reason.

Data Retention and Security:

Data are retained for 12 months after opt-out or project completion, whichever comes first.

Retained data are stored in an encrypted database.

User Rights:

Recipients of OTS SMS may request to view and/or change the limited SMS data on file.

Recipients also may request deletion of their data from SMS files at opt-out.

Email: construction@ontargetsys.com or call us at 207-623-9420.