Privacy Policy

​Privacy Policy

Effective Date: April 6, 2026

Essential Marketing Systems, Inc. (“EMS,” “we,” “us,” or “our”) owns and operates the following websites and related software and services that link to this Privacy Policy (collectively, the “Services”): BestLocalReviews.com, FiveStarReviewSystem.com, RoundPixelLabs.com, FSREVS.com, and any associated platforms.

This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you visit or use our Services. It applies to users in both the United States and Canada.

1. Scope

This Privacy Policy applies to personal information collected through our Services and through communications relating to our Services.

This Privacy Policy does not apply to:
• Websites, platforms, or services operated by third parties that we do not own or control;
• Third-party review sites, social media platforms, payment providers, phone carriers, or other external services you may access through links or integrations;
• Privacy practices of subscriber businesses using our Services, except to the extent EMS directly controls the relevant processing.

If you interact with a subscriber business through our Services, that business may also have its own privacy policy that applies to its handling of your information.

2. Our Role

EMS provides a customer engagement and review platform used by subscriber businesses (such as professional service providers, including healthcare providers) to communicate with and collect voluntary feedback from their customers and leads.

In many cases, EMS processes personal information on behalf of a subscriber business and acts as a service provider or processor. Subscriber businesses are responsible for determining the content of their campaigns, contacts, and communications, and for their own compliance with applicable laws (including consent and opt-out rules for email and text messaging).

Subscribers are solely responsible for ensuring they have all necessary legal rights, permissions, notices, and consents (or other valid legal basis) to provide customer or lead contact information to EMS and to instruct us to send communications, including emails and SMS/text messages, on their behalf. Subscribers must comply with all applicable laws regarding the collection, use, and disclosure of such contact data.

HIPAA and Healthcare-Related Information
EMS does not collect, process, or store Protected Health Information (PHI) as defined by HIPAA. We do not integrate with or access electronic health record (EHR) systems, patient charts, or other regulated healthcare databases. Our Services are a general customer engagement and review platform, and EMS does not act as a Business Associate or sign Business Associate Agreements.

Individuals may voluntarily submit reviews, feedback, or comments about subscriber businesses, including healthcare providers, through our platform. EMS processes that content solely to provide the Services and as directed by the subscriber business. Any responsibility for compliance with HIPAA or other applicable healthcare privacy laws remains with the subscriber business.

3. Personal Information We Collect

We collect personal information that is reasonably necessary to operate our Services and related business functions.

A. Information we collect from subscribers, affiliates, partners, resellers, and account users.

This may include:
• Name;
• Business name;
• Business address;
• Business email address;
• Business telephone number;
• Mobile phone number;
• Account username and password;
• Billing and payment-related information;
• Website URLs and review site preferences;
• Company logo, photographs, profile images, and branding materials;
• Names, job titles, email addresses, phone numbers, and photographs of system managers, employees, or other designated users;
• Content submitted into the platform, such as questions, answers, messages, redirects, coupons, fliers, settings, links, and other campaign or workflow content;
• Referral, reseller, affiliate, or commission-related information;
• Any other information voluntarily provided to us in connection with the Services.

B. Information we collect from reviewers, customers, leads, and other end users interacting with the Services.

Depending on how the Services are configured by a subscriber, this may include:
• Name and contact information you choose to provide, including email address and phone number;
• Star ratings;
• Review, testimonial, survey, feedback, or comment content;
• Photographs or images you choose to provide;
• Information about links clicked or review sites selected through the flow;
• Responses to forms, questions, or prompts presented through the Services;
• Messaging interaction data, such as whether an email or text message was sent, delivered, opened, clicked, replied to, bounced, unsubscribed from, or otherwise interacted with;
• Any other information you voluntarily submit.

C. Information collected automatically.

When you use the Services, we may automatically collect certain technical and usage information, such as:
• IP address;
• Browser type;
• Device type;
• Operating system;
• Referring pages or URLs;
• Pages viewed;
• Date and time of access;
• Approximate location derived from IP address;
• Login, system, and activity logs;
• Performance, security, diagnostic, and troubleshooting information;
• Cookie, session, and similar tracking information.

D. Customer contact information provided by subscribers.

Subscribers may also provide us with contact information for their own customers or leads (including names, email addresses, and phone numbers) so that we can facilitate review requests, feedback campaigns, or other communications on the subscriber’s behalf. We collect, store, and process this information solely as a service provider to the subscriber business and in accordance with their instructions and this Privacy Policy.

4. Sources of Personal Information

We collect personal information from the following categories of sources:
• Directly from you;
• From the subscriber business that uses our Services;
• From customer, reviewer, or lead submissions made through the Services;
• Automatically from your browser, device, and interactions with the Services;
• From payment, referral, reseller, affiliate, or support-related interactions;
• From third parties when needed to operate the Services, such as hosting, analytics, communications, payment, or support providers.

5. How We Use Personal Information

We may use personal information for the following purposes:
• To create, administer, and maintain accounts;
• To provide, operate, configure, and support the Services;
• To enable subscriber businesses to engage with their customers through reviews, testimonials, surveys, feedback requests, redirects, email messages, text messages, and related workflows;
• To send or facilitate emails, SMS or text messages, notifications, reminders, follow-ups, and other communications requested or configured by a subscriber business;
• To present content, messages, links, forms, and branding configured by a subscriber business;
• To make reviewer, customer, or lead submissions available to the relevant subscriber business;
• To process transactions, billing, commissions, referral credits, or related business records;
• To communicate with you about your account, the Services, technical notices, updates, support matters, and administrative issues;
• To respond to inquiries, complaints, requests, or disputes;
• To monitor usage, analyze performance, troubleshoot problems, improve the Services, and develop new features;
• To monitor deliverability, performance, and engagement relating to email and SMS campaigns;
• To protect the security, integrity, and availability of the Services;
• To detect, investigate, prevent, or address fraud, abuse, unauthorized access, or other unlawful or harmful activity;
• To comply with legal obligations and enforce our agreements;
• To send marketing or promotional communications where permitted by law and subject to applicable opt-out rights.

We do not sell or rent personal information to anyone.

6. Email and SMS Communications

Our Services may be used to send email and SMS/text message communications. These may be sent by EMS about our own Services or on behalf of a subscriber business.

In connection with those communications, we or our service providers may collect and process information such as email address or phone number, message content, delivery status, open/click/reply/bounce information, unsubscribe/opt-out status, timestamps, and device/browser information.

You may opt out of promotional email communications by using the unsubscribe link in the email or by contacting us. You may opt out of SMS/text message marketing by following instructions in the message (e.g., replying STOP) or by contacting the sender or EMS.

Service-related, transactional, security, or account communications may still be sent even after opting out of promotional messages, where permitted by law.

7. How We Disclose Personal Information

We do not sell or rent personal information. We may disclose personal information to the following categories of recipients when reasonably necessary:

A. Subscriber businesses

Information you submit as a reviewer, customer, or lead may be made available to the relevant subscriber business.

B. Service providers and contractors

We may share information with vendors that help operate the Services, such as cloud hosting, database, email/SMS delivery, analytics, payment processing, security, and support providers. These parties may use the information only as needed to provide services to us, subject to appropriate restrictions.

C. Affiliates, partners, resellers, and referral relationships

Limited information may be disclosed as needed to administer reseller, referral, partner, or affiliate relationships (e.g., for commission or attribution purposes).

D. Legal, compliance, and protection purposes

We may preserve, use, or disclose personal information when we believe in good faith that it is reasonably necessary to:
• comply with applicable law, regulation, legal process (including subpoenas, court orders, or preservation obligations), or other lawful requests;
• respond to or defend against legal claims, disputes, or government inquiries;
• enforce our agreements or protect our rights, property, or interests;
• detect, investigate, prevent, or address fraud, abuse, security incidents, unauthorized access, or other unlawful or harmful activity;
• protect the safety of EMS, our users, subscriber businesses, or others.

E. Business transfers

In the event of a merger, acquisition, financing, asset sale, or similar transaction, personal information may be disclosed or transferred subject to confidentiality and legal requirements.

8. Cookies and Similar Technologies

We may use cookies, pixels, and similar technologies to operate and secure the Services, maintain logins, remember preferences, understand interactions, measure performance, and improve user experience.

You can adjust your browser or device settings to limit or block certain cookies, though this may affect functionality.

9. Third-Party Links and Platforms

The Services may contain links to third-party sites or platforms. We are not responsible for their privacy practices. Please review their policies before providing information.

10. Cross-Border Processing

EMS is based in the United States. Personal information may be processed, stored, or accessed in the United States or other jurisdictions where we or our service providers operate.

For users in Canada: Your personal information may be transferred outside Canada (including to the United States) for processing and storage. It may be subject to access by courts, law enforcement, or authorities under applicable U.S. or other laws.

11. PIPEDA and Canadian Privacy Compliance (for Users in Canada)

EMS complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) and its 10 fair information principles where applicable to our commercial activities involving Canadian personal information. These principles include accountability, identifying purposes, consent, limiting collection/use/disclosure/retention, accuracy, safeguards, openness, individual access, and challenging compliance.

Privacy Officer: Susan Sommers is our designated Privacy Officer. Contact information is provided in Section 19 below.

12. Retention of Personal Information

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to meet our legal, operational, security, dispute-resolution, backup, recordkeeping, and legitimate business needs, unless a longer period is required or permitted by law.

For example:
• Certain public-facing content, such as testimonials and reviews published on BestLocalReviews.com, may be retained indefinitely as part of the Services. Once published, such content may remain publicly visible, be copied or indexed by search engines or third parties, or appear in caches, and may not be fully retractable even if deleted from our active systems.
• Subscriber account information is generally retained while the account is active and thereafter as needed for billing, tax, legal, contractual, audit, fraud-prevention, backup, security, and legitimate business recordkeeping purposes.
• Campaign, workflow, messaging, and engagement records are retained as needed to provide the Services, support subscriber businesses, maintain system integrity, troubleshoot issues, document opt-outs, and enforce agreements.
• Reviewer, customer, or lead submissions (including contact information provided by subscribers) are retained as directed by the subscriber business and as needed for the Services, support, legal, compliance, and system administration purposes.
• Technical logs and backup copies may be retained even after related information is removed from active systems.

We may delete, aggregate, or de-identify information when we no longer need it in identifiable form. Residual copies may remain in backups or archives for a limited period. Deletion is not always immediate or complete due to legal, contractual, technical, security, fraud-prevention, or operational limitations.

Deletion requests are handled in accordance with Section 13 and are subject to the limitations described there.

We may also preserve information beyond normal retention periods when reasonably necessary for the legal, compliance, or protection purposes described in Section 7.

13. Your Choices and Rights

Depending on your location and relationship with EMS, you may request access to, correction of, or deletion of your personal information (subject to legal, contractual, technical, security, fraud-prevention, backup/archive, and operational limitations).

Deletion is not always immediate or complete. Some information may remain in our logs, backup systems, disaster-recovery archives, or other secure storage for a limited period due to legal, security, fraud-prevention, or system integrity needs. Residual copies may persist even after we delete the active record.

If we process your information on behalf of a subscriber business, we may refer your request to that business where appropriate.

To submit a privacy request, question, or complaint, contact us using the details below. We may verify your identity before processing requests and will explain any limitations if we cannot fulfill a request in full.

14. Accuracy

We take reasonable steps to keep personal information accurate and up to date for its intended purposes. You are responsible for providing accurate information and notifying us of changes.

15. Security

We use commercially reasonable administrative, technical, and physical safeguards to protect personal information. These include restricted access, encryption in transit where appropriate, and secure hosting.

No internet transmission or storage method is completely secure, so we cannot guarantee absolute security.

In the event of a breach, we follow the notification procedures described in Section 16.

16. Data Breach Notification

We will notify affected individuals and regulators of a security breach involving personal information where required by applicable law (including PIPEDA obligations for breaches posing a real risk of significant harm).

We also maintain records of all breaches of security safeguards as required under PIPEDA, regardless of risk level.

17. Children’s Privacy

Our Services are intended for business and general adult customer engagement purposes and are not directed to children under 13. We do not knowingly collect personal information directly from children under 13. If you believe we have received such information, please contact us.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes to how we collect, use, or disclose personal information in a way that is inconsistent with the terms in effect when the data was collected, we will provide appropriate notice where required by law or as we deem reasonably necessary (for example, by posting a prominent notice on the Services or contacting affected users where feasible).

The revised version will include an updated Effective Date. Your continued use of the Services after a revised Privacy Policy becomes effective constitutes your acceptance of the updated policy, to the extent permitted by law.

19. Contact Information

If you have questions, requests, or complaints about this Privacy Policy or our practices, please contact:

Essential Marketing Systems, Inc.
Attn: Susan Sommers, Privacy Officer
821 Kumulani Drive
Kihei, HI 96753
Email: [email protected]

Canadian users may contact the Privacy Officer at the above details regarding PIPEDA-related matters.