01Who we are and what this covers
Indigo Systems and Technology Consulting Inc. operates Anthrogate (the "Service"). This Privacy Policy explains how we handle information when an organization requests a mobile-network verification about you and when you contact us directly.
The Service is a verification intermediary. Depending on the enabled feature, it checks a phone-number association, obtains a SIM-change signal, or compares information supplied for a subscriber match. It does not provide a personal-data repository, consumer profile, or verification-history account.
The bank, fintech, or other organization requesting a check is the Initiating Organization. When we act on its documented instructions, we act as its processor or service provider where those legal concepts apply. The Initiating Organization determines the check's purpose and its own use of the result. We are responsible for processing we determine ourselves, such as responding to a privacy request. Actual responsibilities follow applicable law and the facts, not a contractual label alone.
This Policy covers our handling of information, including service providers acting on our behalf. It does not replace the Initiating Organization's notice or an independently acting mobile operator's notice. Their roles and the recipients used for the Service are described in Section 7.
02Our verification-data commitment
We use verification information only to authorize, carry out, secure, and return the requested check. We do not persistently retain verification inputs, subscriber attributes, network or session identifiers, or verification results in our systems or in systems operated on our behalf.
This commitment applies whether the information comes from a private source or a public source. It also covers copies, hashes, tokens, and derived values that remain linked or reasonably linkable to an individual. A match result is not treated as anonymous merely because it contains only a yes/no answer.
No persistent retention does not mean no processing. Information must be received, transmitted, compared, or used temporarily to perform a check. The commitment concerns verification information after that active processing, not the public text of this website, our software, organization-level service configuration, or the limited administrative records expressly described below.
Independent recipients may retain their own records. A binding legal obligation may also require a narrow exception. Those limits are stated in Sections 6, 7, and 14; they are not a general permission to build a verification database.
03Information used for a check
Only the categories needed for the feature requested are used. The Initiating Organization identifies the enabled check and the information involved before the request. We do not silently add other checks.
| Category | Examples, source, and use |
|---|---|
| Phone information | A mobile number or an authorized representation of it, supplied by you, the Initiating Organization, or an authorized network flow. Used to identify the number being checked. |
| Subscriber-match attributes | Only the supported attributes submitted for an enabled match, such as name, date of birth, or address. Supplied by you or the Initiating Organization and compared with an operator's records. |
| Network and request context | Network address, necessary device or browser request metadata, short-lived authorization tokens, and transaction/session identifiers provided by the connection or authorized provider. Used to route, authorize, protect, and complete the check. |
| Verification results | A match, non-match, unavailable result, supported match score, or SIM-change status or timestamp. Returned by the authorized provider and passed to the Initiating Organization for the requested purpose. |
We do not use these checks to request bank passwords, payment-card security codes, banking PINs, messages, contact lists, call recordings, photographs, or precise device location. Do not send those items to this Service. Subscriber matching is a comparison, not permission to retrieve or disclose a full carrier subscriber record.
04Purpose, authorization, and consent
Verification information is used only for the check presented to you, including authorization and request security necessary to perform it. We do not use it for advertising, data brokerage, cross-service profiling, unrelated analytics, model training, or product-training datasets.
"Silent" describes a verification method without an entered SMS code. It does not mean verification without a required notice, permission, or lawful basis. Where consent is required, it must be obtained through the applicable consent flow before the relevant processing. Reading this Policy or accepting commercial terms is not, by itself, consent to every check.
For customer-directed processing, the Initiating Organization identifies and is responsible for its applicable lawful basis; we process within lawful, documented instructions. The applicable verification purposes and lawful bases are: phone-number association verification, SIM-change risk checks, and subscriber-attribute matching to support the specific account-access, recovery, fraud-prevention, or customer-verification purpose explained in the request. The default offering uses informed, specific End User consent for the requested verification, together with any separate authorization required by the mobile operator or API provider. Where the EU or UK GDPR applies, the selected default basis for that verification is consent under Article 6(1)(a). A non-consent route is not enabled under this default without a documented legal assessment, an appropriate lawful basis, and an updated request notice. A contract with a Business Customer is not treated as the End User's contract or as blanket consent. The party responsible for keeping required consent or authorization evidence is: the Initiating Organization keeps its End User notice, consent, and authorization evidence; the participating operator or authorization provider keeps the evidence required for its own authorization role. These responsibilities and retention periods must be documented in the applicable customer and provider agreements before activation. Anthrogate handles verification-linked authorization state only during the active flow. Anthrogate may keep evidence of a Business Customer's contractual acceptance as a business-administration record, without End User verification payloads. Any independent recordkeeping obligation that applies to Anthrogate must be resolved before enabling the affected flow; allocating a task to another party does not remove that obligation.
For our own administrative processing, we use information to respond to your communication or rights request, administer a business relationship, or meet a specific legal obligation. Where an applicable law requires a lawful basis, the bases and relevant legitimate interests for these activities are: compliance with an applicable legal obligation for legally required rights-request handling and records; and, where justified after considering individuals' rights, legitimate interests in answering inquiries, administering business relationships, protecting administrative channels, and resolving complaints. Where the EU or UK GDPR applies, these correspond respectively to Articles 6(1)(c) and 6(1)(f). Article 6(1)(b) is used only where processing is necessary for a contract with the individual concerned or steps requested by that individual before that contract. We do not assume that an employee contact is personally party to their employer's contract. These administrative bases do not authorize unrelated use or retention of verification information.
You can decline a consent-based check or withdraw consent through the applicable provider or Initiating Organization. Withdrawal applies prospectively and does not undo lawful processing already completed. A requested check may then be unavailable; any alternative authentication method is determined by the Initiating Organization.
05Temporary processing and no persistent copies
Verification information is handled only for the active verification flow. Active processing ends on completion, failure, cancellation, or expiry, and in all cases within 10 minutes from Anthrogate's first receipt of the verification request, including any retries within that flow; retries do not restart this limit. At that point, the Service releases the information from its active processing context and does not keep a retrievable verification record.
Our no-retention configuration excludes verification information from databases, persistent caches, disk-backed queues, retry or dead-letter stores, backups, and storage snapshots. It also excludes it from application and access logs, CDN or firewall logs, analytics, error reports, distributed traces, session replay, and support-system attachments operated by us or on our behalf.
We do not retain raw or hashed phone numbers, user-linked transaction references, or results as a workaround for this commitment. Temporary authentication state is subject to the same processing lifetime. Releasing runtime memory is not a claim that every physical memory byte is instantly or forensically overwritten.
Our verification component does not intentionally write verification information to browser storage or persistent device storage. Separate customer applications and carrier interfaces have their own handling practices. The providers we use on our behalf must meet the applicable no-retention restrictions; we do not avoid this responsibility by calling their storage "third-party storage."
06Retention limits and administrative exceptions
The no-persistent-retention commitment applies to the verification flow. It is not a representation that an organization can operate without keeping any information of any kind.
| Record type | Retention rule |
|---|---|
| Verification inputs, routing context, and outputs | No routine persistent retention. Active processing only, within the maximum lifetime in Section 5. |
| Direct support correspondence | Contact details, message content, and necessary communication metadata voluntarily provided to resolve an inquiry. Retention: only while the inquiry is being handled and for no more than 90 days after it is closed, unless a specific binding legal duty requires a longer period. Remove unnecessary sensitive attachments sooner. |
| Privacy-rights and complaint records | Only the information necessary to authenticate and handle a request, document the response, and meet applicable accountability duties. Retention: a minimal record of the request, response and any appeal for 24 months after final resolution, unless a different period is specifically required by applicable law. Extra identity-verification evidence is removed within 30 days after final resolution unless it must form part of a legally required record. These records do not include a reconstructed verification history. |
| Business-administration records | Business contact details, organization-level credentials and configuration, executed agreements, invoices, and required accounting records. Retention: executed agreements and necessary contractual-acceptance evidence for the relationship and up to 7 years after termination; invoices and required accounting records for up to 7 years after the relevant financial year ends, subject to a different binding legal period. Revoke organization credentials on termination and remove obsolete credential material within 30 days. Delete nonessential business-contact and configuration records within 90 days after they are no longer needed for the relationship. These rules do not permit keeping End User verification information. End-user verification payloads and results are excluded. |
| Specifically required legal records | Only the information and period required by a binding law, preservation duty, or enforceable order, as described in Section 14. |
Administrative retention periods include copies in mail, ticketing, and backup systems acting on our behalf. Those systems are not used as a second verification-record store. Please do not include raw verification payloads, credentials, identity documents, or financial account information in a support request. If unnecessary sensitive information is received, we restrict access and arrange its removal, subject to applicable legal duties.
We do not keep a persistent end-user verification history and cannot reconstruct a completed check after its transient processing ends. A rights request does not require us to create a history that does not exist. It also does not excuse us from explaining processing or addressing administrative information we actually retain.
07Recipients and provider responsibilities
A check necessarily involves a limited disclosure. We send the minimum required information to the authorized mobile operator or API provider and return the result to the Initiating Organization. We do not describe this as "never sharing data." We do not sell verification information or disclose it for cross-context behavioral advertising.
Infrastructure providers acting on our behalf are subject to appropriate contractual restrictions, confidentiality requirements, and security obligations. Independent operators and Initiating Organizations may keep subscriber records, authorization evidence, fraud records, or legally required records under their own notices. Their independent processing is outside our no-retention undertaking, but does not remove any duties we owe for our own disclosure or provider selection.
| Recipient category | Identity, role, location, and retention |
|---|---|
| Initiating Organization | Identified in the request journey together with its privacy notice. Receives the check result and explains its own decision-making and retention. |
| Mobile operators and API providers | Vonage provides carrier verification and primary SMS delivery. Twilio is the planned fallback SMS provider if Vonage fails to deliver a code. The participating mobile operator depends on the user's carrier. Provider processing countries, retention periods, and privacy-notice links are not specified in this policy. |
| Our verification infrastructure | Infrastructure provider names, processing locations, and provider-specific configurations are not specified in this policy. |
| Administrative service providers | Administrative provider names, processing locations, and provider-specific privacy notices are not specified in this policy. |
Confidential professional advisers and competent authorities may receive limited administrative information where necessary for a lawful purpose or mandatory duty. We do not disclose verification information to unrelated parties for their independent commercial use.
08Website, cookies, and tracking
These legal pages contain no analytics, advertising pixels, session replay, third-party scripts, embedded media, or external fonts. They do not set cookies or use browser-storage APIs. The web server still receives connection and request information needed to deliver a page.
These public legal pages are hosted by Netlify. Hosting and network providers receive connection and request information needed to deliver the pages. Provider-specific access-log retention has not been verified for this deployment, so this policy does not represent that identifiable website access logs are disabled. The verification-flow retention commitment applies to verification information; it is not a statement about public website hosting logs. Public HTML pages may also be cached by your browser.
A carrier's authentication page or an Initiating Organization's application may use its own necessary session mechanisms or tracking technologies. Those parties must explain their own practices. This Policy does not consent to their optional tracking on your behalf.
09Security and incident response
We use encrypted transport, restricted access, scoped authorization, and data-minimizing request handling to protect information while it is processed. We limit personnel access to what is necessary for their role and require appropriate protections from service providers handling information for us.
No system or network can guarantee absolute security, and a no-retention architecture does not eliminate interception, compromised-device, configuration, or supply-chain risks. This limitation is not a waiver of our security obligations.
If a personal-data incident occurs, we investigate, contain it, and provide any notices or cooperation required by applicable law and contract. Investigation does not create a general exception permitting routine retention of verification payloads.
10What a result means
A number-verification result concerns the number associated with an authenticated network context. It does not independently identify the person holding the device or authorize a financial transaction. A SIM-change result does not, by itself, distinguish a legitimate replacement from fraud. A subscriber match compares selected information with a provider's records; those records may be incomplete, outdated, or associated with a family or business account.
We return verification signals, not lending, insurance, employment, payment, or account-access decisions. The Initiating Organization decides how to use a signal, supplies its own decision-making notice, and is responsible for applicable human-review and challenge mechanisms. Unavailable data must not be represented as a successful match.
11Your choices and privacy rights
Depending on applicable law, you may have rights to information about processing, access, correction, deletion, restriction, objection, portability, withdrawal of consent, and review or appeal of certain decisions. These rights depend on the circumstances and may have lawful exceptions.
Right to object: Where applicable law provides a right to object to processing based on legitimate interests, you may exercise it using the contact details below. We do not use verification information for direct marketing.
Contact info@indigoconsulting.com to exercise a right or ask about this Policy. We may request only information proportionate to verifying your authority and locating records we actually hold. Do not send an identity document unless a secure, necessary method has been arranged. We respond within the deadlines required by applicable law.
For a customer-directed verification, you may contact the Initiating Organization as well. We assist it as required and do not use that routing to avoid our own obligations. Corrections to a carrier's underlying subscriber records generally need to be made with that carrier.
You may use an authorized agent where permitted, request an explanation of a denial, and appeal where applicable law provides an appeal. You may complain to a competent data-protection authority or other regulator without first contacting us. We do not retaliate for a lawful exercise of privacy rights.
12Regional disclosures
European Economic Area and United Kingdom. Where the relevant data-protection law applies, Sections 3, 4, 6, 7, and 13 describe the information, purposes, lawful bases, recipients, retention, and international-transfer arrangements. Required representative or data-protection-officer details are: not specified in this policy.
California. Where the California Consumer Privacy Act applies, personal-information categories can include identifiers, customer-record information, and internet or network activity. Sources, purposes, recipients, and retention are described above. We do not sell verification information or share it for cross-context behavioral advertising. Applicable requests to know, correct, delete, limit qualifying sensitive-information uses, or opt out may be made through the contact methods in Section 17. We honor applicable opt-out preference signals for any processing to which they apply.
Required California disclosures covering the preceding 12 months, or the shorter period since launch, including administrative information and any materially different historical practices: not specified in this policy.
Other regional rights and mandatory disclosures applicable to the markets in which this Service is offered: deployment is limited to markets expressly authorized in the applicable customer agreement after the required legal and provider assessments. Any mandatory market-specific notice, consent language or request channel must be supplied before activation in that market. A signed order or this Policy cannot waive a person's mandatory local rights. This Policy does not claim certification or universal compliance with every jurisdiction's laws.
13Where processing occurs
Processing locations for the Service and its administrative records are: not specified in this policy. Cross-border routing to an operator or API provider may occur even when we do not retain a verification record.
Where applicable law restricts international transfers, we use the required lawful transfer arrangements. Applicable arrangements, relevant safeguards, and the method for obtaining a copy or further details are: not specified in this policy.
14Narrow legal exceptions
If a binding law, mandatory preservation duty, or enforceable order specifically requires us to retain or disclose information, that requirement can override routine handling. We limit the information, access, purpose, and retention period to what is legally required, assess the validity and scope of a demand where appropriate, and provide notice when legally permitted and required.
This exception does not authorize discretionary retention for unspecified future business needs, product improvement, or speculative law-enforcement requests. We do not recreate previously discarded verification records. Any information lawfully preserved is removed when the relevant duty and any applicable mandatory retention period end.
A material change to routine retention is addressed under Section 16 and must not continue to be marketed as the unchanged no-retention service.
15Children and unauthorized requests
The Service under these Terms is intended for adults and is not directed to people under 18 or the higher age of majority that applies to them. Initiating Organizations must not submit a minor's information under this offering.
If we learn that a request is unauthorized or involves a minor contrary to this Policy, we stop the affected processing where possible and address any retained administrative information as required by law. A statement in a contract does not replace appropriate safeguards in the actual request flow.
16Changes to this Policy
We publish an effective date and version for this Policy. We provide legally required notice of material changes before they take effect and obtain additional consent when required. A new policy does not retroactively authorize an incompatible use of information processed under an earlier notice.
Before introducing retained verification histories, new data categories, advertising uses, or a materially different purpose, we must reassess the service design, applicable legal basis, notices, and agreements. We will not silently reinterpret the no-retention commitment to permit those changes.
17Contact
Service: Anthrogate
Responsible legal entity: Indigo Systems and Technology Consulting Inc.
Business correspondence address: 127 E Main Street, Suite B, Barrington, IL 60010, United States
Privacy and rights requests: info@indigoconsulting.com
Additional required request method: Postal mail addressed to Anthrogate Privacy at the business correspondence address above.
Security reports: info@indigoconsulting.com
Contact records are handled under Section 6. The companion Terms and Conditions describe use of the Service and do not waive applicable privacy rights.
18SMS verification and consent
Anthrogate is a product of Indigo Systems and Technology Consulting Inc., also known as IndigoConsulting. The customer-facing SMS sender is Anthrogate. This SMS program authenticates users into Anthrogate. The business-customer provisions elsewhere in this document continue to describe organizational integrations where applicable.
Users provide their mobile number and see the following disclosure before selecting Continue or Sign in in the intended verification flow:
By continuing, you agree to receive SMS verification codes from Anthrogate at the mobile number you provided when you choose SMS or when carrier verification fails. Message frequency varies with your verification requests. Message and data rates may apply. See our Terms and Privacy Policy.
Users request an SMS by selecting SMS verification, or SMS is triggered automatically when carrier verification fails after consent has been given. Vonage attempts SMS delivery first. Twilio is the planned backup provider and sends a code only if Vonage fails to deliver the SMS. Users enter the code in Anthrogate to complete verification. Email verification is available as an alternative.
Messages contain one-time authentication codes. Message frequency varies with verification requests. Message and data rates may apply.
Pre-launch status: the public consent walkthrough illustrates the intended flow using demonstration data. This website does not collect mobile numbers or send codes. Twilio fallback and STOP/HELP handling remain pending configuration.
Planned keyword support: once configured for launch, reply STOP to opt out of SMS and HELP for assistance. During this pre-launch period, contact info@indigoconsulting.com for support or withdrawal requests. Carrier-verification withdrawal and SMS withdrawal are separate choices.
SMS information and use
During an SMS verification attempt, Anthrogate processes the mobile number, the authentication code and response, and the consent and delivery state needed to perform the requested verification. Email verification uses the email address and code provided for that attempt.
We do not sell or share your SMS opt-in data or personal information with third parties for marketing purposes. Mobile information and messaging consent are not shared with affiliates for marketing or promotional purposes. Operational disclosure to delivery providers is limited to what is needed for verification and message delivery.
Retention and provider responsibilities
Anthrogate deletes user verification information when the verification attempt completes or fails. Cancellation, expiry, and the maximum active-processing lifetime remain governed by Section 5. The separate administrative record categories and narrow legal exceptions in Sections 6 and 14 remain applicable; they do not create a routine verification history.
Vonage provides carrier verification and primary SMS delivery. Twilio is the planned fallback SMS provider. Their processing roles and applicable retention obligations must be documented before the fallback is activated. The distinction in Section 7 between providers acting on our behalf and independently acting recipients continues to apply. This policy does not claim that carriers or independently acting providers delete their records at the end of Anthrogate's verification attempt.
Carrier verification consent
Carrier verification uses the following separate authorization:
You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to Anthrogate or its service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud. See our Privacy Policy for how we treat your data.
For SMS or privacy assistance, contact info@indigoconsulting.com. See the SMS Terms.