Introduction
Gold Manager Pro is developed and operated by Fonsek Companies LLC, a Michigan limited liability company ("we," "us," or "the Company"). This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you use our inventory management application ("the Application") for precious metals businesses.
Summary: We collect only the information necessary to provide our gold and jewelry inventory management services. We do not sell or share your personal data with third parties for advertising purposes.
Biometric & Face Data
Gold Manager Pro offers optional biometric authentication (Face ID, Touch ID, and fingerprint unlock) as a convenience feature to secure access to the app. This section explains in detail how we handle biometric and face data:
Face data is NOT collected, stored, or retained by Gold Manager Pro.
How Biometric Authentication Works:
- When you enable Face ID, Touch ID, or fingerprint unlock in Gold Manager Pro, the app uses your device's built-in biometric authentication system (Apple's LocalAuthentication framework on iOS).
- The biometric authentication process occurs entirely on your device. Gold Manager Pro only receives a success or failure response from the operating system — we never receive, access, process, or store any biometric data, face geometry, facial feature maps, or fingerprint data.
- Your face data and fingerprint data are stored exclusively in the device's Secure Enclave, which is managed by Apple's operating system.
Face Data Retention:
- Gold Manager Pro does not retain any face data at any time. We have no ability to access, extract, or store face data from your device.
- No face data is transmitted to our servers, stored in our databases, or included in any backups.
- Since we do not collect face data, there is no retention period — zero face data is stored by our application.
Third-Party Sharing of Face Data:
- Gold Manager Pro does not share face data with any third parties. Since we do not collect or have access to face data, there is no face data to share.
- None of our third-party service providers (Firebase, RevenueCat, or any other) receive, process, or store any biometric or face data from our application.
Purpose of Biometric Features:
- The sole purpose of biometric authentication in Gold Manager Pro is to provide a secure and convenient way for users to unlock and access the app, protecting sensitive business and transaction data.
- Biometric authentication is entirely optional and can be enabled or disabled at any time in the app's Settings.
In summary: Gold Manager Pro uses your device's native biometric system (Face ID / Touch ID) only to verify your identity locally on your device. We never collect, store, retain, transmit, or share any face data, facial geometry, or fingerprint data. All biometric processing is handled by Apple's operating system within your device's Secure Enclave.
Police Reporting & Law Enforcement Data Sharing
Gold Manager Pro offers optional police reporting features that, when enabled by the store owner, automatically transmit transaction data to law enforcement agencies. This section explains how data is shared through these services:
Important: Police reporting features are entirely optional and must be explicitly enabled and configured by the store owner in Settings. No data is shared with law enforcement unless the store owner activates these features.
RISSProp Integration:
- RISSProp is a law enforcement property reporting platform operated by the Regional Information Sharing Systems (RISS), a program funded by the U.S. Department of Justice.
- When enabled, transaction data — including customer name, date of birth, address, identification details, physical description, item descriptions, and transaction photos (item, ID, and customer photos) — is formatted into an XML report and uploaded to RISSProp's servers.
- Data is transmitted to and stored on Microsoft Azure Government Cloud infrastructure (
.usgovcloudapi.net), which meets U.S. government security and compliance standards (FedRAMP High, CJIS, IRS 1075).
- Once submitted, the data is accessible to authorized law enforcement personnel through the RISSProp platform. Gold Manager Pro has no control over how law enforcement agencies use, retain, or share this data after submission.
- The store owner is responsible for obtaining any required customer consent and complying with local, state, and federal regulations regarding the reporting of secondhand goods transactions to law enforcement.
Email Reports:
- When enabled, transaction reports may be sent via email (as CSV attachments) to configured recipients, which may include local law enforcement agencies (e.g., sheriff departments).
- Email reports contain transaction details including customer information, item descriptions, and transaction metadata.
- Email reports do not include transaction photos as attachments.
LeadsOnline Integration:
- LeadsOnline is a law enforcement property reporting service operated by LeadsOnline LLC.
- When enabled, transaction data — including customer name, date of birth, address, identification details, item descriptions, transaction amounts, and photos (customer photo, ID photo, and item photos encoded as Base64) — is formatted into a SOAP XML request and transmitted to LeadsOnline's servers via their web service API (hosted at w3api.leadsonline.com).
- For interoperability with law enforcement systems, certain item values may be standardized or normalized before transmission (for example, language normalization and measurement format normalization such as
pulgadas → in).
- Photos included in submissions are configurable by the store owner (customer photo, ID photo, item photo) and are downloaded from Firebase Cloud Storage, converted to Base64 format, and embedded directly in the SOAP request sent to LeadsOnline.
- Once submitted, the data is accessible to authorized law enforcement personnel through the LeadsOnline platform. Gold Manager Pro has no control over how law enforcement agencies use, retain, or share this data after submission.
- Your LeadsOnline API credentials (Store ID, username, password) are stored in your Firebase account configuration and transmitted to LeadsOnline's API during each submission. Gold Manager Pro does not share these credentials with any other party.
- Automatic "No Transaction Day" reporting (optional): If you enable this feature, our servers run a scheduled background process that, once per day at the time and timezone you configure, transmits a "No Transaction Day" notice to LeadsOnline for days on which your store recorded no buy transactions. This automated transmission contains only your Store ID, API credentials, and the calendar date — no customer or transaction personal data is included. This feature is disabled by default and can be turned off at any time per store.
Your Control: Store owners can enable or disable each police reporting channel independently at any time in Settings → Police Reports. Individual options allow control over which photos (item, ID, customer) are included in reports.
Shipping & Insurance Data Sharing
Gold Manager Pro offers an optional shipping feature that must be enabled and configured by the store owner in Settings using the store's own Jewelers Mutual / iShipJM credentials. When you use this feature to quote, purchase, or track a shipment:
- The recipient's name, shipping address, phone number, and (if provided) email address, along with the declared value, package weight and dimensions, are transmitted to Jewelers Mutual Group / iShipJM (operated on the TransGuardian platform) and to the selected carrier (USPS, UPS, or FedEx).
- This information is used solely to validate addresses, generate shipping labels, calculate postage, provide package insurance, send optional shipment notification emails to the recipient, and enable tracking and insurance claims.
- Each store uses its own carrier and insurance account; Gold Manager Pro transmits this data on the store's behalf and does not use it for any other purpose.
- Once transmitted, the data is handled according to the privacy practices of Jewelers Mutual / iShipJM and the selected carrier. Gold Manager Pro has no control over how those parties use, retain, or share the data after transmission.
Your Control: The shipping feature is entirely optional. No recipient data is transmitted to any carrier or insurer unless the store owner enables shipping and actively creates a shipment.
SMS and Mobile Data Privacy
This section describes how Fonsek Companies LLC ("we," "us," or "the Company") collects, uses, and protects mobile phone numbers and related consent information in connection with the text messaging (SMS/MMS) features offered through Gold Manager Pro. It applies both to our direct subscribers (jewelry and precious metals businesses) and to the end customers of those businesses whose contact information may be processed through the Application (a "business-to-business-to-consumer" or B2B2C model).
No Mobile Information Will Be Shared or Sold to Third Parties for Marketing. Mobile phone numbers and SMS consent (opt-in) information will NOT be shared, sold, rented, leased, traded, assigned, or otherwise transferred to any third parties or affiliates for their own marketing or promotional purposes under any circumstances. This category of data is expressly excluded from any sale, transfer, or sharing of information described elsewhere in this Privacy Policy.
Information We Collect for SMS:
- Mobile phone numbers provided by a business or its end customers for the purpose of receiving text messages.
- Records of opt-in consent, including the date, time, method, consent type (transactional and/or promotional), and the store associate who recorded it.
- Message delivery metadata (such as delivery status) necessary to operate the service.
- Opt-out (STOP) and help (HELP) requests, in order to honor and document them.
How Consent Is Collected (Opt-in Flow):
Consent is collected in-store, at the point of sale, through the Gold Manager Pro application running on the business's own device (tablet or smartphone). During the customer registration or purchase process, the store associate asks the customer for their SMS preferences and records the customer's verbal consent by checking the corresponding box(es). Transactional and promotional consent are collected separately and independently, each with its own disclosure text:
Transactional (order updates): "Client consents to receive transactional order updates via SMS. Msg freq varies. Msg & data rates may apply. Reply STOP to cancel."
Promotional (marketing): "Client consents to receive promotional & marketing SMS offers. Msg freq varies. Msg & data rates may apply. Reply STOP to cancel."
- The two consent checkboxes are independent: a customer may opt in to transactional messages only, promotional messages only, both, or neither. Consent to one category is never bundled with, or required for, the other.
- Both checkboxes are always presented unchecked by default. A box is only checked to reflect the specific consent the customer has expressly given. No pre-checked boxes or implied consent mechanisms are used.
- Numbers collected for transactional order updates only (for example, repair or workshop status alerts) are never added to the promotional/marketing audience.
- Each opt-in event is recorded with a timestamp, the customer's phone number, the store location, the consent type(s) selected, and the identity of the store associate who recorded it, creating an auditable consent log that can be exported at any time by the store owner.
- Consent to receive text messages is not a condition of purchasing any goods or services.
How We Use Mobile Information:
- To deliver the text messages you or your business have consented to receive, including jewelry order status alerts, review requests, and occasional promotional offers.
- To process opt-out and help requests and to maintain a record of consent for legal and compliance purposes.
- To operate, secure, troubleshoot, and improve the messaging functionality of the Application.
How We Protect Mobile Information:
- Mobile phone numbers and consent records are stored securely using industry-standard safeguards and access controls, and are used solely for the operational delivery of the messaging service.
- We use trusted messaging infrastructure providers (such as Twilio, our SMS gateway, and mobile carriers) strictly as service providers to transmit messages on our behalf. These providers are contractually limited to processing the data only as needed to deliver the messages and are not permitted to use mobile information for their own marketing purposes.
- End customer data processed in this B2B2C model is held only for the operability of the software and the legitimate business purposes of the originating business.
Your Choices:
- You may opt out of receiving text messages at any time by replying STOP to any message. You may reply HELP for assistance.
- Because messages are delivered through a shared Gold Manager Pro sender, replying STOP unsubscribes you from SMS messages from all participating Gold Manager Pro stores associated with your number.
- Opting out of SMS will not affect your ability to use the core features of the Application, although you may no longer receive text-based alerts or notifications.
Business (Jewelry Store) Responsibility: Where a jewelry or precious metals business uses Gold Manager Pro to message its own end customers, that business acts as the data controller and responsible sender for those communications. The business is solely responsible for obtaining and documenting valid opt-in consent from its end customers and for complying with all applicable laws (including the TCPA and CTIA guidelines). Fonsek Companies LLC and Gold Manager Pro process such mobile information only as a service provider, strictly to operate the messaging functionality on the business's behalf, and never for our own marketing purposes.
For questions about SMS data practices, contact us at support@goldmanagerpro.com.
Third-Party Services
We use the following third-party services:
- Google Firebase: Cloud storage, authentication, and analytics
- RevenueCat: Subscription and payment processing
- Apple App Store / Google Play Store: App distribution and payments
- Twilio: Cloud communications platform operated by Twilio Inc. When SMS features are enabled, Twilio is used solely as a service provider to transmit text messages (SMS/MMS) on our behalf to the recipients who have opted in. Twilio processes mobile phone numbers and message content only as needed to deliver the messages and is not permitted to use this information for its own marketing purposes.
- Third-party price APIs: Gold and precious metal price data (reference only)
- RISSProp (RISS): Law enforcement property reporting platform operated by the Regional Information Sharing Systems program, funded by the U.S. Department of Justice. Data is hosted on Microsoft Azure Government Cloud. Used only when police reporting is enabled by the store owner.
- LeadsOnline: Law enforcement property reporting service operated by LeadsOnline LLC. When enabled by the store owner, transaction data and photos are transmitted to LeadsOnline's servers via SOAP API for law enforcement access.
- Jewelers Mutual / iShipJM (TransGuardian): Insured shipping platform. When the store owner enables the optional shipping feature, recipient information (name, address, phone, email), declared value, and package details are transmitted to iShipJM and the selected carrier (USPS, UPS, or FedEx) to validate addresses, generate labels, provide insurance, and enable tracking and claims.
Each of these services has its own privacy policy. We encourage you to review their policies.
Your Rights
Depending on your location, you may have the right to:
- Access: Request a copy of your personal data.
- Rectification: Correct inaccurate information.
- Deletion: Request deletion of your account and data.
- Portability: Export your data in a readable format.
- Withdraw Consent: Revoke permissions granted at any time.
- Opt-Out: Opt out of certain data processing activities.
To exercise these rights, contact us at: support@goldmanagerpro.com
Data Retention
We retain your data while your account is active. If you request account deletion:
- Your data will be permanently deleted within 30 days
- Some data may be retained for legal or tax obligations
- Backups are deleted in regular cycles
- Aggregated, anonymized data may be retained for analytics
- Law Enforcement Data: Data previously submitted to law enforcement reporting platforms (RISSProp, LeadsOnline, or via email) cannot be deleted by Gold Manager Pro, as it is under the control of the respective law enforcement agencies. Contact the relevant agency directly regarding retention or deletion of that data.
Cookies and Similar Technologies
The mobile application does not use traditional cookies. However, we use:
- Firebase Analytics: To understand application usage (can be disabled in settings).
- Local Storage: To keep your session active on the device.
- Device Identifiers: For subscription management and fraud prevention.
Children's Privacy
Gold Manager Pro is designed for users 18 years of age and older. We do not knowingly collect information from minors. If you believe we have inadvertently collected information from a minor, please contact us immediately.
International Data Transfers
Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have different data protection laws. By using the Application, you consent to such transfers.
California Privacy Rights (CCPA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act:
- Right to know what personal information is collected
- Right to know whether your data is sold or disclosed
- Right to say no to the sale of personal information (we do not sell your data)
- Right to equal service and price
Governing Law
Michigan Law Applies: This Privacy Policy is governed by and construed in accordance with the laws of the State of Michigan, United States. Any disputes arising under this policy shall be resolved in the courts located in Holland, Michigan, Ottawa County.
Changes to This Policy
We may update this policy periodically. We will notify you of significant changes through the application or by email. Your continued use of the application after changes constitutes acceptance of the updated policy.
Data Security Limitations
While we implement reasonable security measures to protect your data, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information.
Contact Information
If you have questions about this Privacy Policy, contact us: