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SMS Consent Policy

SMS TEXT MESSAGE AND NOTIFICATION CONSENT POLICY ROCCIBEL LLC

This Policy shall be governed by the Telephone Consumer Protection Act (TCPA, 47 U.S.C. § 227) and the Texas Data Privacy and Security Act (TDPSA), as well as Texas Business & Commerce Code Chapter 302 (as amended by Senate Bill 140, effective September 1, 2025), and other applicable federal and state regulations governing commercial electronic communications and personal data protection.

Effective Date: October 1, 2026

  1. IDENTIFICATION:

This Policy is issued by ROCCIBEL LLC (hereinafter ROCCIBEL), a U.S. company domiciled at 24285 Katy Freeway, Suite 300, Katy, TX 77494, United States, with inquiries email: support@zenttu.com. ROCCIBEL is a company whose main corporate purpose is the marketing and distribution of beauty products and services, including - without limitation - makeup, skincare items, cosmetics, and facial and body treatments, as well as any other aesthetic wellness product it may offer, through its e-commerce platform available at https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version).

ROCCIBEL acts as the Controller of the personal data collected through the SMS Program described in this Policy, in accordance with the Texas Data Privacy and Security Act (TDPSA). Technical management of the SMS Program is carried out by the Processor designated under the documented instructions of ROCCIBEL and pursuant to the contractual agreements currently in force between the parties.

This Policy supplements - and must be read together with - the Privacy and Personal Data Security Policy, the Privacy Notice, and the Website Terms and Conditions of Use of ROCCIBEL, without replacing them.

  1. PURPOSE

The purpose of this Policy is to establish, in a clear, accessible, and legally grounded manner, the conditions under which ROCCIBEL collects and manages Consumers' consent for sending transactional and marketing text messages (SMS) through the SMS Program; the rights available to the Consumer in connection with this communication channel; the available Opt-In and Opt-Out mechanisms; and the obligations that ROCCIBEL assumes with respect to the processing of personal data in the context of text-message communications, with the aim of becoming a benchmark for regulatory compliance in the beauty e-commerce sector.

  1. SCOPE OF APPLICATION

This Policy applies to any natural person who provides their mobile phone number to ROCCIBEL through the checkout process on the website https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version) or other expressly enabled channels, and who grants consent to receive text messages under the terms described herein.

This Policy is primarily directed at Consumers located in the State of Texas. However, since ROCCIBEL operates in multiple countries and states, Consumers located in other jurisdictions who receive SMS communications will additionally be subject to the local regulations applicable to commercial electronic communications, which ROCCIBEL will seek to observe in a proportional and reasonable manner.

  1. DEFINITIONS

For all purposes of this Policy, the following definitions shall apply:

  • Privacy Notice: A written communication issued by the data controller (Controller), addressed to the data subject with respect to the Processing of their personal data, informing the data subject of the existence of the personal data Processing policies and the information applicable to them, how to access such policies, and the purposes of the intended Processing of personal data.

  • Contact Channels: Channels made available to data subjects for handling requests, inquiries, complaints, and/or communications. These include Electronic Support at support@zenttu.com, and the Mailing Address: 24285 Katy Freeway, Suite 300, Katy, TX 77494, United States.

  • Carrier / Telecommunications Operator: A telecommunications services company (such as AT&T, Verizon, T-Mobile, among others) through whose network text messages are delivered to the Consumer's device. Carriers apply their own technical and regulatory compliance standards, including the CTIA Guidelines, compliance with which by ROCCIBEL is a necessary condition to ensure effective delivery of SMS Program messages.

  • Consent: A clear manifestation, through an affirmative act, freely, previously, expressly, and knowingly given by the data subject to authorize the Processing of personal data.

  • Consumer: A natural person residing in the State of Texas, acting solely in a personal or household context.

  • Data Controller: A natural or legal person, public or private, that alone or jointly with others determines the database, purposes, and means of processing personal data. ROCCIBEL acts as Controller with respect to the personal data collected through the SMS Program.

  • Personal Data: Any information, including sensitive information, linked or reasonably linkable to an identified or identifiable natural person. In the context of the SMS Program, this mainly includes the Consumer's mobile phone number.

  • Device: Any device capable of accessing the Service or receiving text messages, such as a mobile phone or any other SMS-enabled communication device.

  • Disclosure, Sharing, and Sale: Any disclosure, communication, copying, or transfer of personal data from one party to another, regardless of the means used. ROCCIBEL will not share SMS Program data with third parties for third-party marketing purposes without the Consumer's express consent.

  • Hard Bounce: A permanent technical block automatically applied by the platform to a phone number when an Opt-Out is executed. Once the Hard Bounce is activated, ROCCIBEL cannot send marketing messages to that number - whether automated or manual - until the consumer expressly re-subscribes.

  • Marketing Message or Promotional Message: An SMS communication sent by ROCCIBEL to the Consumer for the purpose of promoting products, services, offers, discounts, events, product launches, abandoned-cart reminders, or any content of a commercial or advertising nature.

  • Transactional Message: An SMS communication sent by ROCCIBEL to the Consumer within the framework of a pre-existing commercial relationship, for the sole purpose of informing about the status of an order, confirming a transaction, notifying a recurring charge, communicating a payment failure, confirming a cancellation, or conveying operational information directly related to a service requested by the Consumer. These require prior express consent (not necessarily written). Once a transactional message includes any promotional element, it is reclassified as a Marketing Message.

  • Minor: A person under thirteen (13) years of age.

  • Opt-In: The act by which the Consumer grants express and affirmative consent to receive text messages from ROCCIBEL, by actively checking the box enabled for that purpose during the Website checkout process or through another expressly authorized subscription mechanism.

  • Opt-Out: The act by which the Consumer revokes their consent to receive marketing text messages from ROCCIBEL through the enabled channels.

  • Prior Express Written Consent (PEWC): A written agreement, bearing the Consumer's signature, that clearly and conspicuously authorizes an identified sender to deliver, or cause to be delivered, advertisements or telemarketing messages to the Consumer using an automatic telephone dialing system (ATDS) or an artificial or prerecorded voice. The messages and texts must be logically and topically associated with the interaction that generated the consent, and the agreement must identify the telephone number to which the signer authorizes delivery of such messages.

  • Processor: A natural or legal person that processes personal data on behalf of the Controller (Responsable), following its instructions and without making decisions of its own regarding the purposes or means of the processing.

  • SMS Program: The text-messaging service operated by ROCCIBEL through the Processor's platform, through which both transactional messages and marketing messages are sent to the consumer, depending on the type of consent previously granted. This is the internal functional designation adopted by ROCCIBEL to refer to the entirety of its text-message communication services.

  • Service Provider: Any natural or legal person that processes data on behalf of ROCCIBEL. This refers to third-party companies or individuals engaged by ROCCIBEL to facilitate the Service, provide the Service on its behalf, or perform services related to the SMS Program.

  • Targeted Advertising: Means displaying to a target Consumer audience an advertisement selected based on personal data obtained from that consumer's activities over time and across unaffiliated websites or online applications, in order to predict the Consumer's preferences or interests. The term does not include:

    • An advertisement that: (i) is based on activities within a website or online application owned by the controller; (ii) is based on the context of a Consumer's current search query, or visit to a website or online application; or (iii) is directed to a Consumer in response to the Consumer's request for information or feedback; or

    • The processing of personal data solely to measure or report on advertising performance, reach, or frequency.

  • Complaint: Dissatisfaction with the processing of personal data.

  • Consent Record (Timestamp): Digital evidence automatically generated and retained by the platform at the time the consumer grants their Opt-In, including the date, exact time, and IP address from which the act of consent was performed.

  • ROCCIBEL: A legal entity, owner and operator of the SMS Program, in charge of its operational and functional administration and of the processing of the associated personal data, considered in this document as the Controller of the personal data.

  • Website: The official website of ROCCIBEL, accessible at https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version), through which the checkout process operates, constituting the primary Opt-In mechanism for the SMS Program.

  • Request: A formal requirement submitted by a consumer to the Controller of Personal Data Processing to exercise their rights under the TDPSA and other applicable regulations.

  • Third Party: Any person other than the Consumer, the Controller (Responsable), the Processor (Encargado), or an affiliate of the Controller (Responsable) or Processor (Encargado).

  • Territory: Refers to the State of Texas, United States of America, as well as any other jurisdiction within or outside the territory of the United States in which ROCCIBEL offers its products through its e-commerce platform.

  • Data Subject: A natural person whose personal data is processed by ROCCIBEL. In the context of the SMS Program, the Data Subject is any natural person who has provided their mobile phone number and whose data is processed in connection with their subscription to the SMS Program.

  • Processing: Processing means any operation or set of operations performed, by manual or automated means, on personal data or sets of data. This includes, among others, the collection, use, access, storage, analysis, modification, communication, Disclosure, Sharing, Sale, deletion, or any other action performed on personal data, in accordance with the TDPSA.

5. CLASSIFICATION OF THE PROGRAM'S SMS MESSAGES

The SMS Program of ROCCIBEL comprises two categories of messages, subject to different consent standards under the TCPA and the CTIA Guidelines. Properly classifying each communication is essential to ensure regulatory compliance and protect the Consumer's rights.

5.1. Transactional Messages

Transactional Messages are those sent within the framework of a pre-existing commercial relationship, for the sole purpose of informing the Consumer about operational aspects of their order or subscription. These messages do not require marketing Prior Express Written Consent (PEWC), although they do require a minimum level of consent derived from the contractual relationship. The SMS Program's Transactional Messages include, without limitation:

  • Confirmation of an order placed.

  • Shipping notification and order tracking status updates.

  • Alert of a payment processing failure or declined card.

  • Reminder of an upcoming recurring subscription charge.

  • Confirmation of subscription or order cancellation.

  • Operational communications directly related to a service requested by the Consumer.

Once any of the foregoing messages includes a promotional, advertising, or commercial-incentive element - however minimal - that message loses its transactional classification and becomes subject to the marketing PEWC standard. ROCCIBEL undertakes to maintain strict segregation of its message content in order to preserve the correct classification.

5.2. Marketing Messages or Promotional Messages

Marketing Messages are those sent for the purpose of promoting products, services, offers, or commercial opportunities of ROCCIBEL. These messages in all cases require the Consumer's Prior Express Written Consent (PEWC), obtained in advance, expressly, in writing, and independently. The SMS Program's Marketing Messages include, without limitation:

  • Special offers, discounts, and promotional codes.

  • Announcements of new product launches.

  • Seasonal campaigns and holiday communications.

  • Abandoned-cart reminders with incentives.

  • Loyalty program updates and exclusive benefits.

  • Invitations to commercial events or promotional activities.

6. CONSENT MECHANISM (OPT-IN)

6.1. Checkout Form

The primary Opt-In mechanism for the SMS Program of ROCCIBEL operates during the Website checkout process, managed through the platform. In this process, the consumer finds a selection checkbox that is clearly identified and placed in a visible location, offering the option to subscribe to the SMS Program. This checkbox has the following technical and legal characteristics:

  • Never pre-checked: by technical design, in compliance with the active affirmative consent standard required by the TCPA. The consumer must perform a positive and unambiguous act to express their consent.

  • Active affirmative act: checking the box constitutes the Consumer's expression of Prior Express Written Consent (PEWC) to receive marketing text messages from ROCCIBEL.

  • Segregation of consent: if the consumer provides their phone number for order-shipping purposes but does not check the marketing box, the platform technically blocks the sending of any commercial campaign to that number, allowing only the sending of transactional messages.

6.2. Mandatory Call-to-Action (CTA) Text

In accordance with 47 C.F.R. § 64.1200(f)(9), Section 5 of the FTC Act, and the CTIA Guidelines, a disclosure text must appear clearly, visibly, and conspicuously next to the Opt-In checkbox, simultaneously communicating two essential elements to the Consumer: first, that by checking the box the Consumer is giving express authorization to ROCCIBEL to send automated promotional text messages to the phone number provided; and second, that the Consumer is not required to check that box or accept that agreement as a condition of making any purchase or accessing any ROCCIBEL product or service.

6.3. Consent Record (Timestamp)

At the moment the Consumer completes the Opt-In act, the platform automatically generates and retains a Consent Record (Timestamp) that includes the exact date and time of the consent click, the IP address of the device from which the act was performed, the version of the form and of the Call-to-Action text in effect at that time, and the phone number to which the consent is linked. This Record constitutes the legal proof of ROCCIBEL's PEWC under the TCPA and 47 C.F.R. § 64.1200(a)(7)(iii).

6.4. Welcome Message

In accordance with the CTIA Guidelines (May 2023), the first message sent following subscription to the SMS Program must contain the following minimum elements: the name of the SMS Program and identification of ROCCIBEL as sender; Contact Channel information; a general description of the type of messages the Consumer will receive; the estimated sending frequency; a rate disclosure ("Msg & data rates may apply"); and a help instruction ("Reply HELP for help").

7. CONTENT AND CONDITIONS OF THE SMS PROGRAM

7.1. Types of Messages

The consumer subscribed to the SMS Program will receive the types of messages described in Section 5 of this Policy. ROCCIBEL undertakes that the content of all its messages will be truthful, clear, relevant to the Consumer, and consistent with the purposes disclosed at the time of Opt-In.

7.2. Message Frequency

The frequency of SMS Program messages may vary depending on ROCCIBEL's commercial activity and campaigns. This frequency may vary during special seasons or periods of higher commercial activity. The estimated frequency will always be clearly disclosed to the Consumer in the Call-to-Action text at the time of Opt-In.

7.3. Applicable Rates

The SMS Program is free of charge to the Consumer from ROCCIBEL's standpoint. However, the Consumer's Carrier may apply message and data rates under the plan the Consumer has with their telecommunications operator. ROCCIBEL is not responsible for any rates the Consumer's Carrier may charge for receiving text messages, and will expressly disclose this in the Call-to-Action text and in the Welcome Message.

7.4. Sender Identification and Sending Number

Messages under the SMS Program will be sent from the number assigned by the Processor in accordance with its technical integration. The type of number enabled - whether 10DLC, short code, or toll-free - will be determined by the architecture of the Processor's platform applicable to ROCCIBEL's case. In accordance with current registration requirements, the Processor will register the Brand and Campaign with The Campaign Registry (TCR). With respect to Texas Business & Commerce Code Chapter 302: since ROCCIBEL's SMS Program operates entirely on a consent-based basis (a consent-based program), ROCCIBEL considers the exemption from registration and bonding with the Texas Secretary of State to be applicable, based on the non-binding guidance interpretation issued by the Office of the Texas Attorney General in November 2025, applicable to operators of SMS programs in which all recipients have granted express opt-in. That interpretation does not exempt ROCCIBEL from the risk of a private action under the Texas Deceptive Trade Practices Act (DTPA) in the event of non-compliance with the conditions of the exemption. Accordingly, ROCCIBEL must rigorously and verifiably retain documentary evidence of that consent basis (Consent Record/Timestamp) in response to any request from a regulatory authority or private claim.

7.5. Time-of-Day Restrictions

In accordance with 47 C.F.R. § 64.1200(a)(1), SMS Program messages will be sent only between 8:00 a.m. and 9:00 p.m., the Consumer's local time. ROCCIBEL will configure its sending systems to observe this time restriction across its consumers' different time zones, ensuring that no marketing message is received outside that window.

8. REVOCATION OF CONSENT (OPT-OUT)

ROCCIBEL guarantees the Consumer the right to revoke their consent to receive marketing text messages at any time, easily, free of charge, and immediately, through the mechanisms described in this Section.

8.1 Opt-Out by Channel

The Consumer may opt out immediately by replying 'STOP' (or 'ALTO'/'CANCELAR') to the text message received, which constitutes the primary unsubscribe channel under the CTIA Guidelines. Alternatively, the Consumer may clearly indicate their unsubscribe request and the phone number to be excluded by email to support@zenttu.com with the subject line 'SMS PROGRAM OPT-OUT', or by written communication addressed to 24285 Katy Freeway, Suite 300, Katy, TX 77494, United States. The STOP reply is processed immediately; the other channels apply a maximum period of three (03) business days to process the Opt-Out.

8.2. Effects of Opt-Out

Once the Opt-Out is executed through the authorized channels, the following effects occur automatically and immediately: the system automatically unchecks the 'accepts SMS marketing' box on the Consumer's profile in the platform; the Hard Bounce is activated on the Consumer's phone number, preventing any further sending of marketing messages, even manually, until the Consumer expressly re-subscribes; and the number is recorded on the SMS Program's internal Do Not Contact list.

8.3. Single Opt-Out Confirmation Message

In accordance with the FCC (47 C.F.R. § 64.1200(a)(10)), after receiving an Opt-Out request, ROCCIBEL may send a single confirmation message within the following five (5) minutes, the content of which will be limited to acknowledging receipt of the unsubscribe request, without including any promotional or advertising element. No further marketing message will be sent after this confirmation message.

8.4. Opt-Out Processing Period

ROCCIBEL will honor the Opt-Out practically immediately. In any event, the Opt-Out will be processed within a maximum period of three (03) business days from receipt of the request, in accordance with the FCC (47 C.F.R. § 64.1200(a)(10)).

8.5. Re-Subscription to the SMS Program

A consumer who has executed an Opt-Out may re-subscribe to the SMS Program by sending an email to support@zenttu.com with the subject line 'RE-SUBSCRIBE SMS PROGRAM', by written communication addressed to 24285 Katy Freeway, Suite 300, Katy, TX 77494, United States, or by checking the consent box again during checkout. Re-subscription generates a new Consent Record (Timestamp), independent of the prior one, which is permanently canceled, with the new consent operating autonomously.

9. PROCESSING OF PERSONAL DATA UNDER THE SMS PROGRAM

9.1. Personal Data Collected

Within the SMS Program, ROCCIBEL collects and processes the following Consumer personal data: mobile phone number; Consent Record (Timestamp) with date, time, and IP address of the Opt-In act; category of consent granted (marketing and/or transactional only); message interaction history, including delivery status, Opt-Out, and re-subscription; and customer profile data linked to the phone number.

9.2. Purposes of Processing

Personal data under the SMS Program is processed exclusively for the following purposes: sending text messages to the Consumer according to the category of consent granted; retaining evidence of Prior Express Written Consent (PEWC) for TCPA regulatory compliance; handling Consumer rights requests related to the SMS Program; managing Opt-Out lists and complying with the do-not-contact obligation; and internal analysis of the SMS Program's effectiveness, on an aggregated basis and without individual Consumer profiling.

9.3. Technical Segregation of Data by Type of Consent

The platform implements automatic technical segregation between the data of consumers who have consented to receive marketing messages and those who have only provided their number for transactional purposes. The system blocks, by design, the sending of any marketing campaign to numbers that have not completed the marketing Opt-In, even if such numbers are stored in the same customer database. This technical segregation constitutes a guarantee of compliance with the purpose-limitation principle enshrined in the TDPSA.

9.6. Data Retention Period

ROCCIBEL will retain the phone number and the Consent Record for as long as the Consumer remains subscribed to the SMS Program, and for the additional period necessary to comply with legal obligations, defend claims, or undergo regulatory audits, in accordance with 47 C.F.R. § 64.1200(a)(7)(iii). Once the retention period has elapsed, the data will be securely deleted or anonymized in accordance with the practices described in ROCCIBEL's Privacy Policy.

9.7. Right to Erasure - Data Deletion

If the Consumer requests deletion of their personal data under the SMS Program, ROCCIBEL will execute the 'Delete personal data' function on the platform, which purges the phone number and its consent history within up to three (03) days. This function is irreversible. The request must be submitted through the enabled Contact Channels and will be processed in accordance with ROCCIBEL's Procedure for Handling Consumer Requests Regarding Personal Data Protection.

9.8. Security of SMS Program Data

ROCCIBEL adopts the technical, organizational, and administrative measures necessary to ensure the security, confidentiality, and integrity of the personal data processed under the SMS Program, in accordance with the standards set forth in its internal policies. In the event of a security breach compromising SMS Program personal data, ROCCIBEL will apply the notification protocol set forth in Texas Business & Commerce Code § 521.053, which requires notifying affected individuals within sixty (60) days following detection of the incident.

10. MINORS

The SMS Program of ROCCIBEL is not directed at minors, and ROCCIBEL will not knowingly collect personal data from minors in connection with the SMS Program. In accordance with the Children's Online Privacy Protection Act (COPPA, 15 U.S.C. § 6501), it is absolutely prohibited to send marketing text messages to the phone numbers of minors under thirteen (13) years of age without verifiable prior parental consent.

As a matter of internal policy, and consistent with what is stated in ROCCIBEL's Privacy Policy, the SMS Program extends this restriction to all persons under eighteen (18) years of age: no person under 18 may subscribe to the SMS Program. If ROCCIBEL becomes aware that it has collected the phone number of a minor under 13, it will immediately remove that number from all SMS Program lists. Parents or guardians who discover that a minor's number is subscribed to the SMS Program may report it through the enabled Contact Channels, in particular by email to support@zenttu.com.

11. CONTENT RESTRICTIONS

ROCCIBEL will not send SMS messages that contain:

  • SHAFT Content: Sex (sexual content), Hate (hate speech), Alcohol (without age verification), Firearms, Tobacco (including CBD).

  • False, deceptive, or misleading information regarding the sender's identity, the products offered, or the commercial terms.

  • Content impersonating ROCCIBEL or any other entity.

  • Material that infringes third parties' intellectual property rights.

  • Any content that violates applicable federal or state law.

12. CONSUMER RIGHTS

In accordance with the Texas Data Privacy and Security Act (TDPSA) and other applicable regulations, the Consumer has the right to exercise the following rights in connection with the processing of their personal data under the SMS Program:

  • Right of access: to request information about the personal data ROCCIBEL processes in the context of the SMS Program, including the Consent Record and message history.

  • Right of correction: to request correction of an inaccurate or outdated phone number or other personal data.

  • Right of deletion: to request deletion of their personal data from the SMS Program, in accordance with the procedure described in Section 9.6 of this Policy.

  • Right to data portability: to request that a copy of their personal data be provided in a readable and structured format.

  • Right to opt out of data processing: The Consumer has the right to opt out of the processing of personal data.

  • Right to Opt-Out: to revoke, at any time, the consent granted to receive marketing messages, in accordance with the mechanisms described in Section 8 of this Policy.

  • Right to file complaints and claims: the consumer may send their requests to ROCCIBEL, which undertakes to resolve them within a maximum of 45 days. If the consumer is not satisfied with the decision adopted by ROCCIBEL, the consumer may file a complaint with the Office of the Texas Attorney General, the authority with jurisdiction over data protection in this jurisdiction.

  • Right to be informed: The data subject has the right to be informed at all times by ROCCIBEL about the processing that will be given to their personal data, as well as any modifications and updates made to the privacy notice, the data protection policy, and any other purpose or security measures applicable to their personal data.

The formal exercise of the foregoing rights - with the exception of the SMS Program Opt-Out, which is exercised in accordance with Section 8 - will be processed in accordance with ROCCIBEL's Privacy and Personal Data Security Policy: confirmation of receipt within a maximum of three (03) business days and a substantive response within forty-five (45) calendar days, extendable once for an additional forty-five (45) days.

13. AMENDMENTS TO THE POLICY

ROCCIBEL reserves the right to amend this Policy at any time, in order to reflect regulatory, operational, or technical changes related to the SMS Program. The current version will always be available at https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version).

Material changes to the Policy will be notified to the Consumer through an informational SMS or by email, with reasonable minimum advance notice before their effective date, indicating the new effective date. The Consumer's continued use of the SMS Program after notification of material changes will constitute acceptance of the updated version of the Policy. Non-material changes, such as typographical corrections or clarifications that do not modify rights or obligations, will take effect immediately upon publication on the Website.

14. CONTACT CHANNELS AND MECHANISMS AVAILABLE FOR HANDLING REQUESTS, INQUIRIES, AND COMPLAINTS RELATED TO THE SMS PROGRAM

In order to ensure the exercise of rights related to the SMS Program and the protection of associated personal data, ROCCIBEL makes the following official Contact Channels available to Consumers:

  • ROCCIBEL website: https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version)

  • Electronic Support: You may send a formal request to our email address designated for the SMS Program support@zenttu.com , indicating 'SMS PROGRAM' in the subject line and specifying the right you wish to exercise or the applicable request.

  • Mailing Address: You may also send us a written request to our physical address at 24285 Katy Freeway, Suite 300, Katy, TX 77494, United States, clearly indicating your request and providing the documentation required for validation.

All requests will be processed in accordance with the timeframes and conditions established under applicable data protection regulations, including the Texas Data Privacy and Security Act - TDPSA for consumers located in Texas. If requests are received from consumers in other states or countries, ROCCIBEL will apply the requirements that correspond in a proportional and reasonable manner, preferentially applying the TDPSA unless a supplementary law offering broader coverage and protection to the consumer exists.