Privacy policy, terms and privacy requests
What your privacy policy and terms should cover about ACR's calls, texts and emails, where ACR keeps the links, and how Shopify privacy requests work.
Last reviewed November 7, 2026
This article explains how Growth Dept ACR behaves. It is not legal advice. Ask your own counsel which rules apply to your store.
Describe what shoppers will get
Your privacy policy and terms should match what shoppers actually receive. With ACR on, a shopper who leaves checkout may get:
- calls, texts and emails about the unfinished order from an AI assistant speaking for your brand;
- a recorded call, with an announcement where every party must agree;
- a first text that carries “Reply STOP to opt out.”, and a HELP reply that gives your support email and says message and data rates may apply;
- emails with an unsubscribe link and, when the brand profile has one, your company address.
Say how to stop: reply STOP, use the unsubscribe link, or tell the agent on a call. ACR acts on each at once.
Rules behind ACR's defaults
These concern consent and the messages themselves. Have your lawyer check how your pages and checkout wording line up with them.
- Calls: under the FCC's 2024 ruling, AI calls to mobile numbers need prior express consent, and telemarketing calls need prior express written consent: a signed written agreement that names the number and says signing is not a condition of purchase. Shopify's checkout boxes cover SMS and email marketing, so SMS consent covers calls belongs on only when your checkout wording names calls, as ACR's recommended wording does. See consent.
- Revoking consent: FCC rules let a shopper revoke consent by any reasonable means, which is why ACR treats plain-language requests as opt-outs.
- Email in the US (CAN-SPAM): no prior consent is needed, but each commercial email needs a working opt-out, notice of it, a valid postal address and, unless the shopper gave prior consent, identification as an advertisement. Opt-outs must take effect within 10 business days.
- Email and texts in Canada (CASL): messages need express or implied consent, must identify the sender with contact details, and must offer an unsubscribe that takes effect within 10 business days. Implied consent covers a purchase in the past two years or an inquiry in the past six months. Whether an abandoned checkout counts as an inquiry is a reading the Act does not settle.
- Australia (Spam Act): email and texts need consent, must say who sent them and how to reach them, and must offer an unsubscribe that takes effect within 5 business days.
Where ACR keeps your links
The brand profile's Information page has Terms of service page and Privacy policy page under Support and policies. Both are optional, and Fill from website can find them on your site.
Check pages, on the same card, reads both pages as they are typed (or, when a field is empty, the usual Shopify policy page on your website) and lists five statements US carriers look for before a store sends marketing texts: the privacy policy's two sentences, word for word (“Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes.” and “Text messaging originator opt-in data and consent will not be shared with any third parties.”), how to opt out with STOP and get help with HELP, that message and data rates may apply, and that carriers are not liable for late or lost messages. Each shows Found, with the words it found, Not found, or Not read when the page did not load. With a text AI set up, a statement worded differently counts as found only with a quote. It saves nothing and does not change your pages.
Carrier registration sends both links with the brand's text campaign, and a US brand cannot be submitted without them (see carrier registration). The agent's brief includes your Support email but not these links, and publishing a campaign does not require them.
Privacy requests from Shopify
For stores connected through the Shopify app, ACR acts on Shopify's privacy requests and lists them in the Privacy requests card on the Integrations settings page. Only admins see them.
- Customer asked for their data: ACR gathers what your store holds about the customer (leads, checkouts, orders, runs, interactions and hand-offs) into a sealed file and posts a notification that links to it. Press Download and send the file to the customer. It is kept for 30 days, and every download is recorded in the audit log.
- Customer asked to be erased: ACR removes the shopper's name, phone, email, checkout details and cart links, plus the content and summaries of their conversations, and ends their open runs. Their call recordings stop playing at once, and ACR asks ElevenLabs to delete those calls, audio and transcript included. The lead stays, marked Redacted.
- Store asked for all its shopper data to be erased: Shopify sends this about 48 hours after the app is uninstalled. ACR deletes the store's leads, checkouts, runs, conversations, hand-offs, orders, conversions and suppression list, asks ElevenLabs to delete the store's recorded calls, and ends the Shopify connection.
Requests that do not come through Shopify
Leads from the Custom API or a CSV file have no request intake. An admin can delete leads in Leads management: their details, runs, calls, texts, emails, events and hand-offs go, while orders, conversions and the suppression list stay. Redacting a lead by hand is not available.