Privacy Policy

• When you use SentLogic Service, we store all the content you provide, including information related to you as a customer or an end user of the Service. We gather this information from you directly when you enter it, or from integrations that you linked to the Service (Google, Facebook, Instagram, Shopify, etc.).
• In some cases, we can receive information from third parties, e.g. from a payment service provider on whether your payment was successful.
• When you send us emails or message us. When we receive emails or messages from you in the chat, we can store the content of such emails, attachments as well as your contact details.
• When you submit forms on the Site or participate in our events. When you complete forms on the Site (contact us, subscription, demo request, event registration, etc.) we collect your contact details and information you complete in the form. If we arrange joint events together with our partners, we can receive information from our partners.
• When you use the Site. When you use the Site, we collect certain information, as described in more detail below that may, alone or in combination with other information, constitute personal data (e.g. cookie files).
• When you join our communities, Facebook and other groups, we can see data in your profile and process comments you posted in our groups. However, we don’t gather that information or copy it into our systems, but rather just have access to it.

• Customer account details. To create or update your account and provide the Service we collect from you and third-party integrations (e.g. Google, Facebook, Instagram) information about you, as a customer or end-user of the Service. This includes id, email, status, linked pages and accounts, products in use, location, etc.
• Shopify order data. If you connect a Shopify store to the Service, we access order data (order status, totals, and cart-attribution identifiers) via Shopify's API to attribute revenue to your Instagram conversations. We do not access or store your customers' names, email addresses, phone numbers, or physical addresses from Shopify.
• Financial information. To process your payments for the Service subscription, we need your debit/credit card (last four digits of the card number), account details and payment information.
• Contact details and business data. We receive information about our customers and potential customers for cooperation and communication purposes. This includes full name, title, company, email or other contact details as may be necessary.
• Requests, messages and submitted forms details. We receive and process your messages, support requests, emails and information you share with us via online forms or social media accounts. This includes the content of such communications as well as your contact details if any.
• Usage data, logs and other technical data. When you interact with the Service, metadata and log files are collected automatically. Log data may include the Internet Protocol (IP) address, your browser type and settings, the date and time you used the Service, information about browser configuration plugins, language preferences, the pages or features which you browsed, time spent on those pages or features, the frequency of pages and functions use, the links clicked on or used. If you use the Service from your phone, this may also include the type of device, operating system, device settings and device identifiers.
• Email performance data. To track engagement and performance metrics of our newsletters, we can use a ‘clear image’ (gif) in email communications. Much of this data is aggregated. If you wish to turn off this tracking, you can do so by turning off images in the email itself.
• Website cookies and similar technologies. We use cookie technology on the Site. See details in Cookie Statement.
• Customer Content. As you use our Service, you may import into our system personal data you have collected from your users, customers, prospective customers, social media and messaging platform contacts (collectively “Subscribers”) or other individuals. We process this data only on your behalf as our customer. We have no direct relationship with your Subscribers or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission and legal basis for us to collect and process information about those individuals. We process such Subscriber personal data solely as a processor, on your behalf and on your documented instructions, only to provide the Service, and never for our own purposes. As the controller of your Subscribers' personal data, you are responsible for having a lawful basis and any required consents for us to process it.
• We ask that you not send or disclose to us any sensitive personal data (e.g., aadhar details, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Service or otherwise.

• To operate the Service: We use data to enter into the agreement with you as a customer and operate, maintain and administer your account in the Service, as well as to communicate with you regarding the account (sending announcements, technical notices, updates, security alerts, and support and administrative messages) and to respond to Service-related requests, questions and feedback. We also use your data to perform our billing obligations.
• To provide the Service we process Customer Content information on your behalf as a customer.
• To communicate with you and inform you about the Service. If you request information from us, register for the Service, complete a form or feedback on a Site, or participate in our surveys, promotions or events, we may send you SentLogic-related marketing communications if permitted by law. In all such communications, we will provide you with the possibility to opt-out.
• To conduct events and communicate with you. We use your personal data, which you provided while registering for the event, to send you reminders about the event, communications related to the event and SentLogic-related services. As well, we may ask for your feedback. In communications, we always provide the possibility to opt-out from communications.
• To comply with law. We use your personal data as necessary to comply with applicable laws, including sanction requirements, accounting and tax obligations, legal processes or audits, to respond to subpoenas or legally binding requests from government authorities. Before disclosing any information to an authority upon its request, we check the validity of such request carefully.
• To negotiate, enter and perform agreements. We have to collect and process information about our counterparties and their representatives to negotiate and enter into legally valid agreements and cooperate with them.
• For compliance and safety. We use your personal data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

• Service Providers. We employ third-party companies and individuals to help us with performance of certain activities, e.g. payment service providers. We also use third-party software to process data (e.g. CRM, email agent, cloud storage solutions, etc.). Our current sub-processors include Amazon Web Services (cloud hosting, database, and file storage), OpenAI (AI reply generation), Stripe (payment processing), and Google (account sign-in and email delivery). We also share data with the platform integrations you choose to connect (Meta/Instagram, Shopify).
• We also use third-party cookies on the Site. See more details in Cookie Statement.
• These third parties are permitted to use personal data about you only to perform these tasks only for lawful business purposes in accordance with the terms of the agreement(s) we have in place with such service providers and for no other purpose.
• Professional Advisors. We may disclose your personal data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
• Third-party Applications and Integrations. For the provision of the Service we receive and share data with integrations and apps linked by customers (Google, Facebook, Instagram, Shopify, etc.).
• Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of SentLogic (or its assets) will continue to have the right to use your personal data and other information in accordance with the terms of this Privacy Policy. Further, SentLogic may also disclose aggregated personal data in order to describe our Service to prospective acquirers or business partners.
• Compliance with Laws and Law Enforcement. SentLogic may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
• Corporate Affiliates. We may share personal data with our corporate affiliates.

• If you wish to access your personal data that SentLogic collects, you can do so at any time by contacting us.
• You can also contact us to update, correct or delete information in your account.
• If you are in the European Economic Area (“EEA”), the UK, or Switzerland, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data where it is technically possible.
• Similarly, if you are in the EEA, the UK, or Switzerland, and provided we have collected and processed your personal data under your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on other lawful processing grounds.
• You may submit your request by sending an email to contact@SentLogic.com. We will respond to all requests in accordance with applicable data protection laws.
• Access to Data Controlled by our Customers. We don’t have any direct relationships with customers’ Subscribers, i.e. the individuals whose personal data is stored by our customers the Service. An individual who seeks access, or who seeks to correct, amend, or delete personal data processed in the Service by our customers should direct their request to the customer directly.

• We take reasonable and appropriate measures to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal data.
• Despite these efforts to store personal data collected on and through the Site and/or the Service and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of personal data during its transmission or its storage in our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to personal data. We do not warrant or represent that personal data about you will be protected against, loss, misuse, or alteration by third parties.
• The payment instrument processing vendor we work with uses security measures to protect your information both during the transaction, and after it is complete.
• If you have any questions about the security of your personal data, you may contact us by email contact@SentLogic.com.

• If a security breach causes an unauthorized intrusion into our system that materially affects you or your Subscribers, then we will notify you as soon as possible and later report the action we took in response.

• We process data to perform a contract with you on the use of the Service (Art. 6(1)(b) of the GDPR or UK GDPR);

• to communicate with you and inform you about our Service;
• to comply with the law we are subject to;
• to conduct events and communicate with you;
• to negotiate, enter, and perform agreements;
• for compliance and safety.

• You have the right to request that we disclose:
• The categories of personal data we have collected about you;
• The categories of personal data we have sold or disclosed for a business purpose;
• The categories of sources from which we have collected personal data about you;
• The business or commercial purposes for selling, sharing or collecting personal data about you;
• The categories of personal data sold or shared, if any, about you, as well as the categories of third parties to whom the personal data was disclosed, by category of personal data for each party to whom personal data was sold; and
• The specific pieces of personal data collected.
• You may submit a request to know by contacting us at privacy@SentLogic.com . The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.

• You have the right to request that we delete any personal data about you that we have collected. Upon receiving a verified request to delete personal data, we will do so unless otherwise required or authorized by law. You may submit a request to delete personal data by contacting us at privacy@SentLogic.com.

• You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us and confirm with us that you provided the authorized agent permission to submit the rights request. This verification process is not necessary if your authorized agent provides documentation reflecting that the authorized agent has the power of attorney to act on your behalf under Cal. Prob. Code §§ 4121 to 4130.

• You may submit a request for access and requests to delete personal data about you via email at privacy@SentLogic.com.
• Upon receipt of a request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.
• We will acknowledge the receipt of your request within ten (10) business days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 calendar days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. In order to protect your privacy and the security of personal data about you, we verify your request by email.
• Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
• We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

• You have the right not to be discriminated against for the exercise of your California privacy rights described above. Unless permitted by the California Consumer Privacy Act, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you with a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

You have the right to delete your Account and all associated personal data at any time. You may do so through the account settings in the Services or by contacting us directly at contact@SentLogic.com. When you initiate the deletion process, your Account and all associated data will be automatically and immediately deleted. The deletion occurs instantly upon confirmation and all information tied to your Account will be permanently removed.

When you delete your Account, we will permanently delete all personal data associated with your Account, including but not limited to:

• Account and Profile Information: All personal information, account settings, preferences, profile data, and identification information associated with your Account.
• Third-Party Account Connections: All information about your connected accounts (Instagram, Facebook, Google, Shopify, etc.), including authentication tokens, permissions, access credentials, and linked account data. We do not retain any access credentials or connection information after account deletion.
• Service Usage Data: All automations, automation settings, configurations, flows, triggers, actions, and any associated content or media created or stored through the Services.
• Contact and Communication Data: All contact information, contact lists, message history, conversation data, chat logs, and any communications stored in connection with your Account.
• Billing and Payment Information: All subscription details, billing history, payment information, and transaction records associated with your Account, except as required by applicable law for record-keeping purposes (such as tax and accounting requirements).
• User Generated Content: All content, files, media, and materials you have uploaded, created, or stored through the Services.
• Technical and Usage Data: All usage data, logs, metadata, IP addresses, device information, and other technical data associated with your Account.

We do not retain any of your personal data after account deletion. All information is permanently removed from our active systems, databases, and backups in accordance with our data deletion procedures. Once your Account is deleted, the data cannot be recovered or restored. This includes:

• Removal from all active databases and storage systems
• Deletion from backup systems within our standard retention period
• Revocation of all access credentials and authentication tokens
• Termination of all third-party integrations and connections

Upon account deletion, all access rights and permissions associated with your Account are immediately and permanently revoked. This includes:

• Access to the Services and all features
• Access to any third-party platform integrations (Instagram, Facebook, and other connected services)
• API access tokens and authentication credentials
• Any other access rights or permissions granted to your Account

We do not maintain any residual access or permissions after account deletion. All access credentials are permanently revoked and cannot be restored.

Account deletion is an irreversible action. Once you confirm the deletion of your Account, the process cannot be undone. We strongly recommend that you export or backup any data you wish to retain before proceeding with account deletion. For more detailed information about account deletion, please refer to our Terms of Service - Account Deletion section.

Notwithstanding the foregoing, we may retain certain information as required by applicable law, regulation, or legal process. Such retention will be limited to the minimum amount of information necessary to comply with such requirements (such as tax records, accounting requirements, or legal obligations) and will be maintained in accordance with our Privacy Policy and applicable data protection laws.

Please note that deletion of your Account with SentLogic does not automatically delete your accounts or data with third-party services (such as Instagram, Facebook, Google, or other platforms). You are responsible for managing your accounts and data with such third-party services separately. We do not have control over data stored by third-party services.

Your right to request account deletion is part of your broader data protection rights. If you are located in the EEA, UK, or Switzerland, you also have the right to request deletion of your personal data under Article 17 of the GDPR. If you are a California resident, you have the right to request deletion under the California Consumer Privacy Act. For more information about your data protection rights, please see Section 5 of this Privacy Policy.

If you have any questions about account deletion, our data removal practices, or wish to request deletion of your Account, please contact us at contact@SentLogic.com or through our support channels. We will process your request in accordance with applicable data protection laws and this Privacy Policy.