Privacy Policy

Sales Automation Systems LLC ("SAS," "Company," "we," "us," or "our") is a Nevada limited liability company with its address at:

We operate the website salesautomation.systems and coldemailinfrastructure.com (each, the "Site") and related products and services that link to or reference this Privacy Policy (collectively, the "Services").

This Privacy Policy explains how we collect, use, disclose, and safeguard information about individuals ("you") in connection with the Site and Services. This Privacy Policy is incorporated by reference into, and forms part of, our Terms and Conditions ("Legal Terms").

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, or subsequently withdraw your agreement to it, you must not use, or immediately cease existing use of, the Services.

This Privacy Policy applies to:

• Visitors to our Site;
• Individuals who create or use accounts on the Services;
• Representatives and employees of our customers and business partners;
• Individuals who interact with our sales, marketing, or support teams (e.g., via email, phone, SMS, or in-person); and
• Individuals whose personal data we process in connection with our Services in our capacity as a controller (as described below).

This Privacy Policy does not apply to personal data that our customers upload into the Services or otherwise provide to us for processing on their behalf ("Customer Data") where we act as a processor or service provider. In those cases, our customers (or their own clients) are responsible for their own privacy notices, and our processing of Customer Data is governed by our agreements and any applicable Data Processing Addendum ("DPA") between SAS and the customer, not this Privacy Policy.

Controller

For purposes of most data protection laws, SAS is the controller of personal data that we collect and process about you in connection with:

• Your use of our Site;
• Your interactions with our sales, marketing, and support functions; and
• Your SAS account as a user of the Services (to the extent we determine the purposes and means of processing).

Contact Details

If you have questions or concerns about this Privacy Policy or our privacy practices, you can contact us at:

If required by law, SAS may designate a data protection officer or representative; contact details can be provided upon request.

SAS as a Data Controller

We act as a data controller when we determine the purposes and means of processing personal data, including when we:

• Operate and secure the Site and Services;
• Manage SAS accounts and billing;
• Conduct sales and marketing activities;
• Provide customer support; and
• Analyze usage of the Services for product improvement, security, and compliance.

SAS as a Data Processor/Service Provider

We act as a processor or service provider when our customers use the Services to upload, store, or process personal data about their own leads, contacts, or customers (for example, names, email addresses, phone numbers, notes, call recordings, campaign performance data, etc.) ("Customer Data"). In those cases:

• The customer is the controller (or business) for Customer Data.
• We process Customer Data only on the customer's instructions as set out in our agreement and any applicable DPA.
• Requests from individuals about Customer Data (e.g., access, deletion) should generally be directed to the relevant SAS customer.

The categories of personal data we collect depend on how you interact with us and the Services.

Information You Provide Directly

We may collect personal data that you provide directly to us, including:

Account and Profile Data

• Name, job title, company name, industry
• Business email address, phone number, address
• Login credentials (username, hashed password)

Billing and Payment Data

• Billing contact information (name, email, address)
• Limited payment card details (e.g., last four digits, expiration date) as relayed by our payment processor; we do not store full card numbers

Communications and Support

• Messages, emails, tickets, call recordings, and other communications with our sales, support, or customer success teams
• Feedback, surveys, and responses to forms

Contractual and Business Relationship Data

• Copies of contracts or order forms signed with SAS
• Information relating to renewals, upgrades, or service changes

SMS and Phone Communications

• Phone numbers you provide or verify for use with the Services
• Opt-in and opt-out records for SMS or call-based notifications
• SMS consent source, timestamp, program name, and the consent language shown when you opt in
• Content of text or voice messages where applicable

Information Collected Automatically

When you access or use the Site or Services, we automatically collect certain information, including:

Device and Usage Data

• IP address, browser type and version, device identifiers, operating system
• Dates and times of access, pages viewed, referring/exit pages
• Feature usage, clicks, and other interaction data within the Services

Log and Security Data

• System logs, authentication logs, error logs
• Information related to suspected security incidents or abnormal behavior

We use this information to operate, secure, and improve the Services and to generate aggregate analytics.

Cookies and Similar Technologies

We use cookies, web beacons, pixels, and similar technologies to:

• Remember your preferences and settings;
• Authenticate users and maintain sessions;
• Understand how the Site and Services are used; and
• Provide certain features (e.g., time zone handling, language preferences, or A/B testing).

When you submit a form, book a meeting, or otherwise engage with us, you consent to our use of cookies and similar technologies, including analytics and marketing cookies. You can manage your preferences at any time through our cookie settings page.

You can control cookies through your browser settings and, where required by law, through cookie consent tools. Some features of the Services may not function properly if you disable certain cookies.

Information from Third Parties

We may receive personal data about you from third parties, such as:

• Our customers, partners, resellers, or contractors;
• Publicly available sources (e.g., professional networking or business contact data);
• Identity verification or anti-fraud providers; and
• Marketing and lead-generation partners, where permitted by law.

We treat this information in accordance with this Privacy Policy and any additional restrictions imposed by the source.

We use personal data for the following purposes (and, where required by law, on the legal bases indicated):

To provide and operate the Services

Creating and managing accounts, providing access to features, enabling integrations, and providing customer support.

Legal bases (where applicable): performance of a contract, legitimate interests, or your consent.

To process transactions and manage billing

Handling payments, renewals, subscriptions, refunds, and accounting.

Legal bases: performance of a contract, legal obligations (e.g., tax), legitimate interests.

To communicate with you

Sending service-related notices, security alerts, support messages, and administrative communications. Providing updates about new features, products, or offers (where permitted).

Legal bases: performance of a contract, legitimate interests, your consent where required.

To support sales and marketing

Contacting prospects and customers about SAS products and related content; managing demos, webinars, events, and communications.

Legal bases: legitimate interests, consent (e.g., email/SMS marketing where required).

To personalize the Services and improve user experience

Tailoring content and experiences, including recommendations and interface adjustments.

Legal bases: legitimate interests, consent (for certain cookies/trackers).

To maintain security and prevent misuse

Detecting, investigating, and preventing fraud, abuse, security incidents, and other harmful activity; enforcing our Legal Terms.

Legal bases: legitimate interests, legal obligations.

To analyze and improve the Services

Conducting analytics, usage trends, quality assurance, and product development.

Legal bases: legitimate interests.

To comply with laws and legal processes

Responding to lawful requests, court orders, subpoenas; maintaining appropriate records.

Legal bases: legal obligations, legitimate interests.

We may aggregate or de-identify personal data so that it is no longer reasonably capable of identifying an individual. We may use and disclose such aggregated or de-identified data for any lawful purpose.

We do not sell personal data for money.

We share personal data only as described below:

Within SAS

With our employees, contractors, and affiliates who need access to the information to perform their roles, subject to confidentiality obligations.

With Service Providers and Vendors

With third-party providers that perform services for us, such as hosting, data storage, analytics, billing and payment processing, email and SMS delivery, identity verification, and customer support tools. These providers are contractually required to use personal data only as necessary to provide the services to us and to maintain appropriate security.

We do not sell, rent, share, or disclose mobile phone numbers, SMS opt-in data, text messaging originator opt-in data, or SMS consent records to third parties or affiliates for their own marketing or promotional purposes. We may share this information with service providers only as needed to deliver, support, secure, and document our SMS communications.

With Our Customers (for Customer Data)

When we act as a processor, we may access or disclose Customer Data in accordance with our agreement with the customer (for example, to provide support, investigate issues, or as instructed by the customer).

Business Transfers

In connection with a merger, sale of assets, financing, acquisition, reorganization, or similar transaction involving SAS, personal data may be disclosed or transferred as part of that transaction, subject to appropriate protections.

Legal and Safety Obligations

When required by law, regulation, or legal process (e.g., subpoena, court order, or government request); when we believe in good faith that disclosure is necessary to:

• Protect the rights, property, or safety of SAS, our customers, or others;
• Detect, prevent, or respond to fraud, security incidents, or illegal activity;
• Enforce our agreements or policies.

With Your Consent

In any other circumstance where you have consented to such sharing.

SAS is based in the United States, and personal data we collect may be stored and processed in the United States or other jurisdictions where we or our service providers operate.

If you are located outside the United States, your personal data may be transferred to a country that may not provide the same level of data protection as your home jurisdiction.

Where required by law, we will implement appropriate safeguards (such as standard contractual clauses or equivalent mechanisms) to protect your personal data and ensure that it is processed in accordance with applicable data protection laws.

We implement appropriate technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures may include:

• Access controls and authentication requirements;
• Encryption of data in transit (and, where appropriate, at rest);
• Network and application-level security controls;
• Logging and monitoring; and
• Policies, training, and contractual confidentiality obligations for personnel and service providers.

However, no security measure is perfect, and we cannot guarantee absolute security of information transmitted or stored using the Services.

You are responsible for:

• Maintaining the confidentiality of your account credentials; and
• Promptly notifying us of any unauthorized access or suspected breach involving your account.

We retain personal data for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by:

• Applicable law (e.g., tax, accounting, or regulatory requirements);
• Our contractual obligations with customers; and
• Our legitimate business needs (e.g., record-keeping, dispute resolution, and security).

When personal data is no longer required, we will delete, anonymize, or otherwise handle it in accordance with our data retention and deletion policies.

Your rights may vary depending on your jurisdiction, but typically include some or all of the rights below.

General Rights

Subject to applicable law, you may have the right to:

• Access your personal data we hold;
• Correct inaccurate or incomplete personal data;
• Delete or request deletion of personal data, in certain circumstances;
• Restrict or object to certain processing;
• Port your personal data in a structured, commonly used, and machine-readable format; and
• Withdraw consent where processing is based on your consent.

To exercise these rights, please contact us at privacy@salesautomation.systems. We may need to verify your identity before processing your request and may deny or limit requests where allowed or required by law (for example, when we must retain data for legal or contractual obligations).

If your data has been submitted to SAS by one of our customers and we process it as a processor, we may redirect your request to that customer.

Marketing Communications

You may opt out of receiving marketing emails by using the "unsubscribe" link in those emails or by contacting us directly. Even after you opt out of marketing communications, we may still send you transactional or service-related messages (e.g., account notices, security alerts).

Where applicable, you may also control SMS or phone-based marketing by replying STOP to any text message or following applicable instructions. For help with SMS communications, reply HELP or contact us directly.

Cookies and Tracking Technologies

You can manage cookies through your browser settings and, where available, through cookie preference tools on our Site. Please note that certain cookies are essential to the functioning of the Services, and disabling them may limit functionality.

Rights of EEA/UK/Swiss and Other Jurisdictions

If you are located in the European Economic Area (EEA), the United Kingdom, Switzerland, Brazil, or other jurisdictions with comprehensive data protection laws, additional rights may apply, including the right to lodge a complaint with a supervisory or data protection authority in your country of residence, place of work, or where an alleged violation has occurred.

We encourage you to contact us first so we can try to resolve your concerns.

California Privacy Rights

If you are a resident of California, you may have additional rights under the California Consumer Privacy Act (CCPA/CPRA), including:

• The right to know what categories of personal information we collect, the purposes for which we use them, and the categories of third parties to whom we disclose them;
• The right to request access to and deletion of your personal information (subject to certain limitations);
• The right to correct inaccurate personal information;
• The right to limit use and disclosure of certain sensitive personal information (if applicable); and
• The right to be free from discrimination for exercising your privacy rights.

No "Sale" or "Sharing" for Cross-Context Behavioral Advertising.

We do not "sell" your personal information for monetary consideration, nor do we "share" your personal information for cross-context behavioral advertising as those terms are defined by California law, based on our current data practices.

You or your authorized agent may submit requests under California law by contacting us at privacy@salesautomation.systems. We may need to verify your identity and residency before fulfilling your request.

The Site and Services may contain links to, or integrations with, third-party websites, services, or applications (for example, CRM integrations, telephony/SMS vendors, analytics tools, or payment processors).

We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you use in connection with our Services.

The Services are intended for business use and are not directed to children under the age of 16. We do not knowingly collect personal data from children under 16.

If we learn that we have collected personal data from a child under 16 without appropriate consent, we will take reasonable steps to delete that information and terminate the associated account.

If you believe a child has provided personal data to us, please contact us at privacy@salesautomation.systems.

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will:

• Update the "Last Updated" date at the top of this page; and
• Where appropriate, provide additional notice (such as via email or in-product notification), especially if the changes are material.

Your continued use of the Services after the effective date of any updated Privacy Policy constitutes your acceptance of the revised policy. If you do not agree to the changes, you must stop using the Services.

If you have any questions about this Privacy Policy or our privacy practices, please contact us: