Privacy Policy

Effective Date: October 17, 2026  |  Last Updated: October 21, 2026

1. Our Two Roles

• As a business (controller): we are responsible for personal information about our own customers, account users, trial users, website visitors, and prospects. For example, account details, billing information, support requests, and website usage.
• As a service provider (processor): when our customers (businesses using the Service) store information about their End Customers, contacts, leads, and callers, we process it on their behalf and only under their instructions. That business is responsible for its own privacy practices. If you are an End Customer of a business that uses Propello Suite, please contact that business directly to exercise your privacy rights. We will help it respond.

2. Information We Collect

2.1 Information You Provide

• Account and profile: name, business name, email, phone number, address, role, password (stored only as a secure hash), and the verified mobile number used for trial access.
• Billing: billing contact, billing address, tax details, and subscription history. Card numbers are collected and stored by our payment processor, not by us. We only receive limited details such as card brand, last four digits, and expiry.
• Business data: customers, contacts, quotes, orders, invoices, products, pricing, decorator price lists, artwork and files, proofs and approvals, storefront and portal content, messages, and notes you enter or upload.
• Communications: support requests, chat messages with us, survey responses, and feedback.

2.2 Information Generated When You Use Features

• Email: messages, headers, attachments, and metadata from mailboxes you connect, and delivery, open, click, bounce, and unsubscribe events for emails sent through the Service.
• Messaging and calls: SMS and WhatsApp content, phone numbers, call recordings, AI transcripts, call duration, and call outcomes.
• AI features: the inputs you submit (such as prompts, emails, orders, images, and voice audio) and the resulting output (such as drafts, summaries, classifications, images, and suggestions).
• Lead discovery and enrichment: when you search for prospects or enrich records, we retrieve publicly available business information (such as business name, website, address, business phone, and business email) from public directories, maps listings, search results, and company websites, and save it to your account.
• Search visibility and website audits: keywords, locations, public search results, competitor listings, and website data related to the businesses you analyze.
• Shipping: addresses and package details sent to obtain shipping rates and labels.

2.3 Information from Connected Services

When you connect a third-party service, we receive the data you authorize, such as accounting records (customers, invoices, items, payments), calendar events, contacts, social media page details, analytics and search console data, business profile data, or data imported from other software. We store authorization tokens encrypted at rest.

2.4 Information Collected Automatically

• IP address, browser, device, operating system, approximate location, referring pages, pages viewed, features used, and timestamps.
• Cookies and similar technologies (see Section 9).
• During free trials, navigation and export activity, used to detect scraping, reverse engineering, and abuse. This monitoring stops when an account converts to a paid plan.

2.5 Google User Data (Sign-In and Connected Google Services)

When you choose Sign in with Google or connect Google services (such as Gmail or Google Workspace mail, Google Calendar, or Google Contacts), we access Google user data only after you grant permission on Google's consent screen. Depending on the features you enable, we receive:

• Sign-in: your Google account ID, name, email address, and profile picture, used to authenticate you and to create or link your account.
• Gmail / Google Workspace mail: email messages, headers, attachments, and mailbox metadata needed to send, receive, organize, and display mail in the Service.
• Google Calendar: events and related metadata, used to display and sync schedules.
• Google Contacts: names, email addresses, phone numbers, and related fields that you authorize us to import or sync.

We use Google user data only to provide the features you connect. We do not use it for advertising, we do not sell or rent it, we do not use it to train general AI models, and humans do not read it except with your consent, for security purposes, or where the law requires. Google user data is isolated to your account. You can revoke access at any time in your account settings or under Google Account permissions.

2.6 Facebook and Instagram Data (Meta Platforms)

If you connect a Facebook Page or a linked Instagram Business or Creator account to publish marketing content, we access Meta data only after you grant permission on Facebook's consent screen. We receive and store:

• Page and account identifiers: the Facebook Page ID, name, and category, and the linked Instagram Business account ID, username, and profile picture URL.
• Access tokens: long-lived Page access tokens (encrypted at rest), granted permission scopes, and token expiry.
• Publishing records: the captions, images, and links you approve, and the post identifiers that Meta returns.

We request only pages_show_list, pages_manage_posts, pages_read_engagement, instagram_basic, instagram_content_publish, and business_management. We do not read your personal profile, friends list, private messages, or advertising data. Meta data is isolated to your account, is never sold or rented, and is not used to train general AI models. Posts are published only after an authorized user approves them. You can disconnect at any time under Marketing → Channels, which immediately erases the stored token, or in your Facebook Apps and Websites settings. See our User Data Deletion Instructions.

3. How We Use Information

• Provide the Service: operate accounts, run the features you use, sync connected services, send messages and make calls you initiate, publish content you approve, and process payments.
• Billing and account management: charge fees, calculate taxes, prevent fraud, and send receipts and notices.
• Support: respond to requests and troubleshoot. Our staff access your account data only as needed for support, security, or legal reasons.
• Security and abuse prevention: detect and prevent fraud, spam, attacks, trial abuse, and breaches of our Terms.
• Improve the Service: analyze usage, mainly in aggregated or de-identified form, to fix issues and improve features.
• Communicate with you: send service, security, and billing messages, and, with consent where the law requires it, marketing messages that you can unsubscribe from at any time.
• Legal compliance: meet legal, tax, accounting, and regulatory obligations, and enforce our agreements.

4. How We Share Information

We share personal information only as follows:

• Service providers who process data on our behalf under contracts that require confidentiality and security, and that limit use to providing their services to us:
  • cloud hosting, databases, file storage, and backups;
  • network security, content delivery, and bot protection;
  • email delivery and email-address verification;
  • SMS, WhatsApp, and voice networks (including the shared numbers used during trials);
  • AI model providers for text, image, speech, and transcription features;
  • search, maps, and public business-data providers (we send search terms, locations, and business names or domains, not your End Customers' full records);
  • payment processing and sales-tax calculation;
  • shipping-rate and label providers;
  • website analytics, error monitoring, and customer support tools;
  • IP geolocation lookups (we send IP addresses only to obtain approximate country, region, and city for campaign click and visit reporting).
• Integrations you connect: data you direct us to exchange with your accounting, payment, email, calendar, social media, telephony, or other connected services.
• The business you deal with: if you are an End Customer, with the business that operates the storefront, portal, or communication.
• Legal and safety: where required by law or legal process, or where necessary to protect rights, safety, or the security of the Service.
• Business transfers: to a successor in a merger, acquisition, financing, or sale of assets, under equivalent protections and with notice to you.

A list of our service-provider categories and their processing locations is available on request at [email protected].

5. International Transfers

We are based in Canada, and our primary infrastructure is located in Canada and the United States. Some service providers (for example, AI and messaging providers) may process data in other countries. When information is processed outside your province or country, it is subject to the laws of that jurisdiction and may be accessible to its courts and authorities. We use contractual and security safeguards to protect it, and we assess transfers as required by applicable law (including Québec law).

6. Retention

• Account and business data: kept while your account is active. After the account closes, it is available for export for 30 days and then deleted. Backups are overwritten on our normal schedule.
• Trial accounts that do not convert: may be deleted 30 days after the trial ends. Trial messages, recordings, and call logs on shared numbers are deleted daily.
• Call recordings and transcripts: kept for the period you configure (90 days by default).
• Connected-service tokens: deleted immediately when you disconnect the service.
• Integration sync logs: 12 months, for auditing.
• Billing and tax records: kept for as long as tax and accounting laws require (generally 7 years).
• Security logs and unsubscribe records: kept as long as needed to protect the Service and to honor opt-outs.
• Email campaign engagement (opens, clicks, website visits, approximate location, and sign-ups attributed to a campaign): individual events (including IP-derived country, region, and city on clicks and consented site visits) are kept for 24 months, after which only campaign totals remain. Visitor codes in campaign links stop linking visits after 30 days.
• Google Analytics: visitor-level data is kept in Google Analytics for 14 months.

7. Security and Breach Notification

• Encryption in transit (HTTPS/TLS), and encryption at rest for credentials, tokens, and payment keys.
• Passwords stored only as salted hashes, role-based access controls, separation of each customer's data, and restricted, logged staff access.
• A firewall, DDoS protection, monitoring, and regular updates.

No system is perfectly secure. If a breach of security safeguards creates a real risk of significant harm, we will notify affected individuals, our customers, and regulators as required by law (including PIPEDA and Québec Law 25).

8. Your Rights

Depending on where you live, you may have the right to access your personal information, correct it, delete it, receive it in a portable format, withdraw consent, object to or restrict certain processing, and opt out of marketing. This includes rights under PIPEDA, Québec's Act respecting the protection of personal information in the private sector, U.S. state privacy laws, and the GDPR and UK GDPR where they apply. We do not sell or "share" personal information for cross-context behavioral advertising, and we do not make decisions with legal or similarly significant effects about you based solely on automated processing.

To make a request, email [email protected]. We may need to verify your identity. We respond within 30 days, or within the time the law requires. You may also complain to the Office of the Privacy Commissioner of Canada, the Commission d'accès à l'information du Québec, or your local authority. Step-by-step deletion instructions are on our User Data Deletion Instructions page.

Public business information: if your business contact details were saved to a customer's account through lead discovery or enrichment, you may contact that business or us to ask what is held and to request correction or deletion. We will forward the request or act on it as the law requires.

9. Cookies and Similar Technologies

• Essential: sign-in, security, load balancing, and fraud and bot prevention. These are required.
• Functional: preferences such as language, layout, and your cookie choice.
• Analytics (off by default): on public marketing and storefront pages, we measure visits with first-party Propello analytics (time on site and pages viewed for visitors who came from an email campaign) and, when connected, Google Analytics. Both load only after you click Accept in our cookie banner. We turn off Google signals and advertising personalization, and we do not send your name or email address to Google.
• Email tracking: emails sent through the Service may contain pixels and tracked links that measure opens and clicks (see Section 9.1).

If your browser sends a Global Privacy Control signal and you have not made a choice, we treat it as a refusal. You can change or withdraw your choice at any time with the Cookie Settings link at the bottom of our pages. Your choice is kept for 12 months. You can also block or delete cookies in your browser, but essential features may stop working.

9.1 Email Campaign Measurement

When we, or a business using the Service, send you a marketing email, the links in it pass through our servers so that clicks can be counted. Links to the sender's own website carry campaign tags (utm_ parameters) and a random visitor code that is not derived from your email address. The website removes the code from the address bar as soon as the page opens, so it is never sent to Google Analytics.

• Every click (consent not required): we record that the link was clicked, the time, browser type, and your IP address. We derive an approximate location (country, region or province, and city) from the IP address using a geolocation lookup service so senders can see where engagement is coming from in aggregate. We do not use this to identify you by name from the click alone, and we do not store your email address in the click log.
• If you accept analytics on a public page: the visitor code and campaign tags are stored in a first-party cookie (pp_attr) for up to 30 days. We also measure your visit on that site's public pages only (not the logged-in app) with first-party Propello analytics: pages viewed, time on site, and the same approximate location from your IP. Your choice is stored in the pp_consent cookie for 12 months.
• Conversions: if you then submit a form on that website (for example, a sign-up request), the submission can be linked to the email you received when attribution cookies are active, so the sender can see which messages lead to sign-ups.
• Google Analytics (optional): if the sender has connected it, Google Analytics receives only campaign-level tags (which campaign and which link), never the visitor code or your contact details. Senders see campaign statistics in aggregate in the Service.

Rejecting analytics in the cookie banner stops first-party visit measurement and attribution cookies; it does not stop click counting or IP-based approximate location on clicks. Unsubscribing from the emails stops future tracking from those messages.

Geolocation lookups use your IP address only; results are cached briefly on our servers. We do not sell location data.

10. Children

The Service is for businesses and is not directed to anyone under 16. We do not knowingly collect children's personal information. If we learn that we have collected it, we delete it.

11. Changes to This Policy

We may update this Policy and will post the new version with a new "Last Updated" date. For material changes, we will notify account holders by email or in-app before the changes take effect.

12. Contact and Privacy Officer

Our Privacy Officer is responsible for our compliance with this Policy, and is also the person in charge of the protection of personal information under Québec law.

• Company: Propello Inc. (Attention: Privacy Officer)
• Privacy: [email protected]
• Support: [email protected]
• Website: https://propellosuite.com