Effective Date: April 1, 2026

This Privacy Policy applies to all products and services on all domains of Eltropy, Inc. and its affiliates (collectively referred to as “Eltropy”).

This privacy policy is applicable to any user signed or registered with or otherwise accessing or using Eltropy domains or sites, either directly or indirectly through some action of Eltropy’s customers, and is effective with respect to any data that Eltropy collected, or collects, about and / or from the user, according to the terms of the Software License Agreement and/or any other applicable agreements that may exist between Eltropy and its customers.

Changes to Privacy Policy:

This Privacy Policy may be updated periodically to reflect changes in Eltropy’s personal information practices with respect to the services or changes in applicable law. Eltropy will review this Privacy Policy periodically, at least on an annual basis. In case of any changes to this Privacy Policy, Eltropy will post them on the Eltropy website and indicate at the top of the Privacy Policy when it was most recently updated. The changes will be effective from the date posted on www.eltropy.com or as otherwise indicated to you in other communications from time to time. The most current version of the Privacy Policy will always be available here: https://eltropy.com/privacy-policy/

What Data is Collected:

Personal Information that you may provide or make available to us through the Services, or that we may generate about you, includes:

Contact Data:  This includes your first and last name, billing and mailing addresses, professional title and company name. 

Eltropy account data: With an Eltropy account, a user can sign into Eltropy services. All information including personal data provided by the user at the time of registering or sign-in is collected by Eltropy.

List and email information: When Eltropy users share collateral with their prospects and customers, from whom they have obtained express or implicit permission for such sharing activity, using either an email distribution list or a direct email, Eltropy has access to the data on the list and the information in the email. Email ID and names are collected and stored during this process.

Mobile Numbers: When Eltropy users share content with their prospects and customers, from whom they have obtained express consent or permission for such sharing activity, Eltropy has access to the data on the list and the information in the message. This applies when users share via Text Message (SMS) Distribution list or a direct Text Message (including but not limited to Short Messaging Services such as SMS, WhatsApp, LINE, LINEWORKS, FB Messenger, etc.) using, for example, either the Eltropy Messenger feature or Eltropy share feature. Mobile numbers and names are collected and stored during this process.

Customer Documents: When Eltropy users share a link with their customers for collection of documents, whether or not containing Personally Identifiable Information (PII), such documents are stored by Eltropy. Users also provide some data directly, such as when inviting another user, sharing a topic with a prospect, using the Eltropy Messenger feature, uploading content, or contacting Eltropy for support.

Operational Data: To operate effectively and provide users the best experiences with our services, Eltropy collects data on how and when our services are used. This operational data helps us improve platform performance, troubleshoot issues, and enhance user experience. This information may include but is not limited to users’ and prospects’ IP address, time, date, browser type, device information, actions and time taken by a user within the application, and error reports or usage data from software running on user devices. To send push notifications via text or similar applications, Eltropy stores device information such as Device ID and Device Serial Number

Communications and Session Data: When users interact with our platform, including through voice, video, or messaging features, Eltropy may collect and store communications data to provide the services and improve quality. This may include video and voice recordings, call and session logs, call transcripts, and associated metadata. This data is used to deliver requested features, provide customer support, and enhance service quality.

For any of the data types described above, Eltropy may also obtain such data about users from third parties or provide such data to third parties (which may include various business partners). For example, when enabled, users may provide information directly to Eltropy’s third-party vendors for account communications functionality or support-related tools. Eltropy may receive, access, or otherwise process that information in connection with providing its services, third-party services, support, and related operations. See “What third-party services do we use” and “Third-party links and products on our services” below for additional information. 

How Data is Used

Eltropy uses the information collected for the following purposes:

• To provide users services which includes using data to improve and personalize users’ experiences
• To communicate with users, among other things, to provide information about an account, security updates or product information
• To market our services and products, including to deliver promotional materials, information concerning product updates and new features, and other non-transactional communications via email
• To help make the insights shown to users more relevant
• To provide promotions and offers by way of direct marketing communications
• To analyze our products and services to help us better understand our customers in order to offer the most relevant communications, services and experiences to you
• To ask you for your opinions on our products and services and to carry out customer surveys, with your separate consent if required
• To provide software updates, maintenance services and support for products and services 
• To comply with the law and legal processes
• To protect the rights, property, or safety of Eltropy  and/or any of our partners, or customers

Eltropy processes personal information for the purposes described above. Eltropy’s legal basis to process personal information includes, without limitation:

• the Software License Agreement signed between Eltropy and each customer.
• So that we can keep our promises to you, such as providing you with services.
• To promote our business interests (for example, to manage our relationship with you and improve your customer service experience), including communications on our website, third party websites, and online platforms.
• To comply with the law and legal processes.
• With your consent (for example, to send direct marketing communications).

Eltropy does not use the information in emails and mobile numbers to prospects or uploaded content to target advertisements to users.

Eltropy does not, under any circumstances, sell users’ lists, or share such lists with any other party, unless required by law.

Who do we share your information with

Eltropy will disclose your information internally within our business, but only to those who need it to further provide services or to help with your requests.

We may also disclose your information as follows:

• Eltropy shares a user’s personal data with the user’s consent and/or as necessary to complete any transaction or provide any service the user has requested or authorized.
• Eltropy shares data with vendors working on our behalf.
• Eltropy shares data with companies which we control or own.
• Eltropy shares data with business partners who we work together with to provide you the services you’ve requested or bought. For example, we may work with a bank so that you can use one of our services to make faster and more efficient payments. These business partners may also control and manage your personal information.
• Eltropy shares data with carefully selected companies that provide services for or on our behalf, such as companies that help us with hosting our servers, hosting databases, providing SMS Gateway services which are part of service, customer contact centers, conducting customer satisfaction surveys, or billing, or that send emails on our behalf.
• Eltropy shares data with other parties when required by law or legal process or as necessary to protect our services: For example, it may be necessary by law, legal process, or court order from governmental authorities to disclose your information. Such parties may also seek your information from us for the purposes of law enforcement, national security, anti-terrorism, or other issues that are related to public security and/or it may also be necessary for the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences.
• Eltropy may also share data with other parties in connection with corporate transactions such as, but not limited to, a merger or transfer, acquisition or sale.
• Eltropy shares data with third parties when you separately consent to or request such sharing.

How do we keep your information secure

We take data protection seriously. We have put in place physical and technical safeguards to keep the information we collect secure. We’ve put secured controls such as SSL Security, multi-factor authentication, 256-bit encryption, personal data masquerading, VPNs to ensure that the personal data is safe and secure. However, please note that although we take reasonable steps to protect your information, no website, internet transmission, computer system, or wireless connection is completely secure.

If we become aware of a security incident, data breach, or other unauthorized access to personal information under our control, we will investigate the matter, take steps we determine are appropriate to contain, remediate, and mitigate the incident, and provide any notices required under applicable law. Where required by applicable law, we will notify affected individuals, customers, regulators, or other third parties within the timeframes and in the manner required by applicable law.

Where do we send your data

Your use of our services will involve the transfer, storage, and processing of your personal information within the United States and, potentially, certain other countries, consistent with this policy.

We will take appropriate measures, in compliance with applicable laws, to ensure that your personal information remains protected. Such measures include the use of standard contractual clauses as well as signing and enforcing data processing agreements with third parties.

What are your rights

• Your personal information belongs to you.
• Users can view or edit their own personal data online for many Eltropy services.
• How users can access or control their personal data will depend on which services they use.
• You can ask us to provide details about what personal information we have collected.
• You can ask us to provide details about how and what we have processed your personal information
• You can ask us with whom and where have we shared your personal information.
• You can ask us how long we are retaining your personal information.
• You can ask us to correct any inaccuracies in your personal information.
• You can ask us to delete your personal information.
• You can ask us to restrict or limit processing, sharing, or transfer of your personal information.
• You can ask us to provide to you your personal information that we have collected so you can use it for your own purposes.
• You can contact us directly or click unsubscribe at the bottom of our marketing emails, if you do not wish to receive such emails from us. 

However, requesting the deletion of your personal information may also result in a loss of access to services we provide. Also, we will not delete data that we are required by law to retain.

How long do we keep your information

We endeavor to not keep your personal information for longer than is necessary for the purpose for which it was collected. However, we also process and retain your information as follows:

1. At least the duration for which the information is used to provide you with a service; and
2. As required under law, a contract, or with regard to our statutory obligations; and
3. In accordance with our data retention policies as they may be modified from time to time.

When personal information is no longer required for the purposes described in this Privacy Policy, we will delete, anonymize, or dispose of it in accordance with applicable law and our records retention practices. We also use reasonable measures designed to support secure disposal or deletion of personal information, taking into account the nature of the information and applicable legal, regulatory, contractual, and operational requirements.

What third-party services do we use

Some of the content, and functionality in our services is provided by third parties. These third parties may use cookies, beacons, tracking pixels, and other tools to collect information about your use of these services. These third parties are not controlled directly by Eltropy, so we recommend that you check their privacy policies to understand how they use your data. For some apps and services, including social networks, we receive and store sign-in information, as well as other information that you allow us to receive when you connect with these apps and services.

Third-party links and products on our services

Our services may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by websites or other services. You should exercise caution and review the privacy statements applicable to the third-party websites and services you use. We also may make available to you certain products or services developed by third parties. Eltropy is not responsible for these third-party products or services.

Cookies, Beacons, and similar technologies

• Eltropy uses cookies (small text files placed on users’ and prospects’ devices) and similar technologies to provide services and help collect data.
• Cookies allow Eltropy, among other things, to store user preferences and settings; enable users to sign-in; provide insights into content usage; combat fraud; and analyze how Eltropy services are performing.
• Eltropy apps use other identifiers for similar purposes.
• Eltropy also uses web beacons to help deliver cookies and gather usage and performance data about our services.
• Our services may include web beacons and cookies from third-party service providers.
• Users have a variety of tools to control cookies, web beacons and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons.
• A user’s browser and other choices may impact experiences with our services.

Our services may link to third-party sites and services. We, as well as certain third parties that provide content or other functionality in our services, use cookies, pixels, beacons, and other technologies in certain areas of our services.

Cookies: Cookies are small files that store information on your computer, mobile phone, or other device. They enable the entity that put the cookie on your device to recognize you across different websites, services, devices, and browsing sessions. Cookies serve many useful purposes. For example:

• Cookies can remember your sign-in credentials, so you don’t have to enter those credentials each time you sign in to a service.
• Cookies help us and third parties understand which parts of our services are the most popular because they help us to see which pages and features visitors are accessing and how much time they’re spending on the pages. Analyzing this information helps us to adapt the services and provide you with a better experience.
• When you use a web browser to access services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the help menu of your browser to learn how to change your cookie preferences. Your device operating system may contain additional cookie controls. Note that some services are designed to work using cookies, so disabling cookies may affect your ability to use those services or certain parts of them.

Applicable Cookie List

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly. 

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. 

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance. 

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information. 

Beacons

We, along with certain third parties, may use technologies called beacons or pixels that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you’ve viewed particular content or a particular email message, and determine the time and date on which you viewed the beacon and the IP address of your device. We and certain third parties use beacons for a variety of purposes, including to analyze the use of our services.

Other Local Storage: We, along with certain third parties, may use other kinds of local storage technologies, such as Local Shared Objects (also referred to as Flash cookies) and HTML5 local storage, in connection with our services. These technologies are similar to the cookies discussed above. They’re stored on your devices and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your devices from standard cookies, so you might not be able to control them using standard browser tools and settings. For information about disabling or deleting information contained in Local Shared Objects, visit http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Children

As a company with a business-to-business focus, we do not knowingly collect personal information from or market to children under the age of 16. If you believe that we may have collected personal information from or about a child under the age of 16, please send an email to legal@eltropy.com with the subject line “Personal Information of a Minor.” 

Contact Us

You can contact us to update your preferences, correct your information, submit a request, or ask us questions.

The easiest way is through the Contact Us page at www.eltropy.com/contact-us

You can also contact us at:

Data Protection Officer, Eltropy Inc.

5201 Great America Parkway, Suite 510

Santa Clara, CA 95054, United States

legal@eltropy.com

California Privacy Rights

If you are a California customer, you have the right to receive, once per year, free of charge, 1) the identity of any third-party company to which we have disclosed your personal information as defined by California’s “Shine the Light” law for that company’s own direct marketing purpose; and 2) a description of the categories of personal information disclosed. 

To request this information, please contact us at legal@eltropy.com or the mailing address set forth in the section entitled “Contact Us.” Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email or mail address.  If you choose to exercise your rights set forth in this policy, you also have a right not to receive discriminatory treatment for exercising your rights.

For California residents, you can provide a CCPA “Do Not Sell” request to us by emailing us at legal@eltropy.comlegal@eltropy.com. 

Do Not Track Signals/Other Signals

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals and similar opt-out preference signals, such as Global Privacy Control (GPC). DNT is a way for users to inform websites that they do not want their webpage visits tracked. Since the industry and legal standard for what DNT means has not been confirmed, we currently do not respond to DNT signals. However, our website has been updated to recognize and honor GPC signals.