1. Scope
This Privacy Policy explains how LO Marketing Tools, operated by [LEGAL ENTITY NAME] (“Company,” “we,” “us,” or “our”), processes personal information in connection with our websites, hosted software, applications, APIs, integrations, support, and related services (the “Services”).
When a business customer uses the Services to process information about contacts, prospects, customers, agents, employees, or other individuals (“Customer Data”), that customer generally determines the purposes and means of the processing and is responsible for its own notices, legal bases, permissions, and compliance obligations.
2. Our Roles and Customer Data
Depending on context, we may act as a business/controller for information concerning our own customers and website visitors and as a service provider/processor for Customer Data processed on behalf of a customer. Our Data Processing Addendum governs processing where we act as processor or service provider.
3. Information We Collect
Account and business information
Names, business names, job titles, email addresses, telephone numbers, billing contacts, account credentials, subscription information, and communications with us.
Usage, device, and security information
IP address, browser/device information, login activity, timestamps, pages/features used, diagnostics, logs, approximate location derived from IP, and security events.
Customer Data
Contact records, business/professional information, real estate activity, campaign information, message content, templates, replies, conversation history, suppression information, consent records, CRM records, and other customer-selected information.
Integration data
Authentication tokens, API credentials or references to credentials, account identifiers, configuration settings, message metadata, delivery events, replies, and data needed to operate customer-enabled integrations.
Public and licensed data
The Services may include business, professional, property, transaction, listing, or other information obtained from public sources, data providers, licensors, customers, or partners. The presence of such data does not establish marketing consent.
4. How We Use Information
We may use information to provide and secure the Services; authenticate users; process subscriptions; operate integrations; deliver requested functionality; maintain logs and audit records; prevent fraud, abuse, spam, and security incidents; provide support; communicate about the Services; improve reliability and usability; enforce agreements; comply with law; and protect rights and safety.
We may create aggregated or de-identified information that cannot reasonably identify an individual and use it for lawful business purposes.
5. Connected Services, Communications Providers, and AI
Customers may connect third-party email, SMS, telecommunications, AI, CRM, cloud, or other providers (“Third-Party Services”). When enabled, information may be transmitted to and processed by that Third-Party Service under the customer's account and the third party's own terms and privacy practices.
Enabling an integration does not make any communication lawful or permitted. Customers remain responsible for recipient eligibility, consent, content, sender identification, opt-outs, suppression, registration, provider policies, and other requirements.
If a customer enables AI functionality, Customer Data may be sent to the AI provider selected or enabled by the customer to perform the requested feature. Customers must be authorized to submit that data and should review the provider's terms and data practices.
6. How We Disclose Information
We may disclose information to vendors supporting hosting, security, analytics, billing, support, communications, and infrastructure; to customer-selected Third-Party Services; to professional advisers; in a financing, merger, acquisition, reorganization, or asset sale; when required by law; or when reasonably necessary to investigate abuse, enforce agreements, protect safety, or defend rights.
7. Cookies and Analytics
Our websites may use cookies, local storage, pixels, and similar technologies for authentication, preferences, security, functionality, analytics, and, if implemented, marketing. Where required, we will provide appropriate choices or consent mechanisms.
8. Retention and Deletion
We retain information as reasonably necessary to provide the Services, maintain security and audit records, comply with legal obligations, resolve disputes, enforce agreements, and protect legal rights. Following termination, Customer Data may be deleted or de-identified under our standard processes, subject to backups, legal holds, security records, fraud prevention, and lawful retention needs.
9. Security
We use administrative, technical, and organizational safeguards designed to protect information appropriate to the nature of the Services. No system is completely secure. Customers are responsible for securing their accounts, credentials, connected provider accounts, users, devices, and configurations.
10. Privacy Rights
Depending on where you live, you may have rights to access, correct, delete, port, restrict, or object to processing. We may verify identity and may deny or limit requests where permitted by law. Requests concerning data controlled by one of our customers should generally be directed to that customer.
11. California Privacy Disclosures
California residents may have rights under the CCPA, including rights to know/access, correct, delete, and receive information about certain disclosures, subject to exceptions. When we process personal information solely as a service provider or contractor for a customer, the customer is responsible for applicable consumer requests.
If our future practices constitute “selling” or “sharing” under the CCPA, or involve covered sensitive-personal-information uses, we will provide legally required notices and choices. This section must be checked against the Company's actual production advertising, analytics, and data-monetization practices before launch.
12. International Transfers
Information may be processed in the United States and other countries where we or our service providers operate. Where required, we will use an appropriate transfer mechanism. The DPA addresses Customer Data transfers where applicable.
13. Children
The Services are designed for businesses and are not directed to children under 18. Customers may not intentionally use the Services to market to children in violation of law.
14. Changes
We may update this Policy and will revise the “Last updated” date. Where required, we will provide additional notice of material changes.
15. Contact
Privacy requests: [PRIVACY EMAIL]
[LEGAL ENTITY NAME]
[MAILING ADDRESS]