Privacy Policy

Thank you for using Saleshandy. At Saleshandy, your privacy is our priority. We are committed to protecting the confidentiality, integrity, and security of your personal data. For our email-related services, we do not store, sell, or transmit the content of your emails from within your inbox. However, we may collect metadata (such as recipient details and engagement data) strictly for providing those Services. For our Lead Finder product, we may provide professional contact details such as business email addresses and mobile numbers to subscribers, as explained in this Privacy Policy. Our platform complies with the latest Content Security Policy (CSP) guidelines, ensuring a secure browsing experience.

This Privacy Policy explains how we collect, use, and protect your personal data when you access or use our websites, products, services, and applications (collectively, the "Services"). It forms part of our Terms of Service, which can be accessed here. By using our Services, you acknowledge that we collect, use, and share personal data as described in this Privacy Policy.

Saleshandy is operated by IKIGAI INFOTECH LLP, which is the "Data Controller" for GDPR and UK-GDPR purposes. You may contact our Data Protection Officer (DPO) at privacy@saleshandy.com. We are ISO 27001:2022 certified and SOC 2 Type II compliant, ensuring that our systems and processes meet internationally recognized standards for confidentiality, integrity, and availability of data.

This Privacy Policy applies to the collection, use, and sharing of personally identifiable information ("Personal Data") we collect when you use our Services.

This Privacy Policy also applies to our browser extensions, including the Saleshandy Dialer Chrome Extension. The extension may detect phone numbers on webpages and allow users to initiate calls, log outcomes, add notes, save activity, and schedule follow-up tasks directly from their browser.

We do not knowingly collect or solicit personal data from children under the age of 16 (or lower if permitted by applicable local law, but never below 13). If you are under this age, please do not attempt to register for our Services or submit any personal data. If we discover that such data has been collected, we will delete it promptly. If you believe we may have collected data from a child, please contact us at privacy@saleshandy.com.

We process your Personal Data only when we have a lawful basis under Article 6 of the GDPR/UK-GDPR, including:

• Consent (where you have explicitly given permission),
• Contractual Necessity (where processing is necessary for a contract with you),
• Legal Obligation (when processing is required to comply with the law),
• Legitimate Interests (where processing is necessary for our legitimate business interests, as long as these do not override your rights).

We may update this Privacy Policy as our Services evolve. Changes will be posted on this page. Where required by law, we will provide additional notice of material changes.

We collect various types of data to provide our Services effectively. The following outlines the data we collect and its lawful basis for processing:

1. Personal Contact Details (Name, Address, Email, Phone Number)
   • Purpose: To sell and market our Services to interested customers.
   • Legal Grounds: Consent (Art. 6(1)(a)) or Contract (Art. 6(1)(b)).
2. Other Personal Details (Browser Type, Pages Visited, Device Information, IP Address, Location Data) — to provide and improve the functionality of our Services.
   • Purpose: To ensure and enhance the functionality of our services with fair usage.
   • Legal Grounds: Legitimate Interests (Art. 6(1)(f)).
3. Mobile Device Information (Device Type, OS, IP Address, Identifiers)
   • Purpose: To optimize mobile functionality.
   • Legal Grounds: Legitimate Interests (Art. 6(1)(f)).
4. Recipient Information (Contact Details of Recipients, Engagement Data)
   • Purpose: To fulfill service agreements.
   • Legal Grounds: Legitimate Interests (Art. 6(1)(f)) and Contract (Art. 6(1)(b)).
5. Call and Communication Data:
   • We may process call and communication data to provide click-to-call functionality, log activity, support call recordings where enabled, and sync relevant details with your account and connected CRMs.
   • Legal Grounds: Legitimate Interests under Article 6(1)(f) GDPR and Performance of a Contract under Article 6(1)(b) GDPR.

In addition to our core Saleshandy services, we also offer a product called Lead Finder, which provides subscribers with professional contact information such as names, job titles, company details, business email addresses, and mobile numbers. This data is collected from publicly available sources, licensed third-party providers, and lawful enrichment processes, and is shared only with subscribers according to their subscription plan. The purpose of providing this data is to enable legitimate business outreach, and the lawful basis for processing includes Legitimate Interests (Art. 6(1)(f) GDPR) and Contractual Necessity (Art. 6(1)(b) GDPR). While we take steps to ensure compliance with applicable data protection regulations (including GDPR, UK-GDPR, and CAN-SPAM), subscribers are solely responsible for using Lead Finder data in a lawful manner and must not engage in spamming, harassment, or other prohibited activities.

The information collected is used to maintain and improve the service. For example, it allows you to save settings or modify aspects of the service based on anonymous usage statistics. Information about support issues may be anonymously used as examples or to provide better support in the help center or FAQ. We will ask you for your permission before your information is used for any purpose not covered in the Privacy Policy.

• To personalize your experience, i.e., your information helps us to better respond to your individual needs;
• To improve our Services, i.e., we continually strive to improve our service based on the information and feedback we receive from you;
• To improve customer service, i.e., your information helps us to more effectively respond to your support needs;
• To contact you: by email, telephone calls, SMS, or other equivalent forms of electronic communication (such as mobile app push notifications) regarding updates or informative communications related to functionalities, products, or contracted services, including necessary or reasonable security updates.

The lawful basis for each type of processing is either consent, performance of a contract, compliance with legal obligations, or legitimate interests as described above.

Any data that we do have will never be shared except under the circumstances described below in Data Disclosure.

We do not sell, trade, or transfer your personal information except as outlined here. Trusted third parties may have access to your data in connection with their services for Saleshandy, provided they adhere to confidentiality obligations. We may also release your information if required to comply with the law or protect our rights.

If we transfer your Personal Data outside the EEA or UK, we ensure that appropriate safeguards, such as Standard Contractual Clauses (SCCs) or adequacy decisions, are in place to ensure lawful transfer.

Currently, Saleshandy does not offer email warming services for any Email Service provider, but this may change in the future. Please stay updated on our offerings.

This section applies to the Saleshandy Dialer Chrome Extension and supplements the rest of this Privacy Policy.

The extension is designed to detect phone numbers on webpages and allow users to make and manage calls from their browser, including logging call outcomes, adding notes, saving activity details, and scheduling follow-up tasks.

To provide this functionality, the extension may request permissions such as activeTab, host permissions, storage, scripting, and notifications. These permissions are used to detect phone numbers, display click-to-call options, store user preferences and session data, support extension functionality, and send call-related alerts or reminders.

We use data accessed through the extension only to provide or improve its stated functionality and in accordance with the Chrome Web Store User Data Policy, including the Limited Use requirements.

The Saleshandy Dialer Chrome Extension scans visible webpage content locally in your browser to identify phone number patterns. We do not transmit, store, or analyze the full contents of webpages you visit.

When you use the extension, we may process limited data needed to provide click-to-call functionality, including phone numbers you choose to call, call metadata, call outcomes, notes, tags, dispositions, follow-up tasks, authentication/session identifiers, and, where applicable, the page URL for CRM activity logging.

Calls made through the Saleshandy Dialer may be recorded where recording is enabled by the user or account administrator. Users are responsible for obtaining any required consent and complying with applicable call recording laws in their jurisdiction and the call recipient's jurisdiction.

Call recordings are stored securely and are accessible only to authorized account users. In limited cases, authorized Saleshandy personnel may access recordings on a need-to-know basis to provide, maintain, troubleshoot, secure, improve, or support the Service, comply with legal obligations, enforce our terms, or prevent fraud or abuse. Such access is subject to internal confidentiality controls and our Privacy Policy and Data Processing Agreement.

Calls made through the Saleshandy Dialer may be routed through third-party telephony service providers, such as VoIP and call infrastructure providers. These providers may process call signaling, audio, call metadata, and related technical data on our behalf to enable calling functionality.

Where required, such providers act as our sub-processors and are subject to contractual confidentiality, security, and data protection obligations consistent with applicable law, our Data Processing Agreement, and this Privacy Policy.

When you connect the Saleshandy Dialer to a third-party CRM or platform, such as HubSpot, Salesforce, Pipedrive, or Zoho, we may sync call activity, notes, tasks, and related details to that platform at your direction.

Your use of any connected third-party service is governed by that service's own terms and privacy policy. Saleshandy is not responsible for the privacy or security practices of third-party services, except for data we transmit to them on your instruction.

The Saleshandy platform includes an in-app Dialer that allows users to place voice calls directly from the Saleshandy web application. This feature is separate from the Saleshandy Dialer Chrome Extension but is subject to the same data protection standards described in this Privacy Policy.

To use the in-app Dialer, your browser may request access to your device's microphone. Microphone access is used only to capture and transmit your voice during an active call and is not used when you are not on a call. You may revoke this permission at any time through your browser settings, but doing so may prevent you from using the in-app Dialer.

Call audio is transmitted in real time through our telephony service providers to enable the call. We do not retain live call audio unless call recording is enabled. Where call recording is enabled, recordings are handled as described in the "Call Recordings and Consent" section of this Privacy Policy.

Saleshandy's use and transfer of data collected or accessed through the Saleshandy Dialer Chrome Extension, including any data received from Google APIs, will comply with the Chrome Web Store User Data Policy and Google API Services User Data Policy, including the Limited Use requirements. Specifically, we affirm that we will not:

• sell user data;
• use or transfer user data for advertising, retargeting, or interest-based ads;
• use or transfer user data for purposes unrelated to the extension's disclosed click-to-call and post-call workflow functionality;
• allow human access to user data except with user consent, for security or abuse prevention, to comply with law, or where data is aggregated and anonymized for internal operations.

We protect your data through encryption, access controls, and administrative, physical, and technical safeguards. Data is encrypted using TLS in transit and AES-256 at rest, where applicable. While no system can guarantee complete security, we take reasonable steps to protect personal data from unauthorized access, loss, misuse, or alteration.

Our ISMS is certified to ISO 27001:2022, and we operate under SOC 2 Type II controls, independently audited for compliance.

Data processed through the Saleshandy Dialer Chrome Extension is protected using the security measures described in this Privacy Policy. Call recordings, notes, and call activity logs are encrypted in transit and at rest. Access is limited to authorized users within the relevant account and authorized Saleshandy personnel on a need-to-know basis.

Where applicable, these controls are maintained under Saleshandy's ISO 27001:2022 and SOC 2 Type II security and compliance programs.

This Privacy Policy and practices are reviewed annually as part of SOC 2 Type II and ISO 27001:2022 audits.

We work with compliance partners, including Sprinto, who support us in maintaining certifications; however, they do not access or process customer personal data.

We neither rent nor sell your Personal Information to anyone. However, we may share your Personal Information with third parties as described in this section:

Group Accounts: If your Saleshandy Account is managed by a company or group administrator, then the administrator or their agents may have access to your account information, as well as all information and stats contained within your account. They may also have the ability to change information, settings, restrict or suspend access to, or terminate your Saleshandy account. Legal Grounds: Contract (Art. 6(1)(b)).

Agents and vendors: We employ other companies and people to perform tasks on our behalf and need to share your information with them, including, in some cases, the Personal Information you have provided to us, in order to make the Services available to you. For example, we may use third-party hosting providers, telephony/VoIP providers, or software developers to help implement and maintain the Services. However, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Legal Grounds: Contract (Art. 6(1)(b)).

Business Transfers: If we are involved in a reorganization, merger, acquisition, or sale of assets, your information may be transferred as part of that deal. In such cases, we will notify you in advance and provide you with options regarding your Personal Data. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event. Legal Grounds: Legitimate Interests (Art. 6(1)(f)).

Protection of Saleshandy and Others: We may access, preserve, or disclose information where necessary to comply with law or legal process, enforce our terms or agreements, protect rights, property, or safety, prevent fraud or abuse, or maintain platform security. Legal Grounds: Legal Obligation under Article 6(1)(c) GDPR and Legitimate Interests under Article 6(1)(f) GDPR.

You have the right to access, update, or request the deletion of your personal data, as allowed by law. If your data is being processed based on your consent, you can withdraw that consent, ask for your data to be transferred, or limit how it's processed. For more information, feel free to contact us at privacy@saleshandy.com.

If you'd like to have your personal information, such as business emails, mobile numbers, or other contact details, removed from our Lead Finder database, just reach out to us at privacy@saleshandy.com. We'll take the necessary steps to remove your details from our system, following your request.

Please note, we may need to verify your identity before processing these requests, to ensure we're acting in your best interest. Once verified, we'll promptly work to remove the requested information, subject to applicable laws and contractual requirements.

We retain Personal Data for as long as your account is active and only for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, enforce agreements, collect fees owed, maintain security, or as otherwise permitted or required by applicable law.

Retention periods are reviewed regularly to support compliance with applicable laws. After the applicable retention period, we may retain information in a depersonalized or aggregated form that does not identify you personally.

User signup data, such as your name, email address, and the fact that you were a Saleshandy user, may be retained in third-party analytics services after account closure unless you request deletion, subject to applicable laws and contractual requirements.

Call recordings, notes, and activity logs created through the Saleshandy Dialer Chrome Extension or in-app Dialer are retained in accordance with your subscription agreement, account settings, and applicable retention policies. We may retain this data for a longer period where required by law, to resolve disputes, enforce agreements, maintain security, or comply with legal obligations.

Whenever you interact with our Services, we automatically receive and record information from your browser or device, which may include cookie information.

Cookies are identifiers transferred to your browser or device that allow us to recognize your browser or device and understand how and when pages and features in our Services are visited. For more information on our cookies and their expiration times, please review our Cookie Policy.

As an EU or UK resident, you have specific rights over your personal data: You can request access to the data we hold about you, ask us to correct any inaccurate or incomplete information, and in some cases, request the deletion of your data. You can also ask us to limit how we use your data, request it in a structured, machine-readable format for portability, and, if possible, transfer it to another provider. If our processing is based on your consent, you have the right to withdraw it at any time (though some services may require fresh consent to continue). Additionally, you can object to certain types of processing, including direct marketing.

To exercise any of these rights, please contact us at privacy@saleshandy.com.

We may need to confirm your identity before we act on your request. If we cannot meet your request, we'll explain why.

• EU Representative — Ametros Ltd, Commerce House, Washington Street West, Cork, Ireland. Email: gdpr@ametrosgroup.com · Website: www.ametrosgroup.com
• UK Representative — Ametros Group Ltd, Lakeside Offices, Thorne Business Park, Hereford, England. Email: gdpr@ametrosgroup.com · Website: www.ametrosgroup.com

Our Services are hosted in the United States through Saleshandy and its service providers. If you reside outside the United States, please note that the laws of the United States may differ from those in your country of residence. By using the Services, you acknowledge and agree that any personal data about you, whether provided directly by you or obtained from a third party, may be transferred to, stored in, and processed within the United States and potentially in other countries where our service providers operate.

Whenever we transfer your personal data outside of the European Economic Area (EEA) or the United Kingdom, we implement appropriate measures to ensure that such transfers comply with applicable data protection laws and that your data remains safeguarded to European standards. These measures may include reliance on the European Commission's Standard Contractual Clauses (SCCs), adequacy decisions (where available), and adherence to internationally recognized security frameworks such as SOC 2 Type II and ISO 27001:2022, which provide for encryption, access controls, and secure data handling.

You may request further information regarding the safeguards we apply to international data transfers and, where applicable, obtain a copy of the relevant contractual or protective measures by contacting us at privacy@saleshandy.com.

This Privacy Policy applies to all services offered by IKIGAI INFOTECH LLP through Saleshandy. This Privacy Policy does not apply to third-party services, websites, platforms, or integrations that are not owned or controlled by Saleshandy. Your use of those third-party services is governed by their own terms and privacy policies.

If you have any questions about this Privacy Notice or our data practices generally, please contact us using the following information:

Name: Saleshandy – IKIGAI INFOTECH LLP

Physical address: 502, 503 Dwarkesh Business Hub, Opp. Visamo Society, Visat Gandhinagar Highway, Motera, Chandkheda, Ahmedabad, Gujarat 382424

Email address for contact: privacy@saleshandy.com