Privacy Policy & Data Processing Addendum (DPA)

Retention Systems

Last Updated:

Introduction

This Privacy Policy and Data Processing Addendum (“Policy”) describes how Gingivital LLC d/b/a Retention Systems (“Retention Systems,” “Company,” “we,” “us,” or “our”) collects, uses, processes, and discloses information when you access or use our website, software platform, and related services (collectively, the “Service”).

By using the Service, you agree to the practices described in this Policy.

1. Interpretation and Definitions

Interpretation

Capitalized terms have the meanings defined below, regardless of whether they appear in singular or plural form.

Definitions

Account
A unique account created to access the Service.
Affiliate
An entity controlling, controlled by, or under common control with another entity.
Client
Any individual or legal entity using the Service.
Client Customer Data
Personal Data uploaded by Clients relating to their customers, leads, or contacts.
Company
Gingivital LLC, 128 North Division St., New York, United States.
Cookies
Small files placed on your Device to enable functionality and analytics.
Country
United States (New York).
Controller
The entity determining the purposes and means of processing Personal Data.
Device
Any device capable of accessing the Service.
Personal Data
Information relating to an identified or identifiable individual.
Processor
The entity processing Personal Data on behalf of a Controller.
Service
The Retention Systems website and software platform.
Service Provider
Third parties that process data on behalf of the Company.
Usage Data
Data collected automatically through use of the Service.
You
The individual or entity using the Service.

2. Scope of This Policy

This Policy applies to:

This Policy does not govern how Clients collect or use their own customers’ data outside the Service.

3. Roles of the Parties (CRITICAL)

4. Information We Collect

4.1 Personal Data (Account & Platform Data)

We may collect:

  • Name
  • Email address
  • Phone number
  • Business name
  • Address and billing details
  • Login credentials
  • Support communications

4.2 Client Customer Data

Clients may upload:

  • Customer phone numbers
  • Email addresses
  • Names
  • Message content
  • CRM notes and metadata

This data is processed solely on Client instructions.

4.3 Usage Data

Collected automatically:

  • IP address
  • Browser type
  • Pages visited
  • Device identifiers
  • Session data
  • Diagnostic and performance logs

5. Cookies and Tracking Technologies

We use:

You may disable cookies via your browser, but some features may not function properly.

6. How We Use Data

We use Personal Data to:

7. Messaging, SMS, Email, and Automation Processing

Retention Systems enables Clients to send SMS, MMS, email, and automated communications to their own customers.

Clients are solely responsible for compliance with applicable laws and requirements, including TCPA, CAN-SPAM, CASL, GDPR (where applicable), and A2P 10DLC and carrier requirements.

8. Data Sharing

We may share Personal Data with:

We do not sell Personal Data.

9. Data Retention

10. International Data Transfers

Data may be processed outside your jurisdiction. Appropriate safeguards are used, including contractual protections.

11. Your Data Rights

Depending on jurisdiction, you may have rights to access your Personal Data, request correction or deletion, or restrict processing.

Requests relating to Client Customer Data should be directed to the Client who collected the data.

12. Security

We implement commercially reasonable safeguards, including access controls, secure infrastructure providers, and monitoring and abuse prevention. No system is 100% secure.

13. Third-Party Service Providers

We may use providers such as cloud hosting providers, messaging and email delivery services, payment processors, and support platforms. Each provider processes data under its own privacy obligations.

14. Children’s Privacy

The Service is not intended for individuals under 13. We do not knowingly collect data from children.

16. Changes to This Policy

We may update this Policy periodically. Changes take effect when posted with a revised “Last Updated” date.

17. Contact Information

Email: greg.ss1000@gmail.com

Phone: (315) 857-4934

Data Processing Addendum (DPA)

This Data Processing Addendum (“DPA”) forms part of the agreement between Retention Systems and the Client. This DPA applies to Retention Systems’ Processing of Personal Data on behalf of the Client in connection with the Service.

A. Scope and Purpose

Retention Systems processes Personal Data solely to provide the Service, including CRM, messaging, automation, analytics, and support.

B. Client Obligations

The Client represents and warrants that:

  • All data is lawfully collected.
  • Proper consent and/or legal basis has been obtained where required.
  • Processing instructions comply with applicable laws.
  • Messaging complies with applicable laws and requirements, including TCPA, CAN-SPAM, GDPR (where applicable), and carrier rules such as A2P 10DLC.

C. Processor Obligations

  • Process Personal Data only on documented instructions from the Client.
  • Ensure personnel authorized to process Personal Data are bound by confidentiality obligations.
  • Implement commercially reasonable technical and organizational security measures.
  • Assist the Client with lawful data subject requests where feasible and appropriate.

D. Sub-processors

The Client authorizes Retention Systems to engage Sub-processors to support delivery of the Service (e.g., hosting, messaging delivery, email delivery, payment processing, analytics, and customer support).

Retention Systems will impose data protection obligations on Sub-processors consistent with this DPA.

E. Data Breach Notification

Retention Systems will notify the Client without undue delay after becoming aware of a Personal Data breach affecting Client Customer Data.

F. Data Deletion

Upon termination of the Service, Personal Data will be deleted or returned upon Client request, subject to legal retention requirements and limited backup retention for disaster recovery.

G. Liability

Liability under this DPA is subject to the limitations set forth in the Terms of Service.

H. Governing Law

This DPA is governed by the laws specified in the Terms of Service.

I. Order of Precedence

  1. This DPA
  2. Terms of Service
  3. Privacy Policy