Privacy Policy – Effective 06/11/2025

Last Updated: 07/04/2025

Crutan LLC (“Crutan,” “Company,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect your information when you use our AI marketing agent platform, website, and services. By using our Service, you agree to this Policy.

Crutan adheres to the Google API Services User Data Policy, including the Limited Use requirements. We do not use, share, or transfer raw or derived user data obtained through Workspace APIs to train, improve, or build generalized AI/ML models. All data processing is performed securely and solely for the individual user’s benefit. Data is anonymized and limited to numerical performance metrics and general industry categorization.

This Policy applies to all users, including visitors, trial users, and subscribers. For inquiries, contact: [email protected]. Data Controller: Crutan LLC, Phoenix, Arizona, USA. Privacy Officer: [email protected].

1. Key Definitions and Data We Collect

Personal Information includes any info that identifies, relates to, describes, or is linked to a person. Processing covers collection, use, storage, and deletion. Service Providers help us operate. Users are those accessing the Service. Analytics Data references your Google Analytics 4 data.

Information we collect: (a) Details you provide: name, email, company info, payment data, communications, preferences. (b) Information collected automatically: Analytics data, feature usage, technical and device data, website interaction, and usage statistics. (c) Data from third parties: Google account/sign-in info, payment status, enrichment providers.

We may combine information from all sources to deliver and improve the Service.

2. How and Why We Use Your Information

Legal Bases: Our processing is based on contract performance, legitimate interests (like improving the Service), your consent, and legal compliance, as applicable under various privacy laws (e.g., GDPR, CCPA/CPRA).

Uses include: providing and managing the Service; analyzing collected data for insights; enabling AI and dashboard features; improving existing and developing new features; payment and fraud prevention; legal and business operations; and communicating updates, marketing, or support.

We may send notifications, updates, and marketing communications (with your consent).

3. Information Sharing, Security, and International Transfers

Your data may be shared with trusted service providers, including payment processors (Stripe), hosting/cloud infrastructure (Google Cloud, Supabase, Cloudflare), and analytics (Google Analytics). All transfers use contractual safeguards and data processing agreements.

Legal requirements: We may disclose your data for legal, regulatory, or safety reasons. In a merger or sale of assets, your data may be transferred accordingly, and you’ll be notified of material changes.

Security: We secure your info using encryption (TLS 1.3, AES-256), network protections, access and authentication controls, regular reviews, and incident response protocols. No system is 100% secure, but we act promptly on risks.

4. Data Retention, Your Rights, and Changes

Data is retained as long as you have an account, and in some cases for legal, operational, or compliance reasons: Marketer Plan (6 months), Pro Plan (2 years), Payment Records (7 years), and as required by law. Deletion requests are available and honored per requirements.

Your rights: Depending on your location, you may have rights to access, correct, restrict, delete, or port your data, and object to certain uses. CCPA/CPRA and GDPR provide additional rights for California and EU residents.

We update this Policy as needed. For material changes, we’ll notify you via email, in-Service, or on our website. Continued Service use means acceptance of updates.

5. Contact and Complaints

Questions? Email [email protected] with subject line “Privacy Policy Inquiry.” Response time is within 30 days. You may also contact relevant authorities, such as the California Privacy Protection Agency or your local EU supervisory body.

Children’s Privacy: Our service is not intended for children under 13. If we discover collection from such users, we delete the information promptly and prevent future collection.

This Policy complies with CCPA, CPRA, GDPR, and related state/federal privacy laws. For legal advice, consult counsel. Effective date: 06/11/2025.