Secrails SL ("Secrails," "we," "our," or "us") respects your privacy and is committed to protecting the personal data of individuals in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation ("GDPR"). This Privacy Policy explains how we collect, use, store, disclose, and protect your data when you interact with our website or use our services.

Depending on the context, Secrails SL, with registered offices at Avda. Monasterio de el Escorial 24, 28049, Madrid, Spain, may act either as a Data Controller (e.g., for marketing, account management) or as a Data Processor (e.g., when processing data on behalf of customers using our platform). Our role will be clearly stated in applicable agreements such as our Data Processing Agreement (DPA).

This document, describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://secrails.com, or any website of ours that links to this Privacy Policy
• Use our platform at https://app.secrails.com/
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed.

If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hi@secrails.com.

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting http://www.secrails.com/contact, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Identification data (name, phone number, email, company)
• Access data (username, password, preferences)
• Billing data (payment info, invoices, VAT number)
• Usage and browsing data (IP, browser, logs, cookies)
• Interaction data (inquiries, support tickets, surveys)
• Marketing data (preferences, business interest)

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/es/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://www.secrails.com/cookie-policy.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
• Security and Authentication Data. We collect security-related data, such as failed login attempts, account lockouts, authentication logs, and device fingerprints used to prevent fraud and unauthorized access.
• Behavioral and Interaction Data. We collect data on how you interact with our platform, including feature usage, time spent on different sections, frequency of logins, and patterns of engagement. This helps us improve functionality and user experience.
• Performance and Diagnostic Data. We collect system performance data, error logs, and diagnostic information to identify and resolve technical issues and optimize platform reliability.
• Preference and Customization Data. We store user preferences such as interface settings, notification choices, and saved customizations to provide a personalized experience.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see our Cookie Notice: https://www.secrails.com/cookie policy.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. What Legal Bases Do We Rely On To Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Send users information about special offers and discounts on our products and services
  • Develop and display personalized and relevant advertising content for our users
  • Analyze how our Services are used so we can improve them to engage and retain users
  • Support our marketing activities
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

4. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

• Affiliate Marketing Programs
• Cloud Computing Services
• Communication & Collaboration Tools
• Data Analytics Services
• Data Storage Service Providers
• Finance & Accounting Tools
• Payment Processors
• Sales & Marketing Tools
• Social Networks
• User Account Registration & Authentication Services
• AI Platforms
• Website Hosting Service Providers
• Retargeting Platforms
• Performance Monitoring Tools
• Ad Networks
• Product Engineering & Design Tools
• Testing Tools

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

To provide this information clearly and understandably, we've divided the purposes for which we may process your data based on the type of data subject you are, along with the corresponding legal bases:

Leads and/or users:

We process your data as a lead or user of our website for the following purposes:

a. The following processing purposes are carried out based on your consent (Art. 6.1.a GDPR):

You have the right to withdraw your consent at any time for these purposes.

• To contact you for commercial purposes through various channels (both online and offline), and to send you personalized commercial communications. If we haven't obtained your contact details directly from you, you have the right to be informed of the origin of the data, such as a web contact form, third-party database, webinar, trade show, conference, or similar event you attended where your contact details were legitimately collected. Data processed: Full name, corporate email and phone number, title, job position, company name and/or sector.
• To manage your participation in our promotional activities, events, courses, and/or webinars, and if needed, to inform you about updates related to these activities. Data processed: Full name, corporate email and phone number, job position, company name, sector and/or size.
• To share your identifying and professional contact data with third-party collaborators involved in promotional actions, only with your specific consent. Data processed: Full name, corporate email and phone number, job position, and in some cases, company name, sector, and/or size. Occasionally, these events, courses, or webinars may be co-organized with other entities. In such cases, we may share your data with them only after obtaining your prior consent, so they can send you information about their own products/services. These third parties will handle your data under their own privacy policies. For more information on third-party data sharing, contact: hi@secrails.com
• To provide you with access to certain resources available on our websites. Data processed: Full name, corporate email, company name, and company size.
• To analyze your behavior on our websites using cookies and tracking technologies, to better understand interests in our products and Data processed:
  • (a) Browsing and traffic data: IP address, behavioral data through cookies.
  • (b) Preferences and needs of your organization: data provided by you or inferred by Secrails about your interests in our platform.
• To record sales meetings for the purpose of improving the sales experience. Data processed: Full name, username, image and voice, preferred language.

We will always seek your prior consent before recording any video meetings with our Sales teams.

b. The following processing purposes are based on the execution of a contract or pre-contractual measures at your request (Art. 6.1.b GDPR):

• To follow up on commercial discussions and send you a tailored pricing proposal. Data processed: Title, job position, company name and/or sector, features of our platform you've shown interest in.
• To manage your request to start using a free trial of our services and respond to related requests (e.g., extension or configuration changes). Data processed: Full name, corporate email and phone number, job position, company name, sector, size, and selected platform features.

c. The following processing purposes are based on our legitimate interest (Art. 6.1.f GDPR):

• To send you personalized marketing communications based on a basic profile of you and your organization via various channels. Data processed: Title, job position, full name, company name, size, sector, interactions with our website (if cookies are accepted), and selected platform features.

If you've consented to receive marketing communications, we may tailor them using the profile generated from this data.

• To advertise via online channels including SMS, messaging apps, and especially third-party platforms or social networks. In these cases, your data (such as name, country, corporate email, and phone number) will be encrypted before being shared to verify matches, ensuring we never directly identify users. Examples include “custom audiences” or “matched audiences” on social networks. These allow us to include or exclude you from advertising campaigns.
• To create similar audiences (“lookalike audiences”) so platforms show Secrails content to users with profiles similar to yours.

If your privacy settings on those platforms prevent marketing activities, we will respect them. If you'd prefer not to receive tailored ads via third-party platforms, you can opt out by writing to hi@secrails.com.

Our legitimate interest here is to improve our marketing strategy and ensure professional leads receive relevant information. You can request more information about our interest assessment at hi@secrails.com.

You may see Secrails ads on social platforms even if we haven't shared your data. These are shown based on the platform's internal targeting—not by us.

• To assign a basic score based on predefined segments. Data processed: Job title, employee range, sector, region, features of interest, lead source, engagement with our content and communications, last demo or signature date with Secrails.

We use algorithmic models to:

• 1. Personalize our commercial interactions and communications.
• 2. Determine your score/segment to improve targeting.

You may object to this profiling at any time. This will not impact your relationship with Secrails, and you will still receive general communications if you have consented to them.

• To schedule a demo of our platform and manage related communications. If an agreement is reached, will send a customized proposal and contract.
• Data processed: Full name, corporate email and/or phone number, title, company name and sector, meeting data, legal representative contact info (for contract purposes).

You may object to this profiling at any time. This will not impact your relationship with Secrails, and you will still receive general communications if you have consented to them.

Our legitimate interest is to contact you about a potential or ongoing commercial relationship (Art. 19 LOPDGDD). You can request more information about our interest assessment at hi@secrails.com.

Clients:

We process your data as a professional contact of Secrails' clients for the following purposes:

a. The following processing purposes are based on your consent (Art. 6.1.a GDPR):

You have the right to withdraw your consent at any time for these purposes.

• To manage your participation in promotional activities, events, courses, and/or webinars, and, if inform you of updates related to those activities. Data processed: Full name, corporate email and phone number, job position, company name, sector and/or company size.
• To analyze your behavior on our platform in order to understand your preferences related to our products, content, and/or services through cookies and similar tracking technologies.
  Data Processed:
  • (a) Browsing, traffic data, and/or metadata: IP address, behavioral data gathered through cookies and other tools.
  • (b) Preferences and organizational needs: Information you provide directly (e.g., which features of Secrails interest you) or that we infer about your organization's needs.

b. The following processing purposes are based on the performance of a contract or the application of pre-contractual measures at your request (Art. 6.1.b GDPR):

• To manage and maintain the contractual relationship with the client. Data processed: Full name, corporate email and phone number, contract data, financial data of the organization, platform usage and metadata, voice and image (for video calls), and other data derived from communications.

This includes services provided throughout the customer lifecycle and direct communication with admin users or others requesting support, such as:

• Initial onboarding and data loading assistance
• Offering and activating new features
• Payment and billing management
• Providing information, resolving issues, scheduling meetings
• Offboarding support

c. The following processing purposes are based on our legal obligations (Art. 6.1.c GDPR):

• Receiving and managing communications through Secrails' internal whistleblower channel. Data processed: As a whistleblower: name, surname, voice (if applicable), email, phone and/or mailing address, description of the facts, supporting documents/evidence. Anonymous submissions are also allowed.

We recommend reviewing the specific privacy policy of our internal channel to understand the full scope of processing and your rights.

• Compliance with legal obligations, including those related to anti-money laundering, anti terrorism financing, and fraud prevention. Data processed: Full name, corporate email and phone number, contract data, financial data of the organization.

These activities are focused on meeting our due diligence obligations under applicable regulations.

d. The following processing purposes are based on our legitimate interest (Art. 6.1.f GDPR):

• Recording customer support calls to ensure service quality, improve the customer experience, and/or participation in product research Data processed: Image, voice, feedback, and communication-related data.

You'll always be informed in advance when calls are recorded.

These recordings help us detect areas for improvement in both support services and product functionality. Your feedback is key to improving your experience with Secrails.

• Conducting satisfaction surveys to assess your experience with our platform and services. Data processed: Full name (unless the survey is anonymous), feedback and communication data.

While these surveys are voluntary, they provide valuable insights to help us improve.

• Creating a basic score for your organization using predictive models to analyze customer lifecycle and tailor our service strategies. Data processed: Job title, employee count (range), sector and region, selected platform features, lead source, interactions with our content (e.g., use of resources, marketing campaigns, communications), latest demo or contract signature date (if applicable).

These predictive models allow us to:

• Assign your organization to predefined segments
• Personalize commercial strategies
• Analyze customer lifecycle stages
• Identify upsell opportunities

We use this data exclusively from internal sources and the client relationship. These models do not make automated decisions — they support human decision-making to improve mutual value.

You may object to this purpose at any time without impacting your use of the Secrails platform. If you do, we will continue offering our services, but in a more general way. You can request details of our assessment by writing to: hi@secrails.com

• Statistical analysis and usage insights from the platform (e.g., number of completed user profiles, performance reviews triggered, etc.) Data processed: Contract data, observed platform usage data, communication records, browsing data, and statistical model outputs.

All processing in this context is conducted with anonymized data only.

This also helps us better understand recurring bugs or issues reported by clients and improve our products accordingly.

5. What Legal Bases Do We Rely On To Process Your Information?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://www.secrails.com/cookie-policy.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. You can opt out by visiting https://tools.google.com/dlpage/gaoptout. The Google Analytics Advertising Features that we may use include: Remarketing with Google Analytics, Google Display Network Impressions Reporting and Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6. Is Your Information Transferred Internationally?

In Short: As a general rule, the data processed by Secrails is not shared with third-party recipients. However, we may transfer, store, and process your information in countries other than your own in certain cases described in this section.

We may collaborate with other entities and share your data with them:

• In the context of webinars, events, or commercial and/or promotional activities, we may share your contact information with our collaborators, partners, or sponsors so they can reach out to you for commercial purposes—always provided that you have given us your prior consent.
• Similarly, if you are a client contact or a lead and have previously given your consent, we may share your data with our partners or collaborators so they can contact you and send you commercial information.
• We may share certain data with third-party social networks or platforms to optimize the connection and organization of your data in our CRM, as well as for the creation of custom or lookalike audiences within their environments in relation to our personalized commercial communications.
• Payment service providers or partners offering regulated banking services under the appropriate license may also receive your data. To process payment transactions and depending on the payment method chosen by the Client, these services may store and process your data as an essential part of executing the contractual relationship. If bank accounts are managed by third-party partners, or payment is made via credit card or transfer, we may need to share your data as a Client. This data sharing must be understood in the context of the exclusive contractual relationship between you as the Client and the third-party partner, and the specific Terms and Conditions of that third-party partner will apply.
• In order to comply with certain legal obligations, we may also need to disclose your data to law enforcement agencies, government bodies, public administrations, courts, or other competent authorities.
• We may also disclose your data to potential buyers or other interested parties in the event of a merger, business restructuring operation (such as an acquisition, joint venture, transfer, spin off, or divestiture). In such cases, we will always ensure appropriate data protection safeguards are in place.
• Additionally, in some cases, we grant access to your data to our service providers who deliver services to Secrails but never for their own purposes. We make every effort to select providers that offer sufficient and appropriate guarantees regarding data protection. Categories of such providers include:
  • Hosting and infrastructure services
  • Call center, chat, and video conferencing services
  • Marketing and advertising services (e.g., personalized email campaigns, event management, survey tools)
  • Payment services
  • Logistics services
  • Analytics services
  • Contract or agreement management platforms, including digital signature tools
  • CRM platforms and complementary services (e.g., calendar integrations, database synchronization)
  • Cybersecurity services
  • Services for profiling and/or categorizing leads and client organizations
  • Financial, accounting, auditing, consulting, tax, and legal advisory services

Our servers are located in Spain and Ireland. If you are accessing our Services from outside Spain and Ireland, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

In certain cases, the data we collect will be transferred to data processors located in third countries, as defined in Article 44 of the GDPR, such as the United States. These transfers will primarily be based on an adequacy decision by the European Union, in accordance with Article 45 of the GDPR.

If there is no adequacy decision in place for the transfer of your data to the third country, we will rely on other safeguards provided under Chapter V of the GDPR. Most commonly, we will transfer your data based on the applicable Standard Contractual Clauses.

However, we may also use other measures provided for under the GDPR, as long as they ensure an adequate level of protection for your data, and you may request information about these measures at any time.

7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twenty four (24) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

At Secrails, we implement state-of-the-art security standards to prevent unauthorized access, maintain data accuracy, and ensure the proper use of information. We also apply appropriate organizational measures to protect your data.

We uphold these same security standards when working with our business and technology partners. We only select and engage data processors and third-party providers that have adequate security measures in place and offer sufficient guarantees—including technical and organizational measures— to ensure the proper protection of the data entrusted to them.

Internally, we also ensure that any Secrails team member with access to your data has signed a confidentiality agreement or clause. In addition, we have implemented internal procedures such as ongoing training and regularly updated policies to ensure data security, as well as the confidentiality, availability, and resilience of our systems and services.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at dpo@secrails.com.

10. What Are Your Privacy Rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In accordance with applicable data protection regulations (GDPR), as a data subject, you have certain rights when we process your personal data. We will respond appropriately and within the legally established time frame when you request to exercise your rights.

As an example, here are some of the rights you may exercise:

• Right to be informed: You have the right to receive clear, transparent, and easily understandable information about how we use your personal data and about your rights.
• Right of access: You have the right to access your personal data.
• Right to rectification: You have the right to have your personal data corrected if it is inaccurate or incomplete.
• Right to erasure ("right to be forgotten"): This right allows you to request the deletion or removal of your personal data when there is no compelling reason for us to continue processing it.
• Right to restrict processing: You have the right to “block” or suppress further use of your personal data. When processing is restricted, we may still store your data but may not use it further.
• Right to data portability: You have the right to obtain and reuse your personal data for your own purposes across different services.
• Right to object to processing: You have the right to object to certain types of processing—for example, if you object to processing based on legitimate interest.
• Right to withdraw consent: If you have given your consent for a specific processing activity, you have the right to withdraw it at any time, freely and without justification.
• Right not to be subject to automated decision-making: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects or similarly significant consequences for you.
• Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Secrails usually handles such requests and provides the information free of charge. To exercise your rights, you may send a written request to the following email address: hi@secrails.com. If you have any questions or suggestions regarding Secrails' processing of your data, you may also contact us through the same address.

Please note that in some cases we may need to verify your identity and request supporting documentation. Likewise, in very specific cases, we may charge a reasonable fee to cover our administrative costs of providing the information, for example:

• Unfounded or excessive/repetitive requests; or
• Multiple copies of the same information.

You also have the right to file a complaint regarding our processing of your personal data with the relevant data protection supervisory authority. Before doing so, you have the right to first contact our Data Protection Officer (DPO).

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://www.secrails.com/cookie policy.

If you have questions or comments about your privacy rights, you may email us at hi@secrails.com.

11. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A - 24 months
• Category B - 24 months
• Category D - 24 months
• Category F - 24 months
• Category H - 24 months
• Category K - 24 months

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

We collect and share your personal information through:

• Targeting cookies/Marketing cookies
• Social media cookies
• Beacons/Pixels/Tags

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Personal information as defined in the California Customer Records law
• Category D. Commercial information
• Category F. Internet or other electronic network activity information
• Category H. Audio, electronic, visual, and similar information
• Category K. Inferences drawn from collected personal information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota's privacy law)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota's and Oregon's privacy law)
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota's privacy law)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida's privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting http://www.secrails.com/contact, by emailing us at hi@secrails.com, by visiting https://www.secrails.com/contact, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

f you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at hola@secrails.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

13. Do Other Regions Have Specific Privacy Rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests
• manage your account with us
• confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

• The Information Regulator (South Africa)
• General enquiries: enquiries@inforegulator.org.za
• Complaints (complete POPIA/PAIA form)
• 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulat or.org.za

14. Do We Make Updates To This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

15. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at hi@secrails.com.

16. How Can You Contact Us About This Notice?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: http://www.secrails.com/contact.