1. Introduction
1.1 Overview
At Flurry ("Flurry," "we," "us," or "our"), we prioritize protecting the privacy and security of our users ("you" or "your"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered sales development platform, including our website, applications, and related services (collectively, the "Service").
1.2 Our Privacy Commitment
We believe that transparency and trust are fundamental to our relationship with our users. Our commitment to privacy extends beyond mere compliance with regulationsβwe strive to protect your data as if it were our own. We design our systems and processes with privacy in mind, ensuring that your information remains secure and confidential while enabling you to leverage our AI-powered sales development tools effectively.
1.3 Scope
This Privacy Policy applies to all information collected through our Service, whether you are a registered user, customer, or visitor. By accessing or using our Service, you agree to the collection, storage, use, and disclosure of your information as described in this Policy.
1.4 Key Definitions
To help you understand this Policy, here are important terms we use:
- Personal Information: Information that identifies, relates to, describes, or can be reasonably linked to a specific individual or household.
- Service: All Flurry websites, applications, platforms, and tools.
- AI Technology: The artificial intelligence systems and features we use to power our sales development platform.
- Business Contact Data: Professional contact information collected and processed for B2B communications.
1.5 Changes to This Policy
We may update this Privacy Policy as our services evolve and privacy practices change. When we make material changes, we will notify you by:
- Posting the updated Privacy Policy on our website
- Sending an email to the primary email address associated with your account
- Providing notice through our Service
Your continued use of the Service after such modifications constitutes your acceptance of the updated Policy.
1.7 Legal Compliance
We design our privacy practices to comply with applicable privacy laws and regulations worldwide. This section outlines our specific compliance measures and your rights under various privacy regulations.
4. Data Storage and Security
4.1 Security Commitment
At Flurry, we implement industry-standard security measures to protect your information from unauthorized access, disclosure, alteration, and destruction. Our security practices are regularly reviewed and updated to maintain the highest standards of data protection.
4.2 Technical Security Measures
We protect your data through multiple layers of security controls. This includes enterprise-grade encryption for data in transit and at rest, secure access controls and authentication systems, and continuous security monitoring. We conduct regular security audits and penetration testing to verify the effectiveness of our protections.
4.3 Data Storage Locations
Your information is primarily stored and processed in data centers located in the United States. All storage locations adhere to equivalent security standards and comply with applicable data protection laws.
4.4 Data Retention
For active accounts, we retain your information for the duration of your account's active status, plus any additional period required by law or necessary to fulfill the purposes outlined in this policy.
4.5 Employee Access Controls
We maintain strict controls over employee access to customer data. Access is granted only on a need-to-know basis and is logged and monitored. All employees undergo regular privacy and security training and are bound by confidentiality agreements. We conduct regular access reviews to ensure appropriate permissions are maintained.
4.6 Incident Response
In the event of a security incident, we maintain comprehensive response procedures. This includes prompt investigation and containment of any incident, notification to affected users as required by law, and coordination with appropriate authorities. We continuously review and update our incident response procedures based on evolving security threats.
4.7 Data Encryption
We implement comprehensive encryption throughout our system. This includes encryption for authentication tokens, credentials, sensitive personal information, and backup data.
4.8 Business Continuity
To ensure continuous access to your data, we maintain robust business continuity measures. This includes regular backups, disaster recovery planning, and redundant data center operations. Our critical systems are monitored 24/7, and we conduct regular recovery tests to verify our procedures.
4.9 User Security Recommendations
To enhance the security of your account, we recommend using strong, unique passwords and enabling two-factor authentication when available. Keep your access credentials confidential and ensure you log out from shared devices. We encourage you to promptly report any suspicious activities related to your account.
5. Data Sharing and Disclosure
5.1 Overview
We share your information with third parties only as necessary to provide our Service or as required by law. Every sharing arrangement is carefully evaluated to ensure appropriate privacy and security standards are maintained.
5.2 Service Providers
To deliver our Service effectively, we work with trusted service providers who perform essential functions. These include hosting our infrastructure, processing payments, providing customer support, analyzing platform usage, and delivering communications. All service providers are contractually bound to use your information solely for providing services to Flurry and must maintain strict security measures.
5.3 Legal Requirements
We may be required to disclose your information in response to valid requests from public authorities, including court orders, subpoenas, law enforcement requests, or to meet national security requirements. We evaluate each request carefully and disclose only the information necessary to comply with the request.
5.4 Protection of Rights
We may share information when we reasonably believe disclosure is necessary to protect our rights, enforce our terms of service, investigate potential violations, or protect against legal liability. This includes protecting the safety and security of our users or the public.
5.5 Aggregated Data
We may share anonymized, aggregated data that cannot reasonably identify individual users. This information helps us provide industry insights, analyze platform performance, and conduct market research. We carefully review all aggregated data to ensure it cannot be reversed to identify individuals.
5.6 Third-Party Integrations
When you choose to connect third-party services with your Flurry account, you control what information is shared. These integrations receive only the data necessary for their intended function. You can review and revoke these connections at any time through your account settings.
6. User Rights and Choices
6.1 Your Privacy Rights Overview
As a user of our Service, you maintain specific rights regarding your personal information. These include the right to access your personal information, correct inaccurate data, request deletion of your information, restrict or object to processing, export your data in a portable format, and withdraw consent for optional processing activities.
6.3 Communication Preferences
We separate our communications into two categories: essential Service communications and marketing communications. Service communications include account notifications, security alerts, and platform updates which are necessary for using our Service. For marketing communications, you maintain full control over what you receive and can opt out at any time through your account settings or by clicking the unsubscribe link in any marketing email.
6.4 Data Deletion
When you request data deletion, we will remove your personal information from our active systems. However, we may retain certain information where required for legal compliance, security purposes, or technical limitations. We will clearly communicate any limitations on data deletion when you make your request.
6.5 Account Controls
Your account settings serve as the primary control center for your privacy preferences. Here you can update your profile information, manage connected email accounts, and configure your data sharing and AI feature preferences. We encourage you to review these settings periodically.
6.6 Regional Privacy Rights
If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information. These include the right to know what personal information is collected, access your personal information, request deletion, and opt out of data sales, all while being protected from discrimination for exercising these rights.
For users in the European Economic Area, the General Data Protection Regulation (GDPR) provides additional rights, including data portability and the right to restrict processing. We honor these rights regardless of your location and strive to provide the highest level of data protection to all users.
6.7 Exercising Your Rights
To exercise your privacy rights, send a detailed request to support@salesflurry.ai. Include your name, contact information, and the specific right you wish to exercise. Our Data Protection Officer is available to assist with any questions about exercising your rights.
6.8 Our Response Process
Upon receiving your request, we will attempt to acknowledge it within three business days. We aim to provide a complete response within 30 days. If we need additional time, we will notify you. Throughout the process, we will keep you informed of our progress and any necessary verification steps.
6.9 Verification and Security
To protect your privacy, we implement a verification process for privacy requests. This may include matching information you provide with our records or requesting additional documentation. We design these processes to be thorough yet minimally intrusive.
6.10 Technical and Legal Limitations
While we strive to honor all legitimate requests, certain limitations may apply. Some data may be required for Service operation, legal compliance, or security purposes. Additionally, technical constraints may affect our ability to separate aggregate data or provide data in specific formats. We will clearly communicate any such limitations when processing your request.
7. Legal Compliance
7.1 Overview
We design our privacy practices to comply with applicable privacy laws and regulations worldwide. This section outlines our specific compliance measures and your rights under various privacy regulations.
7.2 GDPR Compliance
As a data processor, we process data on behalf of our customers according to their instructions.
Under GDPR, we provide specific rights regarding your personal data, including:
- The right to access your personal data and obtain information about how we process it
- The right to rectify inaccurate personal data
- The right to erasure of your personal data when no longer necessary
- The right to restrict or object to certain processing activities
- The right to data portability in a machine-readable format
- The right to withdraw consent for processing based on consent
7.3 California Privacy Rights
For California residents, we comply with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). Under these laws, you have the right to know what personal information we collect, how we use it, and whether we sell or share it. You may also request deletion of your personal information and opt out of certain data sharing practices.
7.4 Children's Privacy
Our Service is not intended for children under 13 years of age. We do not knowingly collect or process personal information from children under 13. If we discover we have collected such information, we will promptly delete it. Parents or guardians who believe we may have collected information from a child under 13 should contact us immediately.
7.5 Data Breach Notification
In the event of a personal data breach, we will notify relevant supervisory authorities and affected individuals as required by applicable law. Our notification will include the nature of the breach, likely consequences, and measures taken to address the breach.
7.6 Compliance Updates
Privacy laws and regulations continue to evolve. We actively monitor these changes and update our practices accordingly. When significant changes affect your privacy rights, we will notify you through appropriate channels.
8. Anti-Spam and Email Practices
8.1 Overview
As an AI-powered sales development platform, we take our responsibility to prevent spam and ensure appropriate email practices seriously. This section outlines our commitment to responsible communication and compliance with anti-spam regulations.
8.2 Email Marketing Standards
We require all users of our Service to follow established email marketing standards and best practices.
8.3 Consent Requirements
Our Service requires users to have a legitimate business relationship or explicit consent from email recipients.
8.4 Opt-Out Management
Every email sent through our platform must include a clear and functioning unsubscribe mechanism.
8.5 User Responsibility
Users must maintain proper email practices by:
- Keeping contact lists current and accurate
- Obtaining necessary permissions for communication
- Following applicable email marketing laws
- Managing bounce rates and list hygiene
- Responding promptly to recipient inquiries
8.6 Technical Controls
Our platform implements robust technical measures to prevent spam, including:
- Rate limiting and volume controls based on account history
- Automated bounce handling and list cleaning
- Required authentication protocols (SPF, DKIM, DMARC)
- Engagement monitoring and feedback processing
8.7 Reporting Abuse
Any recipient who believes they have received unauthorized email through our Service can report it to support@salesflurry.ai. We investigate all reported violations and take appropriate action.
9. AI Technology and Data Security
9.1 Overview
Our AI-powered sales development platform uses advanced artificial intelligence technologies to enhance your sales outreach. This section explains how we implement AI technology, protect your data during AI processing, and maintain security throughout our systems.
9.2 AI Implementation
Our AI technology processes your data to provide features such as personalized messaging, optimal send time prediction, and response analysis. We develop and deploy our AI systems with privacy by design, ensuring that data protection is built into our AI architecture from the ground up.
9.3 Data Processing Safeguards
When processing data through our AI systems, we implement multiple layers of protection. These include:
- AI models trained on anonymized data wherever possible to protect individual privacy
- Strict access controls limiting system access to authorized personnel only
- Processing performed in isolated, secure environments with continuous monitoring
- Regular security audits and compliance checks of all AI systems
- Comprehensive logging of all data access and processing activities
9.4 AI Model Governance
Our AI governance framework ensures responsible use through systematic oversight and monitoring. We maintain:
- Regular evaluations of model performance and potential bias
- Documentation of model purposes, limitations, and intended uses
- Human oversight of critical AI operations and decisions
- Periodic review and updates of model parameters
- Clear escalation paths for AI-related concerns
9.5 Continuous Improvement
To maintain the highest standards of AI security, we regularly:
- Assess privacy impacts of AI systems and updates
- Integrate new privacy-enhancing technologies
- Update security measures based on emerging threats
- Conduct staff training on AI security best practices
- Review and revise AI policies and procedures
9.6 User Recommendations
To maximize security when using our AI features, we recommend that users:
- Regularly review AI-processed content in their account
- Report any unexpected AI behavior immediately
- Follow security best practices for account access
- Maintain familiarity with AI feature settings
- Keep contact information current for security notifications
11. Acknowledgment and Acceptance
11.1 Legal Effect
This Privacy Policy, together with our Terms of Service, constitutes a legally binding agreement between you and Flurry. By using our Service, you acknowledge that you have read, understood, and agreed to be bound by both documents.
11.2 Documentation
This Privacy Policy serves as the complete and exclusive statement of the agreement between you and Flurry with respect to its subject matter, superseding any prior agreements or representations regarding privacy practices.
11.3 Questions and Clarification
If any part of this Privacy Policy is unclear, or if you have questions about how it applies to your use of our Service, please contact us before proceeding with use of the Service. We are committed to transparency and will gladly provide clarification.
11.4 Reservation of Rights
Flurry reserves all rights not expressly granted in this Privacy Policy. No waiver of any provision shall be deemed a further or continuing waiver of such term or any other term. Our failure to assert any right or provision under this Privacy Policy shall not constitute a waiver of such right or provision.
11.5 Acknowledgment
By using Flurry's Service, you acknowledge that you have read this Privacy Policy and understand that it creates legal obligations between you and Flurry. If you do not understand any part of this Privacy Policy, or do not agree with it, you must not use our Service.
Last Updated: April 29, 2025