Privacy Policy

This Privacy Policy explains how Primal Sales AI, LLC ("PrimalSales," "we," "us," or "our") collects, uses, shares, and protects information when you use the PrimalSales.ai platform and website (the "Service").

This Policy applies to information collected from customers, their authorized users, website visitors, and prospect data uploaded to the Service. By using the Service, you agree to the practices described here.

1. Information We Collect

1.1 Information You Provide

• Account information: name, email address, phone number, company name, role/title, password (hashed), payment information (handled by our payment processor).
• Configuration data: sales methodology selections, team member information, integration credentials, customizations.
• Customer Data: CRM records, prospect contact information, deal data, call transcripts, recordings, email content, and other materials you upload or sync to the Service.
• Communications: messages you send to support, feedback you submit, content of demo calls.

1.2 Information Collected Automatically

• Usage data: pages visited, features used, actions taken, timestamps, session duration, click patterns.
• Device and connection data: IP address, browser type and version, operating system, device identifiers, language preferences, referrer URL.
• Cookies and similar technologies: see our Cookie Policy for details.

1.3 Information from Third Parties

• CRM and integration data: when you connect HubSpot, Salesforce, GoHighLevel, Gmail, Slack, or other services, we receive data those services share based on your authorization.
• Authentication providers: if you sign in via Google SSO, we receive basic profile information from Google.
• Payment processors: Stripe provides us with subscription status and payment confirmation, but not full payment card details.

2. How We Use Information

We use information to:

• Provide, operate, maintain, and improve the Service;
• Process subscriptions, payments, and communications;
• Authenticate users and protect against fraud, abuse, and security incidents;
• Generate AI-powered coaching, recommendations, training content, and email drafts;
• Train and improve our AI models on de-identified and aggregated data;
• Send service-related notifications (account, billing, security, product updates);
• Respond to support inquiries and customer feedback;
• Conduct analytics, research, and product development;
• Comply with legal obligations and enforce our Terms of Service.

3. AI and Automated Processing

The Service uses artificial intelligence to analyze calls, deals, emails, and methodology configurations. We use third-party AI providers (currently including Anthropic and OpenAI) to power these features.

When AI processes Customer Data:

• We have contractual agreements with our AI providers prohibiting them from using your data to train their general-purpose models;
• We may use de-identified and aggregated data to improve the Service and our internal AI models;
• AI-generated outputs may contain errors and should always be reviewed by you before use;
• You can disable certain AI features in your account settings.

4. How We Share Information

We do not sell personal information. We share information in these limited cases:

4.1 Service Providers

We share information with vendors who help us operate the Service, under contracts requiring them to protect the data and use it only for the agreed purposes. Categories include:

• Cloud hosting and infrastructure (e.g., Vercel, Supabase);
• AI providers (e.g., Anthropic, OpenAI);
• Payment processing (e.g., Stripe);
• Email and notification delivery (e.g., Resend, SendGrid);
• Analytics and error monitoring;
• Customer support tools.

4.2 Integrations You Authorize

When you connect third-party services (HubSpot, Salesforce, GoHighLevel, etc.), data flows between those services and PrimalSales as you configure. Their use of your data is governed by their privacy policies.

4.3 Legal and Safety

We may disclose information when required by law, subpoena, court order, or governmental request; to protect our rights, property, or safety, or those of users or the public; to investigate fraud, security, or technical issues; or to enforce our Terms.

4.4 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before personal information becomes subject to a different privacy policy.

4.5 Aggregated and De-Identified Data

We may share aggregated and de-identified data (which cannot reasonably identify any individual) for any lawful purpose, including marketing, research, and benchmarking.

5. Your Rights and Choices

Depending on your location, you may have rights including:

• Access: request a copy of personal information we hold about you;
• Correction: request that inaccurate information be corrected;
• Deletion: request that we delete your personal information, subject to legal retention requirements;
• Portability: receive your information in a structured, machine-readable format;
• Opt-out of sale/sharing: we do not sell personal information, but California residents may opt out of any sharing for cross-context behavioral advertising;
• Withdrawal of consent: where processing is based on consent, you may withdraw consent at any time.

To exercise any of these rights, email support@primalsales.ai. We will respond within 30 days (or as required by applicable law). We may need to verify your identity before fulfilling certain requests.

5.1 Authorized Users

If you are an authorized user added to the Service by a customer (your employer), the customer controls your account and decisions about your data. Direct privacy requests to your customer organization first.

5.2 Prospect Data

If your data appears in our Service because a customer (a sales team) uploaded it, that customer is the controller of your data. We act as a processor on their behalf. Direct privacy requests to that customer.

6. California Privacy Rights

California residents have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• The right to know what personal information we collect, use, and share;
• The right to delete personal information;
• The right to correct inaccurate information;
• The right to opt out of "sale" or "sharing" — we do not sell personal information;
• The right to limit use of sensitive personal information;
• The right to non-discrimination for exercising these rights.

To exercise these rights, contact support@primalsales.ai. We do not knowingly collect or sell information of consumers under 16.

7. Data Security

We implement reasonable administrative, physical, and technical safeguards to protect personal information, including:

• Encryption in transit (TLS) and at rest;
• Multi-tenant architecture with org-level data isolation;
• Access controls, authentication, and audit logging;
• Regular security reviews and updates;
• Vendor security assessments.

No system is perfectly secure. If we become aware of a security incident affecting your personal information, we will notify you as required by law.

8. Data Retention

We retain personal information as long as necessary to provide the Service, comply with legal obligations, resolve disputes, and enforce agreements. Specifics:

• Account data: for the duration of your subscription, plus 30 days after termination for export and recovery;
• Customer Data: for the duration of your subscription, plus 30 days after termination, then permanent deletion;
• Payment records: 7 years for tax and accounting purposes;
• Backups: rolling 90 days, with deletion confirmed thereafter;
• Legal hold: longer if required by law, regulation, or active litigation.

9. International Data Transfers

The Service is operated in the United States. If you access the Service from outside the U.S., your information will be transferred to and processed in the U.S. The Service is currently designed for U.S. customers; we do not offer the Service in jurisdictions where transfer of data to the U.S. requires specific safeguards we have not implemented.

10. Children's Privacy

The Service is not intended for individuals under 18. We do not knowingly collect personal information from children under 18. If we learn we have collected such information, we will delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified by email or in-app notice at least 30 days before they take effect. The "Effective Date" at the top reflects the most recent version.

12. Contact Us

For privacy questions, requests, or concerns, contact:

Primal Sales AI, LLC
Email: support@primalsales.ai
Subject line: Privacy Request

Acceptable Use Policy

This Acceptable Use Policy ("AUP") governs your use of the PrimalSales.ai Service. It is incorporated by reference into our Terms of Service.

You may not use the Service for any unlawful, harmful, or prohibited purpose. We reserve the right to investigate and take action — including suspension or termination — if we believe you have violated this AUP.

1. Prohibited Conduct

You may not, and may not permit your Authorized Users to:

1.1 Illegal Activity

• Violate any applicable federal, state, local, or international law or regulation;
• Engage in fraud, money laundering, or other criminal activity;
• Send communications that violate the CAN-SPAM Act, TCPA, GDPR, or similar laws;
• Process personal data without lawful basis or required consent.

1.2 Harmful Communications

• Send spam, unsolicited bulk email, or messages to recipients who have not opted in;
• Use the Service to harass, threaten, defame, or stalk any person;
• Send messages with deceptive headers, false sender information, or misleading subject lines;
• Engage in phishing, social engineering, or impersonation;
• Distribute content that is obscene, hateful, or promotes violence.

1.3 Privacy Violations

• Upload or process personal data without lawful authority;
• Record or transcribe calls without required notice or consent of all parties (where applicable under state law);
• Use the Service to surveil or monitor individuals without lawful authority;
• Process special categories of personal data (health, biometric, etc.) without specific authorization.

1.4 Intellectual Property Violations

• Upload content that infringes copyright, trademark, trade secret, or other intellectual property rights;
• Use the Service to misappropriate confidential information from a current or former employer;
• Remove proprietary notices or attempt to claim ownership of PrimalSales content.

1.5 Service Abuse

• Reverse-engineer, decompile, or attempt to extract source code from the Service;
• Probe, scan, or test vulnerabilities without our written authorization;
• Bypass authentication, access controls, rate limits, or usage measurement;
• Use automated tools to scrape or extract data, except via authorized APIs;
• Interfere with or disrupt the Service, servers, or networks;
• Distribute viruses, malware, or other harmful code;
• Attempt to overwhelm the Service through excessive automated requests.

1.6 AI Misuse

• Attempt to manipulate AI features through prompt injection, jailbreaking, or adversarial input;
• Use AI outputs to generate content for purposes prohibited by this AUP;
• Use the Service to create or distribute deepfakes, impersonations, or deceptive content;
• Train competing AI models using PrimalSales-generated content;
• Bypass safety measures designed into AI features.

1.7 Commercial Restrictions

• Resell, sublicense, or redistribute access to the Service;
• Use the Service to build a directly competing product;
• Allow access by users beyond your subscribed seat count;
• Share login credentials with anyone outside your organization;
• Use the Service to provide outsourced services to third parties without our written consent.

2. Reporting Violations

If you become aware of conduct that violates this AUP, report it to support@primalsales.ai with details. We investigate all reports.

3. Enforcement

We reserve the right (but have no obligation) to:

• Investigate any suspected violation;
• Remove, disable, or restrict access to content that violates this AUP;
• Suspend or terminate accounts for violations;
• Cooperate with law enforcement and report illegal activity;
• Take any action we deem appropriate to address violations.

Account termination for AUP violations does not entitle you to a refund.

4. Your Responsibility

You are responsible for the conduct of your Authorized Users and any activity on your account. Train your team on this AUP and ensure compliance.

5. Changes

We may update this AUP. Continued use of the Service after changes are posted constitutes acceptance.

6. Contact

Questions about this AUP: support@primalsales.ai.

Cookie Policy

This Cookie Policy explains what cookies are, how Primal Sales AI, LLC uses them on the PrimalSales.ai website and Service, and how you can control them.

1. What Are Cookies

Cookies are small text files that websites place on your device to store information. Similar technologies include local storage, session storage, web beacons, and tracking pixels (collectively, "Cookies" in this Policy).

Cookies can be:

• Session vs. Persistent: Session cookies expire when you close your browser. Persistent cookies remain until they expire or are deleted.
• First-party vs. Third-party: First-party cookies are set by us. Third-party cookies are set by services we use.

2. Cookies We Use

2.1 Strictly Necessary Cookies

These cookies are essential for the Service to function. They cannot be disabled. Examples:

• Authentication tokens to keep you logged in;
• Session identifiers to maintain your account state;
• CSRF protection tokens to secure form submissions;
• Load balancing cookies to route traffic correctly.

2.2 Functional Cookies

These cookies remember your preferences and improve your experience. Examples:

• Display preferences (e.g., dark mode);
• Language and region settings;
• Recently viewed items.

2.3 Analytics Cookies

These cookies help us understand how the Service is used so we can improve it. They collect aggregated, non-identifying data. Providers may include:

• Internal product analytics;
• Error monitoring (e.g., Sentry);
• Performance monitoring.

2.4 Marketing Cookies

If used, these cookies track visitors across websites to display relevant advertising. We do not currently use marketing cookies on the public site. If we add them, we will update this Policy and provide opt-out controls.

3. Third-Party Cookies

Some Cookies are set by third-party services we integrate with, including:

• Stripe (for payment processing);
• Google (if you sign in via Google SSO);
• Calendly (for demo bookings).

These third parties have their own privacy and cookie policies, which we encourage you to review.

4. Your Choices

4.1 Browser Controls

Most browsers let you block or delete cookies through their settings. Common options:

• Chrome: Settings → Privacy and security → Cookies and other site data
• Firefox: Preferences → Privacy & Security → Cookies and Site Data
• Safari: Preferences → Privacy → Manage Website Data
• Edge: Settings → Cookies and site permissions → Cookies

If you block strictly necessary cookies, you will not be able to use the Service.

4.2 Do Not Track

Some browsers send a "Do Not Track" signal. We currently do not respond to these signals because no industry-standard interpretation exists.

5. Updates

We may update this Cookie Policy. Changes will be reflected in the Effective Date.

6. Contact

Questions: support@primalsales.ai.

Refund Policy

This Refund Policy applies to all subscriptions to the PrimalSales.ai Service.

1. 14-Day Money-Back Guarantee

If you are a new subscriber and not satisfied with the Service, you may request a full refund of your initial subscription payment within 14 days of your initial subscription start date.

How to Request a Refund

1. Email support@primalsales.ai from the email address associated with your account.
2. Include "Refund Request" in the subject line.
3. State your account email and that you are requesting a refund within the 14-day guarantee window.

Refunds are processed within 5-10 business days to the original payment method. Time to appear on your statement varies by your bank or card issuer.

2. Conditions and Exclusions

The 14-day guarantee applies only if:

• You are a first-time subscriber (not a previous customer who re-subscribed);
• The request is made within 14 days of your initial subscription start date;
• Your account has not violated our Terms of Service or Acceptable Use Policy;
• The request is for the initial subscription payment only (not subsequent renewals).

The guarantee does not apply to:

• Subscription renewals after the initial period;
• Accounts that have been suspended or terminated for AUP violations;
• Founding member subscriptions where stated otherwise in the founding member terms (where the 14-day guarantee continues to apply unless explicitly waived in writing).

3. Cancellation (No Refund Required)

You may cancel your subscription at any time without needing a refund. Cancellation prevents future billing but does not refund the current billing period. To cancel:

• Use the cancel option in your account settings, or
• Email support@primalsales.ai with "Cancel Subscription" in the subject line.

Your access continues through the end of the current billing period.

4. Refunds After 14 Days

After the 14-day window, refunds are not guaranteed and are at our discretion. We may consider refunds in cases of:

• Service outages affecting your ability to use the Service for extended periods;
• Billing errors on our end;
• Other exceptional circumstances reviewed case-by-case.

Submit such requests to support@primalsales.ai with detailed circumstances.

5. Founding Member Subscriptions

Founding member subscriptions are subject to the 14-day money-back guarantee on the same terms as standard subscriptions. After the 14-day window, founding member rates are locked for the life of your subscription, but cancellation rules apply normally.

If you cancel a founding member subscription and later re-subscribe, founding member pricing does not apply to the new subscription.

6. Chargebacks

We ask that you contact us before initiating a chargeback with your bank or card issuer. Chargebacks are expensive and disruptive, and most refund requests can be resolved faster directly. Accounts with unresolved chargebacks may be suspended.

7. Contact

Refund questions: support@primalsales.ai.

Data Processing Addendum

This Data Processing Addendum ("DPA") supplements and forms part of the Terms of Service between Primal Sales AI, LLC ("Processor," "we," "us") and the Customer ("Controller," "you") who has subscribed to the PrimalSales.ai Service.

This DPA applies when you upload, sync, or otherwise transmit personal information of your prospects, customers, or other individuals to the Service.

1. Definitions

• "Personal Information" means any information relating to an identified or identifiable natural person processed via the Service.
• "Processing" means any operation performed on Personal Information, including collection, storage, use, transmission, and deletion.
• "Sub-processor" means any third party we engage to process Personal Information on our behalf.
• "Security Incident" means a confirmed unauthorized access to or disclosure of Personal Information.

2. Roles

You are the Controller and determine the purposes and means of Processing Personal Information through the Service. We are the Processor and process Personal Information only as instructed by you (including via configuration of your account) and as necessary to provide the Service.

3. Scope and Purpose

3.1 Categories of Data Subjects

Personal Information processed via the Service may relate to:

• Your sales prospects and leads;
• Your customers (existing and former);
• Your team members (Authorized Users);
• Other individuals whose data you upload (e.g., call participants).

3.2 Categories of Personal Information

Categories may include: name, email, phone number, company, role, deal information, communication content (calls, emails, messages), CRM records, and any other data you upload or sync.

3.3 Purposes of Processing

We process Personal Information solely to:

• Provide the Service to you;
• Generate AI-powered analyses, recommendations, and content;
• Maintain security, integrity, and availability of the Service;
• Comply with our legal obligations.

4. Our Obligations

4.1 Processing Instructions

We will process Personal Information only on your documented instructions, which include the Terms of Service, this DPA, your account configuration, and additional instructions you provide in writing.

4.2 Confidentiality

We require our personnel and authorized contractors to maintain confidentiality of Personal Information through written agreements or equivalent legal duties.

4.3 Security Measures

We implement and maintain technical and organizational security measures designed to protect Personal Information, including:

• Encryption of data in transit (TLS) and at rest;
• Multi-tenant architecture with org-level data isolation;
• Access controls based on least-privilege principle;
• Authentication, including options for multi-factor authentication;
• Audit logging of administrative actions;
• Regular security reviews of our codebase and infrastructure;
• Vendor security assessments before engaging Sub-processors;
• Incident response procedures.

4.4 Sub-processors

We engage Sub-processors to help deliver the Service. By accepting this DPA, you authorize our use of Sub-processors. Current categories include:

• Cloud hosting and database providers;
• AI service providers;
• Payment processors;
• Email delivery services;
• Customer support tools;
• Analytics and monitoring providers.

We require Sub-processors to commit, in writing, to data protection obligations no less protective than those in this DPA. We remain responsible for Sub-processor performance.

You may request a current list of Sub-processors by emailing support@primalsales.ai.

4.5 Assistance with Data Subject Rights

To the extent legally required and where you cannot fulfill requests directly through the Service, we will provide reasonable assistance in responding to data subject access, correction, deletion, and portability requests.

4.6 Security Incidents

If we become aware of a Security Incident affecting your Personal Information, we will notify you without undue delay (and within 72 hours where reasonably possible). Our notification will include the nature of the incident, categories of data affected, likely consequences, and measures we are taking. We will cooperate reasonably with your investigation and any required notifications to data subjects or authorities.

4.7 Audit Rights

Upon reasonable advance written request (no more than once per year, except after a Security Incident or as required by law), we will make available information necessary to demonstrate compliance with this DPA, including third-party audit reports (e.g., SOC 2) where available. On-site audits may be conducted under reasonable conditions including reasonable scope, scheduling, and confidentiality protections.

4.8 Return or Deletion

Upon termination of your subscription, we will return or delete Personal Information as described in the Terms of Service (typically within 30 days of termination, with backups deleted within 90 days), except where retention is required by law.

5. Your Obligations

You represent and warrant that:

• You have all required legal authority to process and transmit Personal Information to the Service;
• You have provided required notices and obtained required consents from data subjects;
• Your processing instructions comply with applicable law;
• Your collection of call participant data complies with applicable wiretap and recording laws (which vary by state and country).

6. International Transfers

Currently, the Service is hosted in the United States. If you are located outside the U.S. and applicable law requires specific safeguards for international transfers, the Service may not currently meet those requirements. Contact us before subscribing if your jurisdiction requires Standard Contractual Clauses or equivalent mechanisms.

7. Limitation of Liability

The limitation of liability provisions in the Terms of Service apply to claims under this DPA. The total liability of either party for all claims under this DPA is subject to the cap stated in the Terms of Service.

8. Conflict

If there is any conflict between this DPA and the Terms of Service, this DPA prevails for matters concerning Personal Information.

9. Governing Law

This DPA is governed by the laws of the State of Florida, USA, consistent with the Terms of Service.

10. Contact

For questions about this DPA: support@primalsales.ai.

Primal Sales AI, LLC · A Florida Limited Liability Company