Privacy Notice

Effective Date: January 1, 2025

Hello! Revsmart Coaching Group, LLC. is a service-first CRM company that builds software designed to maximize profits. We have developed this Privacy Notice (“Notice”) to explain to you how we collect, use, disclose, and store personal data.

This Notice only applies when Revsmart is the Controller of personal data (example: Revsmart website visitors’ personal data and business-to-business contact data). Revsmart is a Processor, not a Controller, of personal data that we process on behalf of our Subscribers when they use Revsmart products and Services. For clarity, this means that this Notice does not apply to where Revsmart processes personal data as a processor in its products and Services. If you have questions related to how a Revsmart Subscriber utilizes your personal data, please contact them directly. We are not responsible for the privacy or data security practices of our Subscribers. This Notice also does not apply to personal data about current and former Revsmart employees, job candidates, or contractors and agents acting in similar roles.

Table of Contents:

1. Introduction
2. Personal Data We Collect and Disclose
3. How We Process Personal Data
4. Sources of Personal Data
5. Cookies and Tracking Technologies
6. Security and Retention
7. Children’s Privacy
8. External Links
9. Contact Information
10. Supplemental Terms for California Residents
11. Supplemental Information for the EEA, Switzerland, and the U.K.
12. Supplemental Information for Other Regions
13. English Version Controls
14. Revsmart Coaching Group, LLC. Affiliates

1. Introduction

This Notice applies to Revsmart Coaching Group, LLC. and its relevant Affiliates listed in Section 14 (“Revsmart,” “us,” “we,” or “our”). Capitalized terms that we use but are not defined in the Notice (such as Site, Services, Subscriber, Agent, Agent Contact Information, etc.) have the meaning provided in our Main Services Agreement. If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“U.K.”), please refer to Section 11 of this Notice for more information about which specific entity or entities act as a controller of your personal data.

When Does This Notice Apply? This Notice only applies to personal data that Revsmart handles as a Controller (meaning where Revsmart controls how and why your personal data is processed). This includes when you:

• Visit or interact with the Revsmart Site, the Revsmart mobile applications, the Revsmart Marketplace, the Revsmart Developer Portal, our branded social media pages, and other Sites which we operate (collectively, our “Digital Properties”);

• Register for or participate in our webinars, events, programs, marketing, and promotional activities;

• Interact with us in person, such as when you visit our offices; and

• Inquire about or engage in commercial transactions with us.

Changes: We may update this Notice from time to time. Please check back periodically for updates. If you do not agree with any changes we make, you should stop interacting with us. When required under applicable law, we will notify you of any changes to this Notice by posting an update on our Site or in another appropriate manner.

2. Personal Data We Collect and Disclose

The below table describes what personal data we collect about you and to whom we disclose personal data. California individuals: This table includes the parties we disclose personal data to for a business or commercial purpose, as defined by California law.

In addition to the above disclosures, we may share your personal data to respond to lawful requests by law enforcement or other government authorities, including to meet national security requirements, in accordance with our Government Data Request Policy. We may also de-identify, anonymize, or aggregate personal data to use or share with third parties for any purpose, where legally permitted.

3. How We Process Personal Data

We may process your personal data for the below purposes:

Revsmart will honor data subject rights to the extent required by law. You may have the right to access, correct, update, and, in some cases, request deletion of your personal data (subject to exceptions). You may submit a request here.

Revsmart uses a limited number of third-party service providers to assist us in processing data for certain purposes. These third-party providers help support certain site features, perform database monitoring and other technical operations, assist with the transmission of data, and provide data storage services. These third parties may process or store personal data while providing their services. Revsmart maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our obligations under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, including the onward transfer provisions, and Revsmart remains liable if they fail to meet those obligations and we are responsible for the event giving rise to damage.

4. Sources of Personal Data

• Information you provide to us directly, including when you register and communicate with us directly through our Digital Properties, visit our offices, or participate in our events, marketing, and outreach activities.
• Information collected from your employer, coworkers, or friends, including information about representatives or other employees of our current, past, and prospective customers, suppliers, investors, and business partners. We may also receive your information from a friend as part of a referral for our Services.
• Information automatically collected, including technical information about your interactions with our Digital Properties (such as IP address, browsing preferences, and purchase history). More information is available in Section 5 below and in our Cookie Notice.
• Information from public sources, including information from public records and information you share in public forums, such as social media.
• Information from other third parties, including information from third-party service and content providers, entities with whom we partner to sell or promote products and services, and social media networks (including widgets related to such networks, such as the “Facebook Like” button).

We may combine information that we receive from the various sources described in this Notice, including third-party sources and public sources, and use or disclose it for the purposes identified above.

5. Cookies and Tracking Technologies

We use cookies and other tracking technologies and offer you the option to manage these settings as described in our Cookie Notice. Some tracking technologies enable us to track your device activity over time and across devices and websites. While some browsers have incorporated Do Not Track or DNT preferences, we do not honor such signals from web browsers at this time.

6. Security and Retention

We maintain appropriate security procedures and technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, disclosure, alteration, or use.

Your personal data will be generally retained as long as necessary to fulfill the purposes for which we collected the personal data. Once you and/or your company have terminated the contractual relationship with us or otherwise ended your relationship with us, we may retain your personal data in our systems and records to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to evidence our business practices and contractual obligations, to provide you with information about our products and services, or to comply with applicable legal, tax, or accounting requirements. When we have no ongoing legitimate business need nor lawful legal ground to process your personal data, we will delete, anonymize, or aggregate it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. If you want to know more about retention periods applicable to your particular circumstance, please contact us using the details provided in Section 9 below.

7. Children’s Privacy

Our Sites and Services are not directed to children under the age of 16, and we do not knowingly collect online personal data directly from children. If you are a parent or guardian of a minor child and believe that the child has disclosed online personal data to us, please contact us using the details provided in Section 9 below.

8. External Links

When interacting with us, you may encounter links to external sites or other online services, including those embedded in third-party advertisements. We do not control and are not responsible for privacy and data collection policies for such third-party sites and services. You should consult such third parties and their respective privacy notices for more information or if you have any questions about their practices.

9. Contact Information

If you have questions or complaints regarding this Notice or about the Revsmart Coaching Group’s privacy practices, please contact us by email at euprivacy@revsmart.com or privacy@revsmart.com, or at:
Revsmart Coaching Group, LLC.
Attn: Privacy Team
4416 Quail Ridge Way
Norcross, GA 30127, United States

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States.  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit here for more information or to file a complaint.  The services of TRUSTe are provided at no cost to you.

10. Supplemental Terms for California Residents

Pursuant to the California Consumer Privacy Act (“CCPA”), this Section 10 applies to certain personal data collected about California individuals where Revsmart controls how and why the personal data is processed (which the CCPA calls a “business”) and supplements the rest of our Notice above. This Section 10 does not apply to current or former employees, applicants, contractors, or agents.

a. Additional Data Processing Disclosures:
The below table provides the categories of personal data we have sold, shared, or disclosed to third parties, as defined by the California Privacy Rights Act. For reference, the table in Section 2 provides the categories of personal data collected and our disclosures of personal data.

Although we have not “sold” or “shared” personal data for money in the past 12 months, we engage in routine practices with our Digital Properties involving third parties that could be considered a “sale” or “sharing” as defined under California law. We do not knowingly sell or share any personal data of minors under the age of 16. We do not collect or process “sensitive personal information,” as defined by California law, to infer characteristics about you. Revsmart only uses sensitive personal information consistent with the exceptions to the right to limit sensitive personal information.

Financial Incentives: We may offer a benefit or offering in exchange for you providing personal data, such as a discount or coupon to individuals who respond to a survey. As part of these surveys we may collect personal data, such as your name, contact information, preferences, experiences, beliefs, opinions, and other responses to the survey questions. Participation in surveys is governed by the applicable terms and conditions for the survey, which will describe any financial incentives associated with that survey and how to participate. The value of your data is the value of the offer presented to you. We have calculated such value by using the expense related to the benefit. You may withdraw from any financial incentive at any time by emailing us at privacy@revsmart.com. If we offer another type of financial incentive, we will share with you the material terms of each offer when we ask you to participate.

b. Your Data Protection Rights:
Subject to legal limitations, certain California residents may have the below rights.

• Right to Know. You have the right to request information about the categories of personal data we have collected about you, the categories of sources from which we collected the personal data, the purposes for collecting the personal data, the categories of third parties to whom we have disclosed your personal data, and the purpose for which we disclosed your personal data (“Categories Report”). You may also request information about the specific pieces of personal data we have collected about you (“Specific Pieces Report”).
• Right to Delete. You have the right to request that we delete personal data that we have collected from you.
• Right to Correct. You have the right to request that we correct inaccurate personal data that we maintain about you.
• Right to Opt Out of Sale or Sharing. We do not sell personal data to third parties in exchange for money. However, as we explain in Section 5, we share information with advertising partners and allow advertising partners to collect information from our Digital Properties. This exchange may be considered a “sale” or “sharing” under California law, and you have the right to opt out of this “sale” or “sharing” of personal data.

California residents may request to exercise the Right to Know, the Right to Delete, and the Right to Correct by using our webform or by emailing us at privacy@revsmart.com. We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.

How to Fully Exercise the Right to Opt Out of Sale or Sharing: In order to fully exercise the Right to Opt Out of Sale or Sharing with respect to any “sale” or “sharing” of information, you must undertake both of the following steps:

1. Submit a Right to Opt Out of Sale or Sharing request using our webform; and

2. Disable the use of advertising cookies and other tracking technologies by clicking the “Do Not Sell or Share My Personal Information” link in our website footer. You must complete this step on each of our Sites from each browser and on each device that you use. These steps are necessary so that we can place a first-party cookie signaling that you have opted out on each browser and each device you use.

If you block cookies, we will be unable to comply with your Right to Opt Out of Sale or Sharing request for device data that we automatically collect and disclose to third parties online using cookies, pixels, and other tracking technologies. If you clear the cookies in your browser, you will need to follow Step 2 above again. To the extent required by California law, we will honor “Do Not Sell or Share” opt-out preference signals sent in a format commonly-used and recognized by businesses at the browser level, such as an HTTP header field or JavaScript object.

Verification: To process California data protection requests, we will need to obtain information to locate you in our records or verify your identity, depending on the nature of the request. In most cases, we will request information about you, which may include your name, email address, or other information. If you submit a Right to Know “Specific Pieces Report,” we may also request a signed declaration, under penalty of perjury, that you are who you say you are. We may request alternative information under certain circumstances and/or use third parties to help verify your identity.

Authorized Agents: Authorized agents may exercise California data protection rights on behalf of California individuals, but we reserve the right to verify the individual’s identity directly as described above. Authorized agents must contact us by submitting a request through our webform and indicate that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on your behalf by providing signed permission from you. We may also require you to verify your own identity directly with us or to directly confirm with us that you provided the authorized agent permission to submit the request.

Timing: We will process Right to Opt Out of Sale or Sharing requests within fifteen business days from the date we received the request. We will respond to Requests to Delete and Requests to Know within forty-five days unless we need more time, in which case we will notify you, and it may take up to ninety days to respond to your request.