Privacy Policy

1. Introduction and Scope

Gravion Technologies Pvt. Ltd. ("Gravion", "Sentio", "we", "us", or "our") respects the privacy of individuals and is committed to protecting Personal Data entrusted to us. This Privacy Policy explains how we collect, use, disclose, store, retain, and otherwise process Personal Data in connection with the Sentio platform, our websites, applications, products, services, and related interactions (collectively, the "Services").

This Privacy Policy applies to: (a) individuals who visit or interact with our websites; (b) individuals who create, administer, access, or use Sentio Accounts on behalf of our business customers; (c) individuals who communicate with us regarding sales inquiries, support requests, billing matters, or other business-related interactions; and (d) individuals whose Personal Data is processed by Sentio in connection with the provision of the Services to our business customers, to the extent applicable under relevant data protection laws.

Sentio is a business-to-business (B2B) software platform designed to assist organizations in managing leads, customer relationships, event interactions, sales activities, and related business processes. In many cases, Sentio processes Personal Data solely on behalf of and under the instructions of its customers.

By accessing or using the Services, interacting with Sentio, or otherwise providing information to us, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, you should refrain from using the Services or providing Personal Data to us.

2. Information We Collect

Depending on how you interact with Sentio and the Services, we may collect the following categories of information:

2.1 Information You Provide Directly to Us

We may collect information that you voluntarily provide when you create an Account, subscribe to the Services, request a demonstration, communicate with us, seek support, purchase Services, or otherwise interact with Sentio. Such information may include: (a) name; (b) business name and business contact details; (c) job title or designation; (d) email address; (e) telephone number; (f) billing and invoicing information; (g) account credentials and authentication information; (h) communication preferences; (i) information provided in support requests, surveys, feedback submissions, or correspondence with Sentio; and (j) any other information that you choose to provide to us.

2.2 Information Collected Automatically

When you access or use the Services, we may automatically collect certain technical and usage-related information necessary for the operation, security, administration, and improvement of the Services. Such information may include: (a) IP addresses; (b) browser type and version; (c) operating system information; (d) device identifiers; (e) date and time of access; (f) pages viewed and features utilized; (g) login activity and authentication events; (h) system activity logs and diagnostic information; (i) error reports and crash information; and (j) information collected through cookies and similar technologies.

2.3 Customer Data Processed Through the Services

Our customers may upload, submit, store, organize, analyze, or otherwise process information through Sentio in connection with their use of the Services. Such information may include Personal Data relating to their employees, customers, prospects, business contacts, vendors, partners, or other individuals. The nature of such Customer Data is determined solely by our customers. Sentio processes Customer Data on behalf of and under the instructions of its customers for the purpose of providing the Services.

2.4 Information Obtained from Third Parties

We may receive information relating to individuals from third-party sources, including: (a) payment processors; (b) authentication providers; (c) business partners and referral sources; (d) customer-authorized integrations; (e) publicly available business sources; and (f) service providers assisting in the delivery of the Services.

2.5 AI-Related Inputs and Outputs

Where customers utilize AI-enabled functionalities made available through the Services, Sentio may process prompts, instructions, Customer Data submitted for analysis, and AI-generated outputs solely for the purpose of providing the requested functionality. Sentio does not use Customer Data submitted through AI-enabled functionalities to independently market to individuals or to build customer profiles unrelated to the provision of the Services.

2.6 Information We Do Not Intentionally Collect

Sentio does not intentionally collect Personal Data directly from children or individuals below the age required to provide legally valid consent under applicable laws. The Services are designed and intended solely for use by businesses and authorized users acting on behalf of businesses.

3. How We Use Information

Sentio uses Personal Data and other information collected in connection with the Services for the following purposes:

3.1 Provision and Administration of the Services

To establish, maintain, administer, and secure Accounts; provide access to the Services; authenticate users; facilitate customer onboarding; and otherwise provide, operate, maintain, and support the Services.

3.2 Customer Support and Communications

To respond to inquiries, requests, and support tickets; troubleshoot technical issues; communicate regarding updates, service-related notices, billing matters, and administrative information; conduct customer satisfaction surveys; and provide assistance in connection with the use of the Services.

3.3 Billing and Commercial Administration

To process subscriptions and purchases; generate invoices; process payments; administer AI Credit purchases and usage-based offerings; and collect outstanding amounts.

3.4 Security, Fraud Prevention, and Service Protection

To detect, investigate, prevent, and respond to fraud, abuse, unauthorized access, security incidents, or violations of our Terms and Conditions; monitor the integrity, security, and performance of the Services; and protect the rights, property, safety, and legitimate interests of Sentio, our customers, users, and other third parties.

3.5 Service Improvement and Analytics

To analyze usage trends; improve the functionality, reliability, usability, and performance of the Services; and develop reports, statistics, and insights using aggregated or de-identified information.

3.6 Compliance with Legal Obligations

To comply with applicable laws, regulations, legal processes, governmental requests, and regulatory requirements; establish, exercise, or defend legal claims; and enforce our Terms and Conditions.

3.7 AI-Enabled Functionalities

Where customers utilize AI-enabled functionalities, Sentio may process prompts, instructions, Customer Data submitted for analysis, and AI-generated outputs solely for the purpose of providing the requested AI functionality. Sentio does not use Customer Data submitted through AI-enabled functionalities to train, fine-tune, or improve Sentio's own artificial intelligence models or the general-purpose artificial intelligence models of third parties.

3.8 Business Communications

We may use contact information to communicate with customers and prospective customers regarding service-related announcements, account administration matters, billing and payment communications, updates relating to the Services, security notices, and information relating to products or services offered by Sentio where permitted under applicable law.

4. Legal Bases for Processing (Where Applicable)

Depending on the circumstances in which Personal Data is collected and processed, Sentio may rely on one or more of the following legal bases: (a) Performance of a Contract — where processing is necessary to provide, operate, maintain, and support the Services; (b) Compliance with Legal Obligations — where necessary to comply with applicable laws, regulations, court orders, or governmental directives; (c) Legitimate Business Interests — to the extent permitted under applicable laws, for improving, maintaining, and securing the Services, preventing fraud, and protecting the rights and interests of Sentio and its customers; (d) Consent — where required under applicable laws, subject to the right to withdraw consent at any time; and (e) Customer Instructions — where Sentio processes Customer Data on behalf of customers using the Services, carried out pursuant to the instructions of the applicable customer.

5. Customer Data and Roles in Data Processing

Sentio is a B2B software platform that enables customers to collect, organize, manage, analyze, and otherwise process information relating to leads, customers, prospects, employees, vendors, partners, and other business contacts ("Customer Data").

With respect to Customer Data processed through the Services: (a) the Customer is responsible for determining the purposes and means of such processing; (b) the Customer is responsible for ensuring that the collection, use, disclosure, transfer, retention, and processing of Customer Data complies with applicable laws; (c) the Customer is responsible for providing any required notices and obtaining any consents, permissions, authorizations, or other lawful bases necessary for the processing of Customer Data; and (d) the Customer remains responsible for the accuracy, quality, integrity, and legality of Customer Data.

Sentio processes Customer Data solely to provide, operate, maintain, secure, and support the Services, in accordance with the Customer's instructions, and to comply with applicable legal obligations. Sentio does not independently determine the purposes for which Customer Data is collected by customers and does not use Customer Data for Sentio's own marketing activities directed toward the individuals whose information forms part of Customer Data.

6. AI-Enabled Features and Processing

Sentio may offer certain artificial intelligence ("AI") enabled functionalities as part of the Services or through optional add-on offerings. Such functionalities may include, without limitation, lead intelligence, sentiment analysis, conversation summaries, content generation, recommendations, predictive insights, workflow assistance, and other AI-assisted capabilities.

Where customers utilize AI-enabled functionalities, Sentio may process prompts, instructions, Customer Data submitted for analysis, contextual information necessary to perform the requested task, and AI-generated outputs solely for the purpose of providing the requested functionality.

Sentio does not use Customer Data submitted through AI-enabled functionalities to train, fine-tune, or improve Sentio's own artificial intelligence models or the general-purpose artificial intelligence models of third parties. Sentio does not use Customer Data submitted through AI-enabled functionalities to independently market to individuals or to create customer profiles unrelated to the provision of the Services.

AI-generated outputs may contain inaccuracies, omissions, biases, or other limitations inherent in AI technologies. Customers remain solely responsible for independently reviewing, validating, and determining the appropriateness of any AI-generated outputs before relying upon or acting upon such outputs.

7. Cookies and Similar Technologies

Sentio and its authorized service providers may use cookies and similar technologies to operate, secure, and improve the Services and our websites. Cookies are small text files that are stored on a user's device when visiting a website.

7.1 Essential Cookies

These cookies are necessary for the operation of the Services and enable core functionality such as user authentication, session management, security and fraud prevention, and maintaining user preferences.

7.2 Analytics and Performance Technologies

We may use analytics and performance technologies to understand how users interact with the Services, analyze usage patterns and trends, improve functionality, identify technical issues, and evaluate the effectiveness of features.

7.3 Functional Technologies

We may use functional technologies to enhance convenience and improve the user experience by remembering settings, preferences, and configuration choices made by users.

7.4 Managing Cookies

Most web browsers allow users to manage cookies through browser settings. Please note that disabling or restricting certain cookies may impact the availability, performance, or functionality of the Services.

Sentio does not use cookies or similar technologies to sell Personal Data or to facilitate third-party behavioral advertising unrelated to the provision of the Services.

8. Disclosure of Information

Sentio may disclose Personal Data and other information collected in connection with the Services only in the circumstances described in this Privacy Policy or as otherwise permitted or required by applicable laws.

8.1 Service Providers and Subprocessors

Sentio may engage third-party service providers and subprocessors to support the operation, delivery, maintenance, and improvement of the Services, including cloud hosting, authentication, payment processing, communication, customer support, analytics, artificial intelligence, backup, and security providers. Such providers shall be authorized to access and process information only to the extent reasonably necessary and shall be subject to appropriate contractual obligations.

8.2 Customer-Authorized Integrations

Where a Customer elects to enable third-party integrations, Sentio may disclose information necessary to facilitate such integrations in accordance with the Customer's instructions and configuration choices.

8.3 Payment Processing

Sentio may disclose information necessary to facilitate billing, payment processing, fraud prevention, accounting, and related financial activities through authorized payment processors. Sentio does not store complete payment card information except to the extent necessary to fulfill legal obligations.

8.4 Artificial Intelligence Service Providers

Where customers utilize AI-enabled functionalities, Sentio may disclose prompts, instructions, Customer Data submitted for analysis, and other information reasonably necessary to enable the requested functionality through authorized AI service providers. Sentio requires such providers to process such information solely for the purpose of delivering the requested functionality and not for independent model training purposes.

8.5 Legal and Regulatory Requirements

Sentio may disclose information where reasonably necessary to comply with applicable laws, regulations, court orders, or governmental directives; establish, exercise, or defend legal claims; investigate, prevent, or address suspected fraud, security incidents, or violations of our Terms and Conditions; or protect the rights, property, safety, or legitimate interests of Sentio, our customers, users, or third parties.

8.6 Corporate Transactions

Sentio may disclose information in connection with a proposed or actual merger, acquisition, corporate restructuring, sale of assets, financing arrangement, change in control, or other similar corporate transaction involving Gravion Technologies Pvt. Ltd.

8.9 No Sale of Personal Data

Sentio does not sell Personal Data to third parties. Sentio does not disclose Personal Data to third parties for their own independent marketing purposes unrelated to the provision of the Services.

9. International Data Transfers

Sentio primarily hosts and stores Customer Data within data centers located in India. However, in the course of providing the Services, certain information may be accessed, processed, transmitted, stored, or otherwise handled outside India by Sentio, its affiliates, authorized subprocessors, or service providers engaged to support the operation of the Services.

Where Sentio transfers or permits the processing of Personal Data outside India, Sentio shall take reasonable steps to ensure that such transfers are carried out in accordance with applicable laws and subject to appropriate safeguards, including contractual obligations relating to confidentiality, security, and data protection; assessments of the nature and necessity of the transfer; and restricting access to authorized personnel and service providers.

10. Information Security

Sentio implements and maintains reasonable technical, organizational, and administrative measures designed to protect Personal Data and Customer Data against unauthorized access, acquisition, disclosure, alteration, destruction, loss, misuse, or other unlawful forms of processing. Such measures may include access controls and authentication mechanisms; encryption of data during transmission; network security measures; logging, monitoring, and security event detection; backup and recovery processes; secure software development practices; and employee and contractor confidentiality obligations.

While Sentio endeavors to implement and maintain appropriate safeguards, no method of transmission over the internet, electronic storage system, or information security program can guarantee absolute security. Accordingly, Sentio does not warrant or guarantee that the Services will be immune from security incidents, cyberattacks, or unauthorized access attempts beyond Sentio's reasonable control.

11. Data Retention

Sentio retains Personal Data and Customer Data only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with applicable laws, enforce contractual rights, resolve disputes, maintain security, and support the provision of the Services.

11.2 Customer Data

Customer Data processed through the Services shall generally be retained for the duration of the applicable Subscription Term and any applicable Grace Period. Where a Subscription expires and is not renewed, Sentio may provide a grace period of fifteen (15) calendar days, during which the Customer may continue to access and use the Services. Following termination, Sentio shall generally make Customer Data available to the Customer for retrieval for a period of thirty (30) calendar days ("Retrieval Period"), during which the Customer may export or otherwise retrieve Customer Data. After the Retrieval Period, Sentio may permanently delete Customer Data from its production systems.

11.3 Backup and Archival Records

Residual copies of information may continue to exist within backup systems, archival media, disaster recovery environments, system logs, and other operational records for a limited period following deletion from production systems. Such residual copies shall remain subject to applicable confidentiality, security, and data protection obligations.

12. Your Rights and Choices

Depending upon the nature of your relationship with Sentio and the requirements of applicable laws, you may have certain rights and choices relating to your Personal Data. Where Sentio determines the purposes and means of processing Personal Data, individuals may, subject to applicable laws, exercise the following rights: (a) request access to Personal Data maintained by Sentio; (b) request correction, updating, or completion of inaccurate or incomplete Personal Data; (c) request the deletion of Personal Data where retention is no longer necessary; (d) withdraw consent previously provided for specific processing activities; (e) object to or request restrictions on certain processing activities; and (f) request information regarding the categories of Personal Data processed by Sentio.

Where an individual seeks to exercise rights relating to Personal Data contained within Customer Data processed through the Services, such requests should ordinarily be directed to the relevant customer that collected the information.

13. Grievance Redressal and Complaints

Individuals who wish to raise concerns regarding the manner in which Sentio processes Personal Data, seek clarification regarding this Privacy Policy, exercise applicable rights, or submit privacy-related complaints may contact Sentio using the contact details provided below.

Sentio shall endeavor to acknowledge and address grievances and complaints within a reasonable period. Submission of a grievance or complaint to Sentio does not limit any rights or remedies that may otherwise be available to individuals under applicable laws.

14. Third-Party Websites and Services

The Services may contain links to third-party websites, applications, products, services, integrations, or other resources that are not owned, operated, or controlled by Sentio. Sentio does not control and is not responsible for the content, availability, functionality, or security of third-party websites or services; the privacy practices, data handling activities, or policies of third parties; or the accuracy, completeness, or reliability of information made available by third parties.

Customers and users are encouraged to review the applicable privacy policies, terms of service, and other relevant documentation of any third-party services with which they choose to interact. The inclusion of links to third-party websites or the availability of integrations through the Services shall not be construed as an endorsement or representation by Sentio regarding such third parties.

15. Changes to This Privacy Policy

Sentio may revise, amend, update, or otherwise modify this Privacy Policy from time to time to reflect changes in applicable laws, regulatory requirements, industry practices, technologies, business operations, service offerings, security practices, or other legitimate business needs. The "Last Updated" date appearing at the beginning of this Privacy Policy shall indicate the date on which the most recent revision became effective.

The continued access to or use of the Services following the effective date of a revised Privacy Policy shall constitute acknowledgment of the updated Privacy Policy to the extent permitted under applicable laws. Customers and users are encouraged to review this Privacy Policy periodically to remain informed regarding Sentio's privacy practices.

16. Contact Us

If you have any questions regarding this Privacy Policy, wish to exercise rights available under applicable laws, submit a privacy-related request, or raise a grievance relating to the processing of Personal Data by Sentio, you may contact us using the details set forth below:

17. Supplemental Provisions

Nothing in this Privacy Policy shall be construed as limiting any rights, obligations, exemptions, or protections available to Sentio, its customers, users, or individuals under applicable laws. In the event of any inconsistency between this Privacy Policy and any supplemental privacy notice expressly applicable to a particular Service or processing activity, the provisions of such supplemental notice shall prevail solely with respect to the matters specifically addressed therein.

This Privacy Policy shall be interpreted in a manner consistent with applicable laws. If any provision of this Privacy Policy is determined to be invalid, unlawful, or unenforceable under applicable laws, such provision shall be interpreted or modified to the minimum extent necessary to achieve compliance, and the remaining provisions shall continue in full force and effect.