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Trembi Privacy Policy

Last Updated: April 7, 2026

This Privacy Policy describes how Trembi Software Ltd (“Trembi”, “we”, “us”, or “our”) collects, uses, processes, stores, and discloses personal data in connection with the use of our platform, website, and related services (collectively, the “Services”).

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

1. Scope of This Policy

This Privacy Policy applies to:

  • Visitors to our website

  • Customers and account holders

  • Users of the Trembi platform

  • Individuals whose personal data is processed through the Services

This Policy governs both:

  • Data collected directly by Trembi

  • Data processed on behalf of our customers

2. Definitions

For purposes of this Policy:

  • “Personal Data” means any information relating to an identified or identifiable natural person.

  • “Processing” means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.

  • “Controller” means the entity that determines the purposes and means of processing Personal Data.

  • “Processor” means an entity that processes Personal Data on behalf of a Controller.

Where applicable:

  • Trembi acts as a Controller for account and platform data

  • Trembi acts as a Processor for customer data uploaded or managed through the platform

3. Categories of Personal Data Collected

3.1 Account and Registration Data

We may collect:

  • Full name

  • Email address

  • Phone number

  • Business name and related details

  • Login credentials and authentication data

3.2 Customer and Lead Data (Processed on Your Behalf)

Users may upload, generate, or manage:

  • Names of contacts

  • Phone numbers

  • Email addresses

  • Communication records

  • Campaign-related information

This data is processed strictly in accordance with user instructions.

3.3 Technical and Usage Data

We automatically collect:

  • IP address

  • Device identifiers

  • Browser type and version

  • Access times and usage logs

  • Platform interaction data

3.4 Communications Data

We may collect:

  • Messages sent through the platform

  • Customer support inquiries

  • Email correspondence

4. Legal Basis for Processing

Where required by applicable law, Trembi processes Personal Data on the following legal bases:

  • Performance of a contract

  • Legitimate business interests, including platform improvement and security

  • Compliance with legal obligations

  • User consent, where applicable

Users are responsible for ensuring they have a valid legal basis for any Personal Data they upload or process using Trembi.

5. Purposes of Processing

We process Personal Data for the following purposes:

  • Provision and operation of the Services

  • Account management and authentication

  • Processing transactions and billing

  • Delivering messaging and campaign functionality

  • Customer support and communication

  • Monitoring usage and ensuring platform security

  • Preventing fraud, abuse, or unlawful activity

  • Compliance with legal and regulatory obligations

6. Anonymized and Aggregated Data

Trembi may process data in anonymized or aggregated form for purposes including:

  • Product development

  • System optimization

  • Statistical analysis

  • Benchmarking and performance insights

Such data does not identify any individual or specific customer.

7. Data Processing Role

7.1 Trembi as Controller

Trembi acts as a Controller for:

  • Account data

  • Billing data

  • Platform usage data

7.2 Trembi as Processor

Trembi acts as a Processor for:

  • Customer and lead data uploaded by users

In such cases:

  • The user is the Controller

  • Trembi processes data only on documented instructions from the user

8. User Responsibilities

Users agree and acknowledge that they are solely responsible for:

  • The legality of Personal Data uploaded to Trembi

  • Obtaining consent where required

  • Compliance with applicable data protection, privacy, and communication laws

  • Ensuring lawful use of email, SMS, and messaging campaigns

Trembi does not independently verify the legality of user-provided data.

9. Data Storage and International Transfers

Personal Data may be stored and processed in multiple jurisdictions, including:

  • United States

  • European Economic Area (EEA)

  • African jurisdictions

By using the Services, you consent to cross-border data transfers.

Where applicable, Trembi implements reasonable safeguards to protect Personal Data during such transfers.

10. Data Retention

We retain Personal Data for as long as necessary to:

  • Fulfill the purposes outlined in this Policy

  • Comply with legal obligations

  • Resolve disputes

  • Enforce agreements

Following account termination:

  • Users may be granted a limited data export period of up to 14 days, subject to operational and legal constraints

  • Thereafter, data may be deleted, anonymized, or irreversibly de-identified

11. Data Sharing and Disclosure

Trembi does not sell Personal Data.

We may disclose Personal Data to:

11.1 Service Providers

Including but not limited to:

  • Cloud hosting providers

  • Payment processors

  • Messaging and communication service providers

  • Analytics and infrastructure providers

These entities process data on our behalf under contractual obligations.

11.2 Legal and Regulatory Authorities

Where required to:

  • Comply with applicable law

  • Respond to lawful requests

  • Protect rights, safety, or property

11.3 Business Transfers

In connection with:

  • Mergers

  • Acquisitions

  • Asset sales

12. Third-Party Platforms

The Services may integrate with third-party platforms, including:

  • Advertising platforms

  • Messaging providers

  • Communication APIs

When using such integrations:

  • Personal Data may be processed by third parties

  • Their respective privacy policies apply

Trembi is not responsible for third-party data practices.

13. Data Security

Trembi implements commercially reasonable technical and organizational measures to protect Personal Data, including:

  • Access controls

  • Encryption where appropriate

  • Secure infrastructure

  • Monitoring and risk detection systems

However, no method of transmission or storage is completely secure, and absolute security cannot be guaranteed.

14. Data Subject Rights

Subject to applicable law, individuals may have the right to:

  • Access Personal Data

  • Correct inaccurate or incomplete data

  • Request deletion

  • Restrict or object to processing

  • Request data portability

Requests may be submitted through the contact details provided below.

15. Marketing Communications

We may send:

  • Service-related communications

  • Administrative notices

  • Product updates

Marketing communications may be sent where permitted by law and can be opted out of at any time.

16. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Operate and improve our website

  • Analyze usage patterns

  • Enhance user experience

Users may manage cookie preferences through browser settings.

17. Children’s Data

The Services are not intended for individuals under the age of 18.

Trembi does not knowingly collect Personal Data from minors.

18. Changes to This Policy

We reserve the right to modify this Privacy Policy at any time.

Updates will be posted on our website with a revised effective date.

Continued use of the Services constitutes acceptance of the updated Policy.

19. Contact Information

For any questions, requests, or concerns regarding this Privacy Policy or data processing practices, please contact Trembi via the official contact channels listed on our website.

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