1. Introduction

Welcome to CustoMingle. We are committed to protecting your privacy and maintaining transparency regarding how we collect, use, process, and safeguard personal information.

This Privacy Policy explains how we handle personal data when you access or use our website, BOS platform, applications, integrations, communications tools, and related services (collectively, the “Services”).

By accessing or using our Services, you agree to the practices described in this Privacy Policy.

2. Roles and Responsibilities

When using CustoMingle:

• You are the Data Controller of the customer and business data you upload into the platform.
• CustoMingle acts as a Data Processor or service provider, processing such data on your behalf to provide the Services.

We process customer data only:

• In accordance with your instructions,
• To provide and maintain the Services,
• To comply with legal obligations,
• Or as otherwise permitted by applicable law.

3. Information We Collect

a. Information You Provide

We may collect information you voluntarily provide, including:

• Name, email address, phone number, and mailing address
• Business and company information
• Account credentials and profile details
• Billing and payment information (processed through third-party payment providers)
• BOS data such as contacts, communications, notes, files, customer records, and uploaded content
• Support requests and communications with us

b. Automatically Collected Information

When you use our Services, we may automatically collect:

• IP address
• Browser type and version
• Device identifiers and operating system
• Usage activity and platform interaction logs
• Referral URLs
• Session information
• Cookies and similar tracking technologies

c. Information from Third Parties

We may receive information from:

• Payment processors
• Integration and application partners
• Analytics providers
• Authentication or identity verification providers
• Communication and messaging service providers

4. Legal Basis for Processing

We process personal information where necessary to:

• Provide requested Services
• Fulfill contractual obligations
• Process transactions
• Respond to support requests
• Improve platform performance and security
• Comply with legal obligations
• Protect legitimate business interests
• Obtain consent where required by law

5. How We Use Information

We use collected information to:

• Provide, operate, and maintain the Services
• Manage accounts and subscriptions
• Process payments and billing
• Authenticate users and secure accounts
• Deliver customer support
• Improve features, functionality, and user experience
• Monitor usage, analytics, and platform performance
• Prevent fraud, abuse, and unauthorized activity
• Communicate updates, notices, and service-related information
• Comply with legal and regulatory obligations

6. SMS Communications and Messaging

We respect your privacy when it comes to text messaging. If you choose to opt in to receive SMS communications from CustoMingle, your consent and participation will be handled in compliance with applicable laws and industry standards.

Your decision to opt in to SMS communications will never be shared with third parties for purposes unrelated to delivering those services.

However, we may share your personal data, including your SMS opt-in or consent status, with trusted third-party service providers who assist us in operating our messaging services. These may include platform providers, mobile carriers, phone companies, and vendors involved in delivering text messages solely for the purpose of providing these services.

We limit the sharing of SMS-related data to only what is necessary to operate and deliver our messaging services.

The following applies specifically to SMS messaging compliance requirements:

You may opt out of SMS communications at any time by replying STOP.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Enable essential platform functionality
• Remember preferences and settings
• Analyze traffic and usage trends
• Improve performance and user experience
• Support security and authentication

You may control cookies through your browser settings or applicable consent tools.

For more information, please refer to our Cookie Policy.

8. How We Share Information

We do not sell personal information.

We may share information with:

• Service providers and subprocessors supporting our operations
• Payment processors
• Analytics and infrastructure providers
• Communication and messaging vendors
• Integration partners enabled by users
• Legal or regulatory authorities when required by law
• Successors in connection with a merger, acquisition, financing, or sale of assets

We require service providers to process information only for authorized purposes and to maintain appropriate confidentiality and security measures.

9. Subprocessors and Service Providers

We may engage trusted third-party subprocessors to assist with:

• Cloud hosting and infrastructure
• Payment processing
• Analytics and monitoring
• Customer support systems
• Messaging and communication delivery
• Security and fraud prevention

These providers are contractually obligated to protect personal information and process data only as necessary to provide their services.

10. Data Ownership and Confidentiality

You retain ownership of all customer and business data uploaded to the Services.

CustoMingle does not:

• Sell customer data,
• Claim ownership of customer content,
• Or use customer BOS data for unrelated advertising purposes.

We treat customer business data as confidential and access such information only when necessary to:

• Provide support,
• Maintain platform operations,
• Protect system security,
• Comply with legal obligations,
• Or as authorized by you.

11. Data Security

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

• Role-based access controls
• Authentication and account protections
• Encryption where appropriate
• Secure infrastructure practices
• Monitoring and audit logging
• Security testing and maintenance procedures

Despite these efforts, no method of electronic transmission or storage is completely secure.

12. Account Security

You are responsible for maintaining the confidentiality of your account credentials and for all activities occurring under your account.

You should immediately notify us of any unauthorized use of your account or suspected security incident.

13. Automated Tools and Analytics

We may use automated systems, analytics tools, and similar technologies to improve platform functionality, performance, security, and user experience. These systems are not used to make legally significant decisions about users without appropriate human oversight.

14. Data Backup and Recovery

We maintain reasonable backup and recovery procedures intended to help protect customer data from accidental loss, corruption, or system failure.

However, customers are encouraged to maintain independent backups of important information.

15. Data Retention

We retain personal information only for as long as necessary to:

• Provide the Services
• Fulfill contractual obligations
• Comply with legal requirements
• Resolve disputes
• Enforce agreements

Upon account termination, data may be deleted, anonymized, or retained as required by applicable law or legitimate business purposes.

16. Data Breach Response

In the event of a data breach affecting personal information, we will take reasonable steps to:

• Investigate the incident,
• Mitigate potential harm,
• Restore system security,
• And provide notifications where required by applicable law.

17. Your Privacy Rights (CCPA/CPRA)

If you are a California resident, you may have the right to:

• Know what personal information we collect
• Request access to your personal information
• Request deletion of personal information
• Request correction of inaccurate information
• Limit the use of sensitive personal information
• Opt out of certain data sharing practices
• Exercise rights without discrimination

To exercise applicable privacy rights, contact: privacy@customingle.com

We may verify your identity before processing certain requests.

You may also use any available “Do Not Sell or Share My Personal Information” tools provided on our website.

18. International Data Transfers

Your information may be transferred to, stored in, and processed in the United States or other jurisdictions where our service providers operate.

By using the Services, you acknowledge such transfers.

19. Third-Party Services and Integrations

Our Services may integrate with third-party applications, platforms, or services.

We are not responsible for the privacy practices, security, or content of third-party services.

Users are encouraged to review the policies of connected third-party providers.

20. Children’s Privacy

Our Services are not directed to individuals under the age of 13, and we do not knowingly collect personal information from children.

21. Security Monitoring and Enforcement

We reserve the right to monitor platform activity and to suspend, restrict, or terminate access where necessary to:

• Protect platform integrity,
• Maintain security,
• Prevent abuse,
• Investigate violations,
• Or comply with legal obligations.

22. Changes to This Privacy Policy

We may update this Privacy Policy periodically.

Any changes will be posted with a revised Effective Date. Continued use of the Services after updates constitutes acceptance of the revised Policy.

23. Contact Us

For privacy-related questions, requests, or concerns, contact: privacy@customingle.com or visit our Contact Page.