Privacy Policy
This Privacy Policy explains how SISNOVA LLC ("SISNOVA", "we", "us" or "our") collects, uses and shares personal data in connection with the EasyLeads platform, websites and related services (the "Platform"), and the choices and rights you may have.
EasyLeads lets our business customers ("Clients") configure and deploy AI Agents that communicate with their own customers, leads and contacts ("End Users") over messaging channels, and connects to third-party services such as AI model providers, messaging/telecommunications providers and CRM systems.
1. Our Role: Controller and Processor
When we process personal data about our Clients and their account users (for example, to create accounts, provide support and bill for the Platform), we act as a controller.
When our Clients use the Platform to communicate with, and process data about, their End Users (for example the content of conversations, phone numbers, and lead or profile data), the Client determines the purposes and means of that processing. In that case the Client is the controller and SISNOVA acts as a processor on the Client's behalf, processing that data on the Client's instructions. If you are an End User, the Client you interacted with is primarily responsible for your data as controller, and you should direct your requests to that Client (see Section 11).
2. Information We Collect
2.1 Information Clients provide
- Account and contact data — name, business name, email address, phone number and login credentials.
- Billing data — subscription plan and payment information (card details are handled by our payment processor, not stored by us).
- Client Content and Configuration — prompts, instructions, business information, settings and other content Clients enter into the Platform.
2.2 End User data processed on behalf of Clients
- Conversation content — messages exchanged between End Users and AI Agents, including text and, where enabled, transcriptions of voice notes and information extracted from images.
- Contact and lead data — phone numbers, names and other identifiers, lead details and structured customer-profile information captured during conversations.
- Integration data — data exchanged with connected CRM systems.
2.3 Information we collect automatically
- Usage and device data — log data, IP address, browser and device information, and actions taken in the Platform.
- Cookies and similar technologies — used to keep you signed in, remember preferences and understand usage (see Section 13).
3. How We Use Information
We use personal data to:
- provide, operate, maintain and secure the Platform, including deploying and running the AI Agents that Clients configure;
- process conversations through AI model providers to generate responses, transcriptions, embeddings and other Output;
- authenticate users, provide customer support and communicate about the Platform;
- bill for and administer subscriptions;
- monitor, analyze and improve the Platform, its reliability and security, including using aggregated or de-identified data; and
- comply with law and enforce our agreements.
We do not sell personal data. We do not use End User personal data to train our own general-purpose AI models. Personal data is processed by third-party AI providers only to provide the Platform's features, under their terms; the leading API providers we use do not use such data to train their models by default.
4. AI Processing
The Platform relies on third-party AI models (such as those from Anthropic and OpenAI) to power AI Agents. Conversation content and related inputs are sent to these providers to generate Output. As explained in our Terms of Service, AI Output may be inaccurate or inappropriate and should not be relied upon without human review. Clients are responsible for what their AI Agents communicate and for the data they choose to process through the Platform.
6. Sub-Processors and Third-Party Providers
We rely on the following categories of providers to operate the Platform. Their processing is governed by their own terms and privacy policies, and their availability and behavior are outside our control:
- AI model providers — Anthropic and OpenAI (generating responses, transcription, embeddings and image understanding);
- Messaging and telecommunications — Twilio, and the WhatsApp/Meta platforms (delivering and receiving messages);
- Email delivery — Postmark (transactional email);
- CRM integrations — the CRM systems Clients choose to connect (such as Kommo);
- Hosting and infrastructure — cloud hosting, storage and database providers that host the Platform.
The specific list of sub-processors may change as the Platform evolves. A current list is available on request at compliance@sisnova.io.
7. Legal Bases (EEA/UK)
Where the GDPR or UK GDPR applies and we act as a controller, we process personal data on these legal bases: performance of a contract (to provide the Platform); our legitimate interests (to operate, secure and improve the Platform), balanced against your rights; compliance with a legal obligation; and consent where required. Where we act as a processor, our Client is responsible for establishing the legal basis for the processing.
8. International Data Transfers
We are based in the United States and use providers that may process data in the United States and other countries. Where personal data is transferred from the EEA, the UK or other regions, we rely on an appropriate transfer mechanism (such as the European Commission's Standard Contractual Clauses) where required by law.
9. Data Retention
We retain personal data for as long as needed to provide the Platform, and thereafter as needed to comply with legal obligations, resolve disputes and enforce our agreements. For End User data we process on a Client's behalf, retention is controlled by the Client's settings and instructions; we delete or return such data after termination as described in our Terms, subject to legal retention and to backups that cycle out over time.
10. Security
We maintain reasonable administrative, technical and organizational measures designed to protect personal data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
Clients are responsible for the security implications of their own Configuration and Client Content. We are not responsible for the exposure or disclosure of information that results from a Client's misconfiguration, a Client's instructions, or a Client placing into the Platform information that should not be shared (for example an EIN, credentials or other sensitive business information that an AI Agent then discloses). Responsibility for what a Client puts into the Platform — and therefore what may be shared with End Users — rests with the Client.
11. Your Privacy Rights
Depending on where you live and our role, you may have rights to access, correct, delete, port, restrict or object to the processing of your personal data, and to withdraw consent. To exercise rights regarding data we control, contact us at compliance@sisnova.io; we may need to verify your identity.
If you are an End User, the Client whose AI Agent you interacted with is the controller of your data. Please direct your request to that Client; if you contact us, we will refer your request to the relevant Client and assist them as their processor.
12. U.S. State Privacy Rights (including California)
If you are a resident of California or another U.S. state with a privacy law, you may have the right to know or access the personal information we collect, to request its deletion or correction, and to be free from discrimination for exercising your rights. We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act (as amended by the CPRA) and similar laws. The categories of personal information we collect and the purposes for which we use them are described in Sections 2 and 3. You may submit a request, including through an authorized agent, at compliance@sisnova.io. For personal information we process on behalf of a Client, we will refer your request to that Client.
14. Children's Privacy
The Platform is intended for businesses and is not directed to children. We do not knowingly collect personal data from children under 13 (or the age set by local law). Clients must not use the Platform to knowingly collect personal data from children in violation of applicable law.
15. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will revise the effective date above and, where appropriate, provide additional notice. Your continued use of the Platform after an update takes effect constitutes acceptance of the updated Policy.
16. Contact Us
For any privacy question or request, contact us at compliance@sisnova.io. If you are an End User, please also contact the Client whose AI Agent you interacted with, as that Client is the controller of your data.