Privacy Policy

Last Updated: October 12, 2026

This Privacy Policy applies to the processing of personal information by Deal (" Deal," " we," " us," or " our") including on our website available at https://backtrail.ai/ and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Policy (collectively, the " Services").

Disclosure Regarding the California Consumer Privacy Act (Notice at Collection). For information on our processing of personal information that is subject to the California Consumer Privacy Act (" CCPA"), please see Supplemental CCPA Privacy Policy below.

Disclosure Regarding Customer Data. This Privacy Policy does not apply to the personal information that our customers independently provide to us about their prospects or customers pursuant to a written agreement we have entered into with such customers (" Customer Data"). Our customers' respective privacy notices or policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.

1. Updates to This Privacy Policy

We may update this Privacy Policy from time to time in our sole discretion. If we do, we'll let you know by posting the updated Privacy Policy on our website, and/or we may also send other communications.

2. Personal Information We Collect

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, email address, phone number, and other information you store with your account.
Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered "public."
Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.

Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).
Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (" Technologies") to automatically collect personal information through your use of the Services.
- Cookies. Cookies are small text files stored in device browsers.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See "Your Privacy Choices and Rights" below to understand your choices regarding these Technologies.

Personal Information Collected from Third Parties

We may collect personal information about you from third parties.

For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings.

In addition, we may collect personal information about leads and prospects from commercially available sources including, but not limited to, data co-ops and data brokers (" Leads Data").

3. How We Use Personal Information

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

Provide the Services

We use personal information to fulfill our contract with you and provide the Services, such as:

Managing your information;
Providing access to certain areas, functionalities, and features of the Services;
Answering requests for support;
Communicating with you;
Sharing personal information with third parties as needed to provide the Services;
Processing your financial information and other payment methods for products and Services purchased;
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for events.

Administrative Purposes

We use personal information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Carrying out analytics;
Measuring interest and engagement in the Services;
Improving, upgrading, or enhancing the Services;
Developing new products and services;
Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to re-identify such information, unless permitted by, or required to comply with, applicable laws;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
Debugging to identify and repair errors with the Services;
Auditing relating to interactions, transactions, and other compliance activities;
Enforcing our agreements and policies; and
Carrying out activities that are required to comply with our legal obligations.

Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices, you may contact us at any time as set forth in "Contact Us" below.

With Your Consent or Direction

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.

Automated Decision Making

We may engage in automated decision making, including profiling.

For example, we may collect personal information from different public and private sources and compile the personal information to develop profiles on which individuals may be a good prospect for a particular customer.

We may also use fully automated means to analyze Leads Data and create a short list of prospects for our customers.

4. How We Disclose Personal Information

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

Disclosures to Provide the Services

We may disclose any of the personal information we collect to the categories of third parties described below. These providers must implement appropriate security controls, including encryption, access restrictions, and compliance with applicable data protection laws (e.g., GDPR, CCPA). We conduct vendor risk assessments to ensure that our service providers maintain strong data security practices.

Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.

Some of the service providers we may use include:

Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics' Privacy Policy.
LinkedIn Analytics. For more information about how LinkedIn uses your personal information, please visit LinkedIn Analytics' Privacy Policy.
Use of Google Workspace APIs. We do not use any data obtained from Google Workspace APIs to develop, improve, or train generalized artificial intelligence (AI) or machine learning (ML) models. Such data is only used to provide or improve user-facing features that are specifically requested by our users, in accordance with Google's API Services User Data Policy, including its Limited Use requirements.
Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a " Third-Party Service"). Any personal information shared with a Third-Party Service will be subject to the Third-Party Service's privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
Leads Data Shared with Deal Customers. We may share Leads Data with Deal customers. For clarity, Leads Data is data that we independently source and provide to our customers. Leads Data is not Customer Data. We do not share Customer Data that we receive from a customer with any other Deal customers. Any Leads Data shared with a Deal customer will be subject to the Deal customer's privacy policy. We are not responsible for how you use the data Deal provides you.
Other Users You Share or Interact With. The Services may allow Deal users to share personal information or interact with other users of the Services.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services. Once your personal information is shared with our business partner, it will also be subject to our business partner's privacy policy. We are not responsible for the processing of personal information by our business partners.
Deal Customers (Authorized Users Only). In cases where you use our Services as an employee, contractor, or other authorized user of a Deal customer, that customer may access information associated with your use of the Services including usage data and the contents of the communications and files associated with your account. Your personal information may also be subject to the Deal customer's privacy policy. We are not responsible for the Deal customer's processing of your personal information.
Affiliates. We may share your personal information with our corporate affiliates.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as "interest-based advertising", "personalized advertising", or "targeted advertising."

Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed or transferred as part of such a transaction.

5. Your Privacy Choices and Rights

Your Privacy Choices. The privacy choices you may have about your personal information are described below.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).
"Do Not Track." Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.

Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Confirm Whether We Are Processing Your Personal Information;
Request Access to or Portability of Your Personal Information;
Request Correction of Your Personal Information;
Request Deletion of Your Personal Information;
Request Restriction of or Object to our Processing of Your Personal Information; and
Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in "Contact Us" below. We will process such requests in accordance with applicable laws.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in "Contact Us" below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

If your personal information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

6. International Transfers of Personal Information

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country.

If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. Retention of Personal Information

We store the personal information we collect as described in this Privacy Policy for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, comply with applicable laws, and ensure security. When personal information is no longer required for these purposes, we securely delete or anonymize it using industry-standard methods (e.g., data wiping, cryptographic deletion) to prevent unauthorized access or recovery.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. Supplemental Notice for Google Workspace Information

This Supplemental Notice for Google Workspace Information only applies to our processing of information that we obtain from the Google Workspace APIs (" Google Workspace Information").

Use of Google Workspace Information. The use of information received from Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirement. We do not use any Google Workspace Information to develop, improve, or train generalized artificial intelligence (AI) or machine learning (ML) models. Such information is only used to provide or improve user-facing features that are specifically requested by our users, in accordance with Google's API Services User Data Policy, including its Limited Use requirements.
Information Security. Deal's security measures for Google Workspace Information include:
- Encryption: All Google Workspace Information obtained via a restricted scope is encrypted in transit using TLS (Transport Layer Security) and at rest using AES-256 encryption.
- Access Controls: Access to Google Workspace Information is restricted to authorized personnel only and is managed through role-based access controls (RBAC) and multi-factor authentication (MFA).
- Vendor Management: We conduct due diligence on our service providers that process Google Workspace Information and enter into agreements with these service providers that governs their use of Google Workspace Information.
- Data Minimization: We endeavor to collect and retain only the minimum amount of Google Workspace Information necessary to provide our Services and comply with our legal obligations.
- Security Testing, Assessments, and Audits: We conduct regular penetration testing, vulnerability assessments, and security audits in an effort to identify and mitigate potential risks relating to the security of Google Workspace Information.
- Secure Deletion of Google Workspace Information: When Google Workspace Information is no longer needed, we delete or anonymize.
- Incident Response Plan: In the event of a data breach involving Google Workspace Information, we have a structured incident response plan, including notification procedures for affected users and regulatory authorities when required by law.
- Compliance with Standards: Our security practices for Google Workspace Information adhere to industry standards such as SOC 2, where applicable.
Data Minimization: We collect and retain only the minimum amount of personal data necessary to fulfill our services and legal obligations.
Regular Security Audits: We conduct regular penetration testing, vulnerability assessments, and security audits to identify and mitigate potential risks.
Incident Response Plan: In the event of a data breach, we have a structured incident response plan, including notification procedures to affected users and regulatory authorities when required.
Secure Data Deletion: When data is no longer needed, we securely delete or anonymize it in compliance with industry standards and legal requirements.
Compliance with Standards: Our security practices adhere to industry standards such as SOC 2 and GDPR where applicable.

9. Supplemental Notice for EU/UK GDPR

This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.

In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.

Deal's processing of your personal information may be supported by one or more of the following lawful bases:

Performance of a Contract (i.e., to provide the Services to you)
Legitimate Interest
Consent
Compliance with Legal Obligations

10. Children's Personal Information

The Services are not directed to children under 18 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in "Contact Us" below.

11. Supplemental CCPA Privacy Policy

This Supplemental CCPA Privacy Policy supplements our Privacy Policy and only applies to our processing of personal information that is subject to the CCPA.

Notice at Collection

At or before the time of collection, California residents have a right to receive notice of our privacy practices. California residents can find this information below.

Personal Information Collected. See the section of this Supplemental CCPA Privacy Policy titled "Overview of Personal Information Collected, Disclosed, Sold and/or Shared" for a list of personal information which may be collected.
Uses of Personal Information. See the section of this Supplemental CCPA Privacy Policy titled "Uses of Personal Information" for a list of the purposes for which we use personal information.
Is Personal Information "Sold" or "Shared" for "Cross-Context Behavioral Advertising"? Yes. See the section of this Supplemental CCPA Privacy Policy titled "Overview of Personal Information Collected, Disclosed, Sold and/or Shared" for more details.
How Long is Personal Information Retained For? To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
Additional Information. For more information on our privacy practices, please review this Supplemental CCPA Privacy Policy and our Privacy Policy.

Categories of Sources from Which Personal Information Is Collected

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources.

Overview of Personal Information Collected, Disclosed, Sold, and/or Shared

The CCPA provides California residents with the right to know what categories of personal information Deal has collected about them, whether Deal disclosed that personal information for a business purpose (e.g., to a service provider), whether Deal "sold" that personal information, and whether Deal "shared" that personal information for "cross-context behavioral advertising" in the preceding twelve months.

Category of Personal Information	Disclosed for Business Purpose	Sold and/or Shared
Identifiers	Service Providers	Advertising Partners, Deal Customers
California Customer Records (Cal. Civ. Code § 1798.80(e))	Service Providers	Deal Customers
Protected classification characteristics	Service Providers	Deal Customers
Commercial information	Service Providers	Advertising Partners, Deal Customers
Internet or other electronic network activity	Service Providers	Advertising Partners, Deal Customers
Geolocation data	Service Providers	Deal Customers
Professional or employment-related information	Service Providers	Service Providers
Inferences drawn from other personal information	Service Providers	Advertising Partners, Deal Customers
Account log-in, financial account information	Service Providers	N/A
Contents of mail, email, and text messages	Service Providers	N/A

Uses of Personal Information

We may use and disclose the personal information that we collect for the following business and commercial purposes:

Providing the Services as further described in our Privacy Policy;
Processing for administrative purposes as further described in our Privacy Policy;
Processing for marketing purposes as further described in our Privacy Policy;
Processing with your consent or direction as further described in our Privacy Policy;
Processing to carry out automated decision making as further described in our Privacy Policy;
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
Helping to ensure security and integrity;
Debugging to identify and repair errors that impair existing intended functionality;
Short-term, transient use, including non-personalized advertising;
Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions;
Providing advertising and marketing services;
Undertaking internal research for technological development and demonstration;
Undertaking activities to verify or maintain the quality or safety of a service or device.

Right to Opt Out of "Sales" and/or "Sharing" for "Cross-Context Behavioral Advertising"

We "sell" your personal information or "share" your personal information for "cross-contextual behavioral advertising" to provide you with "cross-context behavioral advertising" about Deal's products and services.

We may also "sell" Leads Data to our customers, or "share" Leads Data for "cross-contextual behavioral advertising" with our customers, for their business purposes. California residents have the right to opt out of the "sale" of personal information and the "sharing" of personal information for "cross-context behavioral advertising."

California residents may opt out of our "sale" or "sharing" activities which rely on cookies or similar technologies, by installing the Ghostery ad-blocker browser plug-in and blocking our use of advertising cookies via that tool, or otherwise configuring their Internet browser to prohibit advertising cookies from being set.

California residents may opt out of our "sale" or "sharing" activities that do not rely on the use of cookies or similar technologies, by contacting us as set forth in "Contact Us" in the Privacy Policy.

Disclosure Regarding Individuals Under the Age of 16

Deal does not have actual knowledge of any "sale" of personal information of minors under 16 years of age. Deal does not have actual knowledge of any "sharing" of personal information of minors under 16 years of age for "cross-context behavioral advertising."

Disclosure Regarding Sensitive Personal Information

Deal only uses and discloses sensitive personal information for purposes permitted under applicable laws (e.g., authentication, fraud prevention). We implement enhanced security controls for sensitive data, including encryption, strict access controls, and continuous monitoring to prevent unauthorized access.

Non-Discrimination

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

12. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at privacy@backtrail.ai.