1. Introduction
Welcome to Followups ("we," "our," or "us"). We are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our sales operations automation platform ("Service").
This policy complies with the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and other applicable data protection laws.
2. Information We Collect
2.1 Information You Provide
- Account Information: Email address, name, profile picture (when you sign in with Google or Microsoft)
- Integration Data: API tokens, usernames, and configuration data for third-party services (HubSpot, Telegram, WhatsApp)
- Communication Data: Emails, messages, and content you authorize us to access through connected services
2.2 Information We Collect Automatically
- Usage Data: How you interact with our Service
- Device Information: Browser, OS, IP address, device identifiers
- Log Data: Access times, pages viewed, actions taken
- Cookies and Similar Technologies: Used to maintain authentication state and session integrity
2.3 Information from Third-Party Services
- Google/Gmail: Email content, metadata, and profile info (with explicit consent)
- Microsoft/Outlook: Email content, metadata, and profile info (with explicit consent)
- HubSpot: CRM data, contacts, and sales info (via user-provided API tokens)
- Telegram: Username and messages sent via Followups bot
- WhatsApp: Phone number and messages sent through integration
2.4 Optional Website Analytics
We use Google Analytics only after you accept analytics on this website. When accepted, it helps us understand page visits and product actions such as demo intent, pricing navigation, ROI calculator use, guide-video progress, and language changes. We do not include names, email addresses, CRM content, calendar content, or scheduler responses in those event parameters.
Your choice is stored in a first-party browser preference. Use Analytics settings in the website footer to accept, reject, or change that choice. Rejecting analytics does not prevent you from using the website.
3. How We Use Your Information
We use your information to:
- Provide, maintain, and improve our Service
- Draft, send, and manage emails via Gmail or Outlook
- Sync and manage HubSpot CRM data
- Send notifications through Telegram and WhatsApp
- Authenticate and manage your account
- Analyze Service usage and improve user experience
- Ensure security and prevent fraud
- Comply with legal obligations
4. Legal Basis for Processing (GDPR)
If you are in the European Economic Area (EEA), we process your data under:
- Consent for email, CRM, and messaging access
- Contract performance to deliver our Service
- Legitimate interests (security, analytics, product improvement)
- Legal obligations where required
5. Data Sharing and Disclosure
We do not sell personal data. We may share data with:
- Service Providers: Microsoft Azure (hosting), OAuth providers, and integrations you authorize (HubSpot, Telegram, WhatsApp)
- Legal Requirements: As required by law or court order
- Business Transfers: In case of mergers or acquisitions, with prior notice
6. Data Retention
We retain personal information as long as necessary to provide the Service, comply with legal obligations, and resolve disputes. Deleted accounts are anonymized or erased within 30 days unless retention is legally required.
7. Your Privacy Rights
You may exercise the following rights depending on jurisdiction:
- Access, Rectification, Erasure, Restriction, Portability, Objection, Withdraw Consent (GDPR)
- Know, Delete, Correct, Opt-Out, Limit Use, Non-Discrimination (CCPA/CPRA)
Requests can be made via p r i v a c y @ f o l l o w u p s . r u n.
8. Data Security
We employ:
- TLS/SSL encryption
- Encryption at rest
- Role-based access control
- Regular security audits and employee training
Despite safeguards, no internet transmission is 100% secure.
9. International Data Transfers
Data may be processed outside your country. We use Standard Contractual Clauses (SCCs) and equivalent safeguards for transfers outside the EEA.
10. Data Controller and Representative
Data Controller: Followups
EU Representative: [To be appointed or added upon incorporation]
DPO Contact: d p o @ f o l l o w u p s . r u n
11. Subprocessors and Third-Party Infrastructure
We use subprocessors under GDPR-compliant agreements:
- Microsoft Azure - cloud infrastructure
- Google Cloud - analytics
- HubSpot - CRM integration
- OpenAI - AI-assisted features
12. Google API Services User Data Policy
Our use and transfer of Google API data adhere to the Google API Services User Data Policy, including Limited Use requirements.
We:
- Request minimal necessary scopes
- Use data only for explicitly disclosed functions
- Never sell or use data for advertising
- Never allow human access without consent or legal need
13. Microsoft Integration
We use Microsoft Graph API solely for connected email and profile functionality. Access can be revoked anytime from your Microsoft account settings.
14. AI-Assisted Processing
Followups uses AI to assist with drafting and workflow optimization. AI-generated outputs are user-controlled and not used for profiling or automated decisions with legal effects.
15. Children's Privacy
Not intended for users under 16. Data from minors is deleted upon detection.
16. Do Not Track Signals
Followups does not respond to browser DNT signals.
17. Data Subject Requests
Submit requests via:
- Email: p r i v a c y @ f o l l o w u p s . r u n
- Account dashboard (when available)
Responses within 30 days (GDPR) or 45 days (CCPA/CPRA).
18. Automated Decision-Making
No automated processing results in legal or similar effects without human oversight.
19. Data Accuracy
We maintain accurate records. Users can correct data via account settings.
20. Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be notified via email or in-app.