Legal — Draft for Review

Privacy Policy

July 8, 2026

1. General

Venntive is committed to protecting the privacy of any person or entity that uses, or makes use of, its services, products, or system ("User"). This Privacy Policy explains when and how personal information is collected, used, disclosed, and protected in connection with the Venntive platform and website located at www.venntive.com (the "Site"). Venntive is operated under license from Synchronous Technologies, Inc., dba Complete CRM ("Synchronous Technologies"), and is built on the Complete CRM platform. By using the Site, the User understands and consents to the privacy practices described in this Policy, as reasonably modified from time to time by Venntive.

2. Personal Information We Collect

Venntive collects Personal Information from Users when they register and set up an account, contact Venntive by email, or enter contact information of their own clients or prospects for the purpose of engaging with them through the platform. When Users visit the Venntive website or sites with Venntive tracking scripts embedded, certain information is also automatically collected, including IP address, operating system, browser type, the address of a referring website, and the time and date of the visit.

3. How We Use Personal Information

Venntive uses Personal Information to process User requests, provide services, inform Users about products, and send informational emails. Personal Information provided online may be linked or merged with other Personal Information so that Venntive can confirm identity, better understand User needs, and support the User's own use of the platform. Venntive does not disclose User Personal Information to third parties except as described in this Policy.

4. Control of Personal Information

Venntive gives Users the opportunity to opt out of receiving communications from Venntive and to view, correct, or delete their own Personal Information at any time.

5. Data Ownership and Export

Export control is managed by the account owner, not by a support ticket or waiting period. Data recovery is available for 30 days following account closure. A Venntive instance is not built on proprietary lock-in architecture — your data is not trapped in a configuration that only functions within a single implementation.

6. Security

Venntive, through the underlying Complete CRM platform, maintains technical and organizational security measures designed to protect Personal Information, including encryption of data in transit and at rest, role- and permission-based access controls, network access controls, and regular independent penetration testing. Account information is accessible online only through a confidential password, which Users are responsible for protecting.

7. No Data Deletion Without Consent

Your data is never deleted without your knowledge or consent. Even after an account closes, data recovery remains available for 30 days.

8. Artificial Intelligence

Venntive's native AI capabilities, including NOVA, are proprietary and operate within your Venntive instance — no external model is called, and no data leaves your instance for this purpose.

Where Venntive's AI Copilots use a managed third-party AI integration (currently OpenAI) to generate content, summarize information, or produce text or speech from your inputs:

— Inputs are transmitted to the AI partner solely to generate the requested output in real time.

— These inputs are not used to train, improve, or develop the AI partner's models, and are not retained by the AI partner for training purposes.

— No other account data — including synced email, calendar data, or other Personal Information not directly submitted to an AI feature — is sent to any AI provider for processing, machine learning, or training.

— You are not required to configure your own API key or accept a separate third party's terms of service; the integration is managed by Venntive to Venntive's data standards.

You may choose not to use AI features at any time; doing so prevents any of your data from being sent to an AI partner. Where AI processing involves a cross-border data transfer (e.g., to the United States), that transfer is safeguarded through the mechanisms described in Section 10 below.

9. Data Processing Agreement and Sub-Processors

Because Venntive operates on the Complete CRM platform under license from Synchronous Technologies, data processing on Venntive's behalf is governed by Synchronous Technologies' Data Processing Agreement (DPA), which incorporates the European Commission's Standard Contractual Clauses for international data transfers. Venntive currently engages the following sub-processors in providing the service:

— Olark (conversation and chat functionality)
— Rsync.net (encrypted, immutable disaster-recovery backups)
— Cloudflare (content delivery, DDoS mitigation, and web infrastructure security)
— Twilio, Inc. (calling and messaging services)
— OpenAI (managed AI integration for Copilot features, as described in Section 8)

All sub-processors are located in the United States and are bound by data protection terms consistent with this Policy and the DPA.

10. Data Privacy Framework, GDPR & International Transfers

Synchronous Technologies complies with the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, as administered by the U.S. Department of Commerce, and has certified adherence to the applicable DPF Principles. Where these Clauses or Principles conflict with this Policy, the DPF Principles or Standard Contractual Clauses govern. Individuals in the EU, UK, or Switzerland with inquiries may contact Venntive using the details below, or Venntive’s Data Protection Officer directly.

Venntive supports the principles of the General Data Protection Regulation (GDPR): we collect the minimum information necessary, and Users can exercise applicable rights — including access, correction, deletion, restriction, and data portability — by contacting Venntive.

11. California Consumer Privacy Act (CCPA)

California residents have the right to know what Personal Information is collected, stored, and shared about them, and the right to request deletion, subject to certain legal exceptions. Venntive does not sell Personal Information. Users may exercise CCPA rights by contacting Venntive using the details below.

12. Cookies

Venntive automatically receives certain information whenever a User interacts with the Site, including IP address and browser type, via small text files ("cookies") placed on a User's device. Most browsers accept cookies by default; Users can modify browser settings to reject or be prompted before accepting cookies.

13. Policy Changes

Venntive reserves the right to change or alter this Policy at any time. If Venntive's privacy practices change, Venntive will post the updated policy to the website and update the "last updated" date above.