Privacy Policy

1. Introduction

GETREFLOW LLC ("we," "our," or "us") is committed to protecting your privacy. Penzago is a service of GETREFLOW LLC (d/b/a Penzago). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at penzago.com and use our services, including data received from third-party platform integrations such as Google, Meta/Facebook, LinkedIn, and others.

2. Information We Collect

Personal Information

We may collect personal information that you voluntarily provide when you register for an account, subscribe to a plan, fill out a form, or contact us. This includes your name, email address, business name, phone number, and billing information.

Usage Data

We automatically collect certain information when you access our platform, including your IP address, browser type, operating system, referring URLs, and information about how you interact with our services.

Integration Data

When you connect third-party integrations via OAuth or API key, we access and process data from those services as necessary to provide our automation features. We only access data that you explicitly authorize. The specific data accessed per platform includes:

Google Data

When you connect Google services, we may access: spreadsheet content and metadata (Google Sheets), form structure and response data (Google Forms), calendar events and scheduling information (Google Calendar). All Google data is accessed via OAuth 2.0 with scopes limited to the services you connect.

Meta/Facebook Data

When you connect Facebook or Instagram, we may access: your Facebook Page listings, lead form submissions, page engagement metrics, post management capabilities, Instagram basic profile information, and Instagram content publishing capabilities. Data is accessed only for the Facebook Pages and Instagram accounts you authorize.

LinkedIn Data

When you connect LinkedIn, we access: your basic profile information (name, profile URL), email address, and the ability to create posts on your behalf. LinkedIn data is collected at the time you authorize the connection via OAuth.

Other Integrations

We also support integrations with HubSpot, Salesforce, Microsoft (Outlook Calendar and Mail), Mailchimp, Zoho CRM, Cloze, TikTok, Typeform, JotForm, and Google Sheets. Each integration accesses only the data types and scopes you explicitly authorize during the connection process.

All OAuth tokens and credentials are stored in encrypted vault storage and are never stored in plain text.

3. How We Use Your Information

To provide, operate, and maintain our services
To process transactions and manage your subscription
To execute automation playbooks on your behalf
To execute automation workflows using data from your connected integrations
To send communications on your behalf through connected platforms, only as configured in your active playbooks
To send you service-related communications
To improve and personalize your experience
To monitor usage for billing purposes
To refresh and maintain OAuth tokens to keep your integrations functioning
To detect and prevent fraud or abuse

We do not use data from Google, Meta/Facebook, LinkedIn, or other connected platforms for advertising, user profiling, or training machine learning or artificial intelligence models. Integration data is used solely to provide the automation features you configure.

4. Third-Party Platform Data

Google User Data

GETREFLOW LLC accesses Google user data as described in Section 2 (Google Data) solely to provide user-facing automation features that you configure. Google user data is:

Used only to provide and improve user-facing features of our service
Not sold, rented, or shared for advertising purposes
Not used for training machine learning or artificial intelligence models
Not transferred to third parties except to our workflow automation engine (Activepieces) for playbook execution, with your consent, or as required by law

You may revoke access to your Google data at any time by disconnecting the integration from your Penzago dashboard or by removing access in your Google Account settings.

Meta/Facebook Platform Data

GETREFLOW LLC accesses Facebook and Instagram data as described in Section 2 (Meta/Facebook Data) solely to execute the automation playbooks you subscribe to. Specifically:

We access Page listings, lead data, engagement metrics, and post management capabilities only for Pages you authorize
Instagram data (basic profile and content publishing) is accessed only for accounts connected to your authorized Facebook Pages
We do not sell Facebook or Instagram user data
We comply with Meta Platform Terms and Developer Policies
This privacy policy does not supersede or override Meta's own terms and data policies

You may revoke access at any time by disconnecting the integration from your Penzago dashboard or via Facebook Settings > Apps and Websites.

LinkedIn Member Data

Before you authenticate your LinkedIn account with GETREFLOW LLC, we provide the following disclosures as required by LinkedIn's API Terms of Use:

Data collected: Basic profile information (name, profile URL), email address, and social posting capability
When collected: At the time you authorize the LinkedIn connection via OAuth
How used: Solely to execute social media automation workflows you configure in your active playbooks
How disclosed: LinkedIn data is shared only with our workflow automation engine (Activepieces) for playbook execution and is not sold or shared with other third parties
Withdrawing consent: You may disconnect your LinkedIn integration at any time from your Penzago dashboard
Requesting deletion: You may request deletion of your LinkedIn data via your dashboard settings or by emailing us at hello@getreflow.ai

We comply with LinkedIn's API Terms of Use. Upon consent withdrawal or account closure, your LinkedIn data is deleted promptly.

5. Google API Services Limited Use Disclosure

GETREFLOW LLC's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

We only use Google user data to provide or improve user-facing features that are prominent in our application's user interface
We do not transfer Google user data to third parties except to provide or improve user-facing features, with your affirmative consent, for security purposes, to comply with applicable law, or as part of a merger or acquisition with notice to users
We do not use or transfer Google user data to serve advertising, including retargeting, personalized, or interest-based advertising
We do not allow humans to read Google user data unless we have your affirmative consent, it is necessary for security purposes (such as investigating abuse), to comply with applicable law, or the data is aggregated and anonymized for internal operations

6. Artificial Intelligence Processing

Some features of our platform are powered by large language models from Anthropic (Claude) and OpenAI. These include the AI assistant that answers visitors on the websites of the businesses using our platform, the AI receptionist that responds to text messages on their behalf, automated lead follow-up drafting, and marketing copy generation. To generate each response, we send the relevant conversation content and the business context needed to answer (such as the business name, services, and available appointment times) to the AI provider.

No training: Under our providers' commercial API terms, data we send is never used to train AI models
Provider retention: Anthropic's standard policy is to delete API inputs and outputs within 30 days, except content flagged under its usage policy and content it must keep to meet a legal requirement. OpenAI retains API data for up to 30 days for abuse monitoring. Content flagged by a provider's safety systems may be retained longer as required by their policies
Phone numbers: The SMS receptionist does not put the number a person is texting from into AI prompts. A phone number someone types into a conversation, or that appears in page text the website assistant reads, is part of the conversation content sent to the AI provider
Separation between businesses: the AI can never access data belonging to other businesses on our platform
Storage on our side: The record of AI conversations is stored in our own systems, encrypted at rest and subject to the retention schedule in Section 10

Website assistant

A business may add our AI assistant to its website. The assistant tells visitors it is an AI assistant, and shows one line under the chat: “Chats are saved for the business and processed by an AI provider,” with the business's name. When a visitor chats with it:

What is sent: The visitor's messages, and text from the page of the business's website the visitor has open, are sent to Anthropic to generate each reply. We do not read pages we can identify as showing a visitor's own account information, such as saved searches. On pages we can identify as shown to a visitor signed in to the business's website, we do not read the page's general text, though the details of a property listing on its own page, and the number of results on a search page, can still be read. A business can ask us to exclude any other page
What is saved: The conversation (the visitor's messages and the assistant's replies) is saved for the business, encrypted at rest, for the period in Section 10. The page text itself is not saved, but a reply that quotes the page is saved with the conversation
Who sees it: The business, in its inbox on our platform and in a daily email that includes the conversation's messages, and, where the business has connected its own CRM, in a note that a second Anthropic model writes from the conversation and, if full transcripts are turned on for the business, the full conversation. Copies the business receives by email or in its CRM follow the business's own retention
The business's own notice: The business decides to use the assistant on its website and is responsible for describing it in its own privacy notice

Spoken conversations

A business may turn on a spoken mode for the AI assistant on its website, so that a visitor can talk to it instead of typing. Before the microphone is enabled, the visitor is shown a consent notice and must agree to it. In spoken mode, ElevenLabs, our speech provider, converts the visitor's speech to text and the assistant's replies to speech; the words themselves are still answered by our AI language model provider as described above. Specifically:

No audio is recorded: Speech is processed as it happens and is not saved by us or by ElevenLabs. Every voice agent we provision has audio recording turned off and audio deletion turned on
Transcript held only during the conversation: ElevenLabs needs the text of what was said to run the conversation. We configure each voice agent to keep that transcript for zero days after the conversation ends and to delete the transcript and any personal information in it; it is not retained beyond that
Our record: The text of the conversation is stored on our side exactly as a typed conversation would be, encrypted at rest and subject to Section 10, so the business can follow up

8. SMS/Text Messaging

When a lead or prospective customer submits an inquiry through a web form connected to our platform (such as Typeform, JotForm, or a website contact form), calls a business using our platform, or texts a business's number, they may receive automated SMS text messages from the business they contacted, sent via our platform using Telnyx.

Where a form collects SMS consent, the recipient consents to receive recurring automated conversational, informational, and (only where the opt-in expressly disclosed it) marketing text messages from the business they contacted, as described at opt-in. Some messages are generated by an automated AI assistant, which identifies itself in the conversation.

Message frequency: Varies by program and conversation, as disclosed at opt-in
Message content: Responses to the inquiry, scheduling and appointment messages, requested information, and any recurring content expressly disclosed at opt-in
Opt-out: Reply STOP to any message to unsubscribe from future texts
Help: Reply HELP for assistance, or contact us at hello@getreflow.ai
Message and data rates may apply

Messages are sent only under the consent collected by the business the recipient contacted, or in direct response to contact the recipient initiated. Phone numbers collected via web forms are not sold or shared with third parties for marketing purposes. For full program details, see our SMS Consent & Opt-In Policy.

For questions about SMS messaging, contact us at hello@getreflow.ai.

9. Data Security

We maintain administrative, physical, and technical safeguards designed to meet or exceed industry standards for protecting your information:

Technical safeguards: TLS encryption in transit, AES-256 encryption at rest, row-level security policies for tenant data isolation, encrypted vault storage for OAuth credentials, PKCE and CSRF protection for OAuth flows, API rate limiting, and circuit breakers for external service resilience
Administrative safeguards: Role-based access controls, principle of least privilege, and need-to-know access restrictions for personnel
Physical safeguards: Our cloud infrastructure providers (Vercel, Supabase, Railway) maintain SOC 2 compliant data center security

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

10. Data Retention and Deletion

We retain your personal information for as long as your account is active or as needed to provide our services.

Conversation data: SMS conversations handled by our platform (including the AI receptionist) are retained for 90 days from first contact, after which message content is automatically and permanently deleted and phone numbers are anonymized. Opt-out (STOP) records are retained indefinitely as required by law, so that opted-out numbers are never messaged again. Copies the business receives in its own CRM follow the business's retention.

Website chat: Website chat conversations are deleted 30 days after they start, or 90 days after they start once the visitor gives contact details. Contact details a visitor gives, and the assistant's note about their request, are kept separately as the business's lead record, which this schedule does not delete; a visitor can ask for it to be erased (see Section 11). Copies the business receives by email or in its own CRM follow the business's retention.

Specific retention practices for integration data include:

Google data: OAuth tokens are deleted when you disconnect the integration or delete your account. No Google user data is stored beyond what is needed for active playbook execution
Meta/Facebook data: Long-lived tokens expire after 60 days and require re-authorization. Lead data is retained according to your configured settings
LinkedIn data: Access tokens expire after 60 days; refresh tokens expire after one year. Member social activity data processed through our platform is retained for no more than 48 hours during workflow execution. All LinkedIn data is deleted promptly upon your request

Account deletion: When you request account deletion, we initiate a cleanup process that includes: deleting all OAuth tokens and credentials from our encrypted vault, removing all workflows from our automation engine, anonymizing lead event data for billing audit purposes, and cancelling active subscriptions. Your data is purged within 30 days of the deletion request.

To request deletion of your data, use the account deletion option in your dashboard settings or contact us at hello@getreflow.ai.

Backups: Encrypted backup copies of our database are kept for up to 90 days and then expire. Data deleted from our active systems, including under the schedules above, can remain in those copies until they expire.

11. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal data:

Access: Request a copy of the personal data we hold about you
Correction: Request correction of inaccurate personal data
Deletion: Request deletion of your personal data and integration data
Portability: Request your data in a portable, machine-readable format
Consent withdrawal: Disconnect any third-party integration at any time via your dashboard, revoking our access to that platform's data
Opt-out: Opt out of non-essential data processing or marketing communications
Advertising measurement opt-out: turn on Global Privacy Control or Do Not Track in your browser (see Section 16), or adjust your ad preferences with Meta

To disconnect a third-party integration and revoke data access, visit your dashboard's Integrations page. You may also revoke access directly from the provider's settings:

Google: myaccount.google.com/permissions
Facebook: Facebook Settings > Apps and Websites
LinkedIn: LinkedIn Permitted Services

We process data subject rights requests within 30 days. To exercise any of these rights, contact us at hello@getreflow.ai.

13. Children's Privacy

Our service is not directed at children under the age of 13, and we do not knowingly collect personal information from children under 13. We comply with the Children's Online Privacy Protection Act (COPPA) and the Video Privacy Protection Act (VPPA) where applicable. If you believe we have inadvertently collected information from a child under 13, please contact us at hello@getreflow.ai and we will promptly delete it.

14. Breach Notification

In the event of a data breach affecting your personal information or integration data, we will notify affected users and any required regulators without unreasonable delay and within the timelines required by applicable law (including California's 30-day notification deadline where it applies). We will also promptly notify relevant platform partners — including Google, Meta, and LinkedIn — of any breaches that may impact data received through their APIs, in accordance with their respective developer terms.

15. Legal Compliance

We comply with applicable United States data protection laws and regulations, including the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA) and other applicable federal and state privacy laws. Our services are offered to businesses in the United States. We also comply with the platform-specific terms and data policies of each third-party service we integrate with, including the Google API Services User Data Policy, Meta Platform Terms, and LinkedIn API Terms of Use.

16. Cookies and Advertising Measurement

We use essential cookies to maintain your session and preferences. On our marketing website (penzago.com and getreflow.ai) we also use:

Vercel Web Analytics, a cookieless, first-party page-view measurement service. It sets no cookies and does not identify you across visits.
Meta Pixel and Meta Conversions API (Meta Platforms, Inc.), to measure whether our advertising works and to show relevant ads on Facebook and Instagram to people who visited our website. The Pixel sets the _fbp and _fbc cookies, which we keep for up to 90 days to connect a visit to a later inquiry. When you request a demo, leave your contact details, or book a call through our website, we may also send Meta a hashed (SHA-256) form of the email address or phone number you provided so Meta can match the inquiry to an ad; Meta does not receive the readable value, the content of any conversation, or your IP address from us. We enable Meta's Limited Data Use setting for United States visitors.

Your choices. We honor the Global Privacy Control and Do Not Track browser signals: when either is on, we do not load the Meta Pixel, do not send conversion events about you to Meta, and do not record analytics for your visit. You can also control how Meta uses your data for ads at facebook.com/adpreferences.

These tools are used only on our own marketing website, never inside the Penzago dashboard. If you interact with a Penzago-powered form or AI assistant on one of our customers' websites, that website's own privacy policy applies; any advertising measurement there is configured by that customer.

17. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the "Last updated" date. For material changes that affect how we process your integration data, we will provide additional notice via email or in-app notification.

18. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us at hello@getreflow.ai.