全球隐私框架

This document applies to the customer relationship management software-as-a-service platform, websites, applications, APIs, software, documentation, dashboards, reports, artificial intelligence features, support, and related services made available by SellioCRM, LLC, a limited liability company.

For purposes of this document, "SellioCRM," "Company," "we," "us," and "our" mean SellioCRM, LLC. "Customer," "you," and "your" mean the person or entity accessing or using the Services. If you access or use the Services on behalf of an organization, you represent and warrant that you have authority to bind that organization, and that organization is the Customer.

This document is incorporated into and forms part of the SellioCRM Terms of Service unless expressly stated otherwise.

This Global Privacy Framework describes SellioCRM's privacy governance principles for the Services. It is designed to align SellioCRM's privacy approach across jurisdictions, customers, services, vendors, and internal operations. It is not legal advice and does not replace the SellioCRM Privacy Policy, Cookie Policy, Data Processing Addendum, or applicable agreements.

1. Privacy Governance Principles

• lawful, fair, and transparent processing
• purpose limitation
• data minimization
• accuracy
• storage limitation
• security and confidentiality
• accountability
• privacy by design and by default
• responsible vendor management
• respect for individual rights

2. Global Applicability

This Framework applies to SellioCRM's processing of personal information across the Services and business operations. It is intended to support compliance with applicable privacy laws, including GDPR, LGPD, California privacy laws, Australia Privacy Act, and other relevant privacy and data protection laws.

3. Role Assessment

SellioCRM assesses whether it acts as controller, processor, business, service provider, contractor, operator, or equivalent role depending on the jurisdiction and processing activity. Role determinations may vary by context.

Customer is responsible for determining its own role and obligations for Customer Personal Data submitted to the Services, including CRM data relating to leads, contacts, prospects, customers, representatives, communications, notes, files, and activities.

4. Data Inventory and Purpose Mapping

SellioCRM aims to maintain internal understanding of the categories of personal information it processes, the purposes of processing, systems involved, vendors involved, retention needs, security controls, infrastructure resources, billing usage metrics, and transfer mechanisms.

5. Privacy by Design

SellioCRM seeks to incorporate privacy considerations into product development, system design, vendor selection, AI Feature design, security architecture, data retention, role-based access, export controls, deletion workflows, infrastructure metering, and customer-facing workflows.

6. Data Minimization

SellioCRM encourages Customers to submit only data necessary for the intended CRM use. Customer should redact, pseudonymize, aggregate, or minimize sensitive data where feasible.

SellioCRM may design features to support minimization, export, deletion, role-based access, permission control, and data hygiene where appropriate.

7. Transparency

SellioCRM provides public policies and contractual documents explaining how it processes information, including the Privacy Policy, Cookie Policy, Data Processing Addendum, AI Features Terms, and other applicable terms.

8. Individual Rights

SellioCRM supports privacy rights requests as required by applicable law. Where SellioCRM acts as processor, service provider, contractor, or operator, SellioCRM generally assists Customer in responding to requests rather than responding directly, unless required by law.

9. Vendor and Subprocessor Management

SellioCRM may use vendors and Subprocessors to support the Services, including hosting, compute, database, storage, traffic delivery, communications, email delivery, AI, monitoring, security, analytics, payment, and support providers. SellioCRM evaluates vendors based on risk and imposes contractual obligations relating to confidentiality, security, and data protection where appropriate.

10. International Data Transfers

SellioCRM is based in the United States and may transfer or process personal information in the United States and other countries. SellioCRM uses appropriate transfer mechanisms where required, such as contractual safeguards, Standard Contractual Clauses, adequacy decisions, or other lawful mechanisms.

11. Security and Incident Response

SellioCRM uses commercially reasonable safeguards designed to protect personal information. SellioCRM maintains processes to identify, investigate, mitigate, and communicate Security Incidents affecting systems under its control. Customer remains responsible for Customer-controlled systems, users, credentials, connected accounts, exports, integrations, and communications.

12. Retention and Deletion

SellioCRM aims to retain personal information only as long as reasonably necessary for the purposes described in its policies and agreements. Retention may be affected by account status, Customer settings, billing, tax, accounting, legal, backup, security, fraud prevention, and dispute resolution needs.

13. AI and Automated Processing

SellioCRM may provide AI Features to support CRM workflows such as summarization, drafting, classification, recommendations, forecasting assistance, and data cleanup. AI Features require human review and should not be used as the sole basis for legally or similarly significant decisions about individuals.

14. Training and Awareness

SellioCRM seeks to promote privacy awareness among personnel with access to personal information or systems, appropriate to their roles and responsibilities.

15. Reviews and Improvements

SellioCRM may review and improve its privacy program, policies, processes, vendor controls, security measures, and product features over time. Updates may reflect legal developments, business changes, customer feedback, provider changes, and operational experience.

16. Contact

Privacy framework inquiries may be sent to legal@selliocrm.com.

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