This Privacy Policy explains how Di Rocco Holdings LLC, a Wyoming limited liability company, doing business as RevPulsar ("RevPulsar," "we," "us," or "our"), collects, uses, shares, and protects personal information in connection with our website and Service. It also includes our SMS & Email Messaging Terms in Section 10. By using the Service you agree to this Policy.

This Policy is written to comply with United States privacy laws (including the California Consumer Privacy Act as amended by the CPRA), and with the EU General Data Protection Regulation (GDPR), the UK GDPR, and similar laws, for the benefit of users worldwide. Where local law grants you greater rights, we honor those rights.

Roles. When we provide the Service to a business Customer, that Customer is generally the controller of the personal data of their own contacts and customers, and RevPulsar acts as a processor/service provider acting on the Customer's instructions. For our own website visitors and account holders, RevPulsar is the controller.

1. Information We Collect

1.1 Information you provide. Account and billing details (name, business name, email, phone, payment information processed by our payment provider), the scripts, prompts, settings, and content you configure, and anything you send us (e.g., support requests to [email protected]).

1.2 Customer and contact data you upload. To deliver the Service, we process data about your end customers and contacts that you provide or that is generated through the Service — for example, names, phone numbers, email addresses, appointment details, message and call content, call recordings and transcripts, and related metadata. You are responsible for having a lawful basis and required consents for this data (see our Terms and Conditions).

1.3 Information collected automatically. When you visit our website or use the Service, we and our analytics and cookie tools collect device and usage information such as IP address, browser type, pages viewed, referring URLs, and interaction data. We use Google Analytics and Cookiebot for analytics and cookie-consent management (see Section 6).

1.4 Information from third parties. We may receive information from our third-party communication and AI service providers, payment processors, and integrated platforms in order to operate the Service.

2. How We Use Information

We use personal information to: provide, operate, secure, and improve the Service; set up and authenticate accounts; process payments and manage subscriptions and renewals; route, generate, and deliver calls, messages, bookings, and automations; provide customer support; monitor, prevent, and investigate fraud, abuse, and security issues; comply with legal obligations; and communicate with you about the Service and, where permitted, marketing.

Legal bases (EU/UK). Where GDPR or UK GDPR applies, we process personal data on the bases of: performance of a contract; our legitimate interests in operating and securing the Service; your consent (for example, certain cookies and marketing); and compliance with legal obligations.

We do not sell personal information for money. We do not use AI on your account data to train models for unrelated third parties. Any improvement of the Service is done consistent with this Policy and our provider agreements.

3. AI, Calls, and Message Processing

The Service uses third-party communication and AI service providers to power AI voice, transcription, messaging, and automation features. To provide these features, call audio, recordings, transcripts, and message content may be processed by these providers on our and your behalf. Calls may be recorded and transcribed where you have enabled such features — you are responsible for providing any legally required notice and consent to recording and messaging. AI-generated outputs may be imperfect; please review our Terms and Conditions for the associated disclaimers.

4. How We Share Information

We share personal information only as needed:

Service providers and sub-processors — including our third-party communication and AI service providers, hosting providers, payment processors, and analytics tools — who process data on our behalf under contractual confidentiality and data-protection obligations.

Our business Customers — where you are an end contact, your data is shared with and controlled by the business that uses RevPulsar to contact you.

Legal and safety — to comply with law, legal process, or lawful requests, and to protect rights, safety, and the integrity of the Service.

Business transfers — in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.

We do not sell your personal information for monetary value. Certain analytics/advertising cookies may be considered a "sale" or "sharing" under California law; you can opt out via our cookie controls (Section 6).

5. International Data Transfers

We operate globally and may process and store information in the United States and other countries whose data-protection laws may differ from yours. Where we transfer personal data out of the EEA or UK, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses (and the UK Addendum) or other lawful transfer mechanisms.

6. Cookies and Analytics

Our website uses cookies and similar technologies for functionality, security, and analytics. We use Cookiebot to manage cookie consent and Google Analytics to understand site usage. Where required (such as in the EU and UK), non-essential cookies are set only after you consent through the cookie banner, and you can change or withdraw your choices at any time via the cookie-settings control on our site. You can also manage cookies through your browser settings. Disabling cookies may affect site functionality.

7. Data Retention

We retain personal information for as long as needed to provide the Service, comply with legal obligations, resolve disputes, and enforce agreements. When you cancel, we delete or anonymize account and contact data after a reasonable period, except where retention is required by law or for legitimate business records. You may request deletion as described below.

8. Security

We use reasonable technical and organizational measures designed to protect personal information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your account credentials.

9. Your Privacy Rights

9.1 EU/UK (GDPR / UK GDPR). Subject to conditions, you may request access to, correction of, deletion of, restriction of, or portability of your personal data; object to certain processing; and withdraw consent at any time. You may also lodge a complaint with your local supervisory authority. Where RevPulsar acts as a processor for a business Customer, please direct your request to that Customer; we will assist them as required.

9.2 California (CCPA/CPRA). California residents may request to know, access, correct, and delete personal information, and to opt out of any "sale" or "sharing" and limit use of sensitive personal information. We do not discriminate against you for exercising these rights.

9.3 Other regions. If your local law (for example, in Canada, Brazil, Australia, or elsewhere) grants you privacy rights, we will honor them as required.

9.4 How to exercise. Email [email protected]. We will verify and respond within the timeframe required by applicable law. You may use an authorized agent where the law permits.

10. SMS & Email Messaging Terms

This section governs the text-message (SMS/MMS) and email communications between RevPulsar and you, and supplements the rest of this Policy and our Terms and Conditions. By providing your phone number or email address and opting in, you agree to these messaging terms.

10.1 Consent to receive messages. By providing your mobile number and/or email address and agreeing to receive messages, you consent to receive both transactional (non-marketing) and, where you opt in, marketing communications from RevPulsar by SMS/MMS and email. These may include:

Transactional / non-marketing: account, billing, onboarding, security, appointment, and Service-related notices.

Marketing / promotional: offers, product updates, tips, and related promotions, where you have provided the required consent.

Consent to marketing messages is not a condition of purchase. Message frequency varies.

10.2 SMS program — carriers and cost. Messages are delivered through third-party communication service providers and mobile carriers, which are not liable for delayed or undelivered messages. Message and data rates may apply based on your mobile plan. RevPulsar does not charge you for receiving messages, but your carrier may.

10.3 SMS opt-out and help. You can cancel SMS messages at any time by replying STOP to any message; we will send a single confirmation and then stop sending marketing SMS. You may continue to receive essential transactional messages where permitted by law, and you can opt out of those by emailing [email protected]. For help, reply HELP or email [email protected]. If you change or deactivate your mobile number, please notify us so we do not message a reassigned number.

10.4 Email opt-out. You may receive transactional and (where you opt in) marketing emails. You can unsubscribe from marketing emails at any time using the unsubscribe link in any marketing email or by emailing [email protected]. You may continue to receive transactional emails necessary to your use of the Service.

10.5 Your responsibilities when messaging your own contacts — IMPORTANT. If you use RevPulsar to send SMS or email to your own customers and contacts, you are solely responsible for compliance with all applicable laws, including the U.S. Telephone Consumer Protection Act (TCPA), the CAN-SPAM Act, A2P 10DLC registration and carrier requirements, the UK PECR, the EU ePrivacy rules and GDPR, Canada's CASL, and any other applicable rules. In particular, you must: obtain and document prior express consent (and, for marketing, prior express written consent where required) before messaging any contact; provide clear opt-out instructions (such as "Reply STOP to opt out") and honor opt-outs immediately; include accurate sender identification and, for email, a valid physical postal address and working unsubscribe mechanism as required by law; respect quiet hours, do-not-call/do-not-text registries, and frequency limits; and not send prohibited, deceptive, or illegal content. You agree to indemnify RevPulsar for any claims, fines, or penalties arising from your messaging, as set out in our Terms and Conditions. RevPulsar provides the tools; lawful use of them is your responsibility.

10.6 No guarantee of delivery. Message delivery depends on carriers and third-party communication service providers and is not guaranteed. We are not liable for delayed, blocked, filtered, or undelivered messages.

11. Children's Privacy

The Service is for business use and is not directed to children under 16, and we do not knowingly collect their personal information. If you believe a child has provided us data, contact [email protected] and we will delete it.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be posted here with a revised Effective Date. Your continued use of the Service after changes take effect constitutes acceptance.

13. Contact Us

Di Rocco Holdings LLC (d/b/a RevPulsar) Email: [email protected]

© 2026 Di Rocco Holdings LLC. All rights reserved.