Legal & Compliance

Privacy Policy

Last updated September 30, 2026

1. Introduction

At Cintram, we are committed to protecting your privacy and the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, platform, and services ("Services").

By using our Services, you acknowledge that we process personal information as described in this Privacy Policy.

This Privacy Policy does not apply to the data practices of our Customers, even when they use Cintram to interact with their own clients. Customers are responsible for their own privacy notices and data practices with their End Clients.

2. Our Role

Cintram processes different types of personal information in different roles.

For information we collect directly from website visitors, account holders, and users for our own business purposes (such as account management, billing, support, analytics, and marketing), Cintram acts as the controller or business, as applicable under relevant privacy law.

For Customer Data submitted to the Services by Customers or their Authorized Users, including data about End Clients in portals, forms, messages, files, and workflows, Cintram generally acts as a service provider or processor on behalf of the Customer. Customers are responsible for providing required privacy notices, obtaining required consents, and responding to requests from their End Clients, unless otherwise required by law.

If we receive a privacy request from an End Client relating to Customer Data, we may direct the request to the relevant Customer.

If there is a conflict between this Privacy Policy and an applicable Data Processing Agreement (DPA) regarding Customer Data, the DPA will control for that Customer Data.

3. Information We Collect

3.1 Information You Provide

  • Account and Workspace Information: When you create a Cintram account, we collect your name, email address, phone number (if provided), company name, role, workspace settings, user permissions, and account preferences.
  • Payment Information: If you subscribe to a paid plan, we collect payment information through Stripe, our third-party payment processor. We do not store your full credit card information on our servers. Stripe's privacy policy governs the handling of your payment data.
  • User Content: We collect and store any content you submit, post, or display on or through our Services, including contact information, messages, notes, files, forms, client portal data, and other information you provide in connection with managing your client workflows.
  • Communications: We may collect information from your interactions with us, such as customer support inquiries, live chat conversations, survey responses, or feedback.
  • Phone Number and SMS Preferences: If you choose to provide a phone number and opt in to SMS communications, we collect and store that information to deliver account-related messages as described in Section 3.4.

3.2 Information We Collect Automatically

  • Usage Data: When you use our Services, we automatically collect information about your interactions, including your IP address, browser type, device information, pages visited, and actions taken. This helps us analyze trends, administer the site, and improve our offerings.
  • Website Measurement and Cookies: On cintram.com we measure, with first-party cookies and only as the rule for your region allows, which pages a browser viewed and how it arrived (campaign tags, the linking site’s address, and an advertising click identifier only if you allow marketing). We use no third-party analytics, pixels or tag managers, and we do not store your IP address in these records. Our Cookie Policy explains exactly what is stored, the rules by region, and how to change your choice.

3.3 Information from Third Parties

We may receive information about you from third parties if you choose to connect your Cintram account with other services, such as Google. This may include profile information, account identifiers, calendar or email metadata, authorization tokens, or other information made available through the integration, depending on the permissions you grant. We will only collect the information necessary to provide the integrated functionality you request.

3.4 SMS Communication and Opt-In Consent

If you provide your phone number and separately opt in to receive SMS communications from Cintram, you agree to receive account-related text messages such as billing reminders, support updates, security notices, and system alerts. We will not send marketing text messages unless you separately consent to receive them.

Message frequency varies. Standard message and data rates may apply. Reply STOP to opt out at any time. Reply HELP for assistance.

You can manage or opt out of SMS at any time through your account settings or by following the instructions in any message you receive. We use Twilio to deliver SMS communications. Twilio is contractually obligated to protect your personal information and use it only for the purpose of delivering the messages described above. Cintram does not share SMS opt-in data or consent with any third parties for their own marketing purposes.

4. How We Use Your Information

We use the information we collect for the following purposes:

  • Providing Services: To provide, operate, maintain, and improve our Services, including processing payments, managing subscriptions, customer support, and troubleshooting.
  • Personalization: To tailor your experience on our platform and provide features relevant to your use of Cintram.
  • Communications: To communicate with you about your account, billing, updates, new features, and promotional offers. You may opt out of marketing emails at any time by using the unsubscribe link in the email or by contacting us at [email protected]. You may still receive transactional or service-related messages.
  • Marketing Measurement: To understand which of Cintram’s own pages, campaigns and links lead to signups, trials and subscriptions, using the first-party measurement described in our Cookie Policy. This information stays with Cintram: we do not send it to advertising platforms, and we do not retarget visitors. We do not use private Customer Data, including email content, client records, or portal data, for advertising or marketing to third parties.
  • Analytics and Research: To analyze how you use our Services, track trends, and conduct research to improve our platform.
  • Security and Fraud Prevention: To protect our Services, detect and prevent fraud, and enforce our Terms of Service.
  • AI Features: To power Ayra, our built-in AI assistant, as described in Section 4.1 below.
  • Legal Compliance: To comply with applicable laws, regulations, legal processes, and enforceable governmental requests.

4.1 AI Features and Data Processing

Cintram includes AI-assisted features through Ayra, our built-in AI assistant. Ayra may process your account data, client data, communications, and other Customer Data to support tasks such as drafting messages, summarizing information, recommending actions, or automating workflow steps.

We do not use Customer Data to train AI models unless you authorize that use or it is expressly described in a separate agreement or policy. AI-generated outputs are provided for convenience and should be reviewed before use. They are not legal, financial, tax, medical, or other professional advice. You are responsible for reviewing AI-generated outputs before relying on them or sending them to clients.

5. How We Share Your Information

We do not sell your personal information. We may share your information only in the following circumstances:

  • Service Providers: We use service providers to help operate our business and deliver the Services, and we share data only as needed for those purposes. Depending on the features used, we may share account information, account identifiers, usage data, payment-related information, communication data, device data, and Customer Data with these providers only as needed to provide the Services. These may include:
    • Stripe: Payment processing
    • Amazon Web Services (AWS) and AWS SES: Cloud infrastructure and Cintram platform email notifications
    • Cloudflare: Content delivery network and security
    • SendGrid: Transactional or marketing email delivery for Cintram communications
    • Twilio: SMS communications
    • Intercom: In-app customer support and live chat
    • Google: Calendar and email integrations you choose to connect, such as Google Calendar and Gmail
    These providers are contractually obligated to protect your information and use it only for the purposes we specify. We disclose information to service providers for business purposes such as hosting, payment processing, email delivery, SMS delivery, analytics, security, customer support, troubleshooting, and product functionality. We may add or change service providers as our platform evolves.
  • At Your Direction: We may share or make available Customer Data with Authorized Users, End Clients, or Third-Party Services based on your account settings, portal permissions, integrations, or instructions. You are responsible for the data you choose to share through Cintram's features.
  • Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred to the acquiring entity. We will notify you of any such transfer as required by applicable law.
  • Legal Requirements: We may disclose your information if required to do so by law or in response to a valid legal request from a government or law enforcement authority.
  • Protection of Rights: We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or violations of our Terms of Service.

6. Cookies, Advertising, and Tracking Choices

Cintram measures its own website with first-party cookies, as described in our Cookie Policy. We use no third-party analytics, advertising pixels, retargeting or tag managers.

In the EU and EEA, the United Kingdom, Switzerland and Canada, and wherever we cannot tell your region, nothing is measured until you choose. In the United States, measurement is on by default and you can opt out at any time through “Your privacy choices” in the footer. We honor Global Privacy Control as an opt-out. Withdrawing or opting out ends your browser journey and deletes its measurement records within 24 hours, as our Cookie Policy explains.

7. Your Choices and Rights

Depending on your location, you may have the following rights regarding your personal information:

  • Access: Request access to the personal information we hold about you.
  • Correction: Request correction of inaccurate or incomplete personal information.
  • Deletion: Request deletion of your personal information, subject to legal retention requirements.
  • Object to Processing: Object to the processing of your personal data for certain purposes, including direct marketing.
  • Restrict Processing: Request that we restrict processing of your personal data in certain circumstances.
  • Data Portability: Request a copy of your personal data in a structured, commonly used, and machine-readable format.
  • Withdraw Consent: Where we rely on your consent to process personal data, you may withdraw that consent at any time without affecting the lawfulness of processing based on consent before withdrawal.
  • Lodge a Complaint: If you are located in the EEA or UK, you have the right to lodge a complaint with your local data protection supervisory authority.

We will respond to requests within the time required by applicable law. We may ask you to verify your identity before fulfilling data requests to protect your information. To exercise any of these rights, please contact us at [email protected].

8. Legal Bases for EEA and UK Users

If you are located in the European Economic Area (EEA) or United Kingdom, we process your personal data based on one or more of the following legal bases:

  • Contract: To provide the Services, manage your account, process payments, and provide support.
  • Legitimate Interests: To secure, improve, and analyze our Services, prevent fraud, and communicate with users about service-related matters, where those interests are not overridden by your rights.
  • Consent: For website analytics and marketing measurement on cintram.com (nothing is measured until you accept, and you can withdraw at any time), certain marketing communications, SMS messages, and other processing where consent is required by applicable law.
  • Legal Obligation: To comply with applicable laws, tax and accounting requirements, security obligations, and valid legal requests.

9. Data Security

We use administrative, technical, and organizational safeguards designed to protect personal information, including access controls, encryption where appropriate, and monitoring. Cintram is hosted on Amazon Web Services (AWS). We may also use other cloud infrastructure or service providers as our platform evolves.

No method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee the absolute security of your information. In the event of a data breach that affects your personal information, we will notify you as required by applicable law.

10. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Retention periods may vary depending on the type of data and the purpose of processing.

After account cancellation or termination, we may retain your personal data for up to 90 days to allow for account recovery, comply with legal obligations, resolve disputes, prevent abuse, or maintain backups. After that period, we may permanently delete or de-identify your data from active systems. Residual copies may remain in backups for a limited period, unless we are required to retain data for legal, security, fraud prevention, or compliance purposes.

11. International Data Transfers

Cintram is based in the United States. Your information may be transferred to and processed in the United States or other countries that may have different data protection laws than your country of residence.

If you are located in the European Economic Area (EEA) or United Kingdom, please be aware that your data may be transferred to and processed in the United States. When transferring data internationally, we use appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent legal mechanisms to ensure your data remains protected in accordance with applicable data protection laws.

12. Children's Privacy

Our Services are not directed to children and are not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information promptly.

13. Third-Party Links

Our website and Services may contain links to third-party websites or services not owned or controlled by Cintram. Cintram is not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of those third parties before using their websites or services.

14. California Privacy Rights

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to:

  • Know what personal information we collect, use, and disclose about you
  • Correct inaccurate personal information we hold about you
  • Request deletion of your personal information
  • Opt out of the sale or sharing of your personal information for cross-context behavioral advertising
  • Not be discriminated against for exercising your CCPA or CPRA rights

Cintram does not sell your personal information, and does not share it for cross-context behavioral advertising. Our website measurement, including any advertising click identifier, stays with Cintram and is not sent to advertising platforms. You can still opt out of that measurement at any time through “Your privacy choices” in the footer of our website or with a Global Privacy Control signal, and you can make any request above by contacting us at [email protected].

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable laws. We will notify you of any material changes by posting the updated policy on this page and revising the "Last Updated" date. Where required or appropriate, we may provide additional notice by email or in-app message.

16. Governing Law

This Privacy Policy is governed by the laws applicable to Cintram and your use of the Services, without limiting any rights you may have under applicable privacy laws including GDPR, UK GDPR, or CCPA/CPRA.

17. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at [email protected].

Person in charge of the protection of personal information (Quebec’s Act respecting the protection of personal information in the private sector): Venkata, Founder, reachable at [email protected].