Privacy Policy
Effective date: October 9, 2026
1. Who we are
Sapiura Systems LLC, a Wyoming limited liability company doing business as Pronvi ("we", "us"), provides a software platform and related services to businesses. Contact: hola@pronvi.com, 7345 W Sand Lake Rd, Ste 210, Office 3330, Orlando, FL 32819, USA.
2. Scope: two different roles
2.1 When we are the controller. This Policy covers personal data we collect for our own purposes: data about our clients and their users, prospects, website visitors and people who contact us.
2.2 When we are a processor. Our clients use the Platform to store and communicate with their own customers and contacts ("End Users"). For that data, our client is the controller and we act only on its instructions, under our Data Processing Agreement. If you are an End User of one of our clients, please read that business's privacy policy and send your requests to it. If you contact us, we will forward your request to the relevant client.
3. Data we collect
| Category | Examples | Source |
|---|---|---|
| Account and contact data | Name, business name, email, phone, job title | You |
| Billing data | Billing address, tax ID, payment status, last four digits of card | You and our payment processor |
| Usage and device data | Log-ins, features used, IP address, browser, device, approximate location | Automatically, through the Platform |
| Communications | Support tickets, emails, call recordings (with notice), feedback | You |
| Website and marketing data | Pages visited, form submissions, cookie identifiers, campaign data | Our website and cookies |
| Compliance data | Business registration details for carrier registration (e.g., A2P 10DLC) | You |
We do not collect full payment card numbers; our payment processor handles them.
4. How and why we use data
| Purpose | Legal basis (GDPR, where it applies) |
|---|---|
| Create and manage your account, provide the Services and support | Performance of a contract |
| Billing, collections, tax and accounting | Contract and legal obligation |
| Security, fraud prevention, abuse monitoring and enforcing our Terms | Legitimate interests |
| Carrier registrations and regulatory compliance | Legal obligation and legitimate interests |
| Improving the Platform with aggregated, de-identified data | Legitimate interests |
| Service announcements and account notices | Contract |
| Marketing emails about our own services | Consent or legitimate interests, with an easy opt-out |
We do not sell personal data and do not share it for cross-context behavioral advertising.
5. Who we share data with
- Service providers that host and operate the Platform, process payments, send communications, provide AI features, and support our business (accounting, legal, IT). They may use the data only to provide services to us.
- Integrations you enable, such as payment, calendar or email providers.
- Authorities and carriers when required by law, legal process, or carrier rules, or to protect rights and safety.
- A buyer or successor in a merger, acquisition or sale of assets, under equivalent protections.
A list of our sub-processors is available to clients on request at hola@pronvi.com.
6. International transfers
We are based in the United States and our main hosting providers process data in the United States and other countries. When we transfer personal data from the European Economic Area, the United Kingdom or Switzerland, we rely on the EU–U.S. Data Privacy Framework where our providers are certified, on the European Commission's Standard Contractual Clauses, or on another lawful mechanism.
7. Retention
We keep account and billing data while your account is active and for up to 7 years afterwards for tax, accounting and legal purposes. We keep support communications for up to 3 years. Client Data processed for clients is deleted as described in our Terms and DPA. Logs and backups are deleted on their regular cycles.
8. Security
We and our providers use reasonable administrative, technical and physical measures designed to protect personal data, such as encryption in transit and at rest, role-based access controls, logging, backups and periodic security testing. No system is completely secure; please protect your credentials and enable two-factor authentication.
9. Your rights
9.1 Everyone. You can ask us to access, correct or delete your personal data, and opt out of marketing at any time.
9.2 EEA, UK and Swiss residents. You also have the right to data portability, to restrict or object to processing (including processing based on legitimate interests), to withdraw consent at any time, and to complain to your data protection authority (in Portugal, the Comissão Nacional de Proteção de Dados).
9.3 U.S. state residents. Depending on your state (for example California, Colorado, Connecticut, Virginia, Texas or Utah), you may have the right to know, access, correct, delete and port your data, and to opt out of sale, targeted advertising and profiling. We do not sell or share personal data and do not use it for profiling with legal effects. You may use an authorized agent, and we will not discriminate against you for exercising your rights. You can appeal a decision by replying to our response.
9.4 How to exercise them. Email hola@pronvi.com. We will verify your identity and reply within the time the law requires (generally 30 days in the EU and 45 days under U.S. state laws).
10. Cookies
Our website uses necessary cookies to work and, with your consent where required, analytics and marketing cookies. You can manage preferences in our cookie banner or your browser. We honor Global Privacy Control signals where the law requires.
11. Children
Our Services are for businesses and are not directed to anyone under 18. We do not knowingly collect children's data.
12. Changes
We will post updates here and change the effective date. For material changes, we will notify clients by email or in the Platform.
13. Contact
Sapiura Systems LLC, 7345 W Sand Lake Rd, Ste 210, Office 3330, Orlando, FL 32819, USA, hola@pronvi.com.