Giovreno Privacy Policy

GIOVRENO PRIVACY POLICY Effective Date: September 9, 2026 Last Updated: September 9, 2026 Giovreno is a product of S & C Premier LLC, a New York limited liability company located in Suffolk County, New York. This Privacy Policy explains how S & C Premier LLC ("S & C Premier LLC," "Giovreno," "we," "us," or "our") collects, uses, discloses, stores, and otherwise processes personal information in connection with Giovreno, including its websites, applications, software, portals, artificial intelligence features, automation tools, integrations, APIs, communications systems, industry-specific modules, and related products and services collectively referred to as the "Service." This Privacy Policy applies to individuals who create or use Giovreno accounts, individuals invited to use Giovreno, visitors to Giovreno websites, and other individuals whose personal information is processed directly by S & C Premier LLC in connection with operating the Service. Organizations using Giovreno may also enter or process information concerning their customers, clients, employees, contractors, advisors, suppliers, vendors, prospects, contacts, or other individuals. In those circumstances, the Organization generally determines why and how that information is used, while Giovreno provides the technology used to process it. By using Giovreno, you acknowledge the practices described in this Privacy Policy. 1. ABOUT GIOVRENO Giovreno is a multi-industry business operations, relationship-management, workflow, automation, and intelligence platform. Depending upon an Organization's configuration, subscription, industry, permissions, and enabled functionality, Giovreno may provide features involving customer relationship management, contacts, leads, projects, transactions, reservations and bookings, documents, communications, email, tasks, automation, artificial intelligence, financial records, commissions, expenses, human resources, personnel, contractors, teams, marketing, suppliers, vendors, reporting, analytics, forms, websites, and other business operations. The categories of information processed through Giovreno therefore depend substantially upon how each Organization chooses to use the Service. 2. INFORMATION WE COLLECT We may collect the following categories of information. 2.1 Account and Identity Information When an individual creates, activates, or uses a Giovreno account, we may collect information such as: - first and last name; - email address; - telephone number; - account and user identifiers; - Organization affiliation; - job title, role, team, or business unit; - profile photograph or avatar; - account status; - authentication identifiers; - account creation and activation information; and - account preferences and settings. Passwords and authentication credentials may be handled by authentication providers used by Giovreno. Giovreno should not be used to store passwords or authentication secrets in ordinary notes, documents, or communication fields. 2.2 Organization Information We may collect information about businesses and other Organizations using Giovreno, including: - Organization name and legal name; - business contact information; - website; - industry; - organizational structure; - parent, child, affiliate, team, or business-unit relationships; - branding information; - subscription and plan information; - billing responsibility; and - administrative settings. 2.3 Customer, Client, Contact, and Business Records Organizations may use Giovreno to process information about their own customers, clients, prospects, leads, contacts, vendors, suppliers, contractors, employees, and other individuals. Depending upon how Giovreno is configured, this information may include: - names; - contact information; - addresses; - company information; - preferences; - communications; - notes; - appointments; - tasks; - relationships; - transaction or booking information; - travel or reservation information; - service history; - documents; - marketing attribution; - activity history; and - other information entered by authorized users. The Organization using Giovreno is responsible for determining whether it has an appropriate legal basis, permission, authorization, or consent to collect and process this information. 3. WORKFORCE AND HUMAN RESOURCES INFORMATION Organizations may use Giovreno to manage employees, independent contractors, applicants, advisors, or other workforce members. Depending upon enabled features, information may include: - contact information; - job title; - employment or contractor status; - start dates; - organizational assignments; - onboarding information; - training records; - acknowledgments; - uploaded employment or contractor documents; - tax or administrative forms; - signatures and electronic-signature records; - certifications; - compensation-related business records; and - other information entered by the Organization. Giovreno does not independently determine an Organization's employment, contractor, compensation, hiring, termination, or personnel decisions unless expressly stated as part of a separate service. Organizations remain responsible for complying with applicable employment, labor, tax, privacy, and recordkeeping laws. 4. DOCUMENTS AND FILES Giovreno may allow users to upload, generate, store, process, extract information from, classify, sign, or otherwise manage documents and files. Documents may contain personal information selected by the Organization or user who uploads them. Users and Organizations are responsible for ensuring that they have authority to upload and process documents through Giovreno. We may process documents as necessary to: - store and retrieve them; - generate previews; - extract structured information; - perform search or classification; - enable electronic signatures; - support workflows and automation; - provide artificial intelligence functionality; - protect platform security; and - provide requested Services. 5. ELECTRONIC SIGNATURE INFORMATION Where Giovreno provides electronic-signature functionality, we may process information including: - signer name; - signer email address; - document version; - signature or initials; - date and time of signing; - signing events; - authentication or verification information; - document completion status; - reasonable technical information associated with the signing session; and - audit records designed to evidence execution of the document. Electronic-signature records may be retained for legal, contractual, evidentiary, security, and compliance purposes. 6. LEGAL DOCUMENT ACCEPTANCE Giovreno may maintain records showing that a user accepted the Giovreno Terms of Service, Privacy Policy, or other applicable legal documents. Acceptance records may include: - user identifier; - Organization identifier where applicable; - document type; - exact document version; - effective date; - acceptance timestamp; - acceptance source; - authentication information; - browser or device information; and - privacy-conscious technical audit information. Giovreno may retain prior acceptance records even after a legal document is updated because those records may be necessary to establish which terms applied at a particular time. 7. ARTIFICIAL INTELLIGENCE FEATURES Giovreno may include artificial intelligence, machine-learning, large-language-model, document-intelligence, and related functionality. When a user invokes an AI Feature, information necessary to fulfill the request may be transmitted to an AI service provider or processed using Giovreno's AI infrastructure. Depending upon the feature, information processed may include: - prompts; - instructions; - business records; - selected documents; - extracted document text; - communications; - contact or transaction information; and - contextual data necessary to generate the requested result. Giovreno may use third-party artificial intelligence providers. We seek to limit information transmitted to such providers to information reasonably necessary for the requested functionality and subject such processing to applicable contractual, technical, and organizational safeguards. AI output may be inaccurate and should be reviewed by an appropriate human before being relied upon for material decisions. 8. COMMUNICATIONS If Giovreno provides email, notification, messaging, or related functionality, we may process: - sender and recipient information; - subject lines; - message content; - delivery information; - timestamps; - communication status; - attachments; and - related technical information. Organizations are responsible for ensuring communications they send through Giovreno comply with applicable marketing, consent, opt-out, privacy, telephone, text-message, and electronic-mail requirements. 9. FORMS, LEADS, AND MARKETING INFORMATION Giovreno may provide forms, landing pages, lead-capture tools, campaigns, and related marketing capabilities. When an individual submits a form, information may include: - information entered into the form; - referring page; - landing page; - campaign attribution; - date and time; - UTM or similar campaign parameters; - assigned Organization or user; - reasonable fraud-prevention information; and - other information needed to process the submission. Organizations using Giovreno forms are responsible for providing any notices or obtaining any consents required for their particular use. 10. PAYMENT AND SUBSCRIPTION INFORMATION Giovreno may use third-party payment processors to process subscriptions or other payments. Depending upon the payment method and provider, payment processors may collect payment-card, bank, billing, identity, or transaction information directly. Giovreno generally does not need to store complete payment-card numbers or card security codes. We may receive and retain information such as: - payment-provider customer identifier; - subscription identifier; - transaction identifier; - subscription plan; - billing interval; - payment status; - payment amount; - currency; - renewal information; - trial information; - discounts or promotional information; and - limited billing details. Payment information processed directly by third-party payment providers is governed by those providers' privacy practices in addition to this Privacy Policy. 11. TECHNICAL AND USAGE INFORMATION When individuals access Giovreno, we may automatically receive technical information such as: - IP address or privacy-protected representation of an IP address; - device type; - operating system; - browser type; - application version; - timestamps; - pages or features accessed; - authentication activity; - security events; - error information; - network information; - session information; and - other diagnostic or usage data. We may use this information for security, fraud prevention, troubleshooting, product operation, analytics, audit, and service improvement. 12. COOKIES AND SIMILAR TECHNOLOGIES Giovreno may use cookies, local storage, session storage, or similar technologies where necessary to: - authenticate users; - maintain sessions; - remember settings; - protect security; - prevent fraud; - enable requested functionality; - understand Service performance; and - maintain application state. Where applicable law requires consent for non-essential cookies or similar technologies, Giovreno may provide appropriate controls. 13. HOW WE USE INFORMATION We may use personal information to: - provide and operate Giovreno; - create and manage accounts; - authenticate users; - maintain Organizations and permissions; - provide customer support; - process subscriptions; - provide requested features; - store and process documents; - enable communications; - perform automation; - provide AI Features; - provide reporting and analytics; - detect fraud or abuse; - maintain cybersecurity; - troubleshoot technical problems; - enforce our Terms and policies; - maintain audit and compliance records; - meet legal obligations; - investigate disputes; - protect users, Organizations, S & C Premier LLC, and third parties; and - improve and develop Giovreno. 14. ORGANIZATIONS AND DATA CONTROL Organizations using Giovreno control substantial portions of the information placed into their Giovreno environment. An Organization may determine: - what information it enters; - whose information it collects; - who receives access; - which Giovreno features are enabled; - which users receive particular permissions; - what integrations are connected; and - how its personnel use information available through the Service. If your personal information was entered into Giovreno by an Organization and you have a privacy question relating to that information, you may need to contact that Organization directly. S & C Premier LLC will reasonably assist Organizations with applicable privacy requests where required. 15. ORGANIZATIONAL SEGREGATION AND ACCESS Giovreno is designed to separate information according to Organizations, users, roles, permissions, business units, teams, and authorized organizational relationships. Authorized administrators may be able to access information associated with their Organization. Where Giovreno supports parent-child, host, franchise, supervisory, affiliate, or similar organizational relationships, authorized users may receive access to information according to configured permissions and platform rules. Access does not automatically change legal ownership of underlying information. 16. HOW WE DISCLOSE INFORMATION We may disclose information in the circumstances described below. 16.1 Service Providers We may use service providers that assist with: - cloud infrastructure; - databases; - authentication; - email delivery; - payment processing; - artificial intelligence; - security; - analytics; - error monitoring; - communications; - file storage; and - other technologies required to operate Giovreno. Those providers may process information only as necessary to provide their services and subject to applicable contractual and legal obligations. 16.2 Organization-Directed Disclosures We may disclose or transmit information when an Organization or authorized user intentionally uses a feature that requires information to be shared with: - customers; - clients; - suppliers; - vendors; - integrations; - payment processors; - communications providers; - business partners; or - other recipients selected by the Organization. 16.3 Legal Requirements and Protection We may disclose information when reasonably necessary to: - comply with applicable law; - respond to lawful legal process; - comply with court orders; - protect rights or property; - protect users or the public; - investigate fraud or security threats; - enforce agreements; or - establish, exercise, or defend legal claims. 16.4 Business Transactions Information may be transferred in connection with a merger, acquisition, financing, restructuring, reorganization, sale of assets, or similar corporate transaction, subject to applicable law. 17. WE DO NOT SELL PERSONAL INFORMATION S & C Premier LLC does not sell personal information to data brokers for monetary compensation. If Giovreno engages in activities that constitute "sale," "sharing," or targeted advertising under an applicable privacy law in the future, this Privacy Policy and any required controls will be updated accordingly. 18. DATA RETENTION We retain information for periods reasonably necessary to: - provide the Service; - maintain customer accounts; - fulfill Organization instructions; - comply with contracts; - preserve financial and transaction records; - maintain security records; - maintain legal-document acceptance evidence; - maintain electronic-signature evidence; - resolve disputes; - enforce agreements; - comply with legal obligations; and - establish, exercise, or defend legal claims. Retention periods may vary according to the type of information and the Organization's use of Giovreno. Organizations may be responsible for establishing retention requirements applicable to information they control. Backup copies may remain for a limited period after information is removed from active systems. 19. DATA SECURITY S & C Premier LLC uses administrative, technical, and organizational safeguards reasonably designed to protect information against unauthorized access, alteration, disclosure, destruction, or loss. Security measures may include, where appropriate: - authentication controls; - authorization and role-based permissions; - tenant isolation; - encryption in transit; - restricted administrative access; - logging and monitoring; - security reviews; - audit records; - secure cloud infrastructure; and - other measures appropriate to the nature of the information processed. No electronic system is completely secure, and we cannot guarantee that security incidents will never occur. 20. DATA BREACHES AND SECURITY INCIDENTS If S & C Premier LLC becomes aware of a security incident involving personal information, it will investigate and take appropriate steps based upon the circumstances. Where applicable law requires notification to affected individuals, Organizations, regulators, or other parties, we will provide or assist with such notifications as required. 21. YOUR PRIVACY RIGHTS Depending upon where you live and the circumstances in which your information is processed, you may have rights concerning personal information, including rights to: - request access; - request correction; - request deletion; - request a copy; - object to certain processing; - request restriction of certain processing; - withdraw consent where processing relies upon consent; - request portability where applicable; and - appeal certain privacy-request decisions where applicable. These rights are not absolute and may be subject to exceptions under applicable law. 22. REQUESTS CONCERNING ORGANIZATION-CONTROLLED DATA If an Organization entered your information into Giovreno, that Organization may be the appropriate party to handle your privacy request. Where appropriate, we may direct your request to the relevant Organization or inform you that you should contact it directly. We may assist Organizations in responding to verified privacy requests. 23. VERIFYING REQUESTS We may take reasonable steps to verify the identity and authority of a person submitting a privacy request. Verification methods may depend upon the sensitivity of the information and nature of the request. We may decline or limit requests where permitted by law, including where we cannot reasonably verify identity. 24. AUTHORIZED AGENTS Where applicable law permits an authorized agent to submit a privacy request on an individual's behalf, we may request reasonable proof that the agent has authority to act for the individual. We may also require direct identity verification from the individual where permitted. 25. STATE PRIVACY RIGHTS Residents of certain U.S. states may have additional rights under applicable state privacy laws. Depending upon applicable thresholds, exemptions, and processing activities, these may include rights concerning: - access; - correction; - deletion; - portability; - opting out of sale; - opting out of targeted advertising; - opting out of certain profiling; and - appeal of denied requests. Giovreno will honor applicable rights to the extent required by law. 26. CHILDREN Giovreno is intended primarily for businesses and adult users. Unless Giovreno expressly provides otherwise for a specifically authorized feature, individuals creating Giovreno user accounts must be at least eighteen (18) years old. We do not knowingly provide ordinary Giovreno accounts directly to children. Organizations should not enter information concerning minors unless they have a lawful and legitimate reason, appropriate authority, and use a Giovreno feature appropriate for that purpose. 27. SENSITIVE PERSONAL INFORMATION Certain Giovreno features may permit Organizations to process information that could be considered sensitive personal information under applicable law. Organizations should only enter sensitive information when: - reasonably necessary for a legitimate business purpose; - legally permitted; - appropriately authorized; and - supported by appropriate safeguards. Users should not place passwords, authentication secrets, card security codes, complete financial-account credentials, or similarly high-risk secrets in ordinary notes, messages, or general-purpose storage fields. 28. THIRD-PARTY SERVICES AND INTEGRATIONS Giovreno may integrate with services operated by third parties. When an Organization connects an integration, information may be transmitted between Giovreno and the third party according to the Organization's configuration. Third-party products and services are governed by their own privacy policies and terms. S & C Premier LLC is not responsible for independent privacy practices of third parties. 29. LINKS TO OTHER WEBSITES Giovreno may contain links to external websites or services. This Privacy Policy does not govern websites or services operated independently by third parties. 30. INTERNATIONAL DATA PROCESSING Giovreno and its service providers may process information in the United States and potentially other countries in which service providers operate. Where legally required for international transfers of personal information, S & C Premier LLC may use appropriate contractual or legal transfer mechanisms. 31. BUSINESS CUSTOMERS AND DATA PROCESSING AGREEMENTS Organizations with particular privacy, regulatory, or international data-processing requirements may require additional contractual terms, including a Data Processing Addendum. Where applicable, such agreements supplement this Privacy Policy and the Giovreno Terms of Service. 32. AUTOMATED PROCESSING Giovreno may use automation and artificial intelligence to assist users with business processes, recommendations, classifications, extraction, summarization, or other functions. Unless expressly stated otherwise for a particular feature, Giovreno's automation and AI functionality is designed to assist human users rather than independently make legally significant decisions about individuals on behalf of S & C Premier LLC. Organizations remain responsible for reviewing how they configure automated processes and for complying with laws applicable to their use. 33. CHANGES TO THIS PRIVACY POLICY S & C Premier LLC may update this Privacy Policy to reflect: - changes in Giovreno; - changes in applicable law; - new products or features; - changes in service providers; - security requirements; or - business practices. When changes are material, we may provide notice through Giovreno, email, account notifications, or another reasonable method. We may require users to acknowledge or affirmatively accept a materially updated Privacy Policy where appropriate. We may maintain versioned copies of this Privacy Policy so that acknowledgments or acceptance records can be associated with the policy in effect at a particular time. 34. RELATIONSHIP TO THE TERMS OF SERVICE Use of Giovreno is also governed by the Giovreno Terms of Service. If this Privacy Policy concerns privacy or processing of personal information, this Privacy Policy applies to that subject. Other matters concerning use of Giovreno remain governed by the Terms of Service and other applicable agreements. 35. CONTACT US Questions, privacy requests, or concerns concerning this Privacy Policy or Giovreno's privacy practices may be directed to: S & C Premier LLC Attn: Giovreno Privacy Suffolk County, New York Email: giovreno.platform@gmail.com Please include sufficient information for us to understand and respond to your request. Do not send passwords, authentication credentials, payment-card security codes, or other unnecessary sensitive information by email.