Privacy Policy
In short: we keep the account details you give us and the contacts and notes you upload, only to run the Service for you. We use one necessary cookie to keep you signed in. No advertising and no sale of data. The app itself contains no analytics or tracking; on our public website we use analytics only if you agree in the cookie banner. You can export or delete everything yourself at any time.
1. Who is responsible
1.1 Sales Revolver (the "Service") is operated by Sales Revolver ℅ emit gmbh, Grabenstr. 18, 40789 Monheim ("we", "us"). We are the controller of the personal data described in sections 2 to 4. Contact: hello@sales-revolver.com.
1.2 This policy has two audiences. Most of it is addressed to users — people who hold an account. Section 5 is addressed to people who appear in a user's contact list.
2. Data we collect about users
2.1 Account data. Your name, your email address and a salted hash of your password. We never store your password itself. If you turn on address-book sync to your phone, we also store a hash of the separate sync password needed for it.
2.2 Session data. A record of each sign-in session, stored as a hashed token with its expiry date, so that you stay signed in on your devices.
2.3 Content you create. The contacts and lists you upload, and the outcomes, notes, callback times and call log you record. As far as this relates to you (for example, when you made a call entry), we process it as part of providing the Service. As far as it relates to other people, see section 5.
2.4 Technical data. When your device connects to the Service, our servers necessarily process your IP address, the date and time of the request and basic browser or device information. Our hosting provider keeps these connection logs for up to 30 days. Separately, we keep a security log of account events — sign-ins and failed sign-in attempts, changes to passwords, email addresses and two-factor settings, team changes, exports and deletions — together with the IP address and the time, for 12 months.
2.5 Messages you send us. If you write to us, we keep your message and contact details in order to answer.
2.6 Billing data. If you subscribe to a paid plan, we store which plan you have, the state of the subscription and the reference our payment provider uses for you. Payment itself happens on pages of the payment provider: your card or bank details go to them, not to us, and we never see a full card number.
2.7 We do not collect contact data from the web or from other sources. We do not record calls, and the Service does not have access to your phone's call history or microphone.
3. Why we use it and on what legal basis
Where the GDPR or UK GDPR applies, we rely on the following legal bases:
- To provide the Service — creating and running your account, signing you in, storing and syncing your data between your devices, sending password-reset and other service emails, answering support requests: performance of our contract with you (Art. 6(1)(b) GDPR).
- To keep the Service secure and working — preventing abuse and unauthorised access, finding and fixing faults, enforcing our Terms, and establishing or defending legal claims: our legitimate interests in running a secure and reliable service (Art. 6(1)(f) GDPR).
- To comply with the law — for example keeping records we are required to keep, or responding to binding requests from authorities: legal obligation (Art. 6(1)(c) GDPR).
We do not use your data for advertising, do not build marketing profiles, and do not make decisions about you by automated means that have legal or similarly significant effects. You must provide a name, email address and password to open an account; without them we cannot provide the Service.
4. Cookies and local storage
4.1 We set one cookie, sr_session. It is strictly necessary: it keeps you signed in. It is an httpOnly cookie, which means scripts in the page cannot read it, and it lasts up to 30 days or until you sign out.
4.2 Your browser's local storage holds a few small interface preferences so that the app looks the way you left it. They stay on your device.
4.3 Inside the app (after signing in) we use no advertising, analytics or tracking cookies and no third-party trackers.
4.4 On our public website (the pages describing the Service) we use analytics only with your consent, which we ask for in a banner at the bottom of the page. Until you click "Accept", none of the tools below is loaded and no analytics cookie is set. If you agree, we use:
- Google Tag Manager and Google Analytics (Google Ireland Limited, Ireland): page views, clicks, the pages you came from, approximate location derived from your IP address, and device and browser information. Google Analytics sets cookies such as
_ga(up to 2 years). We do not use Google's advertising features. - PostHog (PostHog Inc., USA; data stored in the European Union, Frankfurt): page views, clicks and recordings of your visit to the website (mouse movements, scrolling and clicks, with text you type masked). PostHog stores an identifier in a cookie or local storage beginning with
ph_(up to 1 year).
4.5 The legal basis is your consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG). You can withdraw it at any time through "Cookie settings" at the bottom of the website; the tools are then switched off and their cookies deleted on your device. Your choice is remembered in your browser's local storage (sr_consent). Google may process data in the USA; it is certified under the EU–US Data Privacy Framework.
5. Contacts uploaded by users
5.1 Our role. Users upload business contacts into the Service — typically company, website, name, phone numbers, email address, position and notes — and record the outcome of their calls. The user decides which contacts to upload and what to do with them. For this data the user is the controller and we act only as a processor, on the user's instructions, under the data processing terms in our Terms of Service. We do not use this data for our own purposes, do not combine it across users, and do not sell or disclose it.
5.2 If someone using Sales Revolver has called you. We did not call you, did not provide your details to the caller and do not decide whether you are called. The person or company who called you is responsible for how your data is used. To find out what they hold about you, to have it corrected or deleted, or to ask not to be called again, please contact them directly — they are legally required to deal with your request.
5.3 If you cannot reach the caller, write to us at hello@sales-revolver.com with enough detail for us to identify the user (for example the caller's name or company, and the date and number of the call). Where we can identify the user, we will forward your request to them. We normally cannot search across all accounts for your details or act on your data ourselves without the user's instruction, unless the law requires us to.
5.4 Our Terms require users to have a lawful basis for every contact they upload and to comply with telemarketing and data-protection law. If you believe a user is misusing the Service, tell us; we can suspend accounts that breach our Terms.
6. Who receives data
6.1 We share personal data only with service providers that process it for us under contract and on our instructions:
- Hosting: Railway Corporation (USA), servers in the European Union (region EU West, Netherlands) — stores and serves all Service data, including the database. Railway processes the data under a data processing agreement that includes the EU Standard Contractual Clauses.
- Email delivery: Brevo (Sendinblue SAS, France) — sends password-reset and other service emails; receives your email address and the content of the message.
- Payments: Stripe Payments Europe, Limited (Ireland) — collects payments for paid plans, issues the invoices and hosts the pages where you pay and manage your subscription; receives your email address, your name or company, your billing address and payment details, and the plan you order. Stripe is itself responsible for the payment data it needs for its own legal duties, and may process data in the USA, where it is certified under the EU–US Data Privacy Framework.
- Website analytics (only with your consent, see section 4): Google Ireland Limited (Ireland) and PostHog Inc. (USA, data stored in the European Union) — receive usage data about visits to our public website, not data from inside the app.
- Mailbox for enquiries: Alfahosting GmbH (Germany) — hosts the mailbox hello@sales-revolver.com; receives the emails you send us and our replies.
6.2 We may also disclose data where the law requires it (for example a binding order from a court or authority), where needed to establish or defend legal claims, or to a successor if the Service is transferred — in which case this policy continues to protect your data and we will tell you beforehand.
6.3 We do not sell personal data and do not share it for advertising.
7. International transfers
7.1 The Service is offered worldwide, and data is stored on servers of Railway Corporation in the European Union (region EU West, Netherlands).
7.2 If personal data that is subject to the GDPR or UK GDPR is transferred to a country that has not been recognised as providing adequate protection, we rely on an appropriate safeguard — in general the European Commission's Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914; Module Two, controller to processor, and Module Three, processor to processor), supplemented by the UK International Data Transfer Addendum where the UK GDPR applies, together with additional measures where needed. You can ask us for a copy at hello@sales-revolver.com.
8. How long we keep data
- Account data and your content: for as long as your account exists. When you delete your account, all of it is deleted from our live systems.
- Individual contacts, lists and notes: until you delete them or your account.
- Sessions: up to 30 days, or until you sign out.
- Password-reset links: expire after a short time and are then invalid.
- Backups: deleted data may remain in backups for up to 30 days before being overwritten.
- Server logs: up to 30 days.
- Security log of account events: 12 months.
- Website analytics: Google Analytics data up to 14 months; PostHog events up to 12 months and recordings of visits up to 30 days.
- Billing records: invoices and payment records are kept for as long as tax and commercial law requires (in Germany up to 10 years).
- Correspondence with us: as long as needed to deal with your request and for any legally required retention period after that.
We keep data longer only where the law requires it or where we need it to establish or defend legal claims. Inactive accounts: [state whether and when inactive accounts are deleted].
9. Security
9.1 The measures we have in place include:
- passwords are stored only as salted hashes, never in readable form;
- session tokens are stored only as hashes, and the session cookie is not accessible to scripts;
- connections to the Service are encrypted with HTTPS;
- each account's data is isolated — a user can access only their own contacts, lists and call log.
9.2 No system is completely secure. Please use a strong, unique password, and tell us at once if you suspect unauthorised access to your account.
10. Your rights
10.1 Depending on where you live, and in particular under the GDPR and UK GDPR, you have the right to:
- access the personal data we hold about you and receive a copy;
- have inaccurate data rectified;
- have your data erased;
- have its processing restricted;
- receive the data you gave us in a structured, commonly used, machine-readable format (portability);
- object, on grounds relating to your particular situation, to processing that we base on our legitimate interests;
- complain to a supervisory authority, in particular in the country where you live or work, or where you think an infringement took place.
10.2 How to exercise them in the app. You can do most of this yourself, at any time:
- Access and portability: export all of your account data as a JSON file, or your call results as a CSV file.
- Rectification: edit your account details, contacts and notes.
- Erasure: delete individual contacts or lists, or delete your account, which deletes all of your data.
10.3 For anything else, write to hello@sales-revolver.com. We may need to confirm your identity before acting. We answer within one month, or within the period the applicable law sets. Exercising your rights is free of charge, and we will not treat you less favourably for doing so.
11. Notice for residents of US states
11.1 Some US states, including California, give their residents rights over their personal information, such as the rights to know, access, correct and delete it, and to opt out of its sale or of its use for targeted advertising.
11.2 We do not sell personal information, do not share it for cross-context behavioural advertising, and do not use it for targeted advertising or for profiling with legal or similarly significant effects. We do not knowingly process sensitive personal information beyond the account credentials needed to sign you in.
11.3 The categories of personal information we collect, their sources, the purposes and the recipients are set out in sections 2, 3 and 6. You can exercise your rights as described in section 10, and may use an authorised agent where the law provides for it. If we decline a request, you may appeal by replying to our decision. For personal information contained in users' contact lists we act as a service provider or processor; see section 5.
12. Children
The Service is a business tool for adults. It is not directed at anyone under 18, and we do not knowingly collect personal data from children. If you believe a child has opened an account, contact us and we will delete it.
13. Changes to this policy
We may update this policy when the Service or the law changes. The current version is always on this page, with its effective date at the top. We will tell you about significant changes by email or in the Service before they take effect.