1. Data Controller
TR Sales LLC
30 N Gould St Ste R
Sheridan, WY 82801
USA
Email: info@attrsales.net2. Data We Process
When using Conversio, the following personal data is processed:
- Account data (name, email address, encrypted password)
- Customer data entered in the CRM (name, phone number, conversation content)
- WhatsApp messages sent and received through the platform
- Usage data and log files (IP address, timestamps, pages visited)
3. Purpose and Legal Basis
- Art. 6(1)(b) GDPR — Contract performance: operating the CRM platform in accordance with agreed terms of use.
- Art. 6(1)(f) GDPR — Legitimate interests: platform security, abuse prevention, technical operation.
4. Data Processors and Third Parties
- Vercel Inc. (Hosting, USA) — Data transfer based on EU Standard Contractual Clauses (SCC).
- Neon Inc. / Supabase (Database) — Storage of all CRM data.
- Groq Inc. (AI processing, USA) — Processing of conversation content for AI-generated responses. Data transfer based on SCC.
- Meta Platforms Ireland Ltd. (WhatsApp Business API) — Processing of WhatsApp messages in accordance with Meta's terms of use.
5. Retention Period
Personal data is deleted as soon as it is no longer required for the purposes for which it was collected. Account data is deleted after account termination. Conversation data is deleted on request or after the agreed usage period expires. Statutory retention obligations remain unaffected.
6. Your Rights
- Right of access (Art. 15 GDPR)
- Right to rectification (Art. 16 GDPR)
- Right to erasure (Art. 17 GDPR)
- Right to restriction of processing (Art. 18 GDPR)
- Right to data portability (Art. 20 GDPR)
- Right to object (Art. 21 GDPR)
- Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)
To exercise your rights, please contact: info@attrsales.net