Privacy Policy

1. Identity of Frigalto and Contact Details

• Controller / Legal Entity: SendWork, Inc. (a Florida corporation)
• Postal Address: 382 NE 191st Street, Suite 42012, Miami, FL 33179, United States
• Privacy Contact Channel (Person in Charge of Protection of Personal Information / Privacy Team): privacy@frigalto.com
• Legal Team Contact: legal@frigalto.com
• Support Contact: support@frigalto.com
• Data Protection Contact for All Regions: Individuals in every country and region where the Service is offered—including the European Economic Area, the United Kingdom, and Brazil—may contact Frigalto about privacy and data protection matters at privacy@frigalto.com or by mail at the postal address above.

2. Our Role: Controller vs. Processor

Frigalto provides business-to-business software for field-service and trade businesses ("Customers") and their staff ("Authorized Users") to manage their operations and serve their own clients ("End Customers"). Our legal responsibilities depend on whether we act as a Controller or a Processor:

2.1 When Frigalto is the Controller (or "Business")

Frigalto acts as the Controller (or "Business" under U.S. state privacy laws) when we determine the purposes and means of processing Personal Data for our own operations, including:

• Account registration, authentication, and business profile records of Customers and Authorized Users;
• Pre-launch waitlist registrations and Frigalto marketing communications;
• Subscription billing, tax-inclusive invoicing, and account management between Customer and Frigalto; and
• Website and application security, fraud prevention, authentication logs, crash diagnostics, support inquiries, and product usage telemetry.

2.2 When Frigalto is the Processor (or "Service Provider" / "Operator")

The Customer (the contractor or service business) is the Controller (or "Business")—and Frigalto acts as a Processor (or "Service Provider")—for all End Customer Data and operational job records that the Customer or its Authorized Users submit, store, or generate in their Frigalto workspace. Frigalto processes that data under the Customer’s instructions pursuant to Schedule 1 (Data Processing Addendum) of our Business Terms of Service.

• Important Notice to End Customers (Homeowners, Property Managers, and Venues): If you received a quote, estimate, invoice, schedule notice, or payment link from a service contractor that uses Frigalto, that contractor controls your Personal Data. Please direct any privacy questions or rights requests regarding your relationship with that contractor directly to them. If you submit a request to Frigalto that identifies a specific contractor, we will forward your request to that contractor and assist them in accordance with our Data Processing Addendum.

3. Categories of Personal Data We Process

3.1 Customer and Authorized User Data (Controller)

• Account & Business Profile Data: Name, business name, trade/industry, company size, role/title, email address, phone number, business address, language preference, market/country, and selected currency.
• Authentication & Permission Data: Login email, authentication identifiers, role-based workspace permissions, and session tokens.
• Subscription Billing & Tax Data: Subscription plan, billing cycle, billing address, business tax registration numbers where provided, Stripe customer and subscription IDs, invoice history, payment status, and non-sensitive card metadata returned by Stripe (such as card brand, last four digits, and expiration date). Frigalto does not collect or store raw payment card numbers or CVV security codes.
• Support & Legal Communications: Messages, attachments, and records exchanged with our support, privacy, or legal teams.

3.2 Waitlist Data (Controller)

• Waitlist Signups: Name, email address, website domain/source page, country/market, language preference, campaign source, timestamp, and marketing consent status. Joining a waitlist does not create a software account or begin a paid subscription.
• Waitlist Security and Eligibility Checks: IP address (used for geographic routing to the correct market and for network risk and fraud checks through MaxMind) and anti-bot verification tokens and browser signals generated by Cloudflare Turnstile.

3.3 Usage, Device, Security, and Offline Local-Device Data (Controller)

• Technical, Diagnostic & Security Data: IP address, approximate geographic region derived from IP address, browser and operating system type, device information, pages and features accessed, authentication and audit logs, crash/error reports, and abuse-detection signals.
• Offline & Local-Device Storage (PWA / IndexedDB): Because the Service supports mobile and offline field use, workspace records and pending offline actions may be cached locally on an Authorized User’s device using browser localStorage and IndexedDB, synchronizing when internet connectivity returns. Important Device Security Note: Logging out of the application does not automatically wipe all locally stored IndexedDB queue rows or cached records from the device’s browser. Local data may remain on the device until cleared by an application cleanup process or until the user manually clears their browser/site data. Authorized Users should secure their devices with passcodes and clear browser data if using a shared device.

3.4 End Customer and Job Operational Data (Processor for Customer)

• End Customer & Job Records: End Customer names, contact details, service site addresses, appointments, tasks, recurring work, estimates, quotes, deposits, invoices, line items, taxes, payment statuses, staff time entries, job notes, photos, videos, attachments, and signatures entered by the Customer.
• Transactional Messages: Estimates, invoices, receipts, and service communications sent by a Customer to an End Customer through the Service, including delivery/bounce status.

3.5 Connected Account and Connected Payment Metadata (If and When Enabled)

If and when Connected Payments are made available in a Customer’s market and the Customer connects a contractor-owned Stripe account to accept payments from End Customers:

• Connected Account Status: Stripe Connected Account identifier, onboarding status, capability flags, and restriction status indicators provided by Stripe.
• Transaction Metadata: Checkout session IDs, payment status, amount, currency, date, and refund/dispute status flags needed to keep the Customer’s invoice records accurate. Raw payment credentials entered by an End Customer on a Stripe-hosted checkout page are provided directly to Stripe under Stripe’s Privacy Policy (stripe.com/privacy).

3.6 AI and Voice Data (Processor for Content / Controller for Usage & Safety Logs)

• AI & Voice Inputs and Outputs: Text prompts, selected workspace context, voice audio submitted for transcription, transcripts, generated drafts or summaries, proposed action previews, user confirmations, and AI action audit records.
• Quota & Safety Logs: Interaction counts (for plan allowance tracking), error logs, and safety/abuse telemetry.

4. Sources of Personal Data

We collect Personal Data: (a) directly from Customers, Authorized Users, and waitlist visitors; (b) automatically from devices and browsers interacting with the Service; (c) from Customers and Authorized Users who input End Customer Data into their workspaces; and (d) from Stripe via signed webhook notifications regarding subscription billing or (where enabled) Connected Payment status.

5. Purposes and Lawful Bases for Processing

Where the EU GDPR, UK GDPR, Brazilian LGPD, or similar laws apply to Frigalto as a Controller, we rely on the following lawful bases (and we do not claim that mere use of the Service constitutes blanket consent to all processing):

• Performance of a Contract (or Pre-Contractual Steps): To register and authenticate accounts, provide the Service and its AI/voice and offline synchronization features, process subscription payments via Stripe, enable Connected Payment recordkeeping where available, send transactional communications, and provide customer support.
• Compliance with Legal Obligations: To calculate and record tax-inclusive subscription invoices, retain required accounting and tax records, respond to valid legal process, and fulfill statutory data protection and security obligations.
• Legitimate Interests: To maintain platform security, tenant isolation, and fraud prevention; diagnose application errors and crashes; enforce our Business Terms of Service; and analyze de-identified or aggregated service performance.
• Consent: For optional marketing communications, waitlist signups, and non-essential cookies/analytics where prior consent is required by law. You may withdraw consent at any time without affecting prior lawful processing.

When Frigalto processes End Customer Data as a Processor, we do so solely on our Customer’s instructions under Schedule 1 (Data Processing Addendum) of our Business Terms of Service.

6. AI and Voice Processing Practices

1. No Generalized Model Training by Frigalto: Frigalto does not use Customer Data, End Customer Data, voice audio, transcripts, or AI outputs to train generalized artificial intelligence models for other customers.
2. Commercial Provider Settings: When AI or voice features are used, requests are routed through commercial API integrations with our authorized AI and voice providers (listed in Schedule 2 below), configured so that Customer Data is not used to train the providers' generalized foundation models absent a separate, specific opt-in. Providers may retain API inputs and outputs temporarily where required by their commercial terms for automated abuse monitoring, error recovery, or legal compliance before deletion.
3. Assistive Review & Confirmation: Where supported in the application interface, consequential AI write actions present a preview for user confirmation prior to modifying workspace records.

7. Disclosures of Personal Data, Subprocessors, and Independent Controllers

7.1 No Sale or Cross-Context Behavioral Advertising. Frigalto does not "sell" Personal Data or "share" Personal Data for third-party cross-context behavioral or targeted advertising.

7.2 Service Providers and Subprocessors. We share Personal Data with vetted infrastructure and service providers that process data on our behalf to host and deliver the Service, including cloud hosting, database and authentication providers, transactional email providers, security and anti-bot verification providers, IP geolocation and fraud-risk providers, commercial AI and voice processing providers (when those features are invoked), and error monitoring and product analytics providers. Our list of authorized subprocessors and their status is attached as Schedule 2 below.

7.3 Stripe’s Dual Role (Processor and Independent Controller). We use Stripe for Frigalto subscription billing and (where available and enabled) Customer Connected Payments. While Stripe acts as a processor/subprocessor for certain payment execution steps directed by Frigalto, Stripe acts as an independent Controller when it collects and processes Personal Data directly for Know-Your-Customer (KYC) identity verification, anti-money-laundering (AML) and sanctions screening, payment network fraud detection, regulatory compliance, and administration of a Customer’s own Connected Account. Stripe’s independent processing is governed by the Stripe Privacy Policy (stripe.com/privacy).

7.4 Other Disclosures. We may also disclose Personal Data: (a) to End Customers or third-party integrations at a Customer’s direction; (b) to courts, regulators, or law enforcement when required by law or necessary to protect safety, rights, or property; or (c) in connection with a corporate merger, financing, acquisition, or sale of assets under confidentiality protections.

7.5 De-Identified Data. Where we create or use de-identified or aggregated technical data, we maintain and use it in de-identified form and do not attempt to re-identify individuals.

8. Cookies, Analytics, and Local Storage

We use cookies, localStorage, and IndexedDB to authenticate users, remember language and market preferences, enable offline PWA functionality, and process Stripe checkouts securely. On public and application pages, we also use PostHog to evaluate feature flags and understand how pages and features are used, and Rollbar to capture application errors; on waitlist and public forms, Cloudflare Turnstile runs an anti-bot security check. You can block or delete cookies and clear site storage at any time in your browser settings, and you can request an analytics opt-out by emailing privacy@frigalto.com. Detailed information about these technologies and your controls is set out in Schedule 1 (Cookie and Local-Storage Notice) below.

9. Marketing and Transactional Communications

Waitlist registrants and business contacts who opt in to receive marketing updates from Frigalto may unsubscribe at any time using the "Unsubscribe" link in any marketing email or by emailing privacy@frigalto.com. Unsubscribing from marketing emails does not affect essential transactional, security, or subscription billing emails required to administer an active account.

10. International Data Transfers

Frigalto is based in the United States, and our service providers process data primarily in the United States and other countries where they operate. When Personal Data is transferred across borders from the EEA, the United Kingdom, Canada (including Quebec), Brazil, other Latin American countries, Australia, or New Zealand, we implement applicable legal transfer mechanisms—including the EU Standard Contractual Clauses, the UK International Data Transfer Addendum, and the unmodified Brazilian ANPD Standard Contractual Clauses under Resolution CD/ANPD No. 19/2024 (set out in Annexes I through V of Schedule 1 of our Business Terms of Service), alongside contractual confidentiality and technical security safeguards.

11. Data Retention and Deletion

We retain Personal Data for as long as necessary to provide the Service and fulfill the purposes described in this Privacy Policy:

• Workspace Data: Retained while a Customer’s trial or paid subscription is active and during the post-termination read-only export window described in the Business Terms of Service, after which active workspace records are scheduled for deletion and encrypted backups age out through standard backup rotation cycles.
• Subscription Billing, Tax & Compliance Records: Retained for the retention periods mandated by applicable tax, corporate, accounting, and audit laws.
• Security, Diagnostic & Support Records: Retained for the period necessary to maintain platform security, comply with statutory log-retention rules (including applicable internet-access record laws), and resolve support or legal inquiries.
• Waitlist & Marketing Contacts: Retained until the contact unsubscribes, requests deletion, or is removed during periodic list hygiene, except for minimal suppression records kept to honor opt-out requests.

12. Security Safeguards and Age Restrictions

12.1 Security Controls. Frigalto maintains technical and organizational safeguards designed to protect Personal Data, including encryption in transit (TLS), encryption at rest across managed cloud databases, logical multi-tenant isolation using row-level security policies, role-based access controls, and separation of cardholder data onto Stripe-hosted checkout pages. No method of transmission or storage is completely infallible, and users are responsible for safeguarding their login credentials and devices.

12.2 Age Restrictions and Minors. No one under the age of 18 may create or operate a Frigalto account, and Frigalto does not knowingly collect Personal Data directly from children for Frigalto’s own Controller purposes. Where a Customer holds incidental information concerning a minor in its workspace records (such as a household contact note or site detail), the Customer is the Controller responsible for ensuring that such record is lawful and appropriate, and Frigalto processes it on the Customer’s instructions.

13. Your Privacy Rights and Requests

Depending on your jurisdiction, you may have the right to request: (a) access to and a portable copy of your Personal Data; (b) correction of inaccurate data; (c) deletion of your data; (d) restriction of or objection to certain processing; and (e) withdrawal of consent where processing is based on consent.

• Submitting a Request to Frigalto (Controller Data): Email privacy@frigalto.com with your name, the email address associated with your interaction with Frigalto, your jurisdiction, and the right you wish to exercise. We will verify your identity (typically via email confirmation) before fulfilling the request. If you are using an authorized agent, we require written authorization and identity verification.
• Appeals: If we decline to act on a request, you may appeal our decision by replying to our response or emailing privacy@frigalto.com with the subject "Privacy Appeal."
• Requests from End Customers of a Contractor: Please contact the contractor or service business directly. If you contact us and identify the contractor, we will route your request to that contractor.

14. Country and Regional Disclosures

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the version and date at the top of this page and provide advance notice to active Customers via email or in-app notification.