Privacy Policy

SALES-T PRIVACY POLICY Effective Date: 20 October 2026 Version: 2026.10.20 1. CONTROLLER AND CONTACT Scope: this policy covers currently available SALES services only — the SALES-T Android application, SALES Admin (Management Web), Professional Account and Company Account surfaces, Organizations, the TULSATO product website at https://tulsato.com, and the public Damocles Services website. It does not describe unreleased SALES modules. This Privacy Policy explains how personal data and business information are processed when you use those currently available services. TULSATO is the product/platform. DAMOCLES SERVICES SINGLE MEMBER P.C. is the operating/legal company that provides TULSATO. TULSATO is not a separate legal company. Controller for Damocles Services website communications and for TULSATO-controlled platform-level account/security processing described here: DAMOCLES SERVICES SINGLE MEMBER P.C. Operating TULSATO DAMOCLES SERVICES ΜΟΝΟΠΡΟΣΩΠΗ Ι.Κ.Ε. Trade name: DAMOCLES SERVICES TULSATO is operated by DAMOCLES SERVICES SINGLE MEMBER P.C. Registered office: ΕΡΜΟΥ ΚΑΙ ΛΥΚΟΒΡΥΣΕΩΣ 14, 14452 ΜΕΤΑΜΟΡΦΩΣΗ, ΑΤΤΙΚΗ, ΕΛΛΑΔΑ GEMI: 196664401000 EUID: ELGEMI.196664401000 AFM: 803425673 VAT: EL803425673 Formed: 08/10/2026 Email: info@damocles-services.com Privacy: privacy@tulsato.com Website: https://damocles-services.com For TULSATO product privacy questions or requests, contact privacy@tulsato.com. Security reports: security@tulsato.com. Product support: support@tulsato.com. The operator contact remains info@damocles-services.com. When an Organization uses SALES to enter or generate operational business records, that Organization normally determines the purposes and means of that processing and acts as controller for those records. DAMOCLES SERVICES SINGLE MEMBER P.C., operating TULSATO, may process such data as a processor to host, secure, maintain, synchronize, support and operate the service. The Data Processing Agreement remains the separate Organization/controller-processor instrument and is not replaced by this Privacy Policy. 2. ACCOUNT DATA Depending on the account type and functions used, SALES may process: - name; - email address; - date of birth for Professional / Salesman accounts; - mobile contact phone number; - country / residence country; - Company legal name, country, contact email, mobile contact phone, and VAT / Tax identifier; - user and account identifiers; - optional profile information you or an Organization administrator provide; - authentication identifiers; - account status and lifecycle status. TULSATO keeps this normal account/registration profile information. Identity / KYC verification for Professional withdrawals and related fraud, compliance, and same-owner payout controls is performed when those operations are requested. Didit is the primary hosted identity-verification provider. The provider may, under its own verification flow, process identity documents, selfies, liveness checks, biometric or equivalent verification data, company documents, and related compliance information. TULSATO does not store raw identity documents, selfies, liveness video, biometric templates, KYB supporting documents, UBO dossiers, or raw provider questionnaires. Current implementation does not retain those raw artifacts at TULSATO. DAMOCLES SERVICES SINGLE MEMBER P.C., operating TULSATO, is the controller for identity verification used for account security, payout-destination ownership, fraud prevention, and related compliance. Didit provides hosted verification as a processor and service provider for that purpose, on TULSATO instructions. Didit may also process limited data as an independent controller for purposes in Didit own terms and notices, including security, abuse prevention, service integrity, audit logging, legal compliance, and legal claims. Didit is not the controller of TULSATO verification purpose. For identity verification and payout same-owner matching, TULSATO processes and may retain minimized verification records, including: identity verification provider reference; verification status and timestamps; minimized verified identity name returned by the provider; normalized or derived matching evidence used to compare the verified name with the payout-account holder; payout-destination ownership verification evidence; and manual review evidence where applicable. Access is restricted through authenticated roles and server-side controls. Didit general verification-data retention is 24 months. A biometric template is deleted with the verification session. Didit model training is opted out. Those provider settings do not set the retention period for TULSATO records. TULSATO minimized identity and payout evidence is kept for as long as needed for verification, payout ownership, fraud prevention, security, disputes, audit, and legal or financial obligations. It is not deleted automatically after 24 months, and it is not the same as raw GPS retention. Didit does not independently verify bank-account ownership for TULSATO. Same-owner payout matching is performed by TULSATO using verified identity-name matching and/or controlled TULSATO or manual evidence. Real fiat funding and Professional earnings payout remain disabled until go-live configuration enables them. 3. PROFESSIONAL, COMPANY AND ORGANIZATION STRUCTURE Professional Accounts: a personal SALES identity used for field use of SALES-T and related Professional access. It is distinct from a single Organization membership. Company Accounts: the Company identity that may create and manage Organizations and Company-level access. Organizations and memberships: an Organization is the workspace that holds business records. A Company assigns roles (including administrators, managers and field roles) and memberships. A Professional may be linked to more than one Organization. Access to an Organization's records follows the membership and role assigned for that Organization. 4. CRM AND BUSINESS RECORDS Authorized users may enter or access business records such as: - Customers; - Contacts; - Visits; - Communications; - Activities; - related notes, status and history. SALES CRM Contacts are business records that a user or Organization manually enters into SALES. SALES does not access the Android address book and does not collect device contacts. The Organization and its authorized users are responsible for ensuring that information entered is accurate, appropriate and lawfully processed. 5. PRECISE LOCATION SALES-T collects precise location only after the user starts a tracking session. Only the authenticated tracked user may start Tracking. Company, Admin, Manager and Platform Admin cannot remotely start GPS Tracking. Tracking does not start if the user cancels the in-app location disclosure. The user starting Tracking is a privacy safeguard and is not GDPR consent. While a session is active and shared with a selected Organization, authorized Organization management may see the user's live precise GPS position in Management/Admin Web. The Company identity site is not a live Tracking map. Other Organizations cannot see the session. Ordinary unrelated Salesmen do not get organization-wide live browse. Stop Tracking ends new GPS collection immediately. No new location fix is collected after Stop. Historical pre-Stop route data may remain according to the applicable retention setting. Historical visibility after Stop is not live tracking. While that user-started session is active, precise location may be collected in the background, including when the app is minimized, not in use, or the screen is locked. A persistent notification is shown while background tracking is active. Location is used for field route recording and visit verification. Visit verification uses customer premises coordinates together with available session GPS, not the button-press location as a substitute for the customer location. Organizations may also configure working hours that affect when tracking is permitted; they do not remotely start tracking. GPS accuracy depends on the device, permissions, satellite visibility, network conditions, operating-system restrictions, battery settings and other technical factors. Routes may contain gaps or incomplete segments. SALES-T uses simplified tracking semantics: GPS route geometry with quality filtering and speed-based sampling. Map coloring uses movement-speed ranges. This policy does not claim automatic AI transport recognition as a current product capability. The Professional stops tracking from the app. Technical safeguards (for example inactivity warning/stop) may also end a session; they do not transfer responsibility for lawful workplace use away from the Organization. 6. RAW GPS RETENTION Detailed raw GPS / route history is a separate retention system from permanent business records. Professional Personal raw GPS retention may be set to: - 0 — same local calendar day only; - 1, 3, 6, 12, 18 or 24 months. The current default is 12 months. 0 means the Professional's local calendar day, not a rolling 24-hour window. Reducing Personal retention makes older Personal raw GPS history unavailable according to that setting. Increasing Personal retention later does not restore previously excluded Personal history. Organizations have an independent raw GPS retention setting using the same value set. Organization-retained location history is not the same store as Personal retention. Derived business records (for example verified visits, activities, KPIs and permanent distance summaries) follow their own business lifecycle and are not deleted merely because raw GPS history expires. On the device, raw GPS may also be held temporarily as an operational local cache and cleaned after approximately 30 days when safely synced or finalized. Local cache cleanup is separate from the cloud retention settings. Reducing retention currently makes expired raw GPS logically unavailable according to existing rules. Expired raw GPS points are then physically deleted once no legitimate Personal or Organization holder remains entitled to retain that point. A later retention increase does not restore already-purged points. Legal hold may defer deletion only through the explicit hold mechanism. Purge audit records counts and identifiers, not raw coordinates. 7. CAMERA, GALLERY AND PHOTOS Camera photos: the Professional may take a photo with the device camera. Capture is user-initiated. SALES-T may record current location context for the attachment according to current app rules. Gallery-selected photos: the Professional may attach a photo using the system Photo Picker / gallery selector. On Android 13 and later this does not require unrestricted persistent access to the device photo library. Gallery EXIF location is not treated as SALES-T tracking evidence. Attachment location follows current SALES app policy. Photo attachments are optional. If a photo includes location metadata, that metadata reflects the attachment context in SALES and is not evidence of the original gallery capture location. Customer photos are private Organization media stored in SALES private storage with signed access for authorized users. Media follows a holder-aware lifecycle: when no legitimate holder/basis remains, storage cleanup may be performed according to current media-lifecycle rules. Automated media-cleanup scheduling is not claimed as enabled in the current service configuration. 8. DEVICE HEALTH For security, support and operational monitoring of an authorized work device, SALES may process: - battery level; - charging status; - network state/class; - GPS status; - last GPS upload; - heartbeat; - device model and manufacturer; - Android version; - app version. Device Health is intended to help an Organization see whether an authorized work device and SALES-T appear operational. It does not access personal photographs, personal messages, call contents, Android contacts, passwords, personal documents or the contents of other applications. 9. DEVICE AUTHORIZATION AND INSTALLATION IDENTIFIER SALES-T may restrict tracking and access to an authorized installation. An installation identifier and related device-authorization records are processed so an Organization can approve, replace or revoke a device. 10. SECURITY AND MFA SALES processes authentication data, device-authorization records, and audit/security logs needed to protect accounts and Organizations. Where the device supports it, biometric unlock may be used to unlock the app on that device. Biometric templates remain on the device and are not uploaded to SALES. 11. MULTI-ORGANIZATION BEHAVIOR A Professional may belong to more than one Organization. Tracking share and CRM visibility follow the Organizations selected or assigned for that activity. Data belonging to one Organization is not made available to another Organization except through authorized membership, role or explicit sharing controls in the current product. 12. SERVICE PROVIDERS ACTUALLY USED SALES does not include advertising or consumer analytics SDKs. Processors / infrastructure actually used for current services include: - Supabase (authentication, database, private storage, related backend functions); - CARTO map tile infrastructure using OpenStreetMap data for in-app and Admin maps; - Google / Android location services on the device for GPS while tracking is active; - server-side geocoding (Google Geocoding via a Damocles-operated function) when an address is geocoded in the product; - Google Gemini and OpenAI API services for Ask SALES product-help answers when remote assistance is used; - a Google AI provider for the complimentary FREE Agent (authorized, scoped tool context only; not a paid Agent); - Google Cloud Vision and OpenAI for Scan Card OCR and extraction when that function is used; - website and email hosting/infrastructure required to operate public pages and transactional messages. Didit is the PRIMARY hosted KYC/KYB provider and is PRODUCTION READY for hosted identity/business verification when those operations are requested. Sumsub remains DORMANT / NOT_CONFIGURED. TULSATO may rely on independent verification providers for identity, business, security or payout verification. Didit may process identity documents, selfies, or biometric/equivalent data under its own verification flow; TULSATO does not store those raw artifacts under the current implementation. Didit does not independently verify bank-account ownership for TULSATO. TULSATO does not claim that Stripe performs KYC/KYB. Where TULSATO plan subscription billing is configured, billing may be processed by a payment service provider (currently Revolut for that subscription billing rail only). That billing rail, where used, does not credit Service Balance or Earnings and does not pay out Professional earnings. Wallet funding of Service Balance and Professional earnings payout remain unavailable until the relevant payment/payout service provider rail is enabled. Stripe is not an active TULSATO payment, KYC, KYB, or payout provider. Advertising SDKs and ad-network scripts are not configured in the current service. HubSpot and Salesforce integrations exist only when an authorized user directs a CRM import connection; they are not a default data flow for every user. SALES does not sell personal data. Information may also be visible to: - the Organization that holds the relevant business records; - authorized administrators and users of that Organization according to role; - public authorities where disclosure is required by law. Processor sharing (hosting/operation) is not the same as making records visible to other users or Organizations. 13. ACCOUNT DELETION Professional Account deletion: - the Professional may request deletion of the Professional Account; - a one-year recovery period applies; - during recovery, normal operational access is disabled; - the Professional may recover the account during that period. Public website pages for the same Professional account lifecycle: - https://tulsato.com/account/delete/ - https://tulsato.com/account/recover/ Company Account deletion: - a Company may request deletion of the Company Account; - a one-year recovery period applies; - during recovery, normal operational access is disabled. After finalization, SALES deletes or anonymizes by default except the minimum data necessary for: - legal obligations; - accounting and tax obligations where applicable; - fraud and security; - disputes; - establishment, exercise or defence of legal claims; - protection of other legitimate users and Organizations; - protection of Damocles Services. SALES does not immediately erase every record, and does not keep everything forever. 14. CRM LAST-HOLDER PRINCIPLE Deleting the creator of a Customer or Contact does not automatically delete those business records. CRM/business data remains while another legitimate holder or context has a valid basis (for example another Organization membership or remaining Company/Organization holder). When no legitimate holder/basis remains, the data becomes eligible for deletion or anonymization. 15. RAW GPS IS SEPARATE Raw GPS retention (section 6) is independent of account deletion and of CRM last-holder rules, except where a specific deletion or legal-hold process also covers location records. 16. LEGAL HOLD Where a legal hold, lawful request, security investigation or dispute requires preservation, SALES may retain the minimum necessary information even if a user or Organization has requested deletion. Legal hold is exceptional and does not replace ordinary retention settings. 17. RIGHTS Subject to applicable law, an individual may have rights including: - access; - correction; - deletion; - restriction; - objection where applicable; - portability where applicable; - lodging a complaint with a supervisory authority (in Greece, the Hellenic Data Protection Authority: https://www.dpa.gr). SALES does not claim that every right can be exercised through fully automated self-service tooling. Requests may be handled through the Organization (for Organization-controlled records), through the in-product Compliance Center where available, and/or privacy@tulsato.com or info@damocles-services.com, with identity verification where appropriate. Erasure is not fully automated. 18. SECURITY AND TRANSFERS Reasonable technical and organizational measures are used, including authenticated access, role-based permissions, row-level database security, encrypted transmission, authorized-device controls and security logging. Some processors may process data outside Greece or the EEA. Where required, an applicable transfer mechanism is used (for example an adequacy decision or Standard Contractual Clauses). No electronic service can be guaranteed completely secure or continuously available. 19. CHILDREN AND AUDIENCE SALES services are intended for business and professional use by authorized personnel. TULSATO accounts are available only to persons aged 18 or older. They are not directed to children. 20. ASK SALES ASSISTANCE Ask SALES is a question-and-answer product-help assistant. When you use it, SALES processes the text you enter to provide product help. It does not execute CRM or Tracking actions. Non-sensitive contextual flags (for example current screen) may be sent to improve answers. To generate some answers, SALES may send your question and relevant product-help excerpts to Google Gemini and, if needed, an OpenAI fallback. This policy does not claim that no data is sent to third-party AI, and does not claim that a full CRM database is sent. 21. COMPLIMENTARY FREE AGENT The complimentary FREE Agent is an action-executing assistant for eligible signed-in users, currently capped at 3 successful actions per eligible user per UTC calendar month. It is not Commercial Agenting. Paid Agent features are off. The Agent proposes a typed action; SALES servers authorize it against your signed-in identity. The model does not alone authorize actions. A dedicated Google AI provider may process Agent traffic. Free-provider failure fail-closes and does not spill into a paid provider. 22. SCAN CARD Scan Card is an OCR/extraction function. When used, the image is processed server-side with Google Cloud Vision and then an OpenAI extraction model. The image is transient and is not stored as a dedicated Scan Card object. The user reviews extracted values before any CRM mutation. 23. FEATURES NOT CURRENTLY AVAILABLE The following are not currently available as live user services: advertising networks and AdMob (not configured); wallet Service Balance funding through a payment/payout service provider (not enabled); Professional earnings payout (disabled); public Freelancer marketplace self-registration (closed); Commercial Agenting (closed/hidden); Plus++ (Coming Soon). Authenticated Company and Professional users may use Freelancer Core for Trial and internal USD-denominated engagements under the Financial Terms. Current product currency is USD. SALES Credits are not the current product currency. TULSATO is not a bank, EMI, or payment institution. 24. STORAGE AND FILES Photos, documents and similar files are stored in private object storage with signed access for authorized users. Commercial storage quota is a logical product limit. When over quota, new material writes may be blocked; existing readable data is not automatically deleted. Logical quota is not the same as physical hosting bytes. 25. DATA-SUBJECT REQUESTS AND PROVIDER SWITCHING Organizations may use the Compliance Center for ACCESS, PORTABILITY, RECTIFICATION, ERASURE, RESTRICTION, OBJECTION or OTHER requests. Provider Switching / Exit is a separate legal-portability path and is not the same as paid commercial CRM export. Erasure is not fully automated. 26. FINANCIAL AND WALLET RECORDS TULSATO processes commercial and related personal data needed to operate USD Service Balance, Earnings, conversion, withdrawal review, identity verification for withdrawals, same-owner payout-destination verification, and (where configured) plan billing. Depending on role and functions used, this may include: - wallet and transaction records; - source payment currency, source amount, and source-currency exponent, which are distinct from the USD ledger credit; - provider valuation rate, valuation timestamp, provider fee, and fee currency; - whether an actual provider currency exchange occurred. Actual FX is recorded only when provider evidence shows that it occurred. A read-only rate used for valuation is not an executed conversion; - payout currency and the provider-facing payout amount, which are distinct from the USD Earnings amount; - qualifying funding-currency provenance used for payout eligibility; - Revolut payment or payout references when a Revolut funding or payout rail is used; - Service Balance history; - Earnings history; - earnings-conversion records; - withdrawal requests and review outcomes (ACCEPT / REJECT / FURTHER REVIEW); - payout-destination metadata (masked/display identifiers, ownership lifecycle / verification status, ownership assertions) — not full bank or card credentials if TULSATO does not store them; - identity verification provider references, status, and timestamps; - minimized verified identity name and derived matching evidence used for the same-owner payout check; - payout-destination ownership verification evidence and manual review evidence where applicable; - provider transaction identifiers and billing references returned by a payment service provider; - fraud, security, and account-review metadata; - accounting and audit records; - financial-environment isolation metadata (production / sandbox / QA). TULSATO-controlled records are distinct from provider-controlled payment or KYC data. Raw identity documents, selfies, and biometric artifacts remain with the verification provider under its flow and are not stored by TULSATO under the current implementation. Retention of minimized verification and wallet evidence follows legal, accounting, fraud, dispute and security obligations described in this policy and is not the same as raw GPS retention. Historical completed payouts may retain immutable verification evidence tied to those records. TULSATO internal balances are USD records. TULSATO does not maintain user wallet balances in EUR, GBP, TRY, JPY, or other currencies. A supported funding currency is not by itself a payout currency. Initial payout currencies, when the payout rail is enabled, are EUR, GBP, and USD. Creating a provider payment draft is not a completed payout. Live Service Balance funding and Professional earnings payout remain disabled until TULSATO enables those rails. These categories do not make TULSATO a bank or payment institution. 27. UPDATES This Privacy Policy may be updated. The effective date and version above identify the current text. The TULSATO product public copy is published at https://tulsato.com/privacy/. An aligned Damocles Services copy is published at https://damocles-services.com/privacy/. Material changes may also be communicated through the application, an Organization administrator or another appropriate channel. 28. CONTACT TULSATO product privacy: privacy@tulsato.com Security: security@tulsato.com Support: support@tulsato.com Damocles Services (operator): info@damocles-services.com Website: https://damocles-services.com Requests about data controlled by an Organization should normally be submitted first to that Organization. 29. TULSATO LAUNCH NOTIFICATION TULSATO Launch Notification Visitors may voluntarily provide their full name and email address to be notified when the TULSATO platform officially launches and becomes available for registration. The information is sent by email to DAMOCLES SERVICES IKE and is used exclusively for this notification. No user account or subscriber-list entry is created, and the information is not stored in the platform's application database. Visitors may request at any time that their information no longer be used for further contact by emailing privacy@tulsato.com. The message is delivered to info@tulsato.com. A copy is forwarded to the designated business mailbox. Those mailbox copies are retained under ordinary email retention. This section does not say that the email itself is never retained. Ενημέρωση για την κυκλοφορία του TULSATO Οι επισκέπτες μπορούν προαιρετικά να δηλώσουν το ονοματεπώνυμο και τη διεύθυνση email τους, ώστε να ενημερωθούν όταν η πλατφόρμα TULSATO τεθεί επίσημα σε λειτουργία και είναι διαθέσιμη για εγγραφές. Τα στοιχεία αποστέλλονται μέσω email στην εταιρεία DAMOCLES SERVICES ΙΚΕ και χρησιμοποιούνται αποκλειστικά για την ενημέρωση αυτή. Δεν δημιουργείται λογαριασμός χρήστη ή εγγραφή σε λίστα συνδρομητών και τα στοιχεία δεν αποθηκεύονται σε βάση δεδομένων της πλατφόρμας. Οι ενδιαφερόμενοι μπορούν να ζητήσουν οποτεδήποτε να μη χρησιμοποιηθούν τα στοιχεία τους για περαιτέρω επικοινωνία, αποστέλλοντας email στο privacy@tulsato.com. Το μήνυμα παραδίδεται στο info@tulsato.com. Ένα αντίγραφο προωθείται στο ορισμένο επαγγελματικό γραμματοκιβώτιο. Τα αντίγραφα αυτά διατηρούνται σύμφωνα με τη συνήθη διατήρηση της αλληλογραφίας. Η ενότητα αυτή δεν αναφέρει ότι το ίδιο το email δεν διατηρείται ποτέ.