Effective Date: June 2, 2026

Introduction

Coterna Corp ("we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, and safeguard information when you use the Coterna Corp Platform and related services. By using the Platform, you consent to the practices described in this Policy. If you do not agree to this Policy, you must discontinue use of the Platform immediately. This Policy is incorporated by reference into our Terms of Service.

Information We Collect

2.1 Information You Provide Directly

Full name, business name, and contact information

Billing and payment information, processed securely via a PCI-compliant third-party payment processor — we do not store full payment card numbers on our servers

Email address and phone number

Business details including industry, location, and service offerings

Customer contact lists uploaded or imported into the Platform

Communications and support requests submitted to us

Any other information you voluntarily provide through forms or account setup

2.2 Information Collected Automatically

IP address, browser type, operating system, and device information

Platform usage data, login timestamps, session duration, and feature interaction logs

Cookies, pixel tags, and similar tracking technologies

Performance and diagnostic data

Referring URLs and navigation paths within the Platform

2.3 Information From Third-Party Integrations

We may receive information about you from third-party services you authorize to connect with the Platform, such as Google Business Profile and payment processors. We handle all such data in accordance with this Policy. We do not control and are not responsible for the data practices of third-party services.

How We Use Your Information

We use the information we collect for the following purposes:

Providing, operating, maintaining, and improving the Platform and its features

Processing payments and managing your subscription and billing

Sending transactional communications including receipts, onboarding instructions, account alerts, and support responses

Sending platform updates, feature announcements, and marketing communications, from which you may opt out at any time

Analyzing usage patterns and behavior to improve Platform performance and user experience

Detecting, preventing, and responding to fraud, security incidents, abuse, and violations of our Terms

Complying with applicable legal obligations and regulatory requirements

Enforcing our Terms of Service and other agreements

How We Share Your Information

We do not sell, rent, trade, or share your personal information with third parties or affiliates for their own marketing or promotional purposes. We do not share mobile information or text messaging opt-in data with any third party for marketing purposes under any circumstances. The only limited situations in which information may be accessed are described below.

4.1 Service Providers

We may engage vetted service providers and subcontractors who assist us in operating the Platform, including payment processing, cloud hosting, and customer support services. These providers are contractually bound to protect your information, may only use it to perform services on our behalf, and are prohibited from using it for their own independent or marketing purposes. Mobile information, text messaging originator opt-in data, and consent are never shared with third parties or affiliates for marketing or promotional purposes. The identities of our infrastructure and service providers are confidential and proprietary to Coterna Corp.

4.2 Legal Requirements

We will only release information where we are legally compelled to do so by a valid court order, subpoena, law, or governmental request that we cannot lawfully refuse. This never includes the sale or sharing of mobile information or text messaging opt-in data for marketing or promotional purposes.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy proceeding, your information may be transferred as part of that transaction. You will be notified via email or in-platform notice prior to your information becoming subject to a materially different privacy policy.

4.4 Protection of Rights

We may use information internally to enforce our Terms of Service, protect the security and integrity of the Platform, and investigate potential violations. We do not share this information with outside parties for marketing or promotional purposes.

4.5 No Sharing of Mobile or SMS Data

Coterna Corp does not share, sell, rent, or disclose your mobile information, phone number, text messaging opt-in data, or consent with any third parties or affiliates for marketing or promotional purposes under any circumstances. This data is used solely to deliver the communications you have opted in to receive.

Client Data & End-User Data

As a Coterna Corp Client, you may upload, import, or generate data about your own customers ("End-User Data") into the Platform. You retain full ownership of all End-User Data. Coterna Corp processes End-User Data solely as a data processor acting on your behalf and in accordance with your instructions and this Privacy Policy.

You are solely and exclusively responsible for ensuring that you have the legal right, authority, and all required consents to collect, use, store, and upload End-User Data to the Platform. You represent and warrant that your collection and use of End-User Data complies with all applicable privacy, data protection, and consumer communication laws. Coterna Corp expressly disclaims any and all liability arising from your collection, use, or mishandling of End-User Data.

Data Retention

We retain your personal information for as long as your account is active or as necessary to provide the Platform, comply with legal obligations, resolve disputes, and enforce our agreements. Following termination of your subscription for any reason, we may retain your data for up to thirty (30) days, after which it may be permanently and irreversibly deleted. Coterna Corp has no obligation to recover or restore data following this retention period.

Certain information may be retained longer where required by applicable law or to protect our legitimate legal interests.

Data Security

We implement industry-standard administrative, technical, and physical security measures designed to protect your information against unauthorized access, use, alteration, or destruction. These measures include encrypted data transmission using SSL/TLS protocols, access controls and authentication requirements, and periodic security reviews.

However, no method of data transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your information and are not liable for unauthorized access resulting from factors outside our reasonable control, including your failure to maintain secure login credentials, use of compromised devices, or actions of malicious third parties beyond our control. You are responsible for maintaining the confidentiality of your account credentials and for all activity that occurs under your account.

Cookies & Tracking Technologies

We use cookies, web beacons, pixel tags, and similar technologies to maintain your session, remember your preferences, analyze Platform usage, and improve your experience. You may configure your browser to refuse all or certain types of cookies; however, doing so may limit your ability to use certain features of the Platform.

We do not use tracking technologies to follow you across unaffiliated third-party websites for advertising purposes. We do not sell data derived from cookies to third parties.

SMS & Email Communications

By providing your phone number or email address and using the Platform, you consent to receive transactional communications from Coterna Corp related to your account, subscription, billing, and Platform activity. You may also receive marketing and promotional communications.

You may opt out of marketing communications at any time by replying STOP to any SMS message or by clicking the unsubscribe link in any marketing email. Opting out of marketing communications does not affect your receipt of transactional or account-related messages that are necessary for the operation of your account.

Standard message and data rates may apply to any SMS communications you receive. Coterna Corp is not responsible for any fees charged by your mobile carrier.

Coterna Corp does not share, sell, or disclose any personal information collected through SMS opt-ins with third parties for marketing purposes. All SMS communications are sent solely for the purposes described at the time of opt-in. Message frequency varies based on account activity. Reply STOP to cancel at any time. Reply HELP for assistance. Message and data rates may apply.

No mobile information will be shared with third parties or affiliates for marketing/promotional purposes.

Text messaging originator opt-in data and consent will not be shared with any third parties, except for aggregators and providers of the Text Message services.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Children's Privacy

The Coterna Corp Platform is intended solely for use by adults and is not directed to individuals under the age of 18. We do not knowingly collect, solicit, or store personal information from minors. If we become aware that we have inadvertently received personal information from a minor, we will take prompt steps to delete such information from our records. If you have reason to believe we have collected information from a minor, please contact us immediately at [email protected].

Your Privacy Rights & Choices

Depending on your location and applicable law, you may have certain rights regarding your personal information:

Right to access: request a copy of the personal information we hold about you

Right to correction: request correction of inaccurate or incomplete information

Right to deletion: request deletion of your personal information, subject to legal retention obligations and our legitimate business interests

Right to opt out: opt out of marketing communications at any time

Right to data portability: request your data in a portable format where technically feasible

Right to restrict processing: request that we limit how we use your information in certain circumstances

To exercise any of these rights, submit a written request to [email protected]. We will verify your identity before processing any request and will respond within thirty (30) days. We reserve the right to deny requests that are unfounded, repetitive, or technically infeasible.

Florida Privacy Compliance

Coterna Corp is based in the State of Florida and operates in compliance with applicable Florida privacy and data protection laws, including the Florida Digital Bill of Rights where applicable. Florida residents may have additional rights under state law. For inquiries specific to your rights as a Florida resident, contact us at [email protected].

Do Not Track

Some browsers transmit "Do Not Track" signals to websites. Because there is no universal standard for how to respond to such signals, the Platform does not currently alter its data collection or use practices in response to Do Not Track signals. We will revisit this policy as industry standards develop.

Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When we make material changes, we will notify you via email or in-platform notification at least fourteen (14) days before the changes take effect. The updated Policy will be posted at coterna.com with a revised effective date. Your continued use of the Platform following notification of changes constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically.

If you have any questions, concerns, complaints, or requests regarding this Privacy Policy or our data practices, please contact us in writing at:

Coterna Corp | Email: [email protected] | Website: coterna.com

We will make reasonable efforts to respond to all privacy-related inquiries within thirty (30) business days.