Berrio Global Privacy Policy


Effective: October 30, 2026


At Berrio, Inc. (including its subsidiaries) collectively referred to herein as Berrio (“Berrio”, “us”, “we”, “our”) we believe privacy is a fundamental right, and we take your privacy seriously. We understand that you are entrusting us to handle your personal data appropriately; this is why Berrio is committed to transparency about how we collect, use and share your information, and how we protect it. If you are located within the European Economic Area or UK please see our Supplemental European Privacy Notice.


Purpose and Scope


This Privacy Policy applies when Berrio is acting as the data controller of your personal data and explains how Berrio collects, uses, and shares your personal data for its own purposes; and how you (collectively “you”, “your”, “data subject”) can exercise your privacy rights.


Berrio’s websites, products, and services are designed and intended for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes.


Berrio collects and uses the personal data of our customers/clients, consultants, suppliers, business contacts, shareholders, visitors/guests, and website users for various reasons. When we do so, we will use it in accordance with applicable laws.


This Privacy Policy does not apply to information that we process on behalf of our business customers while providing our services. Our use of personal data that we process on behalf of our business customers would be governed by our agreements, including Data Processing Agreements (DPAs) that we have with such customers. If you are an employee, customer or other individual who interacts with a Berrio customer using our products, please contact that customer or organization directly. If you are a Berrio job applicant, please see our Job Applicant Privacy Notice. If you are a Berrio employee, please see the Employee Privacy Notice.


What Personal Data Do We Collect?


Contact and Request Information: Contact information includes; although not limited to, your name, salutation, email address, job title, employer, business address, location, telephone numbers, social media handles, and other personal data that you voluntarily provide to Berrio when you request information, via online form, chat, phone, respond to enquiries, register for an event, comment or ask questions on our public profiles social media links/handles.


Account Information: Account information includes information provided when you interact with our support channels, including, although not limited to, company name, your name, identifier, billing / invoicing information. For services that require it, we also will collect authentication information, such as mobile number, and/or other unique verification identifiers.


Authentication Information: If you are leveraging single-sign on (SSO), these services authenticate your identity and prepopulate the log-in and sign-in form. If you choose to leverage these services by using your Google or Microsoft credentials, we receive your name and email address from these service providers as permitted by you and/or your organization to authenticate your identity.


Website Information and Mobile Information: When you access our websites, we will collect your device internet protocol (IP) address and information about your device and website usage, including browser type, internet service provider, time zone setting, your location, and clickstream data, date/time stamps. This may include technology to determine content, or other features, for example, when you open a marketing email or click on an embedded link, or if you watch videos on our site, or interact with/message using our chat function. We may use cookies and other tracking technologies including chat technology on our website. When you use our mobile app, we collect certain information from your device such as your device make, model, and memory.


Audiovisual Information: We may record sales phone calls/demos and online meetings (including audio and video content where applicable and in accordance with applicable laws) for business administration purposes. This includes analyzing the content of such calls and online meetings using AI-powered tools to gain better insights into our interactions with our business partners, customers and potential customers (where applicable and in accordance with applicable laws). We will always notify you before a call if it will be recorded and will obtain your consent where required by law.


Photographs, images, footage recorded on CCTV. When you visit Berrio’s offices these may be equipped with closed-circuit television (“CCTV”) systems. Internal cameras are only installed in public areas and open areas, only as permitted by applicable laws.


Marketing Information: Includes your contact and professional details provided through marketing forums, events, clicks, your preferences, your engagement, and participation. Identifiers may include email address, cookie and advertising identifiers, and campaign attribution data and other inferences we can derive from this information.


Public Information about You: We also use third-party search tools, data enrichment, and prospecting information about potential business customers (e.g. LinkedIn Sales Navigator, ZoomInfo, and similar). The way in which these third parties collect personal data is detailed in their own privacy policies, available on their websites. We may collect information from publicly accessible websites, such as your company’s website, professional network services, or press releases. In addition, we may collect personal data from social media and public directories. We may also receive your personal data when you engage or post on public forums that may be accessible in the public domain. This personal data can be viewed, collected, copied, cached or stored elsewhere by others, and Berrio is not responsible for any such use of this personal data.


Information obtained from other sources: Berrio may collect business contact information about you from other sources including referrals, recommendations, newly acquired entities, Berrio partners, co-sponsors of events attended by Berrio, third parties from whom we have purchased business contact information. We also collect information about you from other sources, and we may combine this information with personal data provided by you.


Children Under the Age of 16


Berrio does not knowingly collect the personal data of children under the age of 16. If we learn we have collected the personal data of a child under the age of 16, we will comply with applicable legal requirements to delete this information.


Why Do We Collect Your Personal Data?


Berrio may collect and use personal data about you for the following purposes:


  • Communicate with you and fulfil your request for information or support.

  • Manage your account in accordance with the applicable terms of service, DPA, accounting and financial matters.

  • Provide you with information about our products

  • Manage and enhance our customer relationship management (CRM) system.

  • Identify and enhance our research and development models.

  • Protect our security and network infrastructure, verify accounts and activity by investigating suspicious activity. Detect network instability, undertake troubleshooting, and improve customer experience.

  • Marketing activities to promote our business and to understand your potential interest and to send you personalized direct marketing communications in accordance with law and/or your preferences.

  • Social media and public domain monitoring.

  • To enhance or improve our products and services with the use of Generative AI
    (GenAI) models and chatbots, including although not limited to, content generation, recommendations, quality assurance, code development, and customer support. All data used in GenAI models is handled in accordance with applicable law.

  • Use transcripts to improve our general business management and product development in accordance with applicable laws.

  • We do not use GenAI models and chatbots to make fully automated decisions that have legal or similarly significant effects on individuals.

  • Execute financial arrangements, including those involving a merger, acquisition, sale, transfer, or other transaction of Berrio assets. Berrio will seek reasonable protection for information in these types of business transactions.

  • General business management and customer relationship management.

  • Respond to or otherwise manage any legal claims and comply with legal requirements and obligations.

  • We may create aggregated, de-identified and/or anonymized data from your personal data into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve online services and promote our organization. We will not attempt to re-identify any such data, except when permitted by law.

  • Additionally, in some cases, we may specifically request for your consent to collect, use, or share your personal data, such as when required by law.

Disclosing Your Personal Data


Berrio may disclose your personal data to the following categories of third parties:


Berrio Subsidiaries: Berrio may disclose any of the categories of personal data described above within Berrio where necessary to fulfill a request you have submitted or for customer support, marketing, technical operations, and account management purposes.


Berrio’s Service Providers: Berrio may disclose any of the categories of personal data to third-party service providers or vendors contracted to provide services on our behalf (for example, IT and hosting, data analytics, marketing services, customer support, call recording, chatbot technology, data enrichment, email fulfillment, and payment services). These third-party service providers may use personal data we provide to them only as instructed by Berrio.


Marketing and Event Sponsors: When you participate in webinars, events, and other activities where Berrio collaborates with third parties, we may disclose your contact information and interests in these offerings or services to these third parties to communicate with you.


Third-Party Advertising: When you visit our website, we may enable third parties to use cookies and other trackers to show you ads on third-party websites that are more relevant to you (see Cookies and Other Technologies, below). Under some data protection laws, our disclosure of this information to third parties through cookies and other trackers for targeted advertising may be considered a “sale” or “share” of personal data. Please see our Cookie Policy for more information about the types of cookies we use and to learn more about how to opt-in or opt-out (as applicable) of the sale or sharing (for targeted advertising) of your data.


Professional Advisors: Including legal counsel, consultants, auditors, bankers, insurers, where necessary to provide professional services to us.


As Required by Applicable Law: Including, without limitation, in response to any government or regulatory agency request, to cooperate with law enforcement investigations, or upon receipt of a court order.


Additional Disclosures: Berrio may disclose your personal data to third parties if we
have a good-faith belief that such action is necessary to:
(a) conform to legal requirements or comply with legal processes;
(b) protect and defend our rights or property;
(c) enforce our website Terms and Conditions;
(d) provide to courts and public authorities to protect you, Berrio or third parties
from harm, including fraud or instances where physical safety is at risk;
(e) respond to lawful requests by public authorities, including to meet national
security or law enforcement requirements; and/or
(f) act to protect the interests of our customers, users, or others.


Your Choices


In this section, we describe the rights and choices available to all users.


  • Access or update your information. If you have registered for an account with us through our website(s) or apps, you may review and update certain account information by logging into the account or by contacting us directly.

Your choices and the means Berrio offers individuals for limiting the use and disclosure of your personal data:


  • Opt-out of communications. If you no longer wish to receive marketing-related communications, you may opt-out of receiving these emails by clicking “unsubscribe” found in emails we send you. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

  • Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

  • Advertising choices. You may control or limit use of some of your personal data for targeted advertising by clicking to access your cookie settings or via similar tools.

Declining to provide information. We need to collect personal data to provide certain services. Therefore, if you do not provide the information we identify as required or mandatory, we may not be able to provide those services.


Certain personal data, such as information about medical or health conditions, racial or
ethnic origin, political opinions, religious or philosophical beliefs, is considered “Sensitive Information”. Berrio will not use sensitive information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless Berrio has received your affirmative and explicit consent to do so (opt-in).


Third-Party Websites


Our website(s) and apps may include links to third-party applications, products, services, or websites. If you access those links, you will leave our websites and apps. Berrio does not control these third-party sites or their privacy practices, which may differ from Berrio’s practices. The Berrio Privacy Policy does not cover the personal data you choose to provide to or that is collected by these third parties. You are encouraged to review the privacy documentation of any third-party site you interact with before you allow them to collect and use your personal data.


Cookies and Other Technologies


Berrio and our partners (e.g., marketing partners, analytics, advertising, or service providers) use various tracking technologies such as cookies, web beacons, pixels, tags and scripts alone or in conjunction with cookies to analyze trends on our websites and apps, administer our websites and apps, and to gather firmographic and demographic information about our user base. We receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis in most cases. If you provide personal data on our website and accept cookies, Berrio may combine this data in our CRM or analytics systems.


Please see our Cookie Policy for more details including, information about your choices with respect to advertising and social media cookies. We respond to both the Do Not Track and the Global Privacy Control signal.


Targeted Advertising Practices


We rely on third-party services providers to serve and manage our advertising on other sites. These service providers may use technologies such as cookies and other non-cookie technology to gather information about your activities on our websites and other sites in order to provide you with advertising based upon your browsing activities, interests or other information we may provide them. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out or if located in the European Union click www.youronlinechoices.eu. Please note this does not opt you out of being served ads as you may continue to see more generic ads.


Protecting your Personal Data


Berrio maintains appropriate security, technical and organizational measures to protect your personal data. However, security risks are inherent in all internet and information technologies, therefore, we cannot guarantee the security of your personal data. For more information on our security posture, see Berrio.ai.


Transferring Your Personal Data Internationally


Berrio operates as a global business and complies with applicable legal requirements when we transfer, store, or process your personal data outside of your jurisdiction. We take appropriate safeguards to protect your privacy, your fundamental rights and freedoms, and the ability to exercise your rights. Where required, we have put in place appropriate safeguards with our affiliates, service providers, contractors, distributors and other business partners and agents to ensure that transfers of personal data outside Europe are adequately protected. Unless a jurisdiction is deemed to have adequate safeguards, the safeguards we typically put in place, as applicable, are the European Commission’s Standard Contractual Clauses or the UK’s International Data Transfer Agreement in accordance with the GDPR.


Retaining your Personal Data


We retain your personal data for as long as we have an ongoing legitimate business
need to do so (for example, fulfil our contractual requirements, provide you with a
service you have requested or to comply with applicable legal, tax, or accounting
requirements).


The criteria used to determine appropriate retention periods for personal data include:


  • The length of time we have an ongoing business relationship with you.

  • The amount, nature, and sensitivity of the personal data we process.

  • Whether we have a legal obligation to retain personal data or whether retaining personal data is necessary to resolve disputes, including the establishment, exercise, or defense of legal claims.

Exercising your Privacy Rights


Depending on where you are located and how you interact with Berrio you may have certain legal rights over the personal data we hold about you, subject to local privacy laws. For specific rights that you may have as a resident of the European
Economic Area or the UK please see the European Supplement for additional
information.


To exercise your rights with respect to information covered by this Privacy Policy, please contact us using the contact details at the bottom of this Privacy Policy or by submitting a request through to privacy@berrio.ai. When exercising your rights, Berrio will take steps to verify your identity, including validating your name and the email you use when interacting with Berrio. You may also authorize another person or third party to submit a request to exercise your rights by providing written permission in conjunction with the submission of the requested information or by giving the third party your power of attorney. We will acknowledge your request and provide a follow-up substantive response within a time period permitted by applicable law. In the event that Berrio requires an extension to fulfill a request, we will notify you. If we deny your request, we will provide reasons for that denial.


Berrio will not discriminate against you for exercising your rights. Berrio does not make decisions based solely on automated processing that produces legal or similarly significant effects as part of the processing activities covered by this Privacy Policy.


California “Shine the Light” Disclosure


Under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes.
We comply with this law by offering our customers a choice about the disclosure of personal information to third parties for their direct marketing purposes, and you can make or change such choice as described in the “Your Choices” section above.
Contacting Us


You may contact us via email at privacy@berrio.ai


Or by mail:
Attention: Privacy Office
Berrio Inc.
5051 Peachtree Corners Circle
Suite 200
Norcross, GA 30096, USA


Privacy Policy Updates


Berrio may update our Privacy Policies and supplements periodically to reflect changes to our information practices. When we change the policy in a material way, we will provide you with notice as required by applicable law, including notifying you by updating the date of this Privacy Policy and posting it online or via other appropriate methods. We encourage you to please review this page periodically for updates on our privacy practices.


SUPPLEMENTAL EUROPEAN PRIVACY NOTICE


The information provided in this Supplemental European Privacy Notice (“Privacy Notice”) applies only to individuals in the European Economic Area and United Kingdom, (collectively, “Europe”) in connection with Berrio’s Global Privacy Policy and, as applicable, its Job Applicant Privacy Policy and Employee Privacy Policy. If you are based in Europe, this Supplemental European Privacy Notice applies to you in addition to the Berrio Global Privacy Policy.


References to “personal data” or “personal information” in both the Supplemental European Privacy Notice and the Berrio Global Privacy Policy should be understood to be “personal data” as defined by the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”) and the EU GDPR as it forms part of UK law (“UK GDPR”). Under the GDPR, personal data is information about an individual, from which that individual is either directly identified or can be identified. The GDPR does not include ‘anonymized data’ (i.e., information where the identity of the relevant individual
has been permanently removed, and that individual is no longer identified or identifiable).


Berrio, Inc. is the controller in respect of the personal data covered by this Privacy Notice for the purposes of the GDPR.


With respect to web cookies and other technologies that are not strictly necessary for our provision of our websites and apps, Berrio seeks consent from users of our websites and apps in Europe based on a separate Cookie Policy.


Legal Basis of Processing


In respect of each of the purposes for which we use your personal data, the GDPR requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing your personal data described in this Privacy Notice are listed below.


  • Performance of a Contract Where we are about to enter or have entered into a contract with you (“Performance of a Contract”).

  • Legitimate Interests: Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal data for is set out in the table below.

  • Legal Obligation: Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

  • Consent: Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set forth below, in a table format, the legal basis we rely on with respect to the relevant Purposes for which we use your personal data - for more information on these Purposes and the data types involved, see ‘Why do we collect your personal data’.



Purpose of processing

Categories of personal data

Legal basis

Disclosures

To respond to your comments, questions, requests, improve and enhance the quality and efficiency of our products and business services.

Any and all data categories relevant for the circumstances (except sensitive data)

Legitimate interests

We may disclose this information to service providers, marketing / events partners, third-party advertisers, professional advisors, courts and public authorities, others are required by applicable law.

To manage your account

Contact information, Account information, Authentication information,

Performance of a contract; Legitimate interests

We may disclose this information to service providers, marketing / events partners, third-party advertisers, professional advisors, courts and public authorities, others are required by applicable law.

To monitor the performance and security of our websites and applications

Contact information Authentication information Website/ mobile information

Consent where applicable by law; otherwise Legitimate interests.

We may disclose this information to service providers, marketing / events partners, third-party advertisers, professional advisors, courts and public authorities, others are required by applicable law.

To serve interest-based advertising

Contact information Website/ mobile information Marketing information Public information about you Information obtained from other sources

Consent where applicable by law; otherwise legitimate interests

We may disclose this information to service providers, marketing / events partners, third-party advertisers, professional advisors, courts and public authorities, others are required by applicable law.

Sales and marketing activities to personalize and improve our products and services

Contact information, Account information, Authentication information, Website/ mobile information, Marketing information, audiovisual information

Consent where applicable by law; otherwise Legitimate interests

We may disclose this information to service providers, marketing / events partners, third-party advertisers, professional advisors, courts and public authorities, others are required by applicable law.

To send you personalized direct marketing communications based on your needs and interests

Contact information and request information Marketing information

Consent where applicable by law; legitimate interests

We may disclose this information to service providers, marketing / events partners, third-party advertisers, professional advisors, courts and public authorities, others are required by applicable law.

To comply with our legal and contractual obligations and protect our legal interests

Any and all data types relevant in the circumstances

Legal obligation, performance of a contract, legitimate interests

We may disclose this information to service providers, marketing / events partners, third-party advertisers, professional advisors, courts and public authorities, others are required by applicable law.

To executive financial agreements include those involving a merger, acquisition, or other transaction of Berrio assets.

Contact information and request information Account information Website/ mobile information Audio information Public information about you Information obtained by other sources

Legitimate interests, performance of a contract

We may disclose this information to service providers, professional advisors, courts and public authorities, others are required by applicable law.

General business management and customer relationship managements

Contact information and request information Account information Website/ mobile information Public information about you Information obtained by other sources

Consent where applicable by law; otherwise, legitimate interests, performance of a contract

We may disclose this information to service providers, marketing / events partners, third-party advertisers, professional advisors, courts and public authorities, others are required by applicable law.

To create aggregated, de-identified and/or anonymized data

-

Legitimate interests

We may disclose this information to service providers, marketing / events partners, third-party advertisers, professional advisors, courts and public authorities, others are required by applicable law.

To access protentional interest in our products and services, including through data enrichment, lead scoring and sales prospecting

Marketing information; Inferences

Consent where applicable by law; otherwise, legitimate interests

We may disclose this information to service providers, marketing / events partners, third-party advertisers, professional advisors, courts and public authorities, others are required by applicable law.

Transferring Your Personal Data Outside of Europe


Berrio operates as a global business and complies with applicable legal requirements when we transfer, store, or process your personal data outside of your jurisdiction. We take appropriate safeguards to protect your privacy, your fundamental rights and freedoms, and the ability to exercise your rights. Where required, we have put in place appropriate safeguards with our affiliates, service providers, contractors, distributors and other business partners and agents to ensure that transfers of personal data outside Europe are adequately protected.


Data Retention


Berrio retains your personal data for as long as we have an ongoing legitimate business need to do so (for example, to provide you with the services you have requested or to comply with applicable legal, tax, or accounting requirements).


The criteria used to determine appropriate retention periods for personal data includes:


  • The length of time we have an ongoing business relationship with you.

  • The amount, nature, and sensitivity of the personal data we process.

  • Whether we have a legal obligation to retain personal data or whether retaining personal data is necessary to resolve disputes, including the establishment, exercise, or defense of legal claims.

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.


Your Privacy Rights


European data protection laws provide you with certain rights regarding your personal data. If you are located in Europe, you may ask us to take the following actions in relation to your personal data that we hold:


  • Access. Provide you with information about our processing of your personal data and give you access to your personal data.

  • Correct. Update or correct inaccuracies in your personal data.

  • Delete. Delete your personal data where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove our personal data where you have exercised your right to object to processing (see below).

  • Transfer. Transfer a machine-readable copy of your personal data to you or a third party of your choice.

  • Restrict. Restrict the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it.

  • Object. Object to our processing of your personal data where we are relying on Legitimate Interests - you also have the right to object where we are processing your personal data for direct marketing purposes.

  • Withdraw Consent. When we use your personal data based upon your consent, you have the right to withdraw that consent at any time.

  • Right to Not Be Subject to Automated Decision-making. The types of automated decision-making referred to in Article 22(1) and (4) EU/UK General Data Protection Regulation (“GDPR”) do not take place in connection with your personal data. Should this change, we will inform you about why and how any such decision was made, the significance of it, and the possible consequences of it. You will also have the right to human intervention, to express your point of view, and to contest the decision.

Profiling


Berrio does not use automated profiling in connection with our websites and
applications or use automated decision-making in a way that produces legal effects
concerning you or which significantly affects you.


Your Choices


If personal data covered by this Privacy Notice is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized or is to be disclosed to a non-agent third party in a manner not specified in this Policy, Berrio will provide you with an opportunity to choose whether to have your personal data so used or disclosed. Certain personal data, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, is considered “Sensitive Information”. Berrio will not use sensitive information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless Berrio has received your affirmative and explicit consent (opt-in).


Contact Us - Exercising your Privacy Rights


To exercise your rights with respect to information covered by this European Supplement, please contact us via:


Email at privacy@berrio.ai


Or by mail:
Attention: Privacy Office
Berrio Inc.
5051 Peachtree Corners Circle
Suite 200
Norcross, GA 30096
USA


When exercising your rights, Berrio will take steps to verify your identity, including validating your name and the email you use when interacting with Berrio. You may also authorize another person or third party to submit a request to exercise your rights by providing written permission in conjunction with the submission of the requested information or by giving the third party your power of attorney. We will acknowledge your request and provide a follow-up substantive response within a time period permitted by applicable law. If Berrio requires an extension to fulfill a request, we will notify you. If we deny your request, we will provide reasons for that denial.


Please note that these rights may be subject to limitations and conditions under the
GDPR or applicable national data protection laws.


Berrio will not discriminate against you for exercising your rights. Berrio does not make decisions based solely on automated processing that produces legal or similarly significant effects as part of the processing activities covered by this Privacy Notice.


Your Right to Complain


In addition to your rights outlined above, if you are not satisfied with our response to a
request you make, or how we process your personal data, you may make a complaint
with a data protection authority such as the supervisory authority of your usual place of
residence.


For users in the European Economic Area: the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en


For users in the UK: the contact information for the UK data protection regulator
is below:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk


Last updated October 29, 2026