Privacy Policy

Effective date: October 19, 2026

RETENTION YES SP. Z.O.O. ("us", "we", or "our") operates the https://reteno.com/ website, the Reteno platform and its AI integrations, including the Reteno MCP server (the "Service"). This page explains how we collect, use and disclose personal data and the choices available to you. Where consent is required, it must be obtained separately for the relevant purpose. Unless otherwise defined here, terms have the meanings given in our Terms of Use.

Service

Service means the https://reteno.com/ website, the Reteno platform and its AI integrations operated by RETENTION YES SP. Z.O.O. Integration-specific processing, including connections to ChatGPT, Codex and Claude, is described in Reteno AI integrations.

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

We act as a Data Controller for Personal Data whose purposes and means of processing we determine. Where we process customer data on behalf of an organization using Reteno, we act according to the applicable customer agreement and Data Processing Agreement.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Address, State, Province, ZIP/Postal code, City

• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at any time, through your device settings.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Where applicable law requires consent for non-essential analytics or advertising cookies and similar technologies, those technologies may be used only after that consent is obtained. You must be able to withdraw consent as easily as you gave it.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.

• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

• Security Cookies. We use Security Cookies for security purposes.

Reteno AI integrations

Scope and responsibility

This section explains how RETENTION YES SP. Z.O.O. (Reteno) processes data through its MCP server and integrations with ChatGPT, Codex and Claude. For privacy questions and requests, contact info@reteno.com. Where Reteno processes your organization's customer data on its behalf, the applicable customer agreement and Data Processing Agreement also apply.

When you connect Reteno to one of these AI clients, you authorize the client to request Reteno operations using your connected account. Reteno receives the arguments supplied for those operations and returns results to the requesting client. The data involved depends on the operation and your account permissions.

The integration does not need your full conversation history. Include only the instructions, identifiers, content and files needed for the task. Text or files supplied as tool arguments may contain personal data; do not include unrelated personal information, passwords, payment-card details or other sensitive information in those arguments.

Data processed by the integration

Depending on the operation you request, the integration processes these categories:

• Connection and account information: account and organization identifiers, account settings and permissions, OAuth connection records and authorization credentials needed to maintain the connection. Credentials are handled through authentication, not requested as chat content.
• Contact and audience information: contact and external-customer identifiers, names, email addresses, phone numbers, subscription status, audience membership, preferences and custom contact fields present in the selected records.
• Purchase and transaction events: order or transaction identifiers, purchased products or services, purchase dates, amounts, currencies and transaction status supplied by the customer about its end users. These events form part of the customer's data processed by Reteno on its behalf.
• Device and messaging activity: device or installation identifiers, push tokens, application and operating-system information, message and campaign identifiers, delivery status, opens, clicks, event properties and associated dates. Which fields are involved depends on the selected lookup or messaging operation.
• Business and marketing content: business-profile details, logos, brand assets, sending and reply-to addresses, domains, email HTML and editor models, message text, images, links, templates, workflow settings and targeting conditions. This content may contain personal data that you or your organization have included.
• Reporting data: audience counts, campaign and event metrics, conversion information and requested reporting exports. Some contact, activity or export operations can include individual records rather than only aggregate totals.
• Image generation and editing data: your image brief or editing instructions, source and reference images, masks, selected generation settings, generated or edited images and their hosted URLs.
• Operation and diagnostic information: request, job, upload and export identifiers; retry keys and request hashes; processing status; timestamps and expiry times; file type, size and dimensions; error codes; and security and support logs. Logs can include account or organization identifiers, client IP address, user agent, tool name, request metadata, response status and processing duration. Some results include job or file metadata needed to retrieve an image or export or to recover an interrupted operation.

These categories also apply when information appears within nested response fields, exported files or operation records. Listing a category here does not authorize requesting unrelated data: the operation should remain limited to the task you selected.

Purposes of processing

We use integration data to authenticate and authorize access, carry out requested reads and changes, generate reports and assets, return results, enforce rate limits, recover interrupted operations, prevent duplicate execution, maintain security and investigate service errors. Marketing activity and contact information may be analyzed when you request an audience or campaign analysis.

Image generation and editing support email and campaign design. Rate limits apply. These tools do not initiate a purchase or payment. They create a hosted image result; inserting that result into an email or sending a message requires a separate operation.

Recipients and processing services

The image-processing step sends the material needed for that image operation; it is separate from the AI client's receipt of ordinary Reteno tool results.

Reteno's service providers process data needed to perform their agreed services. Providers processing customer data on our behalf are identified in the subprocessor list in Appendix 1 of our Data Processing Agreement, with the services they provide.

A provider's role depends on the service being used. OpenAI or Anthropic may act as a service provider engaged by Reteno for a particular API operation, while your separately selected ChatGPT, Codex or Claude account receives tool results under your arrangements with that provider. Connecting an AI client does not mean that every provider in the subprocessor list receives your data.

Copies held by your AI client are governed by that provider's applicable privacy notice, service agreement and account or workspace controls. Consumer and business services can have different rules. See OpenAI's privacy information and Anthropic's privacy policy. Reteno's use of the OpenAI image API is governed by Reteno's applicable API agreement and configuration.

Retention

Customer data accessed or changed through an AI integration remains subject to the customer-specific retention periods, deletion requirements and documented instructions described in Customer data retention. This includes contact and audience data, behavioral events, purchase and transaction history, and content saved in the customer's Reteno account. Using an AI integration does not replace the applicable contractual retention schedule.

Processing locations

Reteno's hosting and data-transfer practices are described in Transfer of Data. The AI client selected by the user and the image-processing services receive the data described in Recipients and processing services; their handling of those copies is governed by the applicable provider agreements and settings.

AI training and other uses

The purposes of Reteno's integration processing are described above. Your AI provider's use of content depends on its applicable service terms, agreement and account settings. Connecting Reteno does not change those settings. Do not assume that a consumer AI chat and Reteno's use of an image API have identical data-use rules.

Your controls

You choose whether to connect Reteno and which tasks and files to provide to the integration. You can stop using the integration and disconnect it through the AI client's connection controls. To request revocation of Reteno-side access or assistance with stored integration data, contact info@reteno.com.

Avoid submitting confidential content that should not be processed by the named image providers.

Disconnecting the integration does not undo changes already made to your Reteno account, delete content already saved in Reteno or remove copies already returned to an AI client. Requests concerning Reteno-held data and applicable access, correction or deletion rights can be sent to info@reteno.com. Use your AI provider's controls for copies retained by that provider. Where Reteno processes contact data on behalf of your organization, the request may need to be handled with the account owner under the applicable data-processing agreement.

Use of Data

RETENTION YES SP. Z.O.O. uses the collected data for various purposes:

• To provide and maintain our Service

• To notify you about changes to our Service

• To allow you to participate in interactive features of our Service when you choose to do so

• To provide customer support

• To gather analysis or valuable information so that we can improve our Service

• To monitor the usage of our Service

• To detect, prevent and address technical issues

• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

Where the GDPR applies and Reteno acts as a controller, the legal basis depends on the purpose and circumstances of processing:

Payments are processed where necessary to perform the relevant contract or comply with a legal obligation. When Reteno processes an organization's customer data as a processor, that organization determines the lawful basis for its processing and provides documented instructions under the applicable Data Processing Agreement. Connecting an AI client does not create a new lawful basis for processing unrelated personal data.

Retention of Data

Customer data retention

Reteno retains Personal Data processed on behalf of its customers according to the retention periods and deletion requirements specified in the applicable customer agreement, Data Processing Agreement and documented instructions. These periods may differ between customers and data categories depending on the processing purpose and applicable legal requirements. They cover customer data such as contact profiles, behavioral events, purchase and transaction history, and content saved in the customer's Reteno account.

Customers are responsible for establishing lawful retention periods that are no longer than necessary for their specified purposes and informing individuals about those periods or the criteria used to determine them. The applicable retention period and deletion requirements for a particular customer's data are set out in that customer's agreement and documented instructions.

Reteno returns or deletes customer data in accordance with the applicable agreement and instructions, including the agreed requirements at the end of the retention period or on termination of the services, unless applicable law requires continued retention. These arrangements do not limit individuals' rights under applicable data-protection law.

Data retained for Reteno's own purposes

Where Reteno processes Personal Data for its own purposes, RETENTION YES SP. Z.O.O. retains that Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We retain and use this data to the extent necessary to comply with our legal obligations (for example, if we are required to retain it to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

RETENTION YES SP. Z.O.O. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Personal Data stored in Reteno's core customer-data platform is hosted on Amazon Web Services in Dublin, Ireland, within the European Union. If you are outside the EU and provide data to that platform, it is transferred to the EU for that hosting and processing.

The hosting location of Reteno's core platform does not describe the location of every copy received by an external service. Your selected AI client receives the requested tool results, and Reteno's image-generation and editing operations send the relevant inputs to OpenAI's image API, as explained in Recipients and processing services. Other service-provider processing is described in the Data Processing Agreement. A provider's business address alone does not establish where it processes data.

Where a transfer is subject to GDPR restrictions on transfers outside the EEA, it must meet the applicable requirements, for example through an applicable adequacy decision or appropriate safeguards such as the European Commission's Standard Contractual Clauses, together with any required supplementary measures. The contractual requirements for customer data are set out in sections 7 and 8 and Appendix 3 of the Data Processing Agreement. Accepting this privacy notice is not a substitute for those safeguards.

For information about applicable safeguards or to request a copy, contact info@reteno.com. Information may be redacted where necessary to protect confidential information without preventing you from understanding the safeguards.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, RETENTION YES SP. Z.O.O. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

RETENTION YES SP. Z.O.O. may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation

• To protect and defend the rights or property of RETENTION YES SP. Z.O.O.

• To prevent or investigate possible wrongdoing in connection with the Service

• To protect the personal safety of users of the Service or the public

• To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

Where the GDPR applies to the processing of your Personal Data, you have the rights described below, subject to the conditions and exceptions in that law. RETENTION YES SP. Z.O.O. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where RETENTION YES SP. Z.O.O. relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

Service Providers processing Personal Data on our behalf have access to it to perform their agreed tasks and are subject to the applicable processing agreements. Your selected AI client also receives tool results as described in Recipients and processing services; its handling of those copies is governed by its applicable terms, privacy notice and account settings.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy

Behavioral Remarketing

RETENTION YES SP. Z.O.O. uses remarketing services to advertise on third-party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google AdWords

Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on — https://tools.google.com/dlpage/gaoptout — for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/business/m/interest-targeting

To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

RETENTION YES SP. Z.O.O. may disclose your Personal Data in the good faith belief that such action is necessary to:

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By email: info@reteno.com

• By phone: USA: +1 914 495 1740 PL: +48 571 945 994 DE: +49 176 59647419 UA: +38 056 787 0730