Privacy Policy

Last updated: [DATE]

This Privacy Policy describes how Sela Partners ("Apportunities", "we", "us") processes personal data in connection with the Apportunities platform at apportunities.io (the "Service"). The Service is a business tool: an AI sales opportunity agent that researches a client's market and prepares outreach briefs and drafts. Questions and requests: aviel@agentsela.com.

1. Our Roles: Controller and Processor

• Account, business profile, and usage data. For data about you and your business that we collect to run the Service, we determine the purposes of processing and act as the data controller.
• Contacts you import. For contacts imported by a client from its CRM (names, email addresses, phone numbers, and roles of the client's own contacts), the client is the data controller and we act solely as a processor on the client's documented instructions. If you believe your details were imported by one of our clients, please contact that client; we will assist them in responding.

2. Data We Collect

• Account data: name, business email address, and login details.
• Business profile: the description of your company, offering, target market, and preferences you provide so the agent can research on your behalf.
• Imported contacts: contact records you choose to import from your CRM.
• Usage decisions: your approvals, rejections, and feedback on opportunity briefs and drafts.
• Technical data: basic logs needed for security and operation of the Service.
• Payment data: processed by Invoice4U; we do not store payment card details.

3. How We Use Data

We use data only to run the Service: performing market research for your account, generating opportunity briefs and draft emails, sending emails you approve (paid plans only), enrichment lookups for suggested contacts, support, billing, and securing the platform.

• No cross-client learning. Your data is not used to train models or to improve results for any other client. Each client's workspace is separate.
• No selling. We do not sell or rent personal data, and we do not use it for third-party advertising.

4. AI Processing

Research tasks that include your business profile information are processed by third-party large language model providers accessed via OpenRouter, solely to generate research results and drafts for your account. We send only what is needed for the task and do not permit use of your data beyond providing that output.

5. Subprocessors

We use the following service providers to operate the Service:

| Provider | Purpose | Location | |---|---|---| | Supabase | Database and authentication (Postgres) | EU/US | | Netlify | Hosting and content delivery | US/global | | OpenRouter + underlying LLM providers | AI research and drafting | US/global | | Microsoft (Graph API) | Sending approved emails (paid plans) | US/EU | | Lusha | Contact enrichment lookups | Israel/US | | Hunter | Contact enrichment and email verification | EU | | Invoice4U | Payment processing | Israel |

Some providers are located outside Israel. Where data is transferred abroad, we do so in accordance with the Israeli Privacy Protection (Transfer of Data Abroad) Regulations and rely on providers offering recognized safeguards.

6. Cookies and Local Storage

We use only session and authentication cookies and browser local storage needed to keep you signed in and preserve your session state. We do not use advertising cookies, cross-site tracking, or ad pixels.

7. Retention

We retain personal data for the life of your account plus 30 days after account closure, after which it is deleted or irreversibly anonymized. Limited exceptions apply where retention is required by law (for example, billing and tax records) or for the establishment or defense of legal claims.

8. Your Rights

You may at any time request, by email to aviel@agentsela.com:

• Access to the personal data we hold about you;
• Export of your data in a commonly used machine-readable format;
• Correction of inaccurate data; and
• Deletion of your data (subject to the legal exceptions in Section 7).

We respond within 30 days. For imported contacts, requests will be referred to the relevant client as controller, and we will assist in fulfilling them.

9. Security

We apply security measures appropriate to a business SaaS platform, including:

• Encryption in transit (TLS) for all connections;
• Per-tenant isolation enforced at the database level via row-level security (RLS), so each client's data is segregated;
• Invite-only access during the beta, limiting exposure of the platform;
• Least-privilege internal access to production data.

No system is completely secure; we cannot guarantee absolute security, and we will notify affected clients and authorities of security incidents as required by applicable law.

10. Children

The Service is intended for business users aged 18 or over. We do not knowingly collect data from minors, and accounts are opened for businesses only.

11. Legal Framework

We process personal data in accordance with the Israeli Protection of Privacy Law, 5741-1981, and the regulations under it, including the Privacy Protection (Data Security) Regulations, 5777-2017. Where clients or their contacts are located in the EEA or UK, we honor the principles of the GDPR (lawfulness, purpose limitation, data minimization, and the rights described above) in how we operate; however, we do not represent that the Service holds any formal GDPR certification. Clients subject to the GDPR should assess their own controller obligations before importing contacts, and may contact us to put appropriate data processing terms in place.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be notified by email or in-app notice before they take effect. The current version is always available at apportunities.io.

13. Contact

Sela Partners — aviel@agentsela.com