Warmly procurement policy evidence
Only topics backed by verified findings appear below. Each row preserves the platform's exact policy words and capture provenance.
| Topic | Plan or tier | Risk | Their words | Source |
|---|---|---|---|---|
| DPA, audit rights & data residency | All applicable tiers | low | “Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we treat it. By accessing or using the Site and/or the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not want your Personal Information to be processed as described in this Privacy Policy, please do not use our Site or our Services. Note to Enterprise Customers: If you are an enterprise customer of Warmly and wish to enter into a separate data processing agreement with Warmly in order to comply with your obligations under applicable data protection laws, please contact us at security@warmly.ai .” | Captured 2026-06-08Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | medium | “We are located in the United States and your Personal Information that we collect is processed and stored in the United States. We rely on derogations for specific situations as set forth in Article 49 of the General Data Protection Regulation (“GDPR”) and on contractual clauses in our agreements. In particular, we collect and transfer to the United States Personal Information with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Given the lack of a finding of “adequacy”, there may be a risk that the supervisory authority and/or data processing principles and/or data subject rights in the United States might not be sufficiently appropriate or comprehensive safeguards from the perspective of the EU. We strive, however, to apply suitable safeguards to protect the privacy and security of your Personal Information and only to use it consistent with your relationship with us and the practices described in this Privacy Notice. Our vendors and others with whom we share your Personal Information in accordance with this Policy are either certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks or we use contractual clauses in our agreements with them that are designed to protect the privacy and security of your Personal Information.” | Captured 2026-06-08Open source →Finding permalink → |
| Data retention | All applicable tiers | medium | “To determine the appropriate retention period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it (and whether we can achieve those purposes through other means), and the applicable legal requirements. In some circumstances we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information.” | Captured 2026-06-08Open source →Finding permalink → |
| Data retention | All applicable tiers | medium | “Upon expiration of the applicable retention period we will securely destroy your Personal Information in accordance with applicable laws and regulations.” | Captured 2026-06-08Open source →Finding permalink → |
| Data retention | All applicable tiers | medium | “ Deidentified Information We may at times receive, or process Personal Information to create, deidentified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “We may also share Personal Information with our Enterprise Customers as part of the Services we provide to them. During the course of our business we may also share with third parties aggregated demographic and/or statistical information that is not personally identifiable.” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- to use third-party service providers to send and distribute e-mail and to perform other marketing and support functions on our behalf or otherwise to assist us in providing our Services to you;” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- As necessary or appropriate to protect the rights, property or safety of us, our Customers or others” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company;” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | low | “• Service providers” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “If you reject the invitation to join Warmly, please refer to the Do Not Sell/Do Not Share section of our Privacy Policy to learn how to request the removal of your information via this link: https://warmly.ai/p/removal .” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | low | “- in situations where sharing or disclosing your information is required in order to provide you with information that you have requested;” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- in response to a law enforcement agency’s request;” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “ The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please email us at privacy@warmly.ai . ” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | low | “In the preceding twelve (12) months, disclosed to third parties the following categories of Personal Information for a business purpose:” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- to another entity as part of a merger, bankruptcy, insolvency, receivership, a sale of assets or all or part of a business, or any other corporate change or re-organization; or” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- to a third party or parties, where you consent to such disclosure or disclosure is required or permitted by law.” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- in connection with a legal action or other proceeding, including without limitation, in response to a court order or a subpoena;” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | low | “ We may also disclose your Personal Information:” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | low | “ Except as disclosed in this Privacy Policy, we do not share, rent, or sell Personal Information you have given us to any third party. This section describes the subset of Personal Information we share with partners, customers, and service providers, or for legal, corporate, or compliance purposes.” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- CRM information . We offer enhanced functionality to organizations who opt in to providing us with access to their CRM Application. Please note that our enterprise customers may choose to permit or restrict CRM integration access at the enterprise level. Please contact privacy@warmly.ai for more information.” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- to a person who in our reasonable judgment is seeking the information as an agent of the individual or company;” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | low | “- to process payments” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | low | “We have disclosed Personal Information for a business purpose to the following categories of third parties in the past 12 months:” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- to protect the rights, property, and safety of Warmly and our agents, customers, or others;” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, or any other transaction in which Personal Information held by us is among the assets transferred or constitutes relevant information for evaluation of the transaction” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “To Comply with Legal Obligations. We will process your Personal Information when necessary to comply with legal and regulatory obligations or defend claims. For example, we may share your Personal Information in response to a court order, subpoena, or law enforcement agency's request.Retention of InformationWe will only keep your Personal Information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.” | Captured 2026-06-08Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “ We may provide your Personal Information to service providers or contractors to perform functions on our behalf, including, but not limited to, communicating news; web hosting; information technology and related infrastructure (such as cloud computing); performing Site or Services development or maintenance; providing functionality or other services for our Site and our Services; security and other auditing; sending postal mail, email or other communications; customer service; removing outdated and repetitive information from our lists; analyzing our data; developing, enhancing, marketing or providing any of our Services; processing payments; order fulfillment; or assisting us with other marketing and support functions. These third party providers are required not to use your Personal Information other than to provide the services requested by us.” | Captured 2026-06-08Open source →Finding permalink → |
Informational only, not legal advice. Terms can change; verify every cited source and capture date during procurement review.
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