Effective Date: July 30, 2025
REVNGN, LLC (“we,” “our,” “us”) provides marketing automation, CRM configuration, and bulk communications services to business clients.
This notice explains how we collect, use, share, and protect personal data when we act as a data controller for our own marketing and as a data processor on behalf of clients. It satisfies the California Consumer Privacy Act as amended by CPRA, GDPR, and the eight new state privacy laws taking effect in 2025 (Delaware, Iowa, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Tennessee). fisherphillips.com
| Category | Examples | Purpose | Legal basis |
|---|---|---|---|
| Contact | Name, email, phone | Account creation, service notices | Contract |
| Billing | EIN, postal address, payment token | Invoicing, fraud prevention | Contract, Legal obligation |
| Usage | IP address, browser, event logs | Security, analytics | Legitimate interest |
| Campaign Data (processor role) | Lists, message content, consent records | Deliver SMS, email, voice | Client instructions |
We do not knowingly collect data from children under 13.
Provide and improve services
Authenticate users
Prevent abuse, spam, and fraud
Comply with carrier 10DLC requirements and law enforcement requests springbig.com
We share data only with vetted subprocessors that enable our platform, currently:
Twilio, Mailgun, Google Cloud (hosting), GoHighLevel (SaaS), and Atlassian (support). Each subprocessor is bound by a DPA and industry-standard security controls.
Where applicable, individuals may access, delete, correct, or export their data and object to certain processing. Submit requests at privacy@revngn.com. We verify identity before acting.
We rely on the EU-US Data Privacy Framework or Standard Contractual Clauses as appropriate.
Contact and billing records: 7 years. Messaging logs: 24 months. Opt-in proof: minimum 6 years to satisfy TCPA look-back.
We follow NIST SP 800-53 controls, encrypt data in transit (TLS 1.3) and at rest (AES-256).
We may update this notice; the footer date reflects the latest revision. Material changes are announced by email 30 days in advance.