CICERO 1

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LEGAL

Privacy Policy

How Caesar collects, uses, shares and protects personal information. Effective date: October 26, 2026

Summary. This summary is for convenience only; the full policy governs.

  • We decide how information is used for our merchants, affiliates, website visitors and business contacts.
  • The store is in charge of the data of shoppers who hear from a store that uses Caesar, and we process it for the store. See Section 2.
  • We don't sell personal information or share it for targeted advertising, and we don't share mobile numbers or text-message opt-in data with anyone for their own marketing.
  • We don't let AI providers train their models on messages or shopper data.
  • You can ask to access, correct or delete your information at [email protected].

1. Who we are and what this policy covers

1.1 Who we are. Caesar is operated by iSend LLC, a Wyoming limited liability company, 30 N Gould St, Ste R, Sheridan, WY 82801, USA ("Caesar", "we", "us").

Caesar is an AI sales agent for online stores. A merchant connects its Shopify store and activates the agent, which then messages the store's shoppers on the merchant's behalf, over iMessage, SMS and RCS, to recover abandoned checkouts and sell follow-on products.

1.2 When we are responsible for your information. We are the "controller" (or "business") for personal information about:

  • merchant account holders and their team members: people who sign up for and use Caesar for a business;
  • members of our affiliate program: people and agencies who refer merchants to Caesar;
  • visitors to our websites (caesar.io and panel.caesar.io);
  • business contacts and prospects: people who contact us, book a demo, join our mailing list or attend our events, and business contacts we find through business data sources;
  • people who contact us directly, for example to report abuse or make a privacy request;
  • records we keep to prevent abuse and honor opt-outs across our platform: opt-out and do-not-contact records, Message-Delivery Logs and abuse reports (see Section 3.7).

1.3 When the merchant is responsible. When a merchant uses Caesar to message its shoppers, the merchant is the controller (or "business") for the shoppers' information, and Caesar is its processor (or "service provider"). We process that information only on the merchant's instructions, under our Data Processing Addendum. The merchant's own privacy policy describes how it uses shopper information.

2. If you received a message from a store that uses Caesar

  • To stop messages, reply STOP to any message.
  • To access, correct or delete your information, contact the store that contacted you. It decides how your information is used. If you contact us instead, we'll pass your request to the store and help it respond.
  • What we process for the store usually includes your name, phone number, email address, shipping address, the products you view on the store, the items in your cart or order, and the messages you exchange. The store uses Caesar to text you about abandoned carts, your orders and its offers. Section 5 explains how AI is used.
  • If you never agreed to hear from the store, or a message looks like spam, email [email protected] with "Abuse report" in the subject line. We review every report and can block your number from further messages through Caesar. To do this, we keep a record of numbers that reported abuse or asked not to be contacted.

3. Information we collect

3.1 Account and business information. This includes:

  • name, work email, phone number and job role;
  • sign-in credentials (handled by our authentication provider);
  • business name, legal name, website and store domain;
  • business address;
  • tax ID (EIN), and ownership or management details where we need them for verification or carrier registration.

3.2 Verification and compliance information. This includes:

  • the results of identity-verification and sanctions-screening checks;
  • information submitted for carrier and messaging-channel registrations (for example, US A2P 10DLC);
  • the compliance statements you make;
  • records of your acceptance of our terms and policies: who accepted, when, from which IP address, which versions, and the pricing shown.

3.3 Billing information. This includes billing contact details, payment history, invoices and fee records. Payment card details are collected and stored by our payment processor, Stripe. We receive only limited details, such as card type, last four digits and expiry date.

3.4 Store connection information. This includes your store domain, the access tokens and permissions you grant when you connect Shopify or other integrations, and configuration settings.

3.5 Usage and device information. This includes:

  • IP address and approximate location derived from it;
  • browser and device type;
  • the pages you view and the actions you take on our websites and in the Dashboard;
  • log data;
  • information from cookies and similar technologies (see our Cookie Policy).

3.6 Communications. This includes emails, chat and support messages, feedback, meeting notes and survey responses. If we record a call with you, we tell you at the start.

3.7 Compliance and safety records. This includes Message-Delivery Logs (which record when and how each message was sent, but not what it said), opt-out and do-not-contact records, abuse reports, account actions and configuration history. We keep these to run the service securely, prevent abuse, honor opt-outs and show how messages were sent.

3.8 Affiliate program information. If you join our affiliate program, we collect:

  • your name, email, phone number and company;
  • your referral codes and links, and the clicks and signups they generate (including IP address and device information);
  • your payout details (such as bank or payment-account details);
  • tax forms (such as IRS Form W-9 or W-8, which include your tax identification number);
  • your commission and payout history.

3.9 Demo booking. When you book a demo on our website, our scheduling tool, iClosed (provided by You Scale LLC), collects your name, email, phone number, company and your answers to the booking questions. It may capture what you type into the booking form even if you don't finish submitting it.

3.10 Information from others. We may receive information about you from:

  • your store platform (such as Shopify), when you connect it;
  • Stripe;
  • verification and sanctions-screening providers;
  • carriers and The Campaign Registry (registration outcomes);
  • members of our affiliate program who refer you;
  • business data providers and publicly available business sources, such as company websites and professional profiles.

4. How we use information, and our legal bases

PurposeExamplesLegal basis (where the GDPR or UK GDPR applies)
Provide the serviceCreate and run your account, connect your store, operate campaigns, provide supportPerformance of our contract with you
BillingCalculate fees, charge your payment method, handle disputes and refundsPerformance of contract; legal obligation (tax and accounting)
Run the affiliate programTrack referrals, calculate and pay commissions, collect tax forms, prevent referral fraudPerformance of contract; legal obligation (tax); legitimate interests
Verification and complianceVerify businesses and payees, screen against sanctions lists, register brands with carriers, keep acceptance and opt-out recordsLegal obligation; legitimate interests in operating a lawful, trusted service
Security and abuse preventionDetect fraud, spam and misuse; protect message recipients, carriers and our systems; enforce our policiesLegitimate interests; legal obligation
Improve our serviceUnderstand usage, fix bugs and develop features, using de-identified or aggregated data where possibleLegitimate interests
Communicate with youService and security notices, policy updates, answers to your questionsPerformance of contract; legitimate interests
Sales and marketing to businessesNewsletters, product news, event invitations and sales outreach to business contacts by email; by phone or text only where you've given us permission. You can opt out at any timeLegitimate interests, or consent where required
Legal mattersComply with law, respond to lawful requests, establish or defend legal claimsLegal obligation; legitimate interests

Where we rely on legitimate interests, we have balanced those interests against your rights. Where we rely on consent, you can withdraw it at any time.

5. AI processing

Caesar uses third-party AI model providers (currently Anthropic) to write the Agent's messages and replies. To write a reply, we send the provider the limited context it needs, such as a shopper's first name, the items in their cart and its total, a checkout link and the conversation so far. This context is designed to leave out phone numbers, email addresses or payment details, apart from anything a shopper writes in the conversation themselves.

  • Our AI providers act as our subprocessors. Their contracts don't let them use this data to train their models.
  • We don't use message content, or identifiable merchant or shopper data, to train AI models that are shared with other customers, unless the merchant opts in to a program that says so.
  • We may use de-identified and aggregated insights, such as reply rates or common questions, to improve our service.
  • For our own purposes, we don't make decisions that have legal or similarly significant effects on anyone solely by automated means. We use automated tools to flag possible fraud or abuse, and a person promptly reviews any automated suspension of an account.

6. How we share information

We do not sell personal information, and we do not share it for targeted (cross-context behavioral) advertising. We share it only as follows:

  • Service providers and subprocessors that help us run Caesar, for example for hosting, authentication, AI generation, message delivery, email, payments and scheduling. They may use the information only to provide their services to us. Our current Subprocessor List names them.
  • Messaging networks, carriers and registries, such as Apple (for iMessage), mobile carriers and their vendors, and The Campaign Registry. We share what they need to deliver messages and to register senders.
  • Your store platform and connected tools, as needed for the features you turn on.
  • Payment and payout processors, to process payments and affiliate payouts and to prevent fraud.
  • Verification and sanctions-screening providers, to verify businesses and payees and meet our legal obligations.
  • Members of our affiliate program. If a merchant joined Caesar through a member of our affiliate program, we share limited information with that member: the merchant's business name, signup date, account status, and the amounts the affiliate has earned from that merchant's account. We never share shoppers' data or conversations with affiliates.
  • Professional advisers, such as lawyers, accountants and auditors, under a duty of confidentiality.
  • Tax authorities, for example to report affiliate payments where the law requires.
  • Authorities and others where required, to comply with law or legal process, respond to lawful requests, enforce our terms, or protect the rights, safety and security of Caesar, our users, message recipients or others.
  • Business transfers. In a merger, acquisition, financing or sale of assets, information may transfer to the new owner, subject to this policy.
  • With your consent or at your direction.

Text messaging data. We do not share mobile phone numbers or text-message opt-in data and consent with third parties or affiliates for their marketing or promotional purposes. We share them only with the providers that help us deliver messages, and only for that purpose.

Advertising cookies. Our websites don't use advertising cookies or pixels. If that changes, we'll first update this policy and our Cookie Policy, provide a way to opt out, and honor opt-out preference signals such as Global Privacy Control.

7. International transfers

Caesar is based in the United States. We and our providers process information in the United States and in other countries where our providers operate. When we receive personal information from the European Economic Area, the United Kingdom or Switzerland, we protect it with the European Commission's Standard Contractual Clauses (and the UK and Swiss equivalents) or another lawful transfer mechanism. Contact us for more information about these safeguards.

8. How long we keep information

We keep information only as long as we need it for the purposes in this policy, and then delete or de-identify it.

InformationHow long we keep it
Account and profile informationWhile your account is open, and up to 3 years after it closes
Billing and tax records, including affiliate payout records and tax forms7 years after the transaction
Acceptance records, Message-Delivery Logs and records of the consent status we received5 years after the relationship ends
Opt-out and do-not-contact records5 years after the relationship ends. We keep the number and opt-out date for as long as needed to keep honoring the opt-out
Compliance and safety records (abuse reports, enforcement actions, configuration history)5 years after the relationship ends
Verification and sanctions-screening records10 years after the relationship ends, as sanctions record-keeping rules require
Support communications3 years after the request is closed
Demo-booking and sales-lead information2 years after our last contact, or until you ask us to delete it
Security logsUp to 12 months, unless needed for an investigation
Marketing preferencesUntil you unsubscribe; after that we keep a suppression record so we don't contact you again
Shopper data we process for merchantsAs the merchant instructs and under the DPA. While the store uses Caesar, we delete a shopper's personal details 2 years after their last activity with the store (a message, an order or a store visit), or sooner if the store asks. When the store's account closes, we delete it all within 90 days, or sooner if the store platform requires it. Backups are overwritten within 30 days after that

We may keep information longer if the law requires it, or to establish or defend legal claims.

9. Security

We use administrative, technical and organizational safeguards designed to protect personal information, including encryption in transit and at rest, least-privilege access controls, multi-factor authentication for our team's access to production systems, logging and monitoring, and vendor reviews.

No system is completely secure, so we can't guarantee absolute security. If we learn of a security incident that affects your personal information, we'll notify you as the law requires.

10. Your rights and choices

10.1 Your rights. Depending on where you live and which laws apply to us, you may have some or all of these rights:

  • to know and access the personal information we hold about you;
  • to correct inaccurate information;
  • to delete your information;
  • to port (get a copy of) your information;
  • to object to or restrict certain processing;
  • to opt out of the sale or sharing of personal information, targeted advertising and certain profiling;
  • to limit our use of sensitive personal information;
  • to withdraw consent where we rely on it;
  • to appeal our decision on your request.

10.2 How to exercise them. Email [email protected] with "Privacy Request" in the subject line. We'll verify your identity before we act on the request, for example by confirming that you control the email address on your account. You may use an authorized agent where the law allows, and we may ask for proof of the agent's authority. We respond within the time the law requires, generally 30 to 45 days, and we may extend this where the law allows.

10.3 Appeals. If we decline your request, you can appeal by replying to our decision, or by emailing [email protected] with "Privacy Appeal" in the subject line. If you're still not satisfied, you may contact your state attorney general or, in the EEA, UK or Switzerland, your data protection authority.

10.4 No discrimination. We won't treat you differently for exercising your privacy rights.

10.5 Marketing. You can unsubscribe using the link in any marketing email, or reply STOP to any text from us. We'll still send you service messages about your account.

10.6 Cookies. You can manage cookies as described in our Cookie Policy.

10.7 Shopper requests. If your request is about messages you received from a store, see Section 2.

11. Notice for US state residents

This section adds to the rest of the policy for residents of US states with consumer privacy laws, including the California Consumer Privacy Act as amended by the CPRA.

11.1 What we collect. In the past 12 months we have collected the following categories of personal information:

CategoryExamples
IdentifiersName, email, phone number, IP address, account ID, referral code
Customer recordsBusiness name and address, billing and payout details
Commercial informationTransaction, fee and affiliate payout history
Internet or network activityWebsite and Dashboard usage, referral clicks, log data
Approximate geolocationDerived from IP address
Professional informationJob role, business ownership details
Audio informationRecordings of calls with us, where we tell you the call is recorded
Sensitive personal informationAccount login credentials; tax identification numbers from affiliate tax forms; government-issued identifiers where needed for verification

We collect these from the sources in Section 3, use them for the purposes in Section 4, disclose them to the recipients in Section 6, and keep them for the periods in Section 8.

11.2 Sale and sharing. We don't sell personal information or share it for cross-context behavioral advertising. We don't knowingly sell or share the personal information of anyone under 16.

11.3 Sensitive information. We use sensitive personal information only for the purposes the law permits, such as providing the service, security, verification and tax reporting. We don't use it to infer characteristics about you.

11.4 Shoppers' information. For shoppers' information, we act as the merchant's service provider or processor. Send requests to the merchant (see Section 2).

12. Children

Caesar is a service for businesses and is not directed to children. We don't knowingly collect personal information from children under 16. If you believe a child has given us personal information, contact [email protected] and we'll delete it. Merchants must not use Caesar to message anyone under 18.

13. Links and third-party services

Our websites and service link to, or connect with, third-party services such as Shopify, Stripe, iClosed and Apple. Their own privacy policies govern how they handle your information.

14. Changes to this policy

We may update this policy. We'll post the new version with a new effective date and keep previous versions at caesar.io/legal. If the changes are significant, we'll give you additional notice, for example by email or in the Dashboard.

15. Contact us

  • Privacy questions and requests: [email protected] (subject "Privacy Request")
  • Mail: iSend LLC (Caesar), Attn: Privacy, 30 N Gould St, Ste R, Sheridan, WY 82801, USA

EU and UK representatives. We are appointing representatives for people in the European Union and the United Kingdom, as the GDPR and UK GDPR require, and will list their contact details here. Until then, contact us at [email protected] with "EU/UK privacy" in the subject line, and we will respond directly.

If you are in the EEA, UK or Switzerland, you also have the right to lodge a complaint with your local data protection authority.