Privacy Policy

Last updated September 24, 2026

This Privacy Policy explains how Holztrager Enterprises LLC, doing business as Gamma 91 (“Gamma 91,” “we,” “us,” or “our”), collects, uses, and shares personal information, and the choices and rights available to you.

This policy should be read together with our Terms of Use. Capitalized terms not defined here have the meanings given in the Terms of Use.

1. Who We Are

Gamma 91 is a managed website service for businesses. We design, build, host, and update websites for our business customers, who request changes through our client portal, AI Concierge, and authorized email channels. Gamma 91 is operated from the United States. You can reach us about privacy matters at legal@gamma91.com.

2. Scope of This Policy & Our Role

This Privacy Policy applies to personal information we collect through:

• Our website and platform: gamma91.com, client portals, dashboards, and AI Concierge interfaces;
• Our services: building, hosting, and updating websites for our customers;
• Communications: emails, text messages, calls, and requests sent to us, including change requests from you and your Authorized Senders; and
• Business development: research and outreach to businesses that may benefit from our services.

When we act as a controller: For information about our customers, their authorized users, prospective customers, and visitors to gamma91.com, Gamma 91 decides how and why the information is processed and is responsible for it under this policy.

When we act as a processor or service provider: When you visit or submit a form on a website that Gamma 91 builds or hosts for one of our business customers, that business controls the collection and use of your information, and its own privacy policy applies. We process that information only on the customer’s behalf and according to its instructions. If you have questions about, or want to exercise rights over, information collected through a customer’s website, please contact that business directly. We will assist our customers in responding to such requests.

3. Information We Collect

A. Information you provide to us

• Account and identity information: name, email address, telephone number, business name, role, login credentials, and multi-factor authentication settings.
• Verification information: a verified mobile phone number and a payment card on file when you request a complimentary demo.
• Billing information: billing name and address, plan details, and transaction history. Payment card details are collected and processed directly by our third-party payment processor. Gamma 91 does not store full payment card numbers or security codes.
• Website and brand content: text, photographs, graphics, logos, business details, operating hours, domain names, and design preferences you provide to build or update your website.
• Requests and communications: AI Concierge conversations, text intake briefs, transcripts, emailed change requests from you and your Authorized Senders, and support inquiries.
• Voice recordings: if you submit a voice intake brief or voice request, we store the audio recording separately from its transcript, and use it to understand and carry out your request and to provide support.

B. Information collected automatically

• Device and technical information: IP address, browser type, operating system, device identifiers, and language preferences.
• Usage information: pages viewed, features used, timestamps, and referring URLs within our website and portal.
• Security information: bot-verification results and related browser and device signals used to prevent abuse and automated attacks.

C. Information processed through customer websites

• Form submissions: the fields a visitor submits through a form on a customer’s website (such as name, email address, phone number, and message), which we deliver to the recipients the customer designates.
• Traffic and hosting logs: request logs, including IP addresses, pages requested, and referrers, used to deliver and secure the website and to provide customers with aggregated traffic summaries.

D. Information from public and third-party sources

• Onboarding research: content from your existing website and public online listings, gathered to help design and build your new website.
• Business development: business contact information, such as business names, websites, public listing details, and business email addresses, collected from publicly available sources and business data providers, and verified through email verification services, to identify businesses that may benefit from our services and to contact them.

We do not intentionally collect sensitive personal information, and our Terms of Use prohibit customers from using the services to collect health, financial account, payment card, student, children’s, or other regulated data.

4. How We Use Information

We use personal information to:

• Create, host, update, and deliver websites and related media;
• Carry out requests submitted through the AI Concierge, portal, and authorized email;
• Create and secure accounts, verify identity, and enforce multi-factor authentication;
• Process payments, manage subscriptions, and monitor usage limits;
• Provide customer support and communicate with you about your account and requests;
• Research and contact businesses that may be interested in our services;
• Detect, prevent, and investigate fraud, abuse, security incidents, and violations of our Terms of Use and Acceptable Use Policy;
• Maintain, troubleshoot, and improve our services; and
• Comply with legal, accounting, and tax obligations and enforce our agreements.

Legal bases (EEA and UK): Where the GDPR or UK GDPR applies, we rely on the following legal bases: performance of a contract (to provide the services you request); our legitimate interests (to secure and improve our services, prevent fraud, and conduct business-to-business outreach, balanced against your rights); your consent (where we ask for it, such as for certain text messages, which you may withdraw at any time); and compliance with legal obligations.

5. Artificial Intelligence Processing

Gamma 91 uses artificial intelligence and machine-learning services to interpret requests, generate and update website content and code, and evaluate images and other media.

• Information sent to AI providers: To carry out requests, we send relevant information to third-party AI providers, which may include request text, transcripts, voice recordings, website content, uploaded media, and business details.
• Model training by AI providers: Depending on their terms, AI providers may retain information we send them and use it to train, develop, and improve their models and services. Gamma 91 does not control how AI providers use this information under their own terms and privacy policies.
• Please avoid sensitive information: Do not include sensitive or confidential personal information in requests, uploads, or voice briefs. Regulated data is prohibited under our Terms of Use.
• Human review: Staff may review requests and outputs to provide support, improve quality, and prevent abuse.
• Your responsibility: AI-generated changes can contain errors. Please review updates to your website for accuracy.

6. How We Share Information

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

• Service providers: vendors that process information to provide services to us, in the following categories: cloud hosting and content delivery; database, storage, and authentication; artificial intelligence and machine-learning services; payment processing and billing; email and text message delivery and routing; media processing; web data collection and business research; email verification; and communication and outreach tools. Some providers, including AI providers, may also use information under their own terms, as described in Section 5. A current list of our subprocessors is available to customers on request at legal@gamma91.com.
• At a customer’s direction: for example, delivering form submissions to the recipients a customer designates, or connecting third-party tools a customer asks us to embed on its website.
• Legal and safety: to comply with law, regulation, subpoena, or court order, or to protect the rights, property, or safety of Gamma 91, our customers, or others.
• Business transfers: in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, subject to this policy.
• With your consent: in other cases where you ask or agree to us sharing your information.

7. Data Security

No method of transmitting or storing information over the internet is completely secure, and we cannot guarantee the security of personal information. You provide information at your own risk. You are responsible for keeping your account credentials secure and your list of Authorized Senders up to date, and for notifying us promptly at legal@gamma91.com if you believe your account has been compromised.

8. Data Retention & Deletion

We keep personal information only as long as needed for the purposes described in this policy, including:

• Active accounts: account information, website content, media, request history, voice recordings, and form submission records are kept while your subscription is active.
• Cancelled accounts: we may keep an archived copy of your website, Client Content, request history, and voice recordings for up to one (1) year after cancellation, so you can reactivate or request a copy of your content. Accounts that reached the 36-month milestone may download their complete, standalone static source code package before de-provisioning, as described in the Terms of Use. After the retention period, we may permanently delete this data.
• Complimentary demos: demos and related information may be deleted if you do not subscribe.
• Business development records: kept while they remain relevant to our outreach, and removed or suppressed when you ask us to stop contacting you.
• Records we must keep: billing, tax, and transaction records, and information needed to resolve disputes, enforce agreements, or meet legal obligations, may be kept longer as required or permitted by law. Backups are overwritten on a rolling basis.

You may request deletion of your account and personal information at any time by emailing legal@gamma91.com, subject to the exceptions above.

9. Cookies, Local Storage & Third-Party Embeds

• Essential cookies and local storage: used to keep you signed in, remember your selected organization, secure your session, and remember basic preferences.
• Security and bot detection: we evaluate browser and device signals to prevent automated abuse, without cross-site tracking cookies.
• No advertising trackers: we do not use third-party advertising pixels or data-broker cookies on our website or platform.
• Third-party embeds: some pages include tools provided by other companies, such as our meeting scheduler. When you open or use an embedded tool, its provider may set its own cookies and collect information under its own privacy policy.

You can control cookies through your browser settings, but disabling essential cookies may prevent you from signing in or using parts of the services.

10. Marketing Communications & Text Messages

Email: We may send business-to-business marketing emails, including to business contacts identified from public sources. Every marketing email includes an unsubscribe link, and you can also opt out by emailing legal@gamma91.com. We will still send transactional and account-related messages to customers.

Text messages: If you provide a mobile number, we send verification codes and service-related messages about your account and requests. We do not send marketing text messages without your separate consent. Message and data rates may apply. Reply STOP to opt out or HELP for help. We do not share mobile numbers or text messaging opt-in data with third parties for their own marketing purposes.

11. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding your personal information:

• Access and portability: to know what personal information we hold about you and receive a copy;
• Correction: to correct inaccurate or incomplete information;
• Deletion: to ask us to delete your personal information, subject to legal exceptions;
• Restriction and objection: to limit or object to certain processing, including processing based on legitimate interests and direct marketing;
• Opt-out: to opt out of the sale of personal information, sharing for cross-context behavioral advertising, targeted advertising, and certain profiling. We do not engage in these activities;
• Withdraw consent: where processing is based on consent, without affecting earlier processing; and
• Non-discrimination: we will not discriminate against you for exercising your rights.

How to make a request: Email legal@gamma91.com. We will verify your identity before acting on a request, and we may ask for information to do so. You may use an authorized agent, who must provide proof of their authority. We respond within the time required by applicable law, generally within 45 days (or one month in the EEA and UK), and may extend this where the law permits.

Appeals: If we decline your request, you may appeal by replying to our decision or emailing legal@gamma91.com with “Privacy Appeal” in the subject line. We will respond to your appeal within the time required by law. If you are not satisfied, you may contact your state attorney general or, in the EEA and UK, your local data protection authority.

12. U.S. State Privacy Notices

Residents of California, Virginia, Colorado, Connecticut, Tennessee, and other states with comprehensive privacy laws may have the rights described in Section 11, to the extent those laws apply to Gamma 91. In the past twelve (12) months, we have collected the following categories of personal information, from the sources described in Section 3, and disclosed them for business purposes to the categories of service providers described in Section 6:

We retain each category for the periods described in Section 8. We do not sell personal information or share it for cross-context behavioral advertising, and we have not done so in the past twelve (12) months. We do not use or disclose sensitive personal information for purposes that would require offering a right to limit it.

Global Privacy Control: We honor Global Privacy Control (GPC) signals as a request to opt out of the sale or sharing of personal information for the browser or device that sends them. Because we do not sell or share personal information, no further action is required.

13. International Data Transfers

Gamma 91 is based in the United States, and our service providers may process information in the United States and other countries. These countries may have data protection laws that differ from those where you live. Where required, we rely on appropriate safeguards for international transfers, such as Standard Contractual Clauses.

14. Children’s Privacy

Gamma 91 is a business service and is not directed to anyone under eighteen (18). We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will delete it promptly. If you believe a child has provided us with personal information, please contact legal@gamma91.com.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will revise the “Last updated” date above, and if a change is material, we will notify customers by email or through the client portal before it takes effect.

16. Contact Information

Gamma 91 is a trade name of Holztrager Enterprises LLC. For privacy questions, requests, or legal notices, please contact:

• Email: legal@gamma91.com
• Mail: Holztrager Enterprises LLC, 9111 Cross Park Dr, D200-292, Knoxville, TN 37923