Privacy Notice

Last updated: 2026-01-07

Data Controller: Axon Learning SAS (“Axon Learning”)
Brand / Service: Momentum Lead Solutions (“Momentum”)

1) Identity and Address of the Data Controller

Axon Learning SAS (“Axon Learning”), with registered address at Jilguero 6101, Residencial Los Canarios, Tamaulipas, Mexico, is responsible for the processing of personal data collected through the website, forms, and, where applicable, the Momentum platform.

General contact: contacto@momentumsms.com
Privacy / Legal (ARCO rights): legal@momentumsms.com

2) Personal Data We Collect

2.1) Single Form (early access / custom plans)

• Name (required)
• Email (required)
• Organization (optional)
• Phone number (optional)
• Channel (selection): Companies, e-Government, Politics
• Estimated users (optional)
• Approximate SMS volume (optional)
• Comments (optional)

2.2) Technical and Usage Data (website / app)

IP address, online identifiers, browser type, operating system, device, pages visited, interaction events, and performance metrics.

Identifiers associated with cookies or similar technologies (see Cookie Policy).

2.3) Account and Support Data (if the platform/app is enabled)

Account registration and administration data (e.g., email, name, roles/permissions), access and activity logs, error reports, and incident records.

2.4) Payments and Billing (if you contract a plan)

Billing data you provide (e.g., legal entity name, tax ID, fiscal address, and information required for invoicing).

Payment confirmations and references provided by the payment processor.

3) Sensitive Personal Data

Momentum does not request sensitive personal data through its forms.

However, due to the nature of the “Channel” field (for example, “Politics”) and the content a user may voluntarily enter in the “Comments” field, you may inadvertently share information considered sensitive (such as political opinions).

We recommend not entering sensitive personal data or third-party personal data in the comments field.

If, due to service requirements, sensitive data were to be processed, Axon Learning will apply enhanced security measures and request explicit consent where legally required.

4) Purposes of Processing

4.1) Primary purposes (necessary)

We use your personal data to:

• Register your early access, demo, or custom plan request.
• Contact you and follow up on your request.
• Provide customer support (inquiries, incidents, follow-up).
• Ensure website security and prevent abuse, fraud, or unauthorized access.
• Where applicable, create and manage your Momentum account and provide the service in accordance with the Terms and Conditions.

4.2) Secondary purposes (not necessary)

Additionally, we may process your data for:

• Marketing and commercial prospecting (news, releases, promotions).
• Analytics and measurement (to improve website experience, conversion, and performance).

Opt-out mechanism for secondary purposes:
You may object at any time by sending an email to legal@momentumsms.com with the subject line: “Objection to secondary purposes”.

5) Options to Limit Use or Disclosure of Your Data

In addition to ARCO rights and objection mechanisms, you may:

• Opt out of receiving commercial communications by emailing legal@momentumsms.com with the subject line “Unsubscribe from commercial communications”.
• Adjust cookie usage as described in the Cookie Policy and/or through your browser settings.

6) ARCO Rights (Access, Rectification, Cancellation, and Objection)

You may exercise your ARCO rights by submitting a request to legal@momentumsms.com, including:

• Full name of the data subject.
• Means to communicate the response (email).
• Clear description of the right you wish to exercise.
• Official identification of the data subject (or proof of representation, if applicable).
• Any information that facilitates locating the data (e.g., registered email).

Axon Learning will process requests in accordance with the timeframes and terms established by applicable Mexican law.

7) Revocation of Consent

You may revoke your consent at any time by emailing legal@momentumsms.com with the subject line “Revocation of consent”.
Revocation will not have retroactive effects and may prevent us from continuing to provide the service.

8) Transfers and Data Processors (Service Providers)

Your data may be shared with service providers that support Momentum operations, acting as data processors under Axon Learning’s instructions, including but not limited to:

• LabsMobile (messaging / SMS services, where applicable)
• Stripe (payment processing, where applicable)
• HostGator and/or AWS (infrastructure / hosting)
• Google Analytics 4 (GA4) (analytics)
• Meta (Pixel) (advertising measurement, if enabled)

Some providers may operate from other countries. Axon Learning seeks to ensure that such providers process data under safeguards consistent with this Privacy Notice.

Information may also be disclosed to competent authorities when legally required.

9) Cookies and Similar Technologies

Momentum uses cookies and similar technologies for operation, analytics, and advertising measurement (where applicable).
Please consult the Cookie Policy available in the legal section of the website.

10) Changes to the Privacy Notice

Axon Learning may modify this Privacy Notice at any time.
The current version will be published in the legal section of momentumsms.com, indicating the “Last updated” date.

11) Contact

Privacy / Legal (ARCO): legal@momentumsms.com
General contact: contacto@momentumsms.com

Address: Jilguero 6101, Residencial Los Canarios, Tamaulipas, Mexico

International Privacy Addendum (GDPR & CCPA)

This Privacy Notice also applies to international users and incorporates additional provisions to comply with:

• General Data Protection Regulation (GDPR) for individuals located in the European Union
• California Consumer Privacy Act (CCPA / CPRA) for residents of California, USA

Additional Rights

Where applicable, you may also have the right to:

• Request data portability (GDPR).
• Request restriction of processing (GDPR).
• Request deletion of personal data (“right to be forgotten”).
• Opt out of the sale or sharing of personal data (CCPA), noting that Momentum does not sell personal data.

Requests related to these rights may be submitted to legal@momentumsms.com.