Privacy Policy — DRAFT
Effective: TBD
What we collect
- Account data: email, optional display name, Stripe Connect account ID.
- Conversation data ("Content"): the chat messages you upload via export ZIP or sync via the CLI / MCP.
- Operational data: timestamps, machine fingerprint (CLI installs only), audit log of significant actions.
What we do with it
- We scrub Content for PHI / PCI / government IDs at ingest. Matches are rejected and not retained.
- We redact third-party emails and phone numbers with stable hashes.
- We dedup, score, and label Content. We sell the resulting derived dataset (annotations, scores, labels — not raw outputs) to AI-lab buyers under contracts that prohibit using the data to train a model that competes with the source platform from which Content originated.
CCPA / CPRA (California)
- We are a "data broker" under Cal. Civ. Code §1798.99.80 and registered with the California Privacy Protection Agency.
- Right to know, delete, correct, and opt out of sale: visit selltraces.com/privacy/requests.
- "Do Not Sell or Share My Personal Information" link is available in the footer of every page.
GDPR (EU/UK)
- Lawful basis: consent (Art. 6(1)(a)) for upload + processing; contract (Art. 6(1)(b)) for payouts.
- Joint-controller relationship with downstream lab buyers — DPAs required before any transfer.
- Standard Contractual Clauses for cross-border transfers.
Retention
- Raw Content blobs: retained until user deletes account or 24 months, whichever comes first.
- Derived dataset entries: retained while licensed to lab buyers; we honor deletion requests by tombstoning user-specific records and removing them from future delivery.
Security
- All blobs encrypted at rest with per-trace keys.
- Auth tokens hashed at rest.
- SOC 2 Type II in progress.
Contact
privacy@selltraces.com · DMCA agent: [TBD]
TODO before launch: counsel review for: (i) actual CCPA broker registration filing, (ii) GDPR DPIA, (iii) retention schedule defensibility, (iv) breach notification obligations under FTC Health Breach Notification Rule.