# Privacy Policy Version 2026-05-15 · template document — the operating company must review before treating this as a filed policy. ## 1. Who is responsible This Privacy Policy explains how **[Operating company legal name]** ("we", "us") handles personal information ("PI") collected through the Service. For data submitted through our clients about your end users, we act as a **service provider** (under California CCPA/CPRA) and **processor** (under EU/UK GDPR). ## 2. Personal information we collect **Account data** — name, work email, workspace name, billing country, plan. **Usage data** — dashboard activity, IP address, user-agent for security and abuse prevention. **Support data** — what you send us when you contact support. **Workspace records** — the contents of your ledger live in your tenant; we only see aggregate run counts for billing and quota. We do not knowingly collect personal information from children under 16. We do not sell personal information, and we do not share it for cross-context behavioral advertising. ## 3. Categories under CCPA/CPRA Categories collected in the last 12 months: identifiers (name, email, IP), commercial information (subscription, billing records), internet activity (usage metrics, error logs), professional information (workspace, role). Sources: directly from you, from your use of the Service, and from Stripe for billing data when keys are live. We **do not** sell or share PI as those terms are defined under CCPA/CPRA. ## 4. Your rights under CCPA/CPRA (California) If you are a California resident, you have the right to: - **Know** what PI we hold about you and how we use it; - **Delete** your PI, subject to legal-retention exceptions; - **Correct** inaccurate PI; - **Opt-out** of sale or sharing — N/A, we don't do either; - **Limit** the use of sensitive PI — N/A, we don't process sensitive PI; - **Non-discrimination** for exercising your rights. To exercise rights, email privacy@intramedial.com from the address on your account. ## 5. Your rights under GDPR (EU / UK / EEA) If you are in the EU, UK, or EEA, you have the right to access, rectify, erase, restrict, port, and object to the processing of your personal data, and to lodge a complaint with your local data protection authority. Lawful bases we rely on: performance of the contract (Art. 6(1)(b)), our legitimate interest in operating the Service securely (Art. 6(1)(f)), compliance with legal obligations (Art. 6(1)(c)), and your consent for non-essential analytics (Art. 6(1)(a)) which you can withdraw at any time. ## 6. Where we store data **Your records and content** reside with Cloudflare (Workers, D1, R2, KV, Durable Objects, Queues, Vectorize, Workflows, Workers AI) in the region selected for the workspace. AWS Object Lock witness, Stripe, and Resend are not processing customer data on this fleet yet — see [/.well-known/sub-processors.json](/.well-known/sub-processors.json). **International transfers.** Where personal data of EU/UK individuals is processed by US sub-processors, transfers rely on the EU Standard Contractual Clauses with additional technical and organizational measures. ## 7. Sub-processors See [/.well-known/sub-processors.json](/.well-known/sub-processors.json). We notify customers of changes [notice period] in advance. ## 8. Retention [State the retention period for each category: account data, support tickets, workspace records per plan, and billing records.] ## 9. Cookies We use one essential cookie for authentication. We do not use advertising cookies. ## 10. Security We protect personal information with technical and organizational measures appropriate to the risk: encryption in transit and at rest, workspace-scoped access tokens, append-only hash-linked records where enabled, least-privilege access. See [/security](/security). ## 11. Changes We may update this Policy. Material changes will be notified by email to the account owner [notice period] before taking effect. ## 12. Contact privacy@intramedial.com · [Operating company legal name] · [Jurisdiction].