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PRIVACY POLICY

Last updated: [date]

1. Who this covers

This policy is from [Company legal name] ("we", "us"), [business address], contact [contact email]. It explains how we handle personal information in two different roles:

- As a controller (the party that decides why and how the data is used) of information about the people who use our Service and manage accounts: our customers' administrators and users, and visitors to our sign-up pages.
- As a processor or service provider (acting only on a customer's instructions) of the contact records our customers upload. For that data, the customer decides what is collected and why, and the customer's own privacy notice applies.

"Service" and other defined terms have the meaning in our Terms of Service.

2. What we collect about account users

- Account details: name, email address, company name, and a hashed password (we never store the password itself).
- Billing details: the plan you choose and invoices. Card details are collected and stored by Stripe, not by us. We keep Stripe's customer and subscription identifiers.
- Technical and security data: IP address, browser information, sign-in times, failed sign-in attempts, and session records.
- Usage data: actions in the Service, such as searches, imports, exports and administrative changes, kept as an activity log for security, support and billing (for example, the number of contacts stored).
- Legal acceptances: which version of the Terms and Privacy Policy you accepted, when, and from which IP address.
- Messages: your support requests and the service emails we send you.

We use this to create and run your account, take payment, secure the Service, prevent abuse, send service notices (verification, billing, deletion warnings), give support, meet legal duties, and improve the Service. We do not sell personal information and we do not use it for third-party advertising.

3. Data we process for customers

Customers upload contact records, which can include names, addresses, phone numbers, email addresses and sensitive identifiers such as Social Security numbers and employer identification numbers. We process this only to provide the Service to that customer, under our Terms. Each customer's data is kept in a separate database, and SSNs and similar identifiers are encrypted at rest. We do not use one customer's data for another customer, and enrichment matches only against the customer's own contacts.

The customer is responsible for having the right to collect and upload the data and for any notices and consents owed to the people in it. If you are an individual in a customer's data and want to see, correct or delete it, or opt out of contact, please contact that customer. If you write to us, we will pass the request to the customer, because we cannot act on their data on our own.

4. Who we share data with

We share information only with service providers who help run the Service, under written terms that restrict their use:

- Stripe, Inc. for payment processing;
- [hosting provider] for servers, databases and file storage;
- [email provider] for sending service emails.

We may also disclose information if the law requires it, to protect rights and safety, or in a merger or sale of the business, with notice to affected customers. We do not disclose Customer Data to third parties other than the service providers listed above.

5. Cookies

We use a single session cookie that keeps you signed in. It is needed for the Service to work, it is not readable by scripts on the page (HttpOnly), and it expires after its set lifetime or when you sign out. We do not use advertising, analytics or tracking cookies. If this changes, we will update this policy first.

6. Retention

- Account data is kept while your account is active.
- When a customer cancels, the account is read-only until the paid period ends, then its data is kept for 30 days (exportable on request), then deleted. Backups are kept for up to 14 days, so deleted data leaves backups within 14 days of deletion.
- Billing and tax records, and records of legal acceptances, are kept for as long as the law and our record-keeping needs require.
- Security and activity logs are kept for as long as needed for security and support, then deleted.

7. Security

We protect information with measures that include a separate database per customer, encryption at rest for SSNs and similar identifiers, encryption in transit, access controls and sign-in limits. No method is perfectly secure, and we do not claim any security certification. If a breach affects customer data, we will notify the affected customer's administrators, and we will notify you where the law requires.

8. Your rights

Depending on where you live, you may have the right to access, correct, delete or get a copy of the personal information we hold about you as an account user, to object to or restrict some uses, and to not be discriminated against for using these rights. To use them, email [contact email] from the address on your account. We may need to verify your identity, and we will respond within the time the law requires (generally 45 days). If we cannot do what you ask, we will say why. You can also complain to your state attorney general or other regulator.

For data we hold on a customer's behalf, see section 3.

9. Where data is stored

We operate in the United States and data is stored there. [Attorney to confirm the wording on international transfers if the Service is offered outside the United States.]

10. Children

The Service is for businesses and is not directed to anyone under 18. We do not knowingly collect information from children.

11. Changes

We may update this policy. We will post the new version in the Service and, for material changes, tell your administrators by email before it takes effect. The version number and the date you accepted it are on record.

12. Contact

[Company legal name], [business address], [contact email].