Privacy Policy Changes

A versioned record of every material change to our Privacy Policy. We append entries here whenever the live policy changes; prior entries are not edited.

v3.0

Effective May 6, 2026

Legal-position update — CCPA "publicly available" carve-out, sharper LIA, factual non-data-broker position.

  • Section 3 reframed to lead with the CCPA Cal. Civ. Code §1798.140(v)(2) "publicly available information" carve-out. Scanned-profile data falls within the carve-out and is therefore outside CCPA's "personal information." Under GDPR there is no equivalent carve-out and we continue to treat scanned-profile data as personal data on Art. 6(1)(f) legitimate interest.
  • Section 3.4 sharpened the legitimate-interest balancing: creators have made their accounts public for the purpose of being discovered for business and creator-economy purposes, our processing supports that purpose, and we provide a self-service opt-out.
  • Section 7.1 rewrote the "sale" / "share" analysis: the carve-out means CCPA's sale rules do not attach to scanned-individual data; Customer data is personal information and is not sold. Opt-out at /legal/do-not-sell is honored as a matter of policy regardless of statutory characterization.
  • Section 16.5 added EU and UK Article 27 representative slots (placeholders pending appointment).
  • Section 17 restructured: 17.A California (with carve-out, sale/share status, SPI right to limit, DNSMPI link, GPC, non-discrimination, agents, metrics); 17.B single "Other US States" section listing Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Iowa, Indiana, Tennessee, Florida, Delaware, New Hampshire, New Jersey, Maryland, Minnesota, Rhode Island, Kentucky, Nebraska, plus Texas verbatim §541.103 disclosure and Nevada opt-out; 17.C brief Switzerland acknowledgment.
  • Section 18 rewrote the data-broker section as a factual non-broker position. Same change reflected at /legal/data-broker.

v2.0

Effective May 6, 2026

Major rewrite — substantive legal posture upgrade.

  • Added prominent independence callout naming every major social platform.
  • Restructured Customer-data and scanned-individual-data sections with per-category purpose / legal basis / retention / recipients tables.
  • Disclosed cross-Customer LLM cache reuse explicitly (§3.3).
  • Replaced bare "we do not sell" assertion with reasoned analysis (§7.1) and a dedicated /legal/do-not-sell opt-out flow.
  • Added profiling-and-Art-22 section that acknowledges the product performs profiling and allocates Art. 22 obligations to the Customer where Customers use outputs for adverse decisions (§11).
  • Added "lawfulness of public-data collection" representation (§12).
  • Switched primary international transfer mechanism from SCCs to EU-U.S. DPF where the receiving sub-processor is DPF-certified (§6).
  • Routed EEA/UK/Swiss data subjects exclusively to Anthropic for LLM classification, not Moonshot (§3.6).
  • Rebuilt children section to distinguish 18+ Customer requirement from 13+ COPPA threshold for inadvertently-processed minor data (§14).
  • Added per-jurisdiction response-time table (§9.1).
  • Refreshed GPC honoring list for Texas, Oregon, Delaware, NJ, NH, Minnesota, Maryland (§13).
  • Added Article 30 ROPA reference (§8) and Article 27 EU representative commitment (§16.4).
  • Added sub-processor objection right with right-to-terminate-without-penalty (§5).
  • Added §10 limitation block acknowledging already-downloaded copies are out of our technical control.
  • Tightened TLS commitment to 1.3 minimum (§15).
  • Distinguished 72-hour regulator notification from "without undue delay" individual notification (§15).
  • Added California SPI right-to-limit framework (§17.A.3).
  • Added Texas TDPSA verbatim disclosures required by §541.103 (§17.C).
  • Added §18 data-broker registration disclosure pointing to /legal/data-broker.
  • Added internal complaint-resolution timeline (§16.3): acknowledge within 5 business days.

v1.0

Effective May 3, 2026

First published privacy policy.

  • Initial 9-section policy covering data collected, sub-processors, sharing, retention, removal requests, children, and contact.