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Legal · v1.2

Privacy Policy

Effective date: 11 July 2026 · Last updated: 26 October 2026

1. Who we are

InTheValley LLC, under the name ComplyEdge (“we”, “us”), operates the Service at complyedge.io, eu.api.complyedge.io, api.complyedge.io, dashboard.complyedge.io, trust.complyedge.io, and related properties. InTheValley LLC is a limited liability company organized in Wyoming, United States (filing no. 2026-002075401; registered office 30 N Gould St Ste N, Sheridan, WY 82801, USA). For privacy and support requests, and to exercise any of the rights in section 8, contact support@complyedge.io.

Depending on the processing activity, we act as an independent controller (account administration, website and product analytics, billing) or as a processor (evaluating content you submit through the API on your instructions). Processor terms may be set out in a Data Processing Agreement for enterprise customers. Where a DPA is required, it is executed offline (email countersign), not as an in-product clickwrap.

2. What we collect

Account and authentication

  • Email address
  • One-time passcodes and related auth metadata (delivery status, timestamps). OTP codes are stored hashed and expire after about five minutes
  • Tenant / organization identifiers and plan tier
  • API keys: stored so the authenticated dashboard can Show/Copy them; treat keys as secrets and rotate if exposed. A hash of the key is also stored for lookup

Service usage

  • API request metadata written to the compliance audit log: timestamps, jurisdiction / rule-bundle selection, latency, decision outcome (allow/block/flag), rule IDs, legal citation text when a phrase rule or the injection check fired (stored as the rule description), and the reason sentence when a model wrote one, plus related engine fields (for example engine path)
  • Evaluated text as a keyed hash only (text_hash, HMAC-SHA-256 with a key per account, held in AWS KMS) in standard production audit rows: we do not persist raw prompts/outputs unless a separate written agreement says otherwise. Records written before the keyed hash reached production carry a plain SHA-256 until they expire. Application logs do not include request text or a hash of it
  • User and session identifiers you send as user_id / session_id are stored as keyed pseudonyms (p1:…), never as sent. Records written before pseudonymisation reached production may hold the identifier as sent until they expire. user_role is stored as sent and must not hold a name
  • Decision context, when you send it with a check: the person a decision is about (subject) and the exchange id (correlation_id) are stored as keyed pseudonyms (p1:…), never as sent. The other context fields are stored as sent: the deciding system version, purpose reference, data categories, legal basis, works agreement reference, whether the person is an employee, source reference, decision mode, the notice given, explanation inputs, withheld and escrow references. They should hold references and categories, not names
  • Dashboard activity needed to operate the product

Website and communications

  • Lead-form fields you submit (name, email, optional company, message)
  • Analytics events (page views / funnel steps) sent to our analytics operator when you have accepted analytics: see section 9. The analytics server also records your IP address and browser details
  • Support emails you send us

Billing (paid plans)

  • Payment and invoicing data processed by our payment provider (we do not store full card numbers)

3. Why we process data

  • Provide, secure, and improve the Service
  • Authenticate users and prevent abuse
  • Produce compliance audit trails you request (hash-based records with rule citations)
  • Communicate service notices and respond to support
  • Meet legal obligations and enforce our Terms

Where GDPR applies, legal bases include contract performance, legitimate interests (security, product improvement, B2B communications with opt-out), consent where required, and legal obligation.

4. Retention

  • Audit events: kept 184 days, then expire (DynamoDB TTL). That duration matches the six-month floor for deployers of high-risk AI systems under EU AI Act Art 26(6), which binds from 2 December 2027; for other deployers it is a product term. Your own obligations may require longer retention; a longer period is an Enterprise dashboard setting
  • Audit archive: every change to an audit record is also copied to a write-once (Object Lock) archive in the same region, locked for 180 days and deleted after 400 days, so a damaged record can be recovered
  • Audit timestamps: every hour, the latest hash of each account's audit chain is timestamped by a qualified timestamp provider and kept in a write-once store for 400 days (longer when the account's audit retention is longer, up to 10 years). Each one holds the account id, a sequence number and a hash, and no record content
  • Application logs: kept 90 days (the public MCP endpoint: 14 days); they hold no request text
  • Account data: for the life of the account plus a short wind-down period after deletion/closure
  • Auth OTP codes: short-lived (~5 minutes); expired codes are discarded
  • Backups: point-in-time recovery of the database, 35 days; weekly backups, kept 210 days. Then deleted
  • Account closure: deleting the account deletes its per-account audit key with it, so the keyed hashes and pseudonyms in any remaining copy can no longer be linked to an input or a person. Copies of that key in backups are deleted with those backups (35 and 210 days above)

5. Sharing and subprocessors

We do not sell personal data. We use infrastructure and vendors to run the Service, including:

  • Amazon Web Services (AWS): hosting, storage, compute. Two regions: United States (us-west-2) and Germany (eu-central-1). Each account lives in exactly one region; its submitted content is processed there (it is checked, never stored), its audit records are stored there, and neither is copied to the other. The region is chosen when the account is created (Germany is preselected). Moving an existing account to the other region is done by ComplyEdge support on request
  • Cloudflare: hosts the customer dashboard and trust portal (Cloudflare Pages), and runs the Turnstile bot check on dashboard sign-in, which receives the visitor’s IP address and browser signals
  • OpenAI, LLM evaluation. On a paid plan, after a clean phrase pass, the injection meaning check sends the evaluated text to OpenAI when the month's model budget covers it, including the default path. If that budget is used up, the check does not run and the phrase rules decide. The wider legal review on a check sends the text when use_semantic_fallback is set to true for that request, or when the account's Layer 2 setting is on, and the month's model budget covers it. If that budget is used up, it does not run. On sensitivity detection that request flag does nothing. A model runs there only on a paid plan when the account setting is on and the month's model budget covers it, after the TrustLint rules come back clean. That endpoint does not run the injection check. The API and SDK default is false, so the wider review is off unless turned on. A missing answer on the injection check denies the request.
  • Brevo: transactional email (OTP / notices)
  • Paddle: merchant of record for paid plans. Paddle sells the subscription to you, takes payment, and is responsible for sales tax and VAT on that sale. Billing and payment details are collected by Paddle on its own checkout and handled under Paddle’s own privacy notice; we receive the subscription and customer identifiers needed to activate your plan, not your card details
  • GitHub: public OSS distribution and related source hosting; not a live “connect your private repo” product surface today
  • api.ada-tool.com: analytics operator for marketing pages, AI Trust Center pages and dashboard funnel events, all only after you accept (see section 9)
  • Sectigo: qualified timestamp provider for the hourly audit timestamps (section 4). It receives only a SHA-256 hash, which contains no record content or personal data

Vendors process data under contract and only on our instructions. Paddle is the exception by design: as merchant of record it is the seller of your subscription and an independent controller of the billing data you give it at checkout, not our processor.

Which of these are DPA sub-processors. AWS, OpenAI, Brevo, Cloudflare (the sign-in bot check) and Paddle may process customer personal data through the Service, so they appear in the sub-processor table of the DPA and carry its notice and objection rights. Cloudflare's hosting of the dashboard and trust portal, GitHub, api.ada-tool.com and Sectigo are not sub-processors under that DPA. They relate to frontend hosting, source-code hosting, analytics on our own properties and timestamping a hash, where we act as an independent controller, which is why they are named here and not in the DPA table.

6. International transfers

Accounts in the US region have their submitted content processed (it is checked, never stored) and their audit records stored in the United States, and the exceptions listed below are processed where those vendors operate. Where required, we use appropriate safeguards (e.g. Standard Contractual Clauses) for transfers from the EEA/UK.

Accounts in the EU region have their submitted content processed (it is checked, never stored) and their audit records stored in the EU. Exceptions: the injection meaning check (OpenAI, US) on a paid plan after a clean phrase pass, when the month's model budget covers it, and the wider legal review (OpenAI, US) when you enable it; transactional email (Brevo); billing (Paddle), which never receives content; subscription-plan and account-identity metadata (plan tier, status, account email) exchanged between regions to route billing and sign-in; and the sign-in bot check (Cloudflare), which receives the signing-in user's IP address and browser signals.

7. Security

We use industry-standard controls appropriate to a cloud API product (TLS in transit, access controls, secret management, auditability). No method of transmission or storage is perfectly secure; please protect your API keys and rotate them if you believe they are compromised.

8. Your rights

Depending on your location, you may have rights to access, correct, delete, restrict, or port personal data, and to object to certain processing or withdraw consent. Contact support@complyedge.io. You may also lodge a complaint with your local supervisory authority.

If we process data as your processor, we will assist you in responding to data-subject requests as required by your DPA and applicable law.

9. Cookies and similar technologies

Strictly necessary. We use cookies or local storage for authentication and session continuity on the dashboard. These are required for the Service to function and are set without a separate analytics consent step.

Analytics preference. On marketing pages, on AI Trust Center pages and on the dashboard we also store your analytics Accept/Decline choice in local storage so we can honour it. Remembering a refusal is necessary to honour it.

Marketing analytics, consent required. On our marketing pages (complyedge.io) we use an analytics service operated on our behalf at api.ada-tool.com to measure which pages are read. It stores a randomly generated session_id and user_id in your browser's local storage and sends the page URL (including any query string), path and timestamp to that domain. That server also records your IP address, browser user agent and the device type, operating system and browser read from it, your browser language and the referring page, and uses your IP address and browser language to recognise a returning visitor. It does not load, and nothing for that pixel is stored, unless you accept it when first asked. Declining is remembered and you are not asked again on that browser (except on local development hosts used for product testing). Because the data is transmitted to a domain other than complyedge.io we describe it as a third-party recipient under this Policy.

Dashboard product analytics, consent required. On the dashboard we can send product-funnel events (for example sign-in and first dashboard view) to the same api.ada-tool.com operator so we can improve onboarding. Those events use the same identifiers and fields, and the server records the same IP address and browser details. The dashboard asks separately, because it is a different site from complyedge.io, and it sends nothing and stores no identifier unless you accept.

AI Trust Center analytics, consent required. AI Trust Center pages (trust.complyedge.io) use the same api.ada-tool.com service, with the same identifiers, fields and recorded IP address and browser details, to measure which trust pages are read. They are a different site from complyedge.io, so they ask separately, and nothing loads and no identifier is stored unless you accept.

Changing your choice. Use Analytics settings at the bottom of any page, on complyedge.io, on AI Trust Center pages or on the dashboard. It reopens the same choice, so you can withdraw consent with one click, the same way you gave it. Declining removes the analytics identifiers from your browser. We do not use advertising trackers, and we do not perform cross-site ad retargeting anywhere. Marketing pages may load fonts or CSS from third-party CDNs (for example Google Fonts) for presentation only.

10. Children

The Service is built for professional / organizational use and is not directed to children under 16. We do not knowingly collect their personal data.

11. Changes

We may update this Policy. Material changes will be posted with a new “Last updated” date. Continued use after the effective date constitutes acceptance where permitted by law.

12. Related terms

Use of the Service is also subject to our Terms of Service. Where we act as your processor, see the Data Processing Agreement.

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