Draft prepared: August 9, 2026 · Effective date: Not yet established
1. Scope
This draft applies to information collected through the public website, inquiry forms, email communications, scheduling tools, and related business-development activities. Information processed on behalf of a client under a services agreement or data processing addendum is governed by that agreement and the client’s instructions.
2. Information we collect
Information you provide
- Name, work email, company, role, and store URL.
- Product category, company-size, revenue, and catalog ranges.
- Systems, sales channels, operational challenges, deadlines, budget range, and referral source.
- Communications, scheduling information, and optional marketing preference.
Do not submit store passwords, API keys, customer lists, order exports, payment-card information, health information, government identifiers, or other sensitive personal information through the public website.
Limited technical information
The production site may collect limited security and usage information such as IP address, browser/device details, pages viewed, referring page, date/time, sanitized UTM parameters, interaction events, and error logs. Behaviorally targeted advertising pixels are not planned at launch.
3. How information is used
- Respond to and evaluate service inquiries.
- Schedule meetings and prepare proposals or agreements.
- Provide requested services and maintain business records.
- Operate, secure, and improve the website and service process.
- Comply with legal obligations.
- Send marketing communications only when permitted, with opt-out rights.
4. How information may be disclosed
Information may be disclosed to approved hosting, form, CRM, scheduling, email, analytics, e-signature, invoicing, accounting, security, and support providers; professional advisers; authorized contractors; authorities where required; or a business successor subject to appropriate protections. The actual production vendor list remains to be selected and reviewed.
Proper Commerce does not intend to sell personal information for money or share it for cross-context behavioral advertising at launch.
5. Cookies and similar technologies
The site may use essential security/session technologies, preference storage, limited approved analytics, and scheduling technologies loaded on interaction. See the Cookie Notice for the intended launch posture.
6. Retention
Information will be retained only as long as reasonably necessary. The draft internal schedule anticipates active inquiries during evaluation, inactive leads generally for 12–24 months subject to approval, marketing records until opt-out plus suppression, and contract or financial records as required. The actual production retention schedule remains a launch blocker.
7. Security
Planned safeguards include access controls, multifactor authentication, encryption in transit, secure vendors, data minimization, privacy-safe logging, and access review. No method of transmission or storage is completely secure.
8. Choices and rights
Depending on location and applicable law, individuals may have rights to request access, correction, deletion, portability, restriction, objection, or information about disclosures. Identity and authority may need to be verified. The final request method and appeal process will be established with counsel.
9. International visitors and children
The service is intended for businesses and adults and is not directed to children under 13. The website will be operated from the United States; final international-transfer disclosures depend on the selected vendors and markets served.
10. Changes
The effective policy will display its current last-updated date, and material changes will be communicated as required.
Production contact details
Legal entity, business address, and the relevant privacy, legal, or accessibility contact are not yet approved. Production publication is blocked until those values are confirmed and inserted.