Privacy Policy
LEGAL DRAFT - REQUIRES REVIEW BY QUALIFIED COUNSEL
1. Scope
This Privacy Policy explains how [LEGAL COMPANY NAME] processes personal information in connection with the Platform. It also explains the relationship between the Platform Operator and Tenants. Because the Platform is multi-tenant, users generally interact with a specific Tenant environment, and that Tenant determines many of the purposes for which user data is collected and used.
2. Privacy Roles
Depending on the applicable law and processing activity, a Tenant may act as the controller, business, responsible party, or equivalent entity that determines the purposes and means of processing user information within its tenant environment. The Platform Operator generally processes such information to provide, secure, maintain, support, and improve the Platform under the Tenant's instructions and applicable agreements, and may act as an independent controller/business for limited platform-level activities such as account administration, security, fraud prevention, subscription management, legal compliance, and service analytics. These roles must be confirmed in the final Data Processing Agreement and jurisdiction-specific notices.
3. Tenant-First Use of Data
Personal information collected within a Tenant environment is intended primarily for that Tenant's legitimate operation of the Platform, including account management, commerce, group buying, support, internal communications, fulfillment coordination, research-oriented tools, and related functions. The Platform Operator does not sell user personal information to Vendors or Buyers and does not provide a direct Buyer-Vendor communication channel. Personal information is not made available to another Tenant.
4. Information We May Process
Depending on enabled features and user role, information may include: account identifiers; name; email; telephone number; organization; role; address; billing and shipping details; order and reservation data; product interaction data; support tickets; permitted chat and group-chat communications; uploaded documents; account-security data; login and device information; IP address; browser and operating-system data; language, timezone, and preference settings; subscription and usage data; questionnaire answers; research-profile data; AI interaction data; audit and activity logs; and other information submitted through the Platform.
5. Sensitive and Health-Related Information
The Platform is not designed as an electronic medical record, clinical record, healthcare treatment system, or patient-management system unless a separate written agreement and compliant implementation expressly state otherwise. Users and Tenants should not submit protected health information, clinical records, or other highly sensitive medical information unless the Platform Operator has expressly approved that use in writing and all required legal, contractual, security, and technical safeguards are in place. Research-oriented questionnaire data must not be treated as a clinical diagnosis or medical record merely because it concerns research interests or general wellness topics.
6. Sources of Information
Information may be received directly from users, Tenant Administrators, authorized support personnel, Vendors for operational documents, payment providers, authentication providers, cloud and security providers, shipping carriers, integrations enabled by the Tenant, and automatically from use of the Platform. Where information is received from a Tenant, the Tenant is responsible for having an appropriate lawful basis and providing required notices.
7. Purposes of Processing
We may process information to: provide and operate the Platform; authenticate users; maintain tenant isolation; administer roles and permissions; process or support orders and reservations; manage support; route permitted communications; generate activity and audit logs; provide localization; maintain security; detect fraud or misuse; troubleshoot; back up data; enforce contracts and policies; comply with law; manage subscriptions and usage; operate approved integrations; and provide optional AI, questionnaire, calculator, and knowledge features where enabled.
8. Vendors and Buyers - Communication and Data Separation
Vendors do not participate in direct chat or group chat with Buyers. The Platform should not expose Buyer or Vendor contact information merely to enable direct communication. Where operational fulfillment requires information to be provided to a Vendor, the Tenant should disclose only the minimum information reasonably necessary for the authorized task, and the Platform should use role-based permissions and tenant-scoped access. Buyers should not receive private Vendor account data beyond information intentionally displayed by the Tenant for the transaction.
9. Multi-Tenant Isolation
Tenant data must remain logically isolated. The Platform uses tenant-aware access controls and server-side authorization designed to prevent one Tenant from accessing another Tenant's data. Users must not attempt to circumvent tenant boundaries, manipulate tenant identifiers, access other tenants by URL modification, or use credentials belonging to another Tenant.
10. Service Providers and Subprocessors
The Platform Operator may use service providers and subprocessors for hosting, object storage, email, communications, authentication, monitoring, security, analytics, AI processing, payment processing, customer support, backups, and similar infrastructure. These providers may process information only as necessary to provide their services, subject to contractual, technical, and legal safeguards appropriate to the circumstances. A current subprocessor list may be made available at [SUBPROCESSOR URL OR CONTACT].
11. Payment Information
If payments are enabled, card or financial-account information may be collected directly by an integrated payment provider rather than stored by the Platform Operator. Payment providers process information under their own terms and privacy notices and may perform identity, fraud, sanctions, or risk screening. The Platform may retain transaction identifiers, payment status, amount, currency, customer identifiers, and related records needed to operate the service and reconcile transactions.
12. AI Features
Where AI features are enabled, user prompts, questionnaire answers, selected context, and generated outputs may be transmitted to an approved AI service provider or processed by an internal model. Tenant plan and configuration may determine which AI features are available. The Platform Operator should configure AI providers, where practicable, to minimize unnecessary retention and secondary use. Users should not submit secrets, regulated data, or sensitive personal information to AI features unless explicitly authorized. AI outputs may be retained for audit, support, safety, quality, or user-history purposes as disclosed by the Tenant.
13. Legal Bases
Where applicable law requires a legal basis, processing may rely on performance of a contract, legitimate interests, consent, compliance with legal obligations, protection of rights and security, or other lawful grounds. The specific basis depends on the processing activity, user relationship, jurisdiction, and role of the Platform Operator and Tenant.
14. Data Retention
Information is retained for the period reasonably necessary to provide the Platform, fulfill Tenant instructions, maintain business and audit records, comply with law, resolve disputes, enforce agreements, maintain security, and support backups. Tenant Administrators may have tools or contractual rights to configure or request retention and deletion. Backup copies may persist for a limited period after deletion until overwritten in the ordinary backup cycle.
15. Data Security
The Platform Operator uses administrative, technical, and organizational safeguards designed to protect information, which may include access controls, authentication, encryption in transit, secure credential handling, logging, tenant isolation, private object storage, backups, rate limiting, monitoring, and least-privilege design. No system is completely secure, and we cannot guarantee that unauthorized access, loss, alteration, or disclosure will never occur.
16. International Transfers
Information may be processed in countries other than the user's country of residence. Where required, the Platform Operator and Tenants should implement legally recognized transfer mechanisms, contractual protections, or other safeguards. Hosting and subprocessor locations should be disclosed or made available as required by applicable law.
17. User and Data Subject Rights
Depending on jurisdiction and role, individuals may have rights to access, correct, delete, restrict, object to processing, withdraw consent, obtain a portable copy, appeal a privacy decision, or exercise other statutory rights. Because Tenant-controlled data is generally processed on behalf of the Tenant, requests relating to a Tenant account should usually be directed first to the applicable Tenant. The Platform Operator will assist Tenants as required by contract and law. Requests may also be sent to [PRIVACY EMAIL].
18. Cookies and Similar Technologies
The Platform may use strictly necessary cookies and similar technologies for authentication, security, preferences, tenant routing, language, session management, and application functionality. Analytics or non-essential technologies, if used, should be disclosed and consented to where required. A separate Cookie Notice may be added when the final analytics and advertising stack is known.
19. Children
The Platform is not intended for children unless a specific Tenant use case is expressly approved and legally compliant. The default minimum age should be set by counsel based on target jurisdictions and whether the Platform is business-only or consumer-facing: [MINIMUM AGE]. We do not knowingly authorize child accounts contrary to applicable law.
20. Security Incidents
If a personal-data security incident occurs, the Platform Operator will investigate and take reasonable steps to contain, remediate, document, and notify affected Tenants, individuals, regulators, or other parties where required by law or contract. Tenants must promptly notify the Platform Operator of suspected compromise of Tenant credentials or accounts.
21. Privacy Choices and Tenant Controls
Tenants may configure user access, roles, support workflows, communications, optional modules, and certain retention or feature settings. Users should contact the Tenant Administrator for account-level preferences that the Tenant controls. Platform-level subscription, security, and infrastructure settings remain under the Platform Operator's control.
22. Changes to This Policy
We may update this Privacy Policy as data practices, laws, integrations, or features change. The effective date will be updated and material changes will be communicated as required by applicable law or contract.
23. Contact
Privacy questions or rights requests may be directed to: [PRIVACY EMAIL], [LEGAL COMPANY NAME], [LEGAL ADDRESS]. If a Data Protection Officer or representative is legally required, include: [DPO / REPRESENTATIVE CONTACT].