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Legal / Privacy Policy

EdgeCMS Cloud Privacy Policy

Draft — not in force. This document is a working draft awaiting review by a qualified lawyer. It does not apply to anyone yet, and placeholders in [brackets] are unfilled.

DRAFT — not legal advice, not in force. For review by a qualified lawyer before publication.

Effective date: [EFFECTIVE DATE]

This policy explains how [COMPANY] ([REG NO], [ADDRESS]) ("we") handles personal data for the EdgeCMS Cloud website at [DOMAIN] and the hosted Service.

1. Our role

  • Controller: for your account, billing, support and website data. This policy covers that.
  • Processor: for personal data that our customers put into their workspaces (for example authors or people named in content). We process it only on the customer's instructions, under our Data Processing Addendum. If your data is in a customer's workspace, contact that customer first.

2. Data we collect

Category Examples Source
Account Name, email, hashed password, sign-in provider ID (Google or Microsoft if you use them), MFA settings You, your identity provider
Workspace membership Workspaces you belong to, your role, who invited you You, your workspace admin
Billing Billing contact, company name, tax ID, plan, payment status, last four card digits and expiry as reported by Stripe You, Stripe
Usage and security IP address, browser, request logs, sign-in history, audit log of actions, usage counts for your plan Our systems, Cloudflare
Support Messages you send us You
Website Pages visited, signup form entries, a bot check by Cloudflare Turnstile You, Cloudflare

We do not collect full card numbers; Stripe does. We do not knowingly collect data from children under 16.

3. Why we use it

Purpose Legal basis (GDPR)
Create and run your account and workspaces Contract
Bill you and keep tax records Contract, legal obligation
Secure the Service, prevent abuse and fraud, keep audit logs Legitimate interests, legal obligation
Enforce plan limits and show your usage Contract
Send service emails (security, billing, limit warnings, changes to terms) Contract, legitimate interests
Send product news Consent, which you can withdraw at any time
Improve the Service from aggregated usage Legitimate interests

Where local law (for example Malaysia's PDPA) requires notice or consent in a particular form, this policy is that notice, and we ask for consent where required.

4. AI features

AI features are off until a workspace admin turns them on. When they are on, the text you ask the AI to work on, and the workspace content needed as context, is sent to the AI providers listed in Subprocessors to produce a suggestion. We do not use this data to train models and we choose providers whose terms do not allow them to train on it. AI requests are logged for security and cost control.

5. Who we share it with

  • Subprocessors that run the Service for us, listed in Subprocessors, bound by contracts that protect your data.
  • Your workspace admins, who can see members, roles and the audit log of their workspace.
  • Authorities, when the law requires it. We will tell the affected customer where allowed.
  • A buyer or successor, if the business is sold or merged, under the same protections.

We do not sell personal data and do not share it for advertising.

6. International transfers

Our providers operate globally, including in the United States and [AI PROVIDER REGIONS]. When we transfer personal data out of the EU, UK or another country that restricts transfers, we use Standard Contractual Clauses or another lawful mechanism, and assess the provider's protections.

7. Cookies

We use only essential cookies:

Cookie Purpose Lasts
Session cookie Keeps you signed in to the admin Up to 7 days, refreshed when you use it
Turnstile Bot check on signup and sign-in forms, set by Cloudflare Session

We do not use advertising or cross-site tracking cookies. If we add analytics, we will use a cookieless tool or ask for consent first.

8. How long we keep it

Data Kept for
Account and workspace data While your account is open, then 1 month after closure, then deleted
Workspaces suspended for non-payment or cancelled 1 month, then deleted
Billing records [TAX RECORD PERIOD], as required by tax law
Audit and security logs At least 1 year, up to [LOG MAX]
Backups Expire within [BACKUP EXPIRY] days after the live data is deleted
Marketing preferences Until you unsubscribe, plus a suppression record so we do not email you again

9. Security

We protect personal data with encryption in transit and at rest, access control with least privilege, multi-factor authentication, audit logging, and tested backups. Details are in Annex 2 of the Data Processing Addendum. If a breach affects your personal data and the law requires it, we will notify you and the relevant authority.

10. Your rights

Depending on where you live, you can ask to access, correct, export or delete your personal data, restrict or object to some uses, and withdraw consent. You can export and delete your own account data from your account settings, or email [PRIVACY EMAIL]. We reply within 30 days and may need to verify your identity. Some data must be kept for legal reasons, as listed in section 8.

You can complain to your data protection authority. For example, in the EU, the authority in your country; in Malaysia, the Personal Data Protection Commissioner.

11. Changes

We will post changes here and, for material changes, email you at least 30 days before they apply.

12. Contact

[COMPANY], [ADDRESS] Privacy: [PRIVACY EMAIL] Data protection officer: [DPO]

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