Privacy Policy
Version 1.0 · Effective date: Not yet set — Phase 0, pre-launch (commercial activity has not commenced)
This Privacy Policy describes how RenewalProof (operated by Ellis Intelligence LLC, a Colorado limited liability company, "we", "us", "our") collects, uses, and shares information when you visit renewalproof.com or use the Service. For how we process Customer Data — including IRP plan content, tabletop exercise data (scenario pack, pinned content version, start/end timestamps, ordered inject sequence, decisions and notes recorded), participant records (name, role, join timestamp), attestation data (the sealed evidence-bundle manifest, its SHA-256 hash, the verify token, and the sealed timestamp), reminder preferences, and the canonical events_log audit trail — on behalf of our Customers, see §4 and the Data Processing Addendum at renewalproof.com/dpa.
1. Scope
This Policy covers: visitors to renewalproof.com; Customer (business) account holders and their authorized users; and tabletop exercise participants whose information reaches the Service through a Customer — but only to explain that, for that data, the Customer is the controller and we act as the Customer's processor (see §4 and §12).
2. Information we collect
(a) Directly from Customers and visitors: company name, industry, cyber-insurance renewal date, account email address, name and role of the authorized account holder, billing contact name and email, billing information (tokenized via Stripe — we do not store card numbers), and communications you send us. (b) Automatically: device and connection data, usage data, and cookies (strictly necessary + functional + aggregated analytics only; no third-party advertising trackers). (c) Customer Data — processor role: IRP plan content, tabletop exercise data (scenario pack, pinned content version, start/end timestamps, ordered inject sequence, decisions and notes recorded), participant records (name, role, join timestamp), attestation data (the sealed evidence-bundle manifest, its SHA-256 hash, the verify token, and the sealed timestamp), reminder preferences, and the canonical events_log audit trail. We process this category only on the Customer's instructions to operate the Service (see §4).
3. Information we do not want
The Service is designed to process incident response plan (IRP) documentation and sealed tabletop-exercise attestation data. Do not collect or upload through the Service more than is necessary, and in particular do not upload: classified or export-controlled information; personal financial account numbers; protected health information; any data unrelated to the Customer's own incident response plan, tabletop exercise, or attestation. If we discover such information collected or uploaded inadvertently, we will notify the responsible Customer and request deletion, and may sanitize or delete it without prior notice if necessary to prevent privacy or regulatory exposure.
4. Customer Data and tabletop exercise participants data — our role
4.1 Processor / Service Provider. With respect to all tabletop exercise participants data processed through the Service, the Customer is the controller (or "business") and we are the processor (or "service provider"). We process that data only on the Customer's documented instructions to provide the Service, and not for our own purposes. 4.2 Where we host the collection surface. Where the Service includes a Customer-configurable surface that collects information directly from tabletop exercise participants, we host and render that surface and collect what is entered, but we do so as the Customer's processor and on the Customer's behalf; that person's relationship is with the Customer, not with RenewalProof. 4.3 Minimization. We collect only the participant fields a tabletop exercise requires — name, role, and join timestamp — and no participant contact information; participants do not authenticate and hold no account with us. 4.4 No sale, no share. We do not sell tabletop exercise participants data or Customer Data, and we do not share it for cross-context behavioral advertising. 4.5 No training on Customer Data. We do not use Customer Data to train any model, fine-tune any shared model, or improve a Service used by other customers. 4.6 Tenant isolation. flat per-tenant — role is mapped separately at each layer of the chain. 4.7 Audit-log integrity. Every plan version, exercise state transition, participant join, and seal event is written to the canonical events_log audit trail under your tenant. The public verify surface (renewalproof.com/verify/<token>) is disclosure-only: it discloses a narrow, non-personal summary (scenario name, plan version number, participant count, exercise end date, SHA-256 hash, and seal-match status) to anyone holding the unguessable token, and never discloses the Customer's tenant identity, participant names, or any other tenant's data. It collects no information from, and is not enumerable by, the visitor.
5. How we use information (controller role)
For marketing-site visitors and Customer account/billing contacts, we use information to provide, operate, secure and improve the Service; authenticate users and prevent unauthorized access; process payments and manage subscriptions; communicate about the Service, security incidents and Terms changes; send marketing communications to Customer billing contacts (opt-out anytime); produce aggregated, de-identified usage analytics; and comply with legal obligations. We do not sell personal information and do not share it for cross-context behavioral advertising.
6. What we do NOT do with your information
We do not sell personal information and do not share it for cross-context behavioral advertising. We do not use Customer tenant data to train any model or to improve a Service used by other customers. We do not share tenant data with third parties except as described in §7 (subprocessors, legal compliance, business transfers). RenewalProof is not affiliated with, endorsed by, sponsored by, or officially recognized or supported by any state Department of Insurance, and is not an insurance broker, agent, or producer. No surface of the Service uses a seal, badge, ribbon, watermark, or certificate-style graphic that could suggest such affiliation, endorsement, official recognition, predictive authority, or agency action.
7. Sharing and disclosure
(a) Subprocessors at renewalproof.com/subprocessors, operating under equivalent data-protection restrictions. (b) No AI/LLM provider is used in this pathway — AI processing. N/A — no AI/model provider is in RenewalProof's data path are sent to our AI/model provider for inference. N/A — no AI/model provider is in RenewalProof's data path — this is a control we build and enforce ourselves, not a retention commitment we rely on the provider to make. Zero Data Retention (not yet substantiated): this processing is not currently covered by a written Zero Data Retention agreement or a code-level enforcement gate with the provider; we do not represent Zero Data Retention as a current safeguard, and will not make or reinstate that representation until both the written agreement and the enforcing gate are in place. (c) Subprocessor changes: we will notify the Customer's designated account contacts by email or in-product notice at least 30 days before adding or replacing a subprocessor, and will update the published list at the same time. Notice is deemed given when sent. A Customer may object on reasonable data-protection grounds within 30 days of the date notice is given; if a Customer timely objects, we will not use the new subprocessor to process that Customer's data while we work with the Customer to resolve the objection. (d) Legal compliance. (e) Business transfers, with notice to Customers. (f) With the Customer's written instruction. We do not share tabletop exercise participants data or Customer Data with data brokers, advertising networks, or any third party for purposes outside operating the Service.
8. Cookies and tracking
Strictly necessary, functional, and aggregated-analytics cookies only. No third-party advertising or behavioral trackers.
9. Retention
Customer account data: while active + up to 7 years for accounting and legal purposes. Customer Data: for the subscription term, available for export throughout; deleted within 30 days of a Customer's written deletion request. Absent such a request, upon termination we retain Customer Data for twenty-four (24) months following the effective date of termination, to preserve the evidentiary and statutory record-keeping basis for the underlying record, and will thereafter delete it within 30 days, except as required by law to retain. Minimized identity/contact data: retained only as long as needed for its purpose and not subject to the post-termination period above. Marketing data: until opt-out. Aggregated, de-identified data: indefinitely.
10. Security
Customer data is stored on encrypted infrastructure (disk-level encryption at rest) and served exclusively over TLS with authenticated, least-privilege access; we operate automated health monitoring, with independent external uptime monitoring being brought online ahead of launch. We use tenant isolation between customers. We do not claim SOC 2, ISO 27001, or any audited certification on this pre-launch product; we will update this section as our security program and independent assessments mature. No method of transmission or storage is perfectly secure. Breach notification to affected Customers per the DPA: without undue delay, and in any event within five (5) business days of becoming aware; provided that where the strictest applicable state breach-notification law or a sector-specific notice trigger requires a Customer to act on a shorter timeline, we will use commercially reasonable efforts to notify the Customer within whatever shorter period is necessary for the Customer to meet that deadline.
11. International transfers
Processing occurs in the United States. RenewalProof is offered to United States customers; we do not currently accept customers established in the European Economic Area, the United Kingdom, or Switzerland, and the Service is not designed for the transfer of personal data from those jurisdictions. Before we accept any such customer we will publish the transfer mechanism that applies and update this section. If you access renewalproof.com from outside the United States, the limited information described in §2(b) is processed in the United States.
12. Your rights
Marketing-site visitors and Customer billing contacts: you have the rights afforded by applicable law to access, correct, delete, or port your information and to opt out of sale/share and certain processing. We do not sell or share this information. Email [email protected] or write to 1500 N Grant St, Ste N, Denver, CO 80203, USA; we will verify your request and respond within the time applicable law requires. tabletop exercise participants whose data is processed by a Customer using RenewalProof: the Customer is the controller of that data. Direct your privacy request to that company, not to RenewalProof. We act only as the Customer's processor. We will cooperate with the Customer to fulfill valid access, deletion, correction, or opt-out requests per the DPA and applicable law, and we do not respond directly to data-subject requests unless the responsible Customer explicitly authorizes and instructs us to do so.
13. Regional disclosures
California (CCPA/CPRA). California residents have the rights in §12. In the past 12 months we have collected the categories described in §2 and used them solely as described in §5. We have not "sold" or "shared" personal information as those terms are defined under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020. You have the right not to be discriminated against for exercising these rights. Colorado (Colorado Privacy Act). Colorado residents have rights of access, correction, deletion, portability, and to opt out of targeted advertising, sale, and profiling in furtherance of decisions producing legal or similarly significant effects — we conduct none of these. You may appeal a declined request by replying to our response; if you have concerns you may contact the Colorado Attorney General. Other U.S. states. Residents of other states with comprehensive privacy laws have the rights those laws provide; use the contacts in §12. EEA / UK / Switzerland. To the extent Regulation (EU) 2016/679 (the General Data Protection Regulation) or the UK GDPR applies, our legal bases are our legitimate interests in operating and securing the Service and, where you contact us or hold an account, performance of a contract and our legitimate interest in responding. You have rights of access, rectification, erasure, restriction, portability and objection, and you may lodge a complaint with your local supervisory authority. See §11 for our current transfer posture.
14. RenewalProof Is Not a Law Firm, Insurer, Broker, or Certification Body
RenewalProof is a software tool. It is not a law firm, an insurer, a broker, an investment adviser, or a certification body, and does not provide legal, insurance, investment, or certification advice, representation, or compliance assurance. Use of the Service does not guarantee compliance with any law or standard. Each Customer remains solely responsible for its own compliance. The Service's clocks, reminders, templates and generated documents are designed to assist; they are not a substitute for professional advice.
15. Children's privacy
The Service is for business users and is not directed to individuals under 13. We do not permit account creation by anyone under 13, and we do not knowingly collect information from children under 13 through the marketing site or account flows; see §3. If we learn we have collected information from a child under 13, we will delete it promptly. A Customer that receives a request concerning a minor is the controller of that request.
16. Updates
We will provide 30 days' email notice to Customer billing contacts for material changes to this Policy. Notice is deemed given when sent; the 30-day period runs from the send date, and failure to read a notice does not extend it.
17. Contact
[email protected] — privacy matters. [email protected] — other legal matters. 1500 N Grant St, Ste N, Denver, CO 80203, USA.