Privacy Policy

Data Controller: RacoLab (placeholder pending final owner legal entity confirmation — Decision Log Item 6)
Privacy & Data Protection Contact: support@exevery.app
Effective Date: 2026-10-21

1. Privacy-by-Design & Data Minimization

Exevery is engineered to collect only the minimum technical and transactional data necessary to deliver the ~3GB runtime image, enforce the 14-day Compatibility Mode trial, verify 2-device perpetual licenses, and process orders through Paddle Billing. Free Game Mode requires no user account or personal login.

2. Categories of Data We Collect

• Salted Hardware Device Hash (device_hash — Decisions 1A, 2A & 4A): The macOS client computes a one-way SHA-256 hash locally on your Mac as SHA-256("exevery-device-v1:" + IOPlatformUUID) and transmits it via the X-Exevery-Device-Hash header or API request body alongside the client semantic version (X-Exevery-App-Version). Your raw IOPlatformUUID is never sent to or stored on Exevery servers.
• Daily-Salted IP Hash (ip_hash — Decision 1A): When requesting 30-minute presigned runtime download URLs (POST /v1/runtime/download) or starting a trial (POST /v1/trials), our Cloudflare Worker computes a privacy-minimal, daily-salted SHA-256 hash of the connecting IP address strictly to enforce abuse-prevention rate limits (5 download requests/day per device and 10 requests/day per IP).
• Purchase, Billing & License Records (Paddle Billing MoR): When you buy a Compatibility Mode license, Paddle.com acts as our Merchant of Record and collects your payment details and billing address under Paddle's Privacy Policy. Via signed Paddle webhooks (POST /v1/webhooks/paddle), we store your email address, locale, paddle_customer_id, paddle_transaction_id, paddle_price_id, paddle_event_id, license_id, purchase_at, updates_until, and payment/refund status in Cloudflare D1. We never receive or store raw payment card numbers.
• Voluntary Support & Diagnostic Submissions: If you email support@exevery.app for license recovery, device deactivation assistance, or bug reports, we process your email address and any diagnostic logs you choose to attach.

3. How We Use Your Data & Legal Bases

• Contract Performance & Service Delivery: Issuing Ed25519-signed entitlement envelopes (SignedEntitlementEnvelope), managing 2 concurrent active devices and up to 3 self-service deactivations per rolling 30 days, evaluating 1-year updates_until eligibility, and delivering presigned runtime download URLs.
• Legitimate Interests (Security & Abuse Prevention): Preventing automated bandwidth exhaustion of the ~3GB R2 runtime image, detecting duplicate or replayed webhooks, and enforcing trial integrity.
• Legal & Tax Compliance: Retaining transaction and license records required by applicable tax, accounting, and consumer protection laws.

4. Third-Party Subprocessors & International Transfers

• Cloudflare, Inc.: Hosts exevery.app and api.exevery.app on Cloudflare Workers, stores license/trial state in Cloudflare D1, and serves runtime/release artifacts from Cloudflare R2 across Cloudflare's global edge network.
• Paddle.com Market Limited (and affiliates): Merchant of Record responsible for checkout, payment processing, sales tax/VAT calculation and remittance, invoicing, and refund/chargeback processing.

Because Cloudflare and Paddle operate globally, your data may be processed outside your country of residence subject to standard contractual safeguards and applicable data protection laws.

5. Data Retention

• Rate-Limit & Download Telemetry: Daily rate-limit buckets (rate_limits) and runtime download audit entries (runtime_download_events) are retained only for short-term abuse prevention and security auditing.
• Customer & License Ledger: Customer, license, activation, and idempotent webhook summary records in D1 are retained for the duration of your perpetual license and statutory tax/audit retention periods. Raw webhook payloads are not retained beyond minimal non-PII summaries and SHA-256 digests.

6. Your Privacy Rights (Access, Correction & Deletion)

Depending on your jurisdiction (including the EEA/UK under GDPR, South Korea, Japan, California, and other regions), you have the right to request access to, correction of, export of, or deletion of your personal data held by RacoLab. To exercise these rights, email support@exevery.app from the email address associated with your order or include your device_hash / license key hint.