Privacy Policy

This document describes how the application actually handles data. It has not

been reviewed by an attorney.

Data controller: Ster Analytics LLC ("we", "us", "our").

Effective date: 11 September 2026.

Contact: eeze@steranalytics.com.

This policy explains what personal data our internal CRM and command-center

application (the "Tool") collects, how we use it, where it is stored, how long

we keep it, and the rights available to individuals. The Tool is an internal

system operated by us on our own Google Workspace and Google Cloud Platform

(GCP). Google Workspace is the system of record; the backend is a stateless

broker with no separate database.

1. What data we process

| Category | Examples | Where it is stored |

|----------|----------|--------------------|

| Client contacts | Name, email, phone, company | The organization's Google Contacts |

| Invoices | Number, amount, description, status, recipient name/email, PDF | Master Google Sheet + Google Drive |

| Deals / pipeline | Title, client, value, stage | Google Sheet |

| Form and survey submissions | Whatever the form asks; may include contact details | Google Sheet + Google Contacts + a Drive summary |

| Payment events | Provider event id, invoice number, amount, paid/unpaid status (no card data) | Google Sheet |

| NDAs / agreements | Party names, company, terms, PDF | Google Sheet + Google Drive |

| Projects / tasks | Names, assignees, due dates | Google Sheet |

| Calendar events | Title, time, notes | Google Calendar |

| Team members | Name, email, role, permissions, scrypt password hash | Google Sheet |

| Secrets | Payment-provider keys, webhook secrets, token-signing key | GCP Secret Manager |

| Logs | Request metadata and errors; may contain emails or names | Google Cloud Logging |

We also track conversation metadata (that a message occurred and its

associated contact/timing) but not the content of emails.

We do not store card or payment-instrument data. Card entry occurs on the

payment provider's hosted pages. See our [DPA](DPA.md) and the app's PCI SAQ A

note.

2. How we use the data

We use personal data solely to provide the Tool's features that a user

initiates: maintaining the contact list, generating and sending invoices and

agreements, managing the pipeline, capturing form submissions, reconciling

payments, syncing calendar events, running automations, and administering team

access. We do not use it for advertising, and we do not sell it.

3. Google user data and Google API Limited Use

The Tool accesses Google user data through a service account with domain-wide

delegation impersonating one designated Workspace account, using least-privilege

scopes: read/write Google Contacts, read/append Google Sheets, create/open the

Tool's own files in Google Drive (drive.file), and send-only Gmail. It does

not read mailboxes and does not request access to the entire Drive.

This application's use and transfer of information received from Google APIs

to any other app will adhere to the

[Google API Services User Data Policy](https://developers.google.com/terms/api-services-user-data-policy),

including the Limited Use requirements.

In line with those Limited Use requirements, Google user data is used only to

provide or improve user-facing features; it is not used for advertising, is

never sold, and is not read by humans except with the user's consent, for

security or legal reasons, or when aggregated/anonymized.

4. Legal basis (where GDPR / UK GDPR applies)

Where applicable, we process personal data on the basis of our legitimate

interests in operating the business and managing client relationships, to

perform a contract, and to comply with legal obligations (for example, retaining

financial records).

5. Storage and security

• Data lives in the organization's own Google Workspace and in GCP Secret

Manager; Google encrypts it at rest and in transit.

• The backend is stateless — it keeps nothing between requests, and temporary

invoice/NDA PDF files are deleted after upload.

• Access is controlled by role (owner/member) and per-section permissions,

enforced by the backend. Underlying Workspace files are shared only with the

designated CRM account and the Shared-Drive manager.

• Secrets are stored only in Secret Manager, never in source code, on disk, or

in the browser.

• Traffic to the backend uses HTTPS; payment webhooks are signature-verified.

6. Sharing and sub-processors

We share personal data only with service providers that help us run the Tool:

• Google (Workspace + GCP) — storage, compute, email, calendar, secrets.
• Stripe [if enabled] — card payment processing (customer email, invoice

number, and amount at pay time).

• Bill.com / BILL [if enabled] — invoice payment (customer and invoice

details at pay time).

We do not sell personal data. See the [DPA](DPA.md) for sub-processor details.

7. International transfers

Data may be processed in locations where Google and our payment providers

operate. Where required, transfers rely on the safeguards offered by those

providers (for example, Standard Contractual Clauses). The application itself

runs in Google's us-central1 region, in the United States.

8. Retention

• Business records (invoices, deals, agreements): held in the organization's own

Google Workspace — in Google Contacts, Sheets and Drive — and kept for as long

as the organization keeps them there. The application stores no separate copy,

so deleting a record in Google deletes it outright.

• Contacts: kept until removed by the organization or on a valid deletion

request.

• Logs: 30 days in Google Cloud Logging, then automatically purged.
• Secrets: kept until rotated or disconnected; superseded versions disabled and

destroyed.

• Sessions: 12-hour token lifetime, stateless — nothing is stored.

9. Your rights

Depending on your location (for example under GDPR/UK GDPR or CCPA/CPRA), you may

have the right to access, correct, delete, or restrict the processing of your

personal data, and to object to certain processing. To make a request, contact

eeze@steranalytics.com. Because contact and business data is stored in Google

Contacts, Sheets, and Drive, we can locate and act on it directly.

10. Changes to this policy

We may update this policy. The in-app version served at /api/legal/privacy is

the current version.

11. Contact

Ster Analytics LLC, eeze@steranalytics.com.