Privacy Policy

1. Data Controller and Data Processor Framework

1.1 HarvestEdgeTools as Data Processor

HarvestEdgeTools (“the Factory,” “we,” “us,” or “our”) operates as a DATA PROCESSOR with respect to the personal information of church members, ministry contacts, and other individuals whose data is provided to us by our Partners in the course of building custom tools. We process this data solely on behalf of and under the instructions of our Partners.

1.2 Partner as Data Controller

The church, ministry, or organization using Factory services (“Partner” or “you”) is the DATA CONTROLLER with respect to the personal information of its members, contacts, and constituents. The Partner determines purposes and means of processing, and bears primary responsibility for compliance with applicable data protection laws.

1.3 Factory as Data Controller

HarvestEdgeTools acts as a DATA CONTROLLER with respect to personal information collected directly from Partners in the course of our business relationship, including Account Administrator contact information, billing details, and communications.

1.4 Shared Responsibilities

Responsibility	Party
Obtaining consent from data subjects	Partner (Data Controller)
Responding to data subject access requests	Partner, with Factory assistance
Implementing technical security measures	Both parties
Notifying affected parties in case of breach	Factory notifies Partner; Partner notifies data subjects
Determining data retention periods	Partner, within Factory’s retention framework
Complying with applicable data protection laws	Both parties

2. Information We Collect

2.1 Information Provided Directly by Partners

• Contact Information: Names, email addresses, phone numbers, and mailing addresses of Account Administrators, authorized users, and designated emergency contacts.
• Organizational Information: Church or organization name, denomination, physical address, website URL, and mission description.
• Project Descriptions: Descriptions of tools and services requested, including specifications and design preferences.
• Communication Records: Emails, messages, and communications between Partners and our team or AI agents.
• Church Member Data (as Processor): When building ministry tools, Partners may provide church member data. We process this solely as instructed.
• Form Submissions: Data submitted through website forms.

2.2 Information Generated Through Service Use

• Conversation History: Records of interactions with our AI agents.
• Usage Metrics: Session frequency, duration, features used, and project milestones.
• Technical Logs: Server logs, error reports, and diagnostic information.

2.3 Payment Information

We use Stripe as our payment processor. We do NOT directly collect, store, or process credit card numbers, bank account numbers, or Social Security Numbers. We receive only limited payment information from Stripe (transaction confirmation, amount, billing name, tokenized references).

2.4 Information We Do NOT Collect

We do not knowingly collect: Social Security Numbers, financial account information beyond Stripe tokens, health or medical information, biometric data, precise geolocation data, or information about race, ethnicity, political opinions, or trade union membership.

3. How Data Is Used

3.1 Primary Use

The primary purpose for collecting data is to build the custom tools and applications that our Partners request.

3.2 Permitted Uses

• Service Delivery: Building, testing, deploying, and maintaining custom tools.
• Communication: Responding to inquiries and providing project updates.
• Quality Improvement: Analyzing usage patterns in anonymized and aggregated form.
• Security: Monitoring for unauthorized access and abuse.
• Legal Compliance: Tax recordkeeping and breach notification.
• Theological Validation: Processing content through AQUILA to ensure BFM 2000 alignment.

3.3 What We Never Do With Data

• We never sell Partner data or church member data to any third party.
• We never share Partner data for advertising or marketing purposes.
• We never use church member data for any purpose other than building requested tools.
• We never train external AI models on Partner-specific data.

4. Data Sharing

4.1 Three-Tier Consent Framework

Data sharing is governed by the Partner’s selected consent tier:

• Tier 1 — Share Everything: Project shared as showcase with live link. Written approval required.
• Tier 2 — Framework Only: Anonymized patterns shared. No Partner identity or PII.
• Tier 3 — Nothing Shared: All engagement details confidential.

4.2 Data Never Sold

Regardless of consent tier, Partner data and church member data are never sold to third parties.

4.3 Required Disclosures

We may disclose data when required by valid legal process, law enforcement request, or to protect rights, safety, or property. We will notify the affected Partner promptly unless prohibited by law.

5. Children’s Privacy (COPPA Compliance)

5.1 Factory Services and Children

Factory services are designed for use by adult Account Administrators and authorized users. We do NOT knowingly collect personal information directly from children under 13.

If we become aware that we have collected personal information from a child under 13 without verification of parental consent, we will take prompt steps to delete that information from our systems.

5.2 Tools Built for Partners

When Partners request tools that may be used by children under 13 (e.g., children’s ministry check-in), the Partner as Data Controller is solely responsible for COPPA compliance. The Factory will implement requested technical safeguards. Partners must inform the Factory during discovery if a tool will collect children’s data.

5.3 Reporting

If you believe we have collected information from a child under 13, contact us at [email protected].

6. Third-Party Service Providers

6.1 Essential Service Providers

Provider	Service	Data Shared	Purpose
Anthropic	AI Processing (Claude LLM)	Conversation content, project specs, generated code	AI-powered tool building and content creation
Stripe	Payment Processing	Billing name, email, payment card details (direct to Stripe)	Secure donation processing
InterServer	Hosting Infrastructure	Application code, database contents, configuration files	Hosting of Factory and Partner applications
Cloudflare	CDN and Security	Domain configuration, web traffic metadata	Performance, DDoS protection, SSL/TLS
MongoDB Atlas	Database Services	Project data, knowledge base content	Data storage and retrieval

6.2 Changes to Providers

Material changes affecting Partner data handling communicated at least thirty (30) days before taking effect.

7. Data Breach Notification (Florida §501.171)

7.1 Definition

A “breach” means unauthorized access of data in electronic form containing personal information, consistent with Florida Statute §501.171(1)(a).

7.2 Notification Timeline

• Partner Notification: Within thirty (30) days of breach determination.
• Individual Notification: Within thirty (30) days where Factory is Data Controller.
• Partner Responsibility: Where Factory is Processor, Partner notifies data subjects.
• Law Enforcement Delay: Notification may be delayed if a law enforcement agency determines that notification would impede a criminal investigation, consistent with Florida Statute §501.171(5).

7.3 Notification Content

Breach notifications include: date of breach, description of information affected, Factory contact information, remedial actions taken, and guidance for affected individuals.

7.4 Breach Response Procedures

Upon discovery of a potential breach, the Factory will:

1. Contain: Take immediate steps to contain the breach and prevent further unauthorized access.
2. Investigate: Determine the scope and nature of the breach.
3. Remediate: Implement remedial measures to address the vulnerability.
4. Notify: Provide notification per the timelines above.
5. Document: Maintain a record of the breach, investigation, and all remedial actions.

7.5 Florida Department of Legal Affairs

Breaches affecting 500+ Florida individuals reported within thirty (30) days as required by law.

8. Data Retention and Deletion

8.1 Retention Periods

Data Category	Retention Period
Active project files and code	Indefinitely while active
Completed project files	Two (2) years from completion
Conversation history	One (1) year
Account Administrator contact info	Duration of partnership plus one (1) year
Usage metrics	One (1) year
Payment records	Seven (7) years (IRS)
Technical logs	Ninety (90) days

8.2 Deletion Requests

Partners may request deletion at any time. Data deleted within ninety (90) days unless legally required to retain. Written confirmation provided. Deletion from backup systems may take up to an additional thirty (30) days.

8.3 Aggregate and Anonymized Data

The Factory may retain aggregate and anonymized data indefinitely for service improvement, research, and reporting. Such data does not identify any individual Partner or data subject and is not subject to deletion requests.

9. Your Rights and Choices

• Access and Correction: Request access to your data at any time. Copy provided within thirty (30) days.
• Data Portability: Request complete data export in standard formats within thirty (30) days.
• Deletion: Request deletion per Section 8.2.
• Opt-Out: Opt out of non-essential communications at any time.

10. Security Measures

10.1 Technical Safeguards

• Encryption of data in transit (TLS/SSL)
• Access controls limiting data access to authorized personnel
• Regular security monitoring and logging
• Input sanitization for all LLM prompts to prevent injection attacks
• Secure hosting infrastructure configuration

10.2 Organizational Safeguards

• Limiting access to personal information to personnel who require it
• Maintaining this Privacy Policy and related data handling procedures
• Conducting periodic reviews of security practices

10.3 Limitations

No method of data transmission or storage is completely secure. While we implement reasonable safeguards, we cannot guarantee the absolute security of personal information.

11. Contact Information

DRAFT — NOT LEGAL ADVICE — REQUIRES ATTORNEY REVIEW