Privacy Policy — DRAFT

STATUS: DRAFT for attorney review — NOT legal advice, NOT final, NOT in force. Built on

docs/research/legal-docs-outline.md §5 and the map-feature research. [LAWYER] = needs counsel;

[DECISION] = owner decision; [VERIFY] = confirm the actual technical/vendor behavior before this

line is final. English drafted first (intended controlling language [DECISION]); PT/ES after sign-off.

App name is "Ganavo" (ganavo.app); trademark clearance remains a [LAWYER] item.

Effective date: [to be set at launch] · Last updated: 2026-07-06 (draft)

This policy explains what Ganavo ("we", "us", the "App") collects, how we use it, who we share

it with, and your choices. It also supports Apple's and Google's requirement that apps collecting data

publish a privacy policy and disclose their data practices (the App Store "privacy label" is kept consistent

with this policy) [LAWYER/VERIFY: keep the store data-disclosure label in sync with this document.]

1. What we collect

phone number (stored for verification) [Directory/phone-verify — future].

payment instructions you enter. If you publish a Directory listing, that profile is public by

design [Directory — future].

This is private to your account (protected by row-level security) and not shared with other users.

to transcribe it, and the resulting transcript and AI-drafted quote text. See §3 for how audio is

processed and §6 for retention.

typed name, drawn signature, and date/time, plus a hashed IP address and browser user-agent (kept

as anti-fraud/e-sign evidence — we store a one-way hash of the IP, not the raw IP). This evidence is

associated with your quote and shared with you (the service provider who sent it).

counters; and, for abuse prevention, coarse signals such as a hashed IP or device identifier

[Directory ratings/anti-abuse — future].

county), never as GPS coordinates [Directory — future]**.

• Account identifiers — an anonymous account ID; optionally, a backup email; for certain features, a
• Business profile — your name, business name, contact info, logo, document preferences, and (optional)
• CRM data — your clients (names, contact info, addresses, notes), quotes, and invoices.
• Voice & transcripts — when you use voice features, we capture an audio recording of your dictation
• Client acceptance evidence — when your client accepts a quote via a link, we record the client's
• Usage & abuse signals — counts of certain actions (e.g., AI usage) for limits/billing; rate-limit
• Directory search logs — if you use the Directory, searches are logged at **place granularity (city/

2. Location

Location is used only when you take an action that needs it (e.g., "search near me" in the Directory),

as a one-time read. We do not track your location in the background and do not store your

location as a history. Consumer location powers the current search session only. **[Directory — future; the

data model is built to make this literally true.]**

3. How AI processing works (named providers)

To provide voice and AI features, your content is processed by third-party AI providers:

Anthropic (Claude) to draft a structured quote or translate it.

for automated safety screening [Directory — future].

We send only what's needed for the feature. **We do not use your CRM data or voice content to train our own

models.** Provider handling of data sent to them is governed by their terms; we select providers that offer

business/API data protections. **[VERIFY: confirm ElevenLabs + Anthropic API data-retention/no-train terms

and cite them; [LAWYER] on the disclosure.]**

• Transcription — your voice audio is sent to ElevenLabs to produce a text transcript.
• Quote structuring & translation — the transcript (and quote text you translate) is sent to
• (Directory) content safety — if you publish listing content/photos, they may be sent to Anthropic

4. How we use what we collect

To: provide and maintain the App (create/send quotes, invoices, documents, acceptance links); transcribe and

draft from your voice; translate documents; record client acceptance as e-sign evidence for you; enforce

usage limits and prevent abuse/fraud; secure the service; comply with law; and communicate with you about

the service. We do not sell your personal information. [LAWYER: CCPA "sale/share" definitions.]

5. How your voice audio is handled (retention)

Your voice recording is processed to create the transcript and is not stored by us as a saved recording

— it is handled transiently in our server function and passed to the transcription provider, then discarded

on our side. The transcript becomes part of your quote draft, and is retained as your CRM data if you

save the quote (you can edit or delete it like any quote content). We keep an aggregate count of voice

usage (e.g., seconds) for limits/billing, not the audio. **[VERIFY: confirm this matches the deployed

behavior — audio not persisted by us; transcript retained as quote content — and confirm the transcription

provider's retention; [DECISION] if any change.]**

6. Retention & deletion

public listing, subject to limited retention required by law, accounting, or security/anti-abuse.

quote as a record of the agreement; it is deleted with the quote/account, subject to the same limited

exceptions. [LAWYER: e-sign evidence retention expectations.]

user," so account deletion can't erase honest feedback about others [Directory — future].

• You can delete your account in the App. Deleting removes your profile, CRM data, and (if present) your
• Client acceptance evidence (name, signature, timestamp, hashed IP) is retained with the associated
• (Directory) Ratings you authored are retained if you delete your account, re-attributed to a "former
• We retain limited records as required for legal, tax, or security purposes. [LAWYER: retention schedule.]

7. Who we share with (processors)

We share data with service providers that help us run the App, under contracts limiting their use to

providing services to us. Current/planned processors:

an email provider (e.g., Resend/SES) for notifications, a push provider (Expo), RevenueCat

(subscriptions — Phase 5), a payment processor (e.g., Stripe — Phase 4, the service provider is merchant of record).

We update this list as features ship. We may also disclose information to comply with law or protect rights,

users, and safety. [LAWYER: legal-process disclosure language; keep the processor list current.]

• Supabase — hosting, database, authentication, storage.
• ElevenLabs — voice transcription.
• Anthropic (Claude) — quote structuring, translation, (Directory) content safety.
• Vercel — hosting of the public site and client quote pages (ganavo.app).
• Apple / Google — app distribution and, if offered, in-app purchases [Phase 5].
• Planned: Twilio (SMS phone verification — Directory), Google Web Risk (link safety — Directory),

8. Public information (Directory) & your controls

If you publish a Directory listing, the information in it (business name, area, contact surfaces you choose

to show, photos, and any ratings) is public to anyone using the App. Think before publishing your phone

or email — display toggles let you choose what's shown. Your private CRM data is never made public.

[Directory — future.]

9. Security

We protect data with row-level security (each account can access only its own CRM data), server-side

handling of sensitive keys (never shipped in the app), a curated/minimal data surface on the public quote

page, and hashed (not raw) IP storage for acceptance evidence. We never hold your funds. No system is

perfectly secure; we describe our measures honestly and do not promise absolute security. **[LAWYER: breach-

notification obligations by state.]**

10. Children

The App is for adults (18+). We do not knowingly collect personal information from children. If you

believe a minor has provided us data, contact us and we will address it. [LAWYER: COPPA posture.]

11. Your privacy rights

Depending on where you live, you may have rights to access, correct, delete, or port your personal

information, and to opt out of certain processing. We honor in-App account deletion for everyone. To make

other requests, contact us (§13). We will verify and respond as required by applicable law. **[LAWYER: CCPA/

CPRA + other state laws (e.g., CT); request intake, verification, and response SLA; who answers.]**

12. International & where data is processed

The App is intended for users in the United States; data is processed in the U.S. by us and our

providers. [LAWYER: confirm provider regions; cross-border language if any provider processes elsewhere.]

13. Contact & changes

notice in-App (and by email where available).

• Privacy questions / requests: [privacy inbox email] [HUMAN: set the address.]
• We may update this policy; we'll post the new version with an updated date and, for material changes,

Open items carried from the outline (block finalizing, not drafting)

[VERIFY] voice-audio non-retention + provider retention/no-train · [LAWYER] full review; CCPA/CPRA + state

rights mechanics & SLA; breach notification; retention schedule; e-sign evidence retention · [DECISION]

controlling language · [HUMAN] privacy inbox address · keep the App Store data-disclosure label in sync ·

[Directory/Phase 4/5 — future] sections activate when those features ship · trademark clearance for "Ganavo" [LAWYER].