Privacy Policy

Our principles

These principles guide how we handle your privacy:

• We cannot see your vault. Privara uses a zero-knowledge architecture. Your photos, videos, notes, contacts, and documents are encrypted on your device with keys we never possess. We do not access, scan, or analyse your vault content.
• We collect only what is necessary. Any data we collect is used to operate Privara, fix issues, and improve your experience — nothing more.
• We do not sell your personal information. We do not share your data with advertisers or data brokers for their marketing purposes.
• We disclose data only when required by law or for safety. We access or share personal data only under a lawful obligation or when we have genuine concerns about violations of our Terms of Service or this Privacy Policy.

1. Scope

This Privacy Policy describes how Echo Persona LLC, located at 2201 Menaul Blvd NE Ste A, Albuquerque, New Mexico 87107-1711, United States ("we," "us," or "our"), collects, uses, discloses, and protects information when you use:

• our website at privarahq.com, the Privara iOS application, and any related services (collectively, the "Service");
• any related customer support, communications, marketing, surveys, and events.

This policy applies worldwide. Some regions grant additional rights and require extra disclosures; see Section 15 (Regional Disclosures) for details. For privacy-specific enquiries, you may reach us at privacy@privarahq.com.

By using the Service you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please do not use the Service.

2. Definitions

• Personal Data / Personal Information: information that identifies, relates to, or could reasonably be linked to an identifiable individual.
• Processing: any operation performed on Personal Data — collecting, recording, storing, using, sharing, deleting, or otherwise handling it.
• Controller / Business: the entity that determines the purposes and means of processing Personal Data. For this Service, that is Echo Persona LLC.
• Processor / Service Provider: a party that processes Personal Data on behalf of the Controller / Business.
• Sensitive Data: categories of data that receive heightened protection under certain laws, which may include precise geolocation, biometric information, government-issued identifiers, health data, and similar categories.
• Biometric Information: physiological or behavioural characteristics used for identification, such as fingerprints or facial geometry. Privara uses Apple's biometric APIs (Face ID, Touch ID, Optic ID) but does not itself collect, store, or transmit biometric data — see Section 16.
• User Content: content you upload, store, create, or transmit through the Service, such as photos, videos, notes, voice memos, contacts, and documents.

3. Information we collect

We collect the minimum information necessary to operate the Service. The {appName} iOS app is built to collect as little data as possible — in practice, almost everything stays on your device. Below is a complete description of what we collect and how.

A. Information you provide

• Contact details: name and email address if you contact us, submit a support request, or sign up for updates.
• User Content (vault data): Privara is designed so that all content you store — photos, videos, notes, voice memos, contacts, and documents — remains encrypted on your device. We do not have access to this content. If you choose to share content with us (for example, in a support request), only what you share is received.
• Transaction information: when you purchase a subscription, payment is processed by Apple through In-App Purchase. We may receive limited transaction data (such as confirmation that a purchase occurred, subscription tier, and expiry date) but never your payment card details.
• Feedback and correspondence: information you share when you contact support, respond to surveys, leave App Store reviews, or otherwise interact with us.
• Device permissions: if you grant permission, we may access camera, photo library, microphone, location, contacts, or other device features necessary for Privara's functionality. See Section 4 for a complete list. You can revoke any permission at any time in your device settings.

B. Information collected automatically (website only; app collects nothing)

The {appName} iOS app does not automatically collect usage data, crash logs, analytics events, device identifiers, or IP addresses. The following limited collection applies to our website or is performed independently by Apple — not by us:

• Website analytics: our website uses Vercel Web Analytics for aggregated page view counts and general referrer information (no individual profiles from that service). If you accept analytics in our cookie banner, we also use Google Analytics 4 (GA4), provided by Google Ireland Limited / Google LLC, to measure how the site is used. GA4 may use cookies or similar storage (for example _ga) when you opt in. Advertising-related storage (ad_storage, ad_personalization, ad_user_data) remains denied unless we use Google advertising features and you consent separately. We implement Google Consent Mode v2 so Google tags respect default-denied storage until you consent. This applies to the website only — not the iOS app.
• Apple crash diagnostics (Apple, not us): Apple may independently collect crash reports and device diagnostics in accordance with Apple's Privacy Policy and your device settings (Settings → Privacy & Security → Analytics & Improvements). This data is sent to Apple, not to us.
• No app telemetry: the {appName} iOS app contains no analytics SDKs, telemetry, or background usage-reporting code. We do not receive any data about how you use the app.
• Cookies and similar technologies (website only): we use strictly necessary cookies where required for basic site operation. If you accept analytics in our cookie banner, GA4 may set analytics cookies or use equivalent storage. We use Google Consent Mode v2: defaults deny analytics and advertising storage until you choose Accept analytics or Essential only. We do not use advertising cookies for cross-site behavioural ads on this site. See the Cookie Notice at the end of this policy.

C. Information from third parties

• Apple App Store: purchase verification data and fraud-prevention signals.
• Analytics (website only): our website uses Vercel Web Analytics and, when you consent, Google Analytics 4 as processors to understand site traffic. We do not use analytics providers within the iOS app and do not receive app usage or install analytics from third parties for the app. Google's privacy policy: https://policies.google.com/privacy
• We do not receive data from advertising networks. Privara is subscription-based and does not display adverts.

4. iOS device permissions and sensor data

Privara may request the following iOS permissions and use the following sensor data. Each is used only for the stated purpose and can be revoked at any time in your device's Settings app.

• Camera: used for the direct-to-vault camera feature (capturing photos directly into your encrypted vault) and for break-in detection (silently capturing a front-camera photo when an incorrect passcode is entered).
• Photo Library: used to import existing photos and videos from your device into the encrypted vault.
• Microphone: used to record encrypted voice memos within the app.
• Location Services: used solely for break-in detection. When an incorrect passcode is entered, the app logs the GPS coordinates of the attempt. Location data is stored encrypted on your device and is never transmitted to our servers.
• Face ID / Touch ID / Optic ID: used for biometric vault unlock. Privara calls Apple's LocalAuthentication framework, which handles all biometric matching within the device's Secure Enclave. No biometric data (fingerprint, facial geometry, iris scan) is ever collected, stored, or transmitted by Privara.
• Contacts: if granted, used to optionally import contacts into the app's encrypted contacts feature. Imported contacts are encrypted on-device. We do not upload your address book to any server.
• Notifications: used to deliver break-in detection alerts (approximately 15 minutes after a failed passcode attempt) and optional service announcements.
• Accelerometer: used for the face-down lock and shake-to-lock features. The app detects device orientation or shaking motion and immediately locks the vault. No accelerometer data is stored or transmitted.
• iCloud / CloudKit (Premium): when enabled, used to sync your encrypted vault across your signed-in Apple devices. Only already-encrypted data is transmitted via Apple CloudKit. We cannot decrypt this data.

You can disable any permission at any time by going to Settings > Privacy & Security on your iOS device. Disabling a permission may affect the corresponding feature but will not affect the rest of the app.

5. How we use information

We use information to:

• Provide and operate the Service — store encrypted content, enable features, authenticate users, process subscriptions, and deliver support.
• Maintain safety and security — prevent fraud and abuse, detect suspicious activity, enforce our policies, and protect users.
• Improve and develop — reviewing support feedback, monitoring website analytics, and guiding product decisions to make Privara better.
• Customer support — respond to requests, troubleshoot issues, and provide service updates.
• Billing and transactions — process subscription payments through Apple, manage subscription status, and handle tax or VAT obligations where required.
• Marketing and communications — send service messages, product updates, offers, and newsletters. You can opt out of marketing communications at any time.
• Legal compliance — comply with applicable laws, respond to lawful requests, and establish or defend legal claims.
• With your consent — where required by applicable law, we rely on your consent for certain processing activities, such as specific device permissions or certain marketing in some regions.

6. Legal bases (EEA/UK and similar jurisdictions)

If you are in the European Economic Area, United Kingdom, or a jurisdiction with similar requirements, our legal bases for processing include:

• Contract: processing necessary to deliver the Service you have requested (account operation, feature delivery, subscription management).
• Legitimate interests: security, fraud prevention, service improvement, analytics, and customer support, where not overridden by your data protection rights.
• Consent: for specific device permissions (camera, location, etc.), certain marketing communications, and certain cookies.
• Legal obligation: to comply with tax, accounting, regulatory, and law-enforcement requirements.

7. How we share information

We may share Personal Data as follows:

• Service providers / processors: companies that help us operate the Service, including hosting and infrastructure, analytics, customer support tooling, and email delivery. They process data only as needed to provide services to us and under contractual obligations to protect it.
• Legal, compliance, and safety: to comply with applicable law, legal process, or governmental requests; to enforce our Terms of Service; to respond to claims; or to protect the rights, property, or safety of Echo Persona LLC, our users, or the public.
• Corporate transactions: in connection with a merger, acquisition, reorganisation, or sale of assets, your information may be transferred as part of that transaction. We will provide notice as required by applicable law.
• With your direction: when you choose to share content or direct us to disclose information to a third party.

Break-in detection data (photos and GPS coordinates captured on failed passcode attempts) is stored encrypted on your device only. We never receive, access, or share this data.

We do not sell your Personal Information in the traditional sense. We do not share it with data brokers or advertisers. Some privacy laws define "sale" or "sharing" broadly; see Section 15 for region-specific opt-out information.

8. Analytics and tracking

Analytics

Our website uses (1) Vercel Web Analytics — aggregated, privacy-oriented measurement without the same cookie-based profiling as traditional analytics — and (2) Google Analytics 4 (GA4), subject to your consent via our cookie banner. Until you accept analytics, Google tags run with Consent Mode defaults that keep analytics_storage denied; limited cookieless pings may still occur per Google's Consent Mode behaviour. When you accept, GA4 may use cookies or similar storage. The {appName} iOS app contains no analytics SDK and collects no crash reports, usage events, or telemetry. Apple may independently collect crash diagnostics through their own system, governed by Apple's Privacy Policy.

No advertising or ad tracking

Privara is entirely subscription-based. We do not display advertisements, use advertising SDKs, or collect advertising identifiers (IDFA). The App Tracking Transparency prompt is not shown because we do not track users across other companies' apps or websites.

Cookies (website only)

Where required by law we show a cookie banner before enabling non-essential analytics storage. We use Google Consent Mode v2: defaults deny analytics and advertising storage until you accept; Essential only keeps analytics cookies/storage off. See the Cookie Notice at the end of this policy.

Do Not Track / Global Privacy Control

We respect Global Privacy Control (GPC) signals where legally required. For general "Do Not Track" browser signals, there is no industry consensus on their meaning; however, we do not engage in cross-site tracking.

9. Data retention

We keep Personal Data only as long as necessary for the purposes described in this policy. Specific retention practices:

• Vault content: stored exclusively on your device (and, if enabled, in encrypted form in your iCloud account). Deleted when you delete it, when you use the Escape PIN, or when you uninstall the app. We never possess vault content.
• Break-in detection data: photos and GPS logs from failed passcode attempts are stored encrypted within your vault on-device. You can view and delete them at any time.
• iCloud sync data: encrypted data synced via CloudKit follows Apple's iCloud data retention policies. When you disable sync or delete your vault, synced data is removed.
• Support correspondence: retained for as long as necessary to resolve your issue and for a reasonable period afterwards for quality and training purposes, then deleted.
• Billing records: subscription and transaction records are retained as required by applicable tax and accounting laws (typically 3–7 years).
• Website analytics: Vercel Web Analytics aggregates are retained for up to 12 months, after which they roll off automatically. GA4 data is retained according to the settings in our Google Analytics property (see Google's documentation for Analytics data retention).

If you request deletion of your data, we will process the request within the timeframes required by applicable law, subject to any legal obligations to retain certain records.

10. Security

We employ administrative, technical, and organisational safeguards designed to protect your Personal Data. Key measures include:

• AES-256-GCM encryption: all vault content is encrypted on your device before storage. Encryption keys are generated and stored in the iOS Keychain, protected by the Secure Enclave.
• Zero-knowledge architecture: we do not possess your passcodes, encryption keys, or unencrypted vault content. Even if our systems were compromised, your vault data would remain encrypted and inaccessible.
• Encryption in transit: all communications between the app, our website, and any backend services use TLS 1.2 or later.
• Access controls: internal access to any user-related data (such as support correspondence) is limited to personnel who need it and is subject to audit.
• Biometric security: biometric data for Face ID, Touch ID, and Optic ID is handled entirely by Apple's Secure Enclave hardware and never leaves the device.

No method of electronic transmission or storage is completely secure. Whilst we strive to use commercially acceptable means to protect your data, we cannot guarantee absolute security. If you believe the security of your information has been compromised, please contact us immediately at support@privarahq.com.

11. Your choices and controls

Depending on the Service and your device, you may control:

• Device permissions: revoke camera, photo library, microphone, location, contacts, or notification permissions at any time in iOS Settings.
• Biometric unlock: enable or disable Face ID, Touch ID, or Optic ID for vault access within the app's settings.
• Marketing communications: opt out of marketing emails by using the unsubscribe link in any message or by contacting us. You will still receive essential service communications.
• Cookie preferences: manage or delete cookies through your browser settings. Disabling cookies may affect website functionality.
• Vault data deletion: delete individual items, entire albums, or your full vault from within the app at any time. You can also use the Escape PIN to permanently and irrecoverably destroy the real vault.
• Data deletion requests: contact us at privacy@privarahq.com to request deletion of any personal data we hold (such as support correspondence or account-related records). See Section 12 for details.
• Declining to provide information: some data is necessary to operate certain features. If you do not provide it or revoke the related permission, that feature may not be available, but the rest of the app will continue to function.

12. Individual rights requests

Depending on your location, you may have the right to:

• Access: request a copy of the Personal Data we hold about you.
• Correct: request correction of inaccurate Personal Data.
• Delete: request deletion of your Personal Data, subject to legal exceptions.
• Restrict or limit processing: request that we limit how we use your data.
• Object to processing: object to our processing of your data in certain circumstances.
• Data portability: receive your Personal Data in a structured, commonly used, machine-readable format.
• Withdraw consent: where processing is based on consent, withdraw it at any time without affecting prior processing.
• Appeal: if we decline a request, you may appeal our decision.

How to submit a request

Email privacy@privarahq.com with the subject line "Privacy Rights Request" and include: the email address or phone number associated with your interactions with us, your country or state of residence, and the right you wish to exercise.

Verification: to protect you from unauthorised requests, we may verify your identity before fulfilling a request. If an authorised agent submits a request on your behalf, we may require written proof of authorisation.

We will respond within the timeframes required by applicable law (typically 30 days for GDPR, 45 days for CCPA/CPRA). If we need more time, we will notify you.

13. Children's privacy

The Service is not directed to children under the age of 13 (or under 16 in jurisdictions where a higher age of consent applies). We do not knowingly collect Personal Data from children below the applicable age.

If you are a parent or guardian and believe your child has provided us with Personal Data, please contact us at privacy@privarahq.com. We will promptly investigate and delete any such data.

The Privara iOS app is rated in accordance with Apple's App Store age-rating guidelines.

14. International data transfers

Echo Persona LLC is based in the United States. Your Personal Data may be collected, used, and stored in the United States or other countries where we or our service providers operate. Privacy laws in those locations may differ from those in your country of residence.

For transfers of Personal Data from the European Economic Area, United Kingdom, or Switzerland to countries not deemed to have adequate data protection, we rely on lawful transfer mechanisms including:

• European Commission Standard Contractual Clauses (SCCs) pursuant to Decision (EU) 2021/914.
• UK International Data Transfer Addendum or UK International Data Transfer Agreement (IDTA), where applicable.
• Adequacy decisions issued by the European Commission or UK Secretary of State, where available.

You may contact us at privacy@privarahq.com for more information about the safeguards we have in place.

15. Regional disclosures

A. European Economic Area, United Kingdom, and Switzerland (GDPR / UK GDPR)

Controller: Echo Persona LLC, 2201 Menaul Blvd NE Ste A, Albuquerque, New Mexico 87107-1711, United States. Contact: privacy@privarahq.com.

Legal bases for processing: see Section 6 above.

Your rights under the GDPR include:

access, rectification, erasure ("right to be forgotten"), restriction of processing, data portability, objection to processing, and the right not to be subject to solely automated decision-making (including profiling) that produces legal or similarly significant effects.

Biometric data note: under the GDPR, biometric data processed to uniquely identify an individual is a "special category" of data. Privara does not itself process biometric data — Apple's Secure Enclave handles all biometric matching on-device. We receive only a pass/fail authentication result.

You have the right to lodge a complaint with your local supervisory authority (for example, the ICO in the United Kingdom, the CNIL in France, or the BfDI in Germany).

B. California, United States (CCPA / CPRA and other US state laws)

If you are a California resident (or a resident of another US state with a comprehensive privacy law such as Virginia, Colorado, Connecticut, Utah, Texas, Oregon, or Montana), you may have the following rights:

• Right to know / access: request information about the categories and specific pieces of Personal Information we have collected, the sources, purposes, and third parties with whom we share it.
• Right to delete: request deletion of your Personal Information, subject to certain exceptions.
• Right to correct: request correction of inaccurate Personal Information.
• Right to opt out of sale or sharing: we do not sell your Personal Information. If we ever engage in "sharing" (as broadly defined by the CPRA) for cross-context behavioural advertising, you may opt out.
• Right to limit use of sensitive Personal Information: we collect precise geolocation (break-in detection) and call upon biometric functionality (via Apple's Secure Enclave). You can disable location services and biometric unlock in your device settings.
• Non-discrimination: we will not discriminate against you for exercising your privacy rights.

Categories of Personal Information collected in the preceding 12 months:

• Identifiers (email address — only if you contact us for support)
• Commercial information (subscription tier and expiry date — received from Apple upon purchase)
• Internet or electronic network activity (website page views — aggregated via Vercel Web Analytics; if you consent, measurement via Google Analytics 4; no in-app activity collected by us)
• Geolocation data (precise GPS only for break-in detection — stored encrypted on your device only; we never receive this)
• Sensory data (photos, voice memos — stored encrypted on your device only; we do not access, receive, or process these)
• Inferences: none — we do not derive inferences about you from your use of the app.

Retention: see Section 9.

To submit a request, email privacy@privarahq.com. We will verify your identity before processing. You may designate an authorised agent; we may require written proof of authorisation. We will respond within 45 days (extendable by an additional 45 days with notice).

C. Brazil (LGPD)

If you are located in Brazil or your data was collected in Brazil, the Lei Geral de Proteção de Dados (LGPD) may apply. Under the LGPD, you have rights including: confirmation of processing, access, correction, anonymisation or deletion of unnecessary data, data portability, information about sharing, and the ability to revoke consent.

To exercise these rights, contact us at privacy@privarahq.com.

D. Other jurisdictions

• Canada (PIPEDA / provincial laws): Canadian residents may request access to and correction of their Personal Information. Contact us at privacy@privarahq.com.
• Australia (Privacy Act 1988): Australian residents may request access to and correction of their Personal Information and may complain to the Office of the Australian Information Commissioner (OAIC) if unsatisfied with our response.
• South Africa (POPIA): South African residents have rights under the Protection of Personal Information Act, including access, correction, and deletion. You may lodge a complaint with the Information Regulator.
• India (DPDP Act): Indian residents have rights under the Digital Personal Data Protection Act, 2023, including access, correction, erasure, and grievance redressal. Contact us at privacy@privarahq.com.

If you reside in another jurisdiction with applicable data protection laws, please contact us at privacy@privarahq.com to exercise your rights. We will work in good faith to comply with applicable legal requirements.

16. App-specific data practices (Privara iOS app)

This section describes how data is handled within the Privara iOS application specifically.

On-device encryption architecture

All vault content is encrypted using AES-256-GCM before it is written to storage. Encryption keys are generated on your device and stored in the iOS Keychain, which is protected by the device's Secure Enclave hardware. We never generate, possess, or have access to your encryption keys.

Zero-knowledge design

We cannot see your vault contents, your passcodes, or your encryption keys. Even if you enable iCloud Sync, only already-encrypted data is transmitted. Our servers and personnel have no mechanism to decrypt your data.

Break-in detection

When an incorrect passcode is entered, Privara silently captures a photo using the front camera and logs the GPS coordinates of the device. This data is encrypted and stored within your vault on-device. It is never transmitted to our servers or shared with any third party. You receive a push notification approximately 15 minutes after the attempt. You can review and delete break-in records at any time within the app.

Biometric authentication

Privara supports Face ID, Touch ID, and Optic ID through Apple's LocalAuthentication framework. All biometric matching occurs within the device's Secure Enclave — Privara receives only a pass/fail result. No biometric data (fingerprint templates, facial geometry, iris scans) is ever collected, stored, transmitted, or accessible to Privara or Echo Persona LLC.

On-device processing

OCR text extraction, photo editing (brightness, contrast, crop, etc.), and all encryption/decryption operations run entirely on your device. No vault content is sent to external servers for processing.

iCloud Sync (Premium)

When you enable iCloud Sync, your vault data is encrypted on the sending device before transmission via Apple CloudKit and decrypted on the receiving device. Only encrypted blobs are stored in your iCloud account. We cannot decrypt this data. iCloud Sync is governed by Apple's iCloud Terms of Service and Privacy Policy in addition to this policy.

WiFi Transfer (Premium)

Privara can start a local web server on your device for file transfer over your WiFi network. The connection is protected by a PIN code and QR code authentication. Data travels directly between your devices on your local network. No data is routed through or stored on our servers.

Screen recording and screenshot detection

If the system is recording the screen or a screenshot is taken, Privara can detect it and lock or obscure vault content to protect your privacy. No data about these events is sent externally.

Recovery key

During setup, you receive a 12-character recovery key that can be used to reset your passcodes. If you choose, this key is stored in your iCloud Keychain by Apple. We do not have access to your recovery key.

Escape PIN

The Escape PIN is a separate passcode that, when entered, permanently and irrecoverably destroys the real vault. All files are wiped, all encryption keys are destroyed, and the app opens the decoy vault as if nothing happened. This action cannot be undone and data cannot be recovered by us or anyone else.

17. Apple App Store and platform disclosures

• In-App Purchases: subscription payments are processed by Apple through the App Store's In-App Purchase system. We receive transaction receipts (subscription tier, start/expiry dates, transaction IDs) but never your payment card details, billing address, or Apple ID credentials.
• App Privacy nutrition labels: this Privacy Policy is consistent with the privacy declarations we submit to Apple in App Store Connect. Our App Privacy disclosures on the App Store reflect the data practices described here.
• No ad tracking: Privara does not use the Identifier for Advertisers (IDFA), does not participate in ad networks, and does not track users across other apps or websites. The App Tracking Transparency prompt is not presented because no tracking occurs.
• Apple diagnostics: Apple may independently collect crash reports and diagnostic data from your device in accordance with Apple's own Privacy Policy and your device settings. This collection is managed by Apple, not by us.
• Third-party SDKs: the Privara iOS app does not include third-party advertising, analytics, or tracking SDKs of any kind. Our website (privarahq.com) uses Vercel Web Analytics and Google Analytics 4 when you consent, as described in this policy.

For additional information about Apple's data practices, visit Apple's Privacy site at https://www.apple.com/privacy/.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the "Last updated" date at the top of this page.

For material changes, we will provide additional notice as appropriate — for example, through an in-app notification, a prominent notice on our website, or an email to the address associated with your interactions with us.

Your continued use of the Service after the effective date of a revised policy constitutes your acceptance of the updated terms. If you do not agree with the changes, please stop using the Service.

19. Contact us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We aim to respond to all enquiries within 30 days.

Cookie notice

This Cookie Notice applies to our website at https://privarahq.com only. The Privara iOS app does not use cookies.

Cookies are small text files placed on your device by websites you visit. They help sites function, remember preferences, and understand visitor behaviour.

Types of cookies we may use:

• Strictly necessary cookies: required for the website to function (for example, security and session management). These cannot be disabled.
• Analytics cookies/storage: if you accept analytics in our banner, Google Analytics 4 may store cookies or similar identifiers to measure site usage. Vercel Web Analytics does not rely on the same cookie-based model. You can choose Essential only to decline analytics storage.
• Preference cookies: remember your choices such as language or theme settings.

Managing cookies: you can control or delete cookies through your browser settings. Most browsers allow you to refuse cookies or delete existing ones. Disabling cookies may affect some features of our website.

For more information about cookies, visit . allaboutcookies.org.