2. Key definitions

“Personal Data” means information that identifies or can reasonably be linked to an identifiable individual.
“Client Content” means the information and files you submit (including uploaded documents) in connection with Requests.
“Processing” means any operation performed on data (collection, storage, use, disclosure, deletion, etc.).

3. Information we collect

3.1 Information you provide to us

We collect information you provide directly, including:

• Contact information: first name, last name, email address, phone number.
• Account information: login credentials (stored in hashed form), password reset tokens, security settings.
• Request details: instructions, urgency level, notes, messages, and any contextual information you submit.
• Uploaded files: documents and supporting materials you upload with your Request.
• Billing information: billing name, billing address, invoice details, payment confirmation details, bank transfer references.
• Support communications: emails, chats, feedback, complaints, and other correspondence.

3.2 Information we collect automatically

When you use the Service, we may automatically collect:

• Device and usage data: IP address, browser type, device identifiers, operating system, pages viewed, actions taken, referral URLs, timestamps.
• Log data: access logs, error logs, authentication events, and system activity.
• Approximate location: derived from IP address (city/country level), used for security and analytics.
• Cookies and similar technologies: for session management, preferences, security, and analytics (see Section 8).

3.3 Information from third parties

We may receive information from third parties in limited circumstances, such as:

• Payment processors: confirmation of payment status, chargeback notifications, and limited billing metadata.
• Service providers: security alerts, deliverability signals, or fraud risk indicators.

We do not intentionally collect special category/sensitive personal data (e.g., health data, biometric data, political opinions) unless you choose to include it in your Request. Please avoid uploading sensitive personal data unless it is strictly necessary.

4. How we use your information

We use your information to:

• Provide the Service: receive Requests, communicate, produce and deliver Deliverables, manage accounts, and provide support.
• Process payments: issue invoices, confirm payments, handle refunds (where applicable), and manage billing disputes.
• Security and fraud prevention: protect accounts, detect unauthorized access, prevent abuse, and maintain system integrity.
• Improve and develop: monitor performance, debug, analyze usage trends, and improve features and user experience.
• Compliance and legal obligations: comply with applicable laws, respond to lawful requests, enforce our Terms, and keep required records.
• Communications: send operational emails (e.g., confirmations, status updates), and respond to your inquiries.

We will not sell your personal information.

5. Legal bases for processing (where applicable)

Where data protection laws require a legal basis, we process Personal Data based on one or more of the following:

• Contract: to provide the Service and fulfill Orders you request.
• Legitimate interests: to operate, secure, and improve the Service, prevent fraud, and provide support (balanced against your rights).
• Consent: where we ask you (e.g., optional marketing communications or certain cookies, if implemented).
• Legal obligation: to comply with laws, regulations, and lawful requests.

6. How we share your information

We may share information in the following situations:

6.1 Service providers

We use trusted third-party providers to help run TFOVA (for example: hosting, cloud storage, email delivery, analytics, customer support tools, and payment processing). These providers may process Personal Data on our behalf under contractual obligations to protect it and use it only for specified purposes.

6.2 Legal, compliance, and protection

We may disclose information if we believe in good faith that disclosure is necessary to:

• Comply with law, regulation, legal process, or lawful governmental request.
• Protect the rights, property, and safety of Paylero, our users, or the public.
• Investigate and help prevent security incidents, fraud, or abuse.
• Enforce our Terms & Conditions.

6.3 Business transfers

If we are involved in a merger, acquisition, restructuring, financing, or sale of assets, information may be transferred as part of that transaction, subject to appropriate safeguards.

We do not share Client Content with other customers. We do not publish your Requests or Deliverables publicly.

7. Data retention

We retain Personal Data and Client Content only as long as reasonably necessary for the purposes described in this Policy, including: providing the Service, maintaining business records, resolving disputes, enforcing agreements, and complying with legal obligations.

Retention periods may vary based on data type and context. For example:

• Account data: retained while your account is active and for a reasonable period thereafter.
• Requests and Deliverables: retained to support delivery, revisions, and support inquiries, then archived or deleted based on internal schedules.
• Billing and invoices: retained as required by applicable accounting and tax laws.
• Security logs: retained for a limited period for security and audit purposes.

You may request deletion (see Section 10). Some information may be retained where required by law or for legitimate business purposes (e.g., fraud prevention, dispute resolution).

8. Cookies and similar technologies

We may use cookies, local storage, and similar technologies to:

• Maintain sessions and keep you logged in.
• Remember preferences (e.g., language settings).
• Improve security and prevent abuse.
• Measure usage and performance (analytics).

You can control cookies through your browser settings. If you disable cookies, parts of the Service may not function correctly.

9. Security

We maintain reasonable administrative, technical, and organizational safeguards designed to protect Personal Data and Client Content. Measures may include access controls, encryption in transit (e.g., TLS), least-privilege permissions, and monitoring for suspicious activity.

Despite these efforts, no method of transmission or storage is completely secure. You are responsible for keeping your login credentials confidential and using strong passwords.

10. Your rights and choices

Depending on your jurisdiction, you may have rights regarding your Personal Data, including:

• Access: request a copy of your Personal Data.
• Correction: request corrections to inaccurate or incomplete data.
• Deletion: request deletion of Personal Data (subject to legal and operational limits).
• Portability: request certain data in a portable format (where applicable).
• Objection / restriction: object to or request restriction of certain processing (where applicable).
• Withdraw consent: where processing is based on consent, you can withdraw it at any time.

To make a request, contact us at support@tfova.com. We may need to verify your identity before fulfilling the request.

11. International data transfers

We may process and store data in multiple countries, including where our service providers operate. Where required, we use appropriate safeguards for international transfers.

12. Children’s privacy

TFOVA is not intended for children under 18. We do not knowingly collect Personal Data from children. If you believe a child has provided Personal Data, contact us and we will take steps to delete it.

13. Links to other sites

The Service may contain links to third-party sites. We are not responsible for the privacy practices of those sites. Please review their policies before providing information.

14. Changes to this Policy

We may update this Policy from time to time. The “Effective date” above indicates when the latest version took effect. If we make material changes, we will post the updated Policy on this page and may notify registered users by email or within the Service.

Questions? Please email us at support@tfova.com.