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Privacy Policy

Last Updated: October 31, 2025

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1. Introduction

CustodyComms, LLC ("CustodyComms," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website and services (collectively, the "Service"). Please read this Privacy Policy carefully. By accessing or using our Service, you agree to this Privacy Policy.

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE SERVICE.

We reserve the right to make changes to this Privacy Policy at any time. We will notify you of any changes by updating the "Last Updated" date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates.

2. Information We Collect

We collect information about you in several ways when you use our Service:

2.1 Information You Provide to Us

Account Information: When you register for an account, we collect:

  • Name

  • Email address

  • Phone number (optional)

  • Professional credentials and affiliations

  • Organization/law firm information

  • Billing address

  • Payment information (processed securely by third-party payment processors)

Profile Information: You may provide additional information in your profile, such as:

  • Professional role

  • Bar admission details

  • Areas of practice

  • Professional bio

User Content: When you use our Service, you upload and submit:

  • Communications data for analysis (emails, text messages, etc.)

  • Case information

  • Notes and annotations

  • Reports and analyses you create

Communications with Us: We collect information when you:

  • Contact our customer support

  • Participate in surveys or feedback forms

  • Subscribe to our newsletters or marketing communications

2.2 Information Collected Automatically

When you access our Service, we automatically collect certain information:

Usage Information:

  • Pages or features you access

  • Time and date of your visits

  • Time spent on pages

  • Links you click

  • Search queries within the Service

  • Actions you take within the Service

Device Information:

  • IP address

  • Browser type and version

  • Operating system

  • Device type and identifiers

  • Screen resolution

  • Time zone settings

Cookies and Tracking Technologies: We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your browsing activities. See Section 7 for more details about cookies.

2.3 Information from Third Parties

We may receive information about you from:

  • Payment processors (transaction confirmation, payment method information)

  • Analytics providers

  • Marketing partners

  • Publicly available sources (to verify professional credentials)

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 To Provide and Maintain the Service

  • Create and manage your account

  • Process your transactions and send related information

  • Provide customer support

  • Analyze and process User Content as requested

  • Generate reports and analyses

  • Authenticate your identity

  • Send technical notices, updates, and security alerts

3.2 To Improve Our Service

  • Monitor and analyze usage and trends

  • Develop new features and functionality

  • Conduct research and analytics

  • Test and troubleshoot new products and features

  • Optimize the Service for better performance

3.3 To Communicate with You

  • Respond to your inquiries and requests

  • Send administrative information

  • Provide updates about the Service

  • Send newsletters and marketing communications (with your consent)

  • Request feedback or reviews

  • Notify you of changes to our Terms or Privacy Policy

3.4 For Legal and Security Purposes

  • Comply with legal obligations and processes

  • Enforce our Terms and Conditions

  • Protect against fraudulent, unauthorized, or illegal activity

  • Protect the rights, property, and safety of CustodyComms, our users, and the public

  • Respond to law enforcement requests and legal claims

3.5 With Your Consent

  • For any other purpose disclosed to you when we collect the information

  • For purposes you explicitly consent to

4. How We Share Your Information

We may share your information in the following circumstances:

4.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, including:

  • Cloud hosting providers (data storage)

  • Payment processors

  • Customer support platforms

  • Email service providers

  • Analytics providers

  • Marketing and advertising partners

These service providers are bound by contractual obligations to keep your information confidential and use it only for the purposes for which we disclose it to them.

4.2 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on our Service of any change in ownership or uses of your information.

4.3 Legal Requirements

We may disclose your information if required to do so by law or in response to:

  • Valid requests by public authorities (e.g., court orders, subpoenas)

  • Legal processes or government investigations

  • Enforcement of our Terms and Conditions

  • Protection of rights, property, or safety of CustodyComms, users, or the public

4.4 With Your Consent

We may share your information for any other purpose with your explicit consent.

4.5 Aggregated or De-Identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you. This information may be used for research, analytics, or marketing purposes.

4.6 What We DO NOT Do

  • We DO NOT sell your personal information to third parties

  • We DO NOT rent your personal information to third parties

  • We DO NOT share your User Content (communications data) with third parties except as required by law or with your explicit permission

5. Data Security

5.1 Security Measures

We implement appropriate technical and organizational security measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit using SSL/TLS protocols

  • Encryption of sensitive data at rest

  • Regular security assessments and penetration testing

  • Access controls and authentication requirements

  • Employee training on data security and privacy

  • Secure development practices

  • Regular backups and disaster recovery procedures

  • Network security measures including firewalls and intrusion detection

5.2 Data Sensitivity

We understand that the communications data you analyze through our Service may be highly sensitive, involving custody matters, legal proceedings, and personal information. We treat all User Content with the highest level of security and confidentiality.

5.3 No Absolute Security

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials.

5.4 Security Breach Notification

In the event of a data breach that compromises your personal information, we will notify you and relevant authorities as required by applicable law.

6. Data Retention

6.1 Retention Periods

We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Account Information: Retained for the duration of your account plus a reasonable period thereafter for legitimate business purposes.

User Content: Retained as long as you maintain your account or as necessary to provide the Service. You may request deletion at any time.

Usage and Analytics Data: Typically retained for 24-36 months for analysis and improvement purposes.

Communications: Retained for as long as necessary to respond to your inquiries or as required by law.

6.2 Deletion

When we no longer need your information, we will securely delete or anonymize it. However, some information may remain in backup copies for a limited time but will not be available for active use.

6.3 Legal Holds

We may be required to retain certain information for legal proceedings, regulatory requirements, or investigations, even after you request deletion.

7. Cookies and Tracking Technologies

7.1 What Are Cookies

Cookies are small data files placed on your device that help us improve your experience, understand how the Service is used, and customize content.

7.2 Types of Cookies We Use

Essential Cookies: Required for the Service to function. These include authentication and security cookies.

Analytics Cookies: Help us understand how visitors use our Service through tools like Google Analytics.

Functionality Cookies: Remember your preferences and settings.

Marketing Cookies: Track your browsing habits to deliver relevant advertising (only with your consent).

7.3 Cookie Management

Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Service.

7.4 Do Not Track Signals

Some browsers have "Do Not Track" features. We currently do not respond to Do Not Track browser signals. We will update this policy if our practices change.

7.5 Third-Party Analytics

We use third-party analytics services, including:

8. Your Privacy Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

8.1 Access and Portability

You have the right to:

  • Access the personal information we hold about you

  • Request a copy of your information in a portable format

8.2 Correction

You have the right to:

  • Correct inaccurate or incomplete information

  • Update your account information at any time through your account settings

8.3 Deletion

You have the right to:

  • Request deletion of your personal information

  • Close your account and have your information removed

Note: We may retain certain information as required by law or for legitimate business purposes.

8.4 Restriction and Objection

You have the right to:

  • Restrict how we process your information

  • Object to processing based on legitimate interests

8.5 Withdrawal of Consent

Where we rely on your consent to process information, you have the right to withdraw that consent at any time.

8.6 Marketing Communications

You may opt out of receiving marketing communications from us by:

  • Following the unsubscribe link in emails

  • Adjusting your account notification settings

  • Contacting us directly

8.7 Exercising Your Rights

To exercise any of these rights, please contact us at privacy@custodycomms.com. We will respond to your request within 30 days or as required by applicable law. We may need to verify your identity before processing your request.

9. Children's Privacy

Our Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe we have collected information from a child under 18, please contact us immediately at privacy@custodycomms.com, and we will take steps to delete such information.

10. International Data Transfers

10.1 Location of Data Processing

Your information may be transferred to and processed in the United States or other countries where we or our service providers operate. These countries may have data protection laws that differ from those of your country of residence.

10.2 Safeguards

When we transfer your information internationally, we implement appropriate safeguards, including:

  • Standard contractual clauses approved by relevant authorities

  • Privacy Shield frameworks (where applicable)

  • Other legally approved transfer mechanisms

10.3 Consent to Transfer

By using our Service, you consent to the transfer of your information to countries outside your country of residence.

11. State-Specific Privacy Rights

11.1 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know: You can request information about the categories and specific pieces of personal information we have collected, the sources, purposes, and third parties we share it with.

Right to Delete: You can request deletion of your personal information, subject to certain exceptions.

Right to Opt-Out: You have the right to opt-out of the "sale" or "sharing" of personal information. Note: We do not sell personal information as defined by the CCPA.

Right to Correct: You can request correction of inaccurate personal information.

Right to Limit: You can limit the use and disclosure of sensitive personal information.

Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

Shine the Light: California residents can request information about disclosure of personal information to third parties for direct marketing purposes.

To exercise these rights, contact us at privacy@custodycomms.com or call [phone number].

11.2 Virginia, Colorado, Connecticut, and Utah Residents

If you are a resident of Virginia, Colorado, Connecticut, or Utah, you have rights similar to California residents under your state's privacy laws, including rights to access, correct, delete, and opt-out of certain processing activities.

11.3 Nevada Residents

Nevada residents may opt-out of the sale of certain personal information to third parties. We do not currently sell personal information as defined under Nevada law. If you have questions, contact privacy@custodycomms.com.

12. European Economic Area (EEA) and UK Residents

12.1 Legal Basis for Processing

If you are in the EEA or UK, our legal bases for processing your information include:

  • Consent: Where you have given consent

  • Contract: Processing necessary to perform our contract with you

  • Legal Obligation: Compliance with legal requirements

  • Legitimate Interests: Our legitimate business interests, balanced against your rights

12.2 Your Rights Under GDPR

You have the right to:

  • Access your personal data

  • Rectification of inaccurate data

  • Erasure ("right to be forgotten")

  • Restriction of processing

  • Data portability

  • Object to processing

  • Lodge a complaint with your supervisory authority

12.3 Data Protection Officer

For questions about GDPR compliance, contact our Data Protection Officer at dpo@custodycomms.com.

13. Third-Party Websites and Services

Our Service may contain links to third-party websites, applications, or services. This Privacy Policy does not apply to such third-party services, and we are not responsible for their privacy practices. We encourage you to read the privacy policies of any third-party services you access.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

  • Posting the updated Privacy Policy on our website

  • Updating the "Last Updated" date

  • Sending an email notification (for material changes)

Your continued use of the Service after changes become effective constitutes acceptance of the revised Privacy Policy.

15. Contact Us

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

CustodyComms, LLC
131 Continental Drive, Suite 305
Newark, Delaware 19713
Email: privacy@custodycomms.com

For data protection inquiries (EEA/UK): dpo@custodycomms.com
For California privacy requests: privacy@custodycomms.com

16. Commitment to Privacy

At CustodyComms, we understand that the communications you analyze through our Service involve sensitive family law matters. We are committed to:

  • Maintaining the highest standards of data security

  • Respecting the confidential nature of your work

  • Providing transparency about our data practices

  • Continuously improving our privacy protections

  • Complying with all applicable privacy laws and regulations

We treat your trust as our most valuable asset and will continue to prioritize the privacy and security of your information.

Last Updated: October 31, 2025

By using CustodyComms, you acknowledge that you have read and understood this Privacy Policy.

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