Privacy policy

Last updated: [To be confirmed: date this policy takes effect]

This policy explains what personal information Carina collects, why, who we share it with, and the choices you have. Carina is a product of AgileOps Consulting [To be confirmed: full legal name of the entity, registered address and company number]. In this policy, "we" means that entity.

Who is responsible for what

• Your account. For the information we hold about people who sign in (name, email address, sign-in activity), we decide how it is used and are responsible for it.
• Your organization's workspace. Firms use Carina to run their license applications. The information a firm puts in its workspace, including information about its directors, officers and staff, belongs to that firm. We process it on the firm's behalf and only to provide the service. [To be confirmed: a data processing agreement setting out these terms.]

What we collect

• Account details: your name and email address, the organizations you belong to and your role in each.
• Organization details: the organization's name, legal name and jurisdiction.
• Workspace content: checklist items, owners and due dates; documents you upload (with their file name, type, size and SHA-256 fingerprint); comments; answers to regulator questions; approval records and conditions.
• Fit-and-proper packs: the answers a director or officer gives on their questionnaire, the documents they upload (which may include identity documents), and, when they sign, a signing record: their name and email, when their email was verified, the consent statement they accepted, their browser's description of itself (user agent), their time zone, and the times they opened the pack and signed.
• Activity records: an audit log of changes made in the workspace and a log of who downloaded which document, so that firms can show what happened and when.
• AI review and drafting records: when your organization uses AI review or drafting, we keep a record of each request (which document versions were used, by reference) and the result.
• Billing records: the plan, payment status, amount, currency and the payment provider's references. Card and bank details are handled by our payment provider; we never see or store them.
• Email delivery: the emails we send you (sign-in codes, invitations, reminders) and whether they were delivered.

We don't use advertising or analytics cookies. The app keeps your signed-in session in your browser's local storage.

How we use it

• To provide the service: running workspaces, sending sign-in codes, invitations and reminders, building submission packs and signed PDFs.
• To keep the service secure and accountable: access checks, audit and download logs, usage limits.
• To bill for the service and keep financial records.
• To support you when you ask for help.

We don't sell personal information, and we don't use workspace content for advertising.

AI features

AI features can be turned off by your organization's owner (and are off by default in The Bahamas region). When your organization uses AI review or drafting, the document versions involved and the relevant checklist requirement or question are sent to Anthropic, our AI provider, to produce the review or draft. The results are suggestions for people at your firm to decide on. [To be confirmed: Anthropic's retention and model-training terms under our agreement, stated here in plain words.]

Identity checks

Identity checks are off until your organization's owner switches them on. When they're on, a customer your firm asks to verify their identity gives their ID document and a selfie directly to iDenfy, our identity verification provider, on iDenfy's own pages; a business customer gives its details, documents and the people who own and control it the same way. When your firm screens a person or a business against sanctions, politically exposed persons or adverse-media lists, the name (and the date of birth and nationality or country, if entered) is sent to iDenfy. iDenfy processes this in the EU. We keep the result: statuses and flags, the name, type and issuing country of the document, and for a business its name and registration number. When your organization's retention policy says so, we blank what we hold and ask iDenfy to delete its copy. The results are information for people at your firm to decide on. [To be confirmed: iDenfy's agreement, retention terms and sub-processors, stated here in plain words.]

Who we share it with

We use these service providers to run Carina. Each receives only what it needs for its part:

Dodo Payments sells the subscription to you as the merchant of record, so it processes your payment details under its own privacy policy.

We may also disclose information if the law requires it, and we will tell the affected organization unless we are not allowed to.

Where your data is stored

When your organization signs up, it chooses a data region, and its workspace stays there:

• United States (East): stored with Convex in the United States.
• The Bahamas: stored on a server in The Bahamas (Secure Shore). Emails sent from this region carry no personal information, only a short notice and a link to sign in. AI review and drafting are off unless your organization's owner turns them on; when on, the documents involved are sent to Anthropic in the United States. Identity checks, when your owner switches them on, send customers' identity information to iDenfy in the EU.

The region can't be changed after sign-up. [To be confirmed: Secure Shore's details (data centre location, encryption, backups), and how each region's backups are kept.]

How long we keep it

• Account and workspace information: for as long as the organization's account is open.
• Identity documents and other fit-and-proper material: according to the firm's own retention policy, which the firm controls.
• Audit and download logs, signed declarations and frozen submissions: kept with the workspace, because their purpose is to be a lasting record.
• When an organization closes its account, we delete its workspace after it has had the chance to export it, except where the law requires us to keep something. [To be confirmed: export window and retention periods.]

Security

Every record belongs to one organization, and each request checks that the person asking is an active member of that organization with the right role. Sign-in uses one-time codes sent by email; there are no passwords. Signed and submitted content carries SHA-256 fingerprints so changes can be detected. Connections to Carina are encrypted in transit. [To be confirmed: encryption at rest and any published security practices, once documented.]

Your choices and rights

You can see and correct your name in the app. You can ask us for a copy of your personal information, to correct it, or to delete it. For information in a firm's workspace, we'll work with that firm, which decides what happens to its records. [To be confirmed: the laws that apply, for example The Bahamas' Data Protection (Privacy of Personal Information) Act, and how to complain to a supervisory authority.]

Children

Carina is for businesses and is not meant for anyone under 18.

Changes

If we change this policy, we'll update the date at the top and, for significant changes, tell account owners by email before the change takes effect.

Contact

[To be confirmed: the email address for privacy questions.]