Privacy Policy

Last Updated: April 16, 2026  |  Effective Date: April 16, 2026

Welcome to GoSiteMe (https://gositeme.com) ("Company", "we", "us", "our"), a privately held technology company. This Privacy Policy explains how we collect, use, process, store, share, and protect your personal information when you use our AI development platform, robotics and IoT services, virtual reality environments, application marketplace (App Store), encrypted communications (Veil Protocol), voice technology, hosting services, cryptocurrency features, and all related products and services (collectively, the "Services").

This Privacy Policy is incorporated into and forms part of our Terms of Service. By using our Services, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree, please do not use our Services.

1. Information We Collect

We collect the following categories of information depending on which Services you use:

1.1 Account & Identity Information

• Registration Data: Name, email address, phone number, billing address, username, and password.
• Payment Information: Credit card details, PayPal information, cryptocurrency wallet addresses, and billing history. Payment card data is processed by PCI-DSS compliant third-party payment processors and is not stored on our servers.
• Domain Registration: Registrant name, organization, address, phone, and email as required by ICANN.
• Identity Verification: Government-issued ID, proof of address, or other documentation when required for KYC/AML compliance, enterprise accounts, or high-value transactions.
• Organizational Data: Company name, tax ID, team member details, and administrative contacts for organizational accounts.

1.2 Technical & Device Information

• Browser & Device: IP address, browser type and version, operating system, device type, screen resolution, language preference, time zone, and unique device identifiers.
• Server Logs: Access logs, error logs, request headers, referrer URLs, and timestamps.
• VR Hardware Data: VR headset model, controller type, tracking system capabilities, display specifications, and firmware versions.
• IoT Device Information: Device model, firmware version, MAC address, serial number, network configuration, and connectivity status.
• Robotic Device Information: Robot model, firmware version, hardware configuration, sensor inventory, calibration data, and operational parameters.

1.3 Usage & Behavioral Data

• Platform Usage: Pages visited, features used, session duration, click patterns, navigation paths, and interaction frequency.
• AI Interaction Data: Prompts submitted to AI engines, AI-generated responses, token consumption, engine selection patterns, and conversation metadata (timestamps, session IDs). Prompt content is not used to train AI models.
• VR Behavioral Data: Movement patterns within virtual environments, interaction with virtual objects, session duration, avatar customization choices, social interactions, spatial positioning data, gaze direction, and hand gesture data.
• Robotic Device Usage: Commands issued, task execution logs, operational uptime, error reports, safety event logs, and performance metrics.
• App Store Activity: Applications browsed, downloaded, purchased, installed, rated, and reviewed. Developer analytics including download counts, revenue, and crash reports.

1.4 Biometric Data

• Voice Prints: When you use Voice Cloning, we create a mathematical representation (voice print) of the voice samples you provide. Voice prints are biometric identifiers.
• Voice Recordings: Audio samples provided for Voice Clone creation and voice commands processed through our voice interface.
• VR Behavioral Biometrics: Hand tracking geometry, gaze patterns, head movement patterns, and locomotion patterns that may uniquely identify users.

1.5 Robotic & IoT Sensor Data

• Environmental Sensors: Temperature, humidity, air quality, light levels, sound levels, and other ambient environmental measurements collected by connected devices.
• Camera & Visual Data: Images and video captured by cameras on Robotic Devices for navigation, object recognition, obstacle avoidance, and environmental mapping. We do not continuously stream or store raw video from home robots unless you explicitly enable cloud recording features.
• Location Data: GPS coordinates, indoor positioning data, room mapping data, and movement trajectories of Robotic Devices and IoT Devices.
• Device Health Diagnostics: Battery level, motor status, actuator positions, network signal strength, processing load, and hardware diagnostic data. This is mechanical health data from IoT/Robotic hardware only — not user surveillance telemetry.
• Home Environment Data: Room layouts, floor plans (generated by SLAM algorithms), furniture positions, and occupancy patterns as detected by home robots and IoT sensors.
• Audio Data: Audio captured by microphones on devices for wake-word detection, voice commands, and noise level monitoring. Audio is processed locally on-device when possible; only triggered commands are transmitted to our servers unless you enable always-on cloud features.

1.6 Communication Data

• Veil Protocol Messages: End-to-end encrypted message content is not accessible to GoSiteMe. We collect metadata (sender, recipient, timestamps, message size, delivery status) for service operation.
• Team Chat: Messages in team workspaces are stored on our servers to provide chat history and search functionality.
• Voice Calls: Call recordings (when enabled by users), call duration, participants, and call quality metrics.
• Support Communications: Support tickets, live chat transcripts, and email correspondence with our support team.

1.7 Financial & Cryptocurrency Data

• Transaction History: Purchase records, subscription history, refund records, and invoice data.
• Cryptocurrency Data: Public wallet addresses, transaction hashes, GSM Token balances, staking history, and trading activity on our platform. We never collect or store private keys or seed phrases.
• Affiliate Data: Referral tracking, commission records, and payout history.

1.8 User-Generated Content

• Code & Files: Source code, project files, databases, and media stored in your hosting account or IDE workspace.
• Store Applications: Applications, plugins, themes, and digital goods submitted to the App Store, including source code, assets, descriptions, and screenshots.
• VR Content: Virtual objects, environments, avatars, and other assets created within VR environments.
• Reviews & Ratings: App Store reviews, ratings, and community feedback.

2. How We Use Your Information

We use your information for the following purposes:

2.1 Service Delivery & Operations

• Providing, maintaining, operating, and improving all aspects of our Services
• Processing transactions, billing, and subscription management
• Domain registration, SSL certificate provisioning, and hosting services
• AI engine routing, token consumption tracking, and usage metering
• Robotic Device and IoT Device management, firmware updates, and remote diagnostics
• VR environment rendering, multiplayer coordination, and content delivery
• App Store operation, developer payouts, and content review
• Voice Clone creation, storage, and synthesis
• Encrypted message delivery and key management (Veil Protocol)

2.2 Safety & Security

• Detecting, preventing, and responding to fraud, abuse, security threats, and technical issues
• Monitoring Robotic Devices for safety anomalies and enforcing safety constraints
• Content moderation in VR environments and the App Store
• Network security monitoring, intrusion detection, and incident response
• Enforcing our Terms of Service and Acceptable Use Policy

2.3 Communications

• Transactional notifications (billing confirmations, password resets, security alerts)
• Service announcements, maintenance notices, and status updates
• Marketing and promotional communications (with your consent; you may opt out at any time)
• Responding to support requests and feedback

2.4 Analytics & Improvement

• Analyzing usage patterns to improve platform features and user experience
• Aggregated and anonymized analytics for product development
• AI model performance monitoring (not training) and quality improvement
• Robotics and IoT service optimization based on device health diagnostics (hardware sensor data only)

2.5 Legal & Compliance

• Complying with applicable laws, regulations, court orders, and government requests
• KYC/AML compliance for financial services and cryptocurrency features
• Exercising or defending legal claims
• Export control and sanctions screening

3. Legal Bases for Processing (GDPR)

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we process personal data under the following legal bases:

4. How We Share Your Information

We do not sell your personal information. We may share your information with the following categories of recipients:

4.1 Service Providers

• AI Engine Providers: Your prompts are sent to third-party AI providers (including OpenAI, Anthropic, Google, and others) for processing. These providers process data under contractual obligations and their own privacy policies.
• Payment Processors: Payment data is shared with PCI-DSS compliant payment processors (Stripe, PayPal) to process transactions.
• Cloud Infrastructure: We use cloud hosting providers to store and process data. All data remains within our contracted infrastructure with appropriate data processing agreements in place.
• Domain Registrars: Registration data is shared with accredited registrars and ICANN as required for domain registration.
• Certificate Authorities: Domain validation data is shared with certificate authorities for SSL certificate issuance.
• IoT & Robotics Hardware Partners: Device health diagnostics (battery, motor, sensor readings — not user data) may be shared with hardware manufacturers only for warranty claims, safety recalls, and firmware development, in anonymized or pseudonymized form. This sharing is limited to mechanical health data and never includes personally identifiable information, user behavior, or usage patterns.

4.2 App Store Developers

When you purchase or download a Store Application, the developer may receive: your display name (not email unless you consent), purchase confirmation, and aggregated usage analytics. Developers do not receive your payment details, email address, or other personal information unless you explicitly consent.

4.3 Legal & Safety Disclosures

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

• Comply with applicable law, regulation, legal process, or enforceable government request
• Enforce our Terms of Service or investigate potential violations
• Detect, prevent, or address fraud, security, safety, or technical issues
• Protect the rights, property, or safety of GoSiteMe, our users, or the public
• Respond to an emergency involving danger of death or serious physical injury

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on our website before your information becomes subject to a different privacy policy.

4.5 With Your Consent

We may share your information with third parties when you have given your explicit consent to do so.

5. Data Storage & Security

5.1 Data Location

• Primary Storage: Your data is stored on secure servers located in Quebec, Canada.
• Edge Processing: Some data may be temporarily processed at edge locations for latency-sensitive operations (VR rendering, robotic device control, voice processing).
• On-Device Processing: Certain robotics and IoT functions process data locally on the device. Locally processed data is not transmitted to our servers unless cloud features are enabled.

5.2 Security Measures

• Encryption in Transit: All data transmitted to and from our servers is encrypted using TLS 1.3.
• Encryption at Rest: Data at rest is protected using AES-256 encryption.
• End-to-End Encryption: Veil Protocol messages use end-to-end encryption with post-quantum cryptographic algorithms. We cannot access encrypted message content.
• Access Controls: Role-based access control (RBAC), multi-factor authentication for administrative access, and principle of least privilege.
• Network Security: Firewalls, intrusion detection/prevention systems, DDoS mitigation, and continuous security monitoring.
• Workspace Isolation: User hosting environments and IDE workspaces are isolated in containers with separate encryption keys.
• Regular Audits: Periodic security assessments, penetration testing, and vulnerability scanning.
• Employee Training: All staff undergo regular data protection and security awareness training.

While we implement industry-leading security measures, no system is 100% secure. You are responsible for securing your account credentials, device access, and maintaining your own backups.

5.3 Biometric Data Security

Biometric data (voice prints, VR behavioral biometrics) is stored separately from other personal data with additional encryption layers and access restrictions. Biometric data is never shared with third parties except as required by law.

6. Data Retention

When data reaches its retention limit, it is securely deleted or anonymized so it can no longer be associated with you. You may request earlier deletion of certain data categories (see Section 9).

7. Cookies & Tracking Technologies

7.1 Cookies We Use

7.2 Managing Cookies

You can manage cookie preferences through our cookie consent banner, browser settings, or by contacting us. Disabling essential cookies may prevent the Services from functioning correctly. We respect Do Not Track (DNT) browser signals.

7.3 Other Tracking Technologies

We may use local storage, session storage, pixel tags, and similar technologies for functionality and analytics purposes. These are subject to the same consent requirements as cookies where applicable.

8. AI-Specific Data Practices

8.1 AI Prompt & Response Data

• No Training: Your prompts and AI-generated responses are NOT used to train or fine-tune AI models.
• Processing: Prompts are sent to third-party AI providers in real-time for response generation and are not retained by providers beyond the processing session, except where required by their safety monitoring policies.
• Storage: Conversation history is stored on our servers to provide features like conversation continuity and history search. You can delete your conversation history at any time.
• Logging: We log metadata (timestamp, engine used, token consumption, response latency) for billing, quality monitoring, and abuse prevention.

8.2 AI Agent Behavioral Data

• AI Agent configurations, personality settings, memory states, and behavioral patterns are stored as part of your account data.
• Fleet management data (agent orchestration logs, task assignments, performance metrics) is retained for the duration of your account.
• Agent behavioral data may be analyzed in aggregate and anonymized form to improve AI safety and agent performance across the platform.

8.3 Automated Decision-Making (GDPR Article 22)

We use automated processing for:

• Content moderation: Automated detection of prohibited content in AI outputs, Store Applications, and VR environments.
• Fraud detection: Automated systems to detect suspicious transactions and account activity.
• Safety monitoring: Automated monitoring of Robotic Device behavior for safety anomalies.

You have the right to request human review of any automated decision that significantly affects you. Contact privacy@gositeme.com to exercise this right.

9. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

9.1 Universal Rights

• Access: Request a copy of the personal data we hold about you.
• Rectification: Correct inaccurate or incomplete personal data.
• Deletion: Request deletion of your personal data (subject to legal retention requirements).
• Data Export: Receive your data in a structured, commonly used, machine-readable format (data portability).
• Opt-Out of Marketing: Unsubscribe from marketing communications at any time via email links or account settings.
• Cookie Preferences: Manage cookie consent through our cookie banner or browser settings.
• Account Deletion: Delete your entire account and associated data through account settings or by contacting support.

9.2 GDPR Rights (EEA, UK, Switzerland)

• Restriction: Request that we limit processing of your data in certain circumstances.
• Objection: Object to processing based on legitimate interests, including profiling.
• Automated Decision-Making: Not be subject to decisions based solely on automated processing that produce legal or similarly significant effects.
• Withdraw Consent: Withdraw consent at any time for processing based on consent (without affecting the lawfulness of prior processing).
• Lodge Complaint: File a complaint with your local data protection authority.

9.3 CCPA/CPRA Rights (California Residents)

• Right to Know: Request disclosure of the categories and specific pieces of personal information collected about you.
• Right to Delete: Request deletion of your personal information.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt Out: Opt out of the sale or sharing of personal information. We do not sell personal information.
• Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
• Sensitive Personal Information: You have the right to limit the use and disclosure of sensitive personal information (including biometric data).
• Right to Withdraw Consent: You may withdraw consent for non-essential data processing at any time by visiting your account privacy settings, clicking "Manage Consent Preferences," or by emailing privacy@gositeme.com with the subject "Withdraw Consent." Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal and does not affect processing based on other lawful grounds (e.g., contract performance, legal obligations).

9.3.1 California Shine the Light (Civil Code §1798.83)

California residents may request a list of personal information (if any) we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. We do not currently disclose personal information to third parties for their direct marketing purposes. If this practice changes, we will update this section and provide an opt-out mechanism. To make a Shine the Light request, email privacy@gositeme.com with the subject "Shine the Light Request" and include your California mailing address.

9.4 Quebec Law 25 Rights (Quebec Residents)

• Right to access, rectify, and obtain a copy of personal information held about you.
• Right to withdraw consent for data collection (subject to contractual and legal requirements).
• Right to be informed about automated decision-making and profiling.
• Right to data portability in a commonly used technological format.
• Right to de-indexation (removal from search and public-facing systems).
• Right to file a complaint with the Commission d'accès à l'information du Québec (CAI).

9.5 PIPEDA Rights (Canadian Residents)

• Right to access personal information held by us.
• Right to challenge the accuracy and completeness of your data.
• Right to withdraw consent (subject to legal and contractual restrictions).
• Right to complain to the Office of the Privacy Commissioner of Canada.

9.6 How to Exercise Your Rights

Submit requests to privacy@gositeme.com or through your account settings. We will respond within 30 days (or sooner if required by applicable law). We may verify your identity before processing requests. Some data may be retained as required by law even after a deletion request.

10. Robotics & IoT Privacy

10.1 What Robots Collect

• Navigation Data: Spatial mapping, SLAM-generated floor plans, obstacle locations, and movement paths. This data is primarily processed on-device.
• Camera Data: Visual data for navigation, object recognition, and user interaction. Raw video is processed on-device and is NOT continuously uploaded to our servers unless you explicitly enable cloud recording.
• Audio Data: Microphone input for wake-word detection and voice commands. Audio is processed locally for wake-word detection; only post-wake-word audio is transmitted to our servers for voice command processing.
• Interaction Data: Touch inputs, gesture commands, spoken commands, and behavioral patterns of interaction with the device.
• Environmental Data: Ambient sensor readings (temperature, humidity, air quality, light levels) that may characterize your home environment.

10.2 Your Controls

• You can disable camera, microphone, and individual sensors through device settings or physical hardware switches (where available).
• You can view and delete collected data through your account dashboard.
• You can disable cloud data synchronization and keep all data on-device only.
• You can request a complete data export of all device-collected data.
• You can factory reset devices to erase all on-device data.

10.3 Third-Party IoT Integrations

If you connect third-party smart home devices or platforms to our Services, data exchange between systems is governed by both our Privacy Policy and the third party's privacy policy. We are not responsible for the data practices of third-party IoT devices or platforms.

10.4 GoSiteMe-Manufactured Hardware (Alfred Robot) Data

Alfred Robots manufactured by GoSiteMe collect additional data specific to their operation:

• Spatial Mapping: LIDAR and camera-based floor plans, obstacle maps, and navigation routes are stored on-device by default. Cloud synchronization is available but optional.
• Device Health Diagnostics (opt-in): Motor performance, battery health, sensor calibration, temperature readings, and error logs may be transmitted to GoSiteMe servers only with your explicit consent for product safety monitoring, quality improvement, and predictive maintenance. This data is strictly mechanical/hardware health data — it is not personally identifiable and contains no user behavior, usage patterns, or surveillance data.
• Crash & Safety Event Data: In the event of a collision, fall, emergency stop, or safety anomaly, the Robot automatically records and transmits a safety event report (including sensor data, motor states, and environmental readings from the 30 seconds preceding the event) for safety investigation.
• Firmware Update Data: Current firmware version, update history, and update status are transmitted to manage OTA updates.

Data on Device Return/Disposal: When GoSiteMe Hardware is returned under warranty, traded in, or sent for recycling, GoSiteMe performs certified data destruction (secure overwrite + cryptographic erasure) on all personal data stored on the device. A data destruction certificate is available upon request.

11. VR & Metaverse Privacy

11.1 VR Data Collection

• Movement & Tracking: Head position, hand positions, body movement, gaze direction, and locomotion patterns are processed for VR rendering and interaction.
• Social Interactions: Voice chat (when enabled), text chat, proximity interactions, and multiplayer activities within VR environments.
• Behavioral Analytics: Session duration, environment preferences, interaction patterns, and feature usage.
• User-Generated Content: Virtual objects, structures, and customizations created within VR environments.

11.2 VR Behavioral Biometrics

We acknowledge that movement patterns, gaze data, and hand tracking data may constitute behavioral biometric data that could potentially identify individuals. This data is:

• Used only for rendering, interaction, and platform improvement
• Not used for advertising or sold to third parties
• Anonymized for aggregate analytics
• Subject to biometric data protections where required by law (e.g., BIPA, Texas CUBI)

11.3 VR Content Moderation

We may monitor public VR environments for safety and conduct violations. Private VR spaces are not monitored unless a conduct report is filed. Moderation data may include behavioral logs and session recordings relevant to the reported incident.

12. Voice Technology Privacy

12.1 Voice Command Processing

• Voice commands to Alfred and other AI assistants are transmitted to our servers for processing.
• Voice recordings are processed for speech-to-text conversion and are not permanently stored unless you explicitly save a conversation.
• Processed audio may be briefly retained (up to 48 hours) for quality monitoring and error correction, then automatically deleted.

12.2 Voice Cloning Data

• Voice samples provided for Voice Clone creation are processed to generate a voice model (voice print).
• Raw voice samples are retained for up to 90 days after Voice Clone creation for quality assurance, then permanently deleted.
• The resulting Voice Clone model is stored for the duration of your account and can be deleted at any time through your account settings.
• Voice Clone models are encrypted at rest and are not accessible to GoSiteMe employees except for authorized support and safety review.

12.3 Consent Records

We maintain records of consent for Voice Clone creation, including: the identity of the voice provider, date of consent, method of consent, and scope of authorized use. These records are retained for 5 years after the Voice Clone is deleted.

13. Cryptocurrency & Financial Data Privacy

• Wallet Addresses: Public wallet addresses connected to your account are stored for transaction processing and history.
• Transaction Records: All cryptocurrency transactions through our platform are logged for compliance and audit purposes.
• Blockchain Public Data: Blockchain transactions are inherently public. Transaction hashes and wallet addresses are visible on the public blockchain regardless of our privacy measures.
• KYC/AML Data: If identity verification is required for cryptocurrency features, verification data is processed by certified third-party KYC providers and retained as required by anti-money laundering regulations.
• Private Keys: We NEVER collect, store, transmit, or have access to your private keys or seed phrases.

14. International Data Transfers

14.1 Transfer Mechanisms

Your data is primarily stored and processed in Quebec, Canada. Canada has received an adequacy decision from the European Commission, meaning data transfers from the EEA to Canada are permissible under GDPR. For transfers to other jurisdictions (e.g., AI processing through US-based providers), we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data Processing Agreements with all sub-processors
• Supplementary technical and organizational measures (encryption, pseudonymization, access controls)
• Transfer Impact Assessments where required

14.2 Sub-Processor List

A list of our current sub-processors and their locations is available upon request by contacting privacy@gositeme.com. We will notify subscribers of material changes to our sub-processor list at least 30 days in advance.

14.3 Sub-Processor Objection Rights

In accordance with GDPR Article 28, if you have a legitimate objection to a new or replacement sub-processor, you may submit a written objection to privacy@gositeme.com within 10 business days of receiving our sub-processor change notification. Your objection must include specific, documented reasons why the proposed sub-processor would compromise the protection of your personal data. GoSiteMe will use commercially reasonable efforts to address your concerns, including offering an alternative sub-processor where feasible. If GoSiteMe cannot reasonably accommodate your objection, either party may terminate the affected Services without penalty upon 30 days' written notice, and GoSiteMe will refund any prepaid fees for the unused portion of the terminated Services.

15. Children's Privacy

15.1 Age Requirements

• Our Services are primarily intended for users aged 18 and older.
• Users between 13 and 18 may use certain Services with verifiable parental or guardian consent.
• VR Environments are not recommended for users under 13.
• Cryptocurrency features are restricted to users aged 18 and older.
• Voice Cloning services are restricted to users aged 18 and older.

15.2 COPPA Compliance

We comply with the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from children under 13 without verifiable parental consent. If we discover that we have inadvertently collected personal information from a child under 13 without proper consent, we will promptly delete that information.

15.3 Parental Controls

Parents and guardians of minor users (13-17) can:

• Review and request deletion of their child's personal information
• Manage content access and feature restrictions through parental control settings
• Disable VR features, voice cloning, and other age-restricted services
• Receive reports on their child's usage patterns

Contact privacy@gositeme.com for parental access requests.

16. Third-Party Links & Services

Our Services may contain links to third-party websites, services, and applications. This includes third-party Store Applications, external integrations, and linked services. We are not responsible for the privacy practices, content, or data handling of third-party websites or services. We encourage you to review their privacy policies before providing any personal information.

17. Data Breach Notification

17.1 Notification Timeline

• Regulatory Notification: We will notify the relevant data protection authority (Commission d'accès à l'information du Québec, applicable supervisory authorities under GDPR) within 72 hours of becoming aware of a data breach that poses a risk to individuals' rights and freedoms.
• User Notification: We will notify affected users without undue delay when a breach is likely to result in a high risk to their rights and freedoms.

17.2 Notification Content

Breach notifications will include: (a) the nature of the breach; (b) categories and approximate number of records affected; (c) likely consequences; (d) measures taken or proposed to address the breach; and (e) contact information for our Privacy Officer.

17.3 Biometric Data Breaches

In the event of a breach involving biometric data (voice prints, VR behavioral biometrics), we will provide enhanced notification including specific guidance on risk mitigation, as biometric data cannot be changed like passwords.

18. Privacy Impact Assessments

In compliance with Quebec Law 25 and GDPR, we conduct Privacy Impact Assessments (PIAs) / Data Protection Impact Assessments (DPIAs) before implementing:

• New technologies that process personal data (robotics, IoT, AI features)
• Large-scale processing of biometric data
• Systematic monitoring of publicly accessible areas (VR public environments)
• Cross-border data transfers to new jurisdictions
• New categories of personal data collection

PIAs are reviewed and updated annually or when material changes occur.

19. Data Processing Agreements

Enterprise Customers who are data controllers processing personal data through our platform may request a Data Processing Agreement (DPA) that addresses:

• Processing instructions, purposes, and scope
• Sub-processor management and approval mechanisms
• Technical and organizational security measures
• Data subject request handling procedures
• Breach notification obligations
• Data return and deletion upon termination
• Audit rights and compliance documentation

Contact enterprise@gositeme.com to request a DPA.

20. Do Not Track & Global Privacy Control

We respect the Global Privacy Control (GPC) signal and Do Not Track (DNT) browser preferences. When we detect a GPC or DNT signal, we will:

• Disable non-essential analytics and tracking cookies
• Not engage in cross-site tracking
• Treat the signal as an opt-out of personal information sharing (as required by CCPA/CPRA)

21. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with a revised "Last Updated" date.

• Material changes (new data categories, new sharing practices, changes to biometric data handling, international transfer changes) will be notified via email and/or prominent notice on our website at least 30 days before taking effect.
• Non-material changes (clarifications, formatting, typo corrections) may be made without advance notice.

Continued use of the Services after the effective date of any change constitutes acceptance of the updated Privacy Policy.

22. Additional US State Privacy Rights

In addition to CCPA/CPRA rights for California residents (Section 9.3), residents of the following states have additional privacy rights under their respective state laws:

22.1 Virginia Consumer Data Protection Act (VCDPA)

Virginia residents have the right to: access, correct, and delete personal data; obtain a portable copy of personal data; opt out of the processing of personal data for targeted advertising, sale, or profiling. To appeal a denied request, contact privacy@gositeme.com with subject line "VCDPA Appeal."

22.2 Colorado Privacy Act (CPA)

Colorado residents have the right to: access, correct, and delete personal data; obtain a portable copy; opt out of targeted advertising, sale of personal data, and automated profiling that produces legal or similarly significant effects. Universal opt-out mechanisms (Global Privacy Control) are honored.

22.3 Connecticut Data Privacy Act (CTDPA)

Connecticut residents have the right to: access, correct, and delete personal data; obtain a portable copy; opt out of targeted advertising, sale of personal data, and profiling. You may appeal denied requests within 60 days.

22.4 Utah Consumer Privacy Act (UCPA)

Utah residents have the right to: access and delete personal data; obtain a portable copy; opt out of targeted advertising and sale of personal data.

22.5 Nevada SB-220

Nevada residents may submit a request directing us not to sell their personal information. Submit requests to privacy@gositeme.com. We do not currently sell personal information.

22.6 Oregon Consumer Privacy Act (OCPA)

Oregon residents have the right to: access, correct, and delete personal data; data portability; opt out of targeted advertising, sale of personal data, and profiling.

22.7 Texas Data Privacy and Security Act (TDPSA)

Texas residents have the right to: access, correct, and delete personal data; data portability; opt out of targeted advertising, sale, and profiling. We recognize universal opt-out mechanisms.

22.8 Montana Consumer Data Privacy Act (MCDPA)

Montana residents have rights substantially similar to those under the VCDPA. Submit requests to privacy@gositeme.com.

22.9 Exercising State-Specific Rights

To exercise any state-specific privacy rights, submit a verifiable request to privacy@gositeme.com specifying your state of residence. We will respond within the timeframe required by your applicable state law (typically 45 days). You will not be discriminated against for exercising your privacy rights.

23. California Age-Appropriate Design Code

In compliance with the California Age-Appropriate Design Code Act, we:

• Conduct Data Protection Impact Assessments for features, products, or services likely to be accessed by children under 18
• Default to high privacy settings for users under 18
• Do not use personal information of users under 18 in a way that is materially detrimental to their physical or mental health, or overall well-being
• Do not profile users under 18 by default
• Provide prominent, accessible, and responsive tools for users under 18 to exercise their privacy rights

24. Advertising, Marketing & Behavioral Targeting

24.1 Our Advertising Practices

We may display advertisements within free-tier Services. We use the following types of advertising:

• Contextual Advertising: Ads based on the content of the page or feature you are currently using (not based on your personal data).
• First-Party Advertising: Promotions for our own Services and products based on your usage patterns and subscription tier.

24.2 What We Do NOT Do

• We do NOT sell your personal information to advertisers.
• We do NOT share your AI conversation content, Voice Clone data, IoT sensor data, or VR behavioral data with advertisers.
• We do NOT use end-to-end encrypted communication content for advertising purposes.
• We do NOT serve behavioral ads to users under 18.

24.3 Opting Out

You may opt out of personalized advertising through your account settings, by using the Global Privacy Control (GPC) signal, or by contacting privacy@gositeme.com. Paid subscribers do not receive third-party advertisements.

25. Aggregate & De-Identified Data

25.1 Definitions

"Aggregate Data" means data that has been combined with data from other users and cannot reasonably be used to identify any individual. "De-Identified Data" means data from which all personally identifiable information has been permanently removed using industry-standard techniques and for which we have implemented technical safeguards, business processes, and contractual obligations to prevent re-identification.

25.2 Use of Aggregate & De-Identified Data

We may create, use, and share Aggregate Data and De-Identified Data for any lawful purpose, including: research, analytics, benchmarking, industry reports, service improvement, and new product development. GoSiteMe retains all rights, title, and interest in and to all Aggregate Data, De-Identified Data, statistical analyses, models, indices, benchmarks, and any other derivative works, insights, or intellectual property created from or based on Aggregate Data or De-Identified Data. This data is not subject to the restrictions of this Privacy Policy because it does not constitute personal information. This ownership right survives termination of your account.

25.3 Re-Identification Prohibition

We contractually prohibit any recipients of De-Identified Data from attempting to re-identify individuals. We maintain administrative, technical, and physical safeguards designed to prevent re-identification.

26. Cross-Device Tracking

We may link your activity across multiple devices (desktop, mobile, VR headset, IoT devices, robotic devices) when you log into the same account on different devices. This cross-device linking enables:

• Seamless experience across devices (e.g., starting a task on desktop, continuing on mobile)
• Unified security monitoring and anomaly detection
• Consistent preferences and settings across devices
• Unified analytics and billing

You can manage device linkage through your account settings. Removing a device from your account will stop future cross-device tracking for that device. Previously collected data may be retained as per Section 6.

27. Social Features & Public Profiles

27.1 Public Profile Information

If you create a public profile (e.g., for the App Store, developer community, VR multiplayer, or game leaderboards), the following information may be publicly visible: display name, profile photo, public bio, published applications or content, ratings, review history, public achievements, and public statistics. Never include sensitive personal information in your public profile.

27.2 Social Interactions

Information shared in public channels, team chats, VR public environments, forums, or community features is visible to other users and may be cached or saved by other users. You should have no expectation of privacy for information shared in public or group contexts.

27.3 Controlling Visibility

You can control the visibility of your profile and social features through your account privacy settings, including options to: hide your profile from public search, disable leaderboard participation, restrict who can see your online status, and control who can invite you to VR environments.

28. Biometric Data Retention & Destruction Schedule

28.1 Voice Prints (Voice Cloning)

28.2 VR Behavioral Biometrics

28.3 Destruction Certification

Upon request, we will provide written certification that your biometric data has been permanently destroyed. Requests for destruction certification should be directed to privacy@gositeme.com.

28.4 Biometric Data Purpose Limitation

Biometric data collected by GoSiteMe (including voice prints, VR behavioral biometrics, and any other biometric identifiers) is used solely for the specific purposes disclosed at the time of collection (e.g., Voice Clone creation, VR session optimization, authentication). GoSiteMe will not:

• Use biometric data for individual identification, surveillance, or tracking purposes beyond what is necessary for the disclosed service functionality
• Cross-reference biometric data with external databases, government databases, or third-party datasets without your separate, express written consent
• Share biometric data with law enforcement, government agencies, or any third party without a valid court order, warrant, or your explicit written consent, except where required by applicable law
• Use biometric data for employment screening, credit decisions, insurance underwriting, tenant screening, or any secondary purpose not directly related to the Services
• Sell, lease, trade, or otherwise profit from biometric data

This section is intended to comply with the Illinois Biometric Information Privacy Act (BIPA), Texas Capture or Use of Biometric Identifier Act (CUBI), Washington Biometric Identifiers Law (RCW 19.375), and all other applicable biometric data protection laws.

29. AI Transparency & Model Provenance

29.1 AI Models Used

Our AI features are powered by third-party large language models (LLMs) and proprietary algorithms. We provide transparency about which AI engines are available per subscription tier in our documentation and pricing pages. The specific model used for each interaction is displayed in the user interface where technically feasible.

29.2 AI Training Data

• We do NOT use your personal data, prompts, conversations, or content to train AI models.
• Third-party AI providers may have their own training data policies. We contractually require that our providers do not use your data for model training.
• Any AI features labeled as "fine-tuned" or "custom" are trained on curated, licensed, or publicly available datasets — never on individual user data without explicit consent.

29.3 AI Decision Transparency

For automated decisions that significantly affect you (e.g., content moderation actions, fraud flags, account restrictions), you may request a human review of the decision. To initiate a review:

1. Submit a request within 30 calendar days of the automated decision by contacting support@gositeme.com with the subject "AI Decision Review" and including your account identifier and a description of the decision you wish to contest.
2. Initial response: GoSiteMe will acknowledge your request within 3 business days and provide a meaningful explanation of the decision criteria, the data relied upon, and the significance of the decision.
3. Human review: A qualified human reviewer will complete a substantive review within 15 business days of the initial acknowledgment, and will communicate the outcome in writing.
4. Appeal: If you disagree with the human review outcome, you may submit a final appeal within 10 business days of receiving the review decision. Appeals are escalated to a senior reviewer and resolved within 10 business days.

This process is available to all users regardless of jurisdiction. For EEA users, this process supplements (and does not replace) your rights under GDPR Article 22.

29.4 AI Limitations Disclosure

AI-generated content may contain errors, hallucinations, biases, or inaccuracies. AI outputs should be independently verified before use in critical applications. We do not guarantee the accuracy, completeness, originality, or non-infringement of AI-generated content.

30. Lawful Interception & Government Access

30.1 Government Requests

We may be compelled to disclose user data in response to valid legal process, including court orders, subpoenas, warrants, national security orders, and requests from law enforcement agencies in Canada and other jurisdictions. We evaluate each request for legal validity and narrow scope before compliance.

30.2 Transparency

• We will notify you of government requests for your data unless prohibited by law or court order (e.g., under a gag order or national security letter).
• We publish a transparency report annually detailing the number and types of government requests received, complied with, and challenged. The transparency report is available at gositeme.com/security.

30.3 End-to-End Encrypted Communications

For communications encrypted with Veil Protocol (end-to-end encryption), we are technically unable to provide decrypted message content in response to any request, including government orders, because we do not hold the encryption keys. We can only provide metadata (sender, recipient, timestamps, message sizes) for encrypted communications.

30.4 No Backdoors

We do not build backdoors, maintain decryption master keys for end-to-end encrypted communications, or provide "lawful interception" capabilities that would compromise the integrity of our encryption. If compelled by law to modify our encryption architecture, we will pursue all available legal challenges and provide public notice to the extent permitted.

31. Accessibility of This Policy

31.1 Plain Language Summary

We strive to write this Privacy Policy in clear, understandable language. If you have difficulty understanding any section, contact privacy@gositeme.com and we will provide a plain-language explanation.

31.2 Format Accessibility

This Privacy Policy is available in accessible HTML format that is compatible with screen readers and assistive technologies. Alternative formats (large print, audio summary) are available upon request. Contact accessibility@gositeme.com.

31.3 Languages

This Privacy Policy is available in English and French. For Quebec residents, the French version shall prevail in the event of any discrepancy.

32. Encryption Sovereignty

32.1 Encryption Architecture

GoSiteMe employs a 10-layer hybrid encryption architecture combining classical and post-quantum cryptographic primitives. Your communications, files, AI interactions, device diagnostics, and device data are protected by:

• Kyber-1024 (ML-KEM) — NIST-approved post-quantum key exchange;
• ECDH P-256 — Classical elliptic-curve key exchange;
• AES-256-GCM — 256-bit authenticated encryption;
• Dilithium-inspired lattice signatures — Post-quantum message authentication;
• Double Ratchet — Per-message forward secrecy;
• Hash Chain Integrity — Tamper-evident message chains;
• Key Commitment — Protection against ciphertext manipulation;
• Steganographic Obfuscation — Traffic analysis resistance.

This encryption stack is designed to resist attacks from current classical computers, future quantum computers, and nation-state adversaries.

32.2 Zero-Knowledge Architecture

GoSiteMe operates on a zero-knowledge principle for encrypted content. We cannot read your messages, decrypt your files, listen to your calls, or access your encrypted AI conversations. Your encryption keys are generated and stored exclusively on your device. We never have access to your keys and never will.

32.3 Forward Secrecy

Every message is encrypted with a unique per-message key derived from a continuously ratcheting cryptographic chain. Even if an attacker compromises a single message key, they cannot decrypt any past or future messages. This protection operates automatically and requires no User action.

33. No-Backdoor Privacy Guarantee

33.1 Absolute Prohibition

GoSiteMe guarantees that it has never, and will never, insert any backdoor, surveillance mechanism, key escrow system, or decryption capability into any of its products, services, encryption libraries, AI systems, or device firmware. This prohibition is absolute and applies regardless of:

• Court orders, warrants, or subpoenas from any jurisdiction;
• National security letters or FISA orders;
• Legislative mandates or regulatory directives;
• Pressure from law enforcement, intelligence agencies, or government officials;
• Contractual demands from business partners or investors;
• Internal corporate decisions, including decisions by future management or owners.

33.2 Technical Enforcement

This guarantee is enforced technically, not merely by policy. GoSiteMe's encryption architecture makes backdoor insertion mathematically detectable. Any modification to the cryptographic protocols would be detectable through the published cryptographic specification and independent audit mechanisms.

34. Anti-Compelled Disclosure

34.1 Response to Legal Process

When GoSiteMe receives legal process requesting User data:

1. GoSiteMe will scrutinize the legal validity, scope, and jurisdiction of every request;
2. GoSiteMe will challenge overbroad, vague, or jurisdictionally improper requests;
3. GoSiteMe cannot provide decrypted communications because we do not have the keys;
4. GoSiteMe will notify the affected User to the maximum extent permitted by law;
5. GoSiteMe will publish aggregate statistics about legal requests received in its Transparency Report;
6. GoSiteMe will never voluntarily provide User data to any government absent valid legal process.

34.2 What We Can and Cannot Provide

In response to valid legal process, GoSiteMe can only provide unencrypted metadata that it retains (such as account creation date and subscription tier). GoSiteMe cannot provide: message content, file content, call audio/video, AI conversation content, device diagnostic data, or any other end-to-end encrypted data. This is a technical impossibility, not a policy choice.

35. Warrant Canary & Transparency

35.1 Warrant Canary

GoSiteMe publishes a cryptographically signed Warrant Canary at gositeme.com/security, updated quarterly. The absence or non-renewal of any Canary statement should be interpreted accordingly by Users. See Section 69 of the Terms of Service for full Warrant Canary provisions.

35.2 Transparency Report

GoSiteMe publishes an annual Transparency Report disclosing: the number and type of legal requests received, the number challenged, the number complied with, and the categories of data provided. The Transparency Report is available at gositeme.com/security.

36. Alfred OS & Robot Data Privacy

36.1 Alfred OS Data Processing

Alfred OS — GoSiteMe's AI operating system for robotics and automation — processes data locally on the device (edge AI) whenever possible. Data transmitted to GoSiteMe infrastructure (device diagnostics, fleet management, firmware updates) is encrypted end-to-end using the same 10-layer encryption stack described in Section 32.

36.2 Sensor Data Privacy

Robots and devices running Alfred OS may collect sensor data including camera feeds, LiDAR, depth sensors, microphones, GPS, accelerometers, and environmental sensors. This data is:

1. Processed locally on the device wherever feasible;
2. Encrypted before any transmission;
3. Never sold, shared, or monetized;
4. Never used for advertising or profiling;
5. Retained only as long as necessary for the stated purpose;
6. Deletable by the User at any time.

36.3 Edge AI Model Privacy

AI models deployed to Alfred OS devices (vision, navigation, NLP, anomaly detection) run entirely on-device. Inference results are not transmitted to GoSiteMe unless the User explicitly configures cloud processing. No User data is used to train GoSiteMe AI models without explicit User opt-in consent.

36.4 MQTT & Device Diagnostics Privacy

Fleet diagnostic data transmitted via MQTT broker infrastructure is encrypted with per-topic encryption keys. Topic-level access control lists (ACLs) ensure that only authorized Users and devices can subscribe to diagnostic topics. GoSiteMe does not inspect, log, or retain the content of encrypted MQTT messages beyond the configured message TTL.

37. Sovereign Data Processing

37.1 No Bulk Data Collection

GoSiteMe does not engage in bulk data collection, mass surveillance, or dragnet data harvesting. Data collection is limited to the minimum necessary to provide the requested service. GoSiteMe does not build advertising profiles, behavioral models, or predictive analytics based on User data.

37.2 No Data Brokerage

GoSiteMe is not a data broker and will never become one. GoSiteMe will never sell, trade, license, or provide User data to data brokers, advertisers, analytics companies, AI training companies, or any other entity seeking bulk User data.

37.3 Encryption at Rest

All User data stored on GoSiteMe infrastructure is encrypted at rest using AES-256. Encryption keys are managed using a hierarchical key management system with per-tenant key isolation. GoSiteMe employees do not have access to User encryption keys.

38. Contact Us

For questions about this Privacy Policy, your data, or to exercise your privacy rights:

Regulatory Authorities:

• Quebec: Commission d'accès à l'information du Québec (CAI) — www.cai.gouv.qc.ca
• Canada: Office of the Privacy Commissioner of Canada — www.priv.gc.ca
• EU/EEA: Your local data protection authority (list at edpb.europa.eu)

GoSiteMe — A privately held technology company
Copyright © 2026 GoSiteMe. All rights reserved.
This document does not constitute legal advice.