Privacy Policy

Brighter Days Advisory LLC doing business as Kelsey Quality ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information.

1. DATA COLLECTION

We collect the following information:

• Account Information: Name, email address, and profile picture via Google OAuth
• Document Access: Read-only access to Google Drive documents you authorize for scanning
• Compliance Data: Gap findings, clause references, document classifications, and compliance scores generated from your scans
• Usage Data: Information about how you interact with the Service

2. AI DISCLOSURE

We use Anthropic Claude to analyze your documents against ISO 13485, FDA QMSR, and related regulatory requirements.

Your document content is processed in-flight and is NOT stored by us or our AI provider. Only compliance metadata (gap findings, clause references, document classifications) is retained.

Important: We do not use your documents or compliance data to train machine learning models. We do not permit our AI providers to use your content for model training purposes.

3. TRACKING

We use cookies and tracking technologies to monitor service performance, analyze usage patterns, and improve user experience.

4. DATA HOSTING

We use Vercel for hosting and infrastructure services. Your data is stored on servers located in the United States.

5. DATA SECURITY

We implement industry-standard security measures to protect your data:

• OAuth tokens are encrypted at rest
• Document content is processed in-flight via encrypted API calls and is never written to persistent storage
• Sensitive data is transmitted over secure HTTPS connections
• Access to user data is restricted to authorized personnel only

6. PAYMENT PROCESSING

Payment information is processed by Paddle, our third-party payment provider. We do not store or have access to your full payment details.

7. COMPLIANCE WITH API POLICIES

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

8. YOUR RIGHTS

Depending on your location, you may have the following rights:

All Users:

• Access: Request a copy of your data at any time
• Deletion: Request deletion of your account and associated data
• Correction: Update inaccurate information via your account settings

EU/EEA Users (GDPR):

• Right to data portability
• Right to restrict processing
• Right to object to processing
• Right to lodge a complaint with a supervisory authority

California Users (CCPA):

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of sale of personal information (we do not sell your data)
• Right to non-discrimination for exercising privacy rights

Australia/New Zealand Users:

• Rights under the Privacy Act 1988 (Australia) and Privacy Act 2020 (New Zealand)

To exercise any of these rights, contact us at: support@kelseyqms.com

9. DATA RETENTION AND DELETION

• Active Accounts: Compliance scan results are retained as long as your account is active. Document content is never stored.
• Deletion Requests: You may delete scan results via your account at any time.
• Account Deletion: For full account deletion, contact support@kelseyqms.com. We will process your request within thirty (30) days and permanently delete all associated data.
• Backups: Deleted data may persist in encrypted backups for up to thirty (30) days before permanent removal.

10. CHILDREN'S PRIVACY

This Service is not directed at individuals under thirteen (13) years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, contact us immediately at support@kelseyqms.com.

11. DATA BREACH NOTIFICATION

In the event of a data breach that affects your personal information, we will notify you via email within seventy-two (72) hours of discovery and provide information about the nature of the breach and steps we are taking to address it.

12. INTERNATIONAL DATA TRANSFERS

If you are accessing the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States. By using the Service, you consent to this transfer.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of material changes via email at least thirty (30) days before the changes take effect. Your continued use after the effective date constitutes acceptance of the updated policy.

14. CONTACT US

For questions or concerns about this Privacy Policy or our data practices, contact us at:

Email: support@kelseyqms.com