PRIVACY POLICY

Last Updated: October 1, 2026

PLEASE READ THIS PRIVACY POLICY CAREFULLY. THE RECORDS YOU CREATE ON APPCLOSE ARE DESIGNED TO BE PRESERVED AS EVIDENCE, AND NO USER, INCLUDING YOU, CAN ALTER OR DELETE THEM. SECTIONS 9, 11, AND 12 EXPLAIN WHAT THAT MEANS FOR YOUR INFORMATION.

AppClose, Inc. (the “Company,” “we,” “us,” or “our”) provides the AppClose website, mobile application, and related services, including AppClose Pro (together, the “Platform” or the “Services”). This Privacy Policy describes the personal information we collect, how we use and share it, how long we keep it, and the choices and rights you have. It applies to AppClose Users and AppClose Pro Users, however they access the Platform. We do not sell your personal information, we do not use it for targeted advertising, and we do not allow third-party advertising in the App or on the Site.

Capitalized terms that are not defined in this Privacy Policy have the meanings given to them in our Terms of Service. Where this Privacy Policy and the Terms of Service describe the same practice, they are intended to be read together. This Privacy Policy is a notice, not a consent form. Where the law requires your consent for a particular use of your information, we ask for it separately in the Platform.

Changes to this Privacy Policy. We may update this Privacy Policy by posting the updated version on the Site with its effective date. For material changes, we will notify you through the AppClose Official Chat or by email before the change takes effect. If you have questions about this Privacy Policy or your rights, contact our Privacy Office and Data Protection Officer at privacy@appclose.com.

1. What Is Personal Information?

Personal information is information that identifies, or can reasonably be linked to, a particular person, such as a name, email address, phone number, or identification number. Information that has been aggregated or de-identified so that it can no longer reasonably identify a person is not personal information. We keep de-identified information in that form, and we do not attempt to re-identify it.

2. Information We Collect

2.1 Sign-up Data. When you register as an AppClose User, you provide your first name, last name, email address, phone number, country, city, and, if you live in the United States, your zip code. We also record the date and time you signed up and the IP address you signed up from. Together these are your Sign-up Data. We also collect your state or province, your gender if you choose to provide it, whether your use of AppClose is court ordered, and, if it is not, how you heard about AppClose. Unless a court orders otherwise, you decide whether to share your name and email address with your co-parent, a family law professional, or others in your circle, and whether other Users can find you in the App by email address or phone number. We cannot locate your Account or your records by name alone. Please keep a mobile phone number or a recovery email address on file; without one, we cannot verify your identity if you lose access to your registered email address.

2.2 Subscription, Billing, and Fee Waiver Information. If you buy a Subscription on the Site, your payment information and billing address are collected and stored by Stripe, Inc. and its Link service (“Stripe”), our payment processor and merchant of record for Site purchases, and not by us. If you buy a Subscription in the App, Apple or Google handles your payment information under their own terms. We keep records of your Subscription status, Plan, Subscription Period, transaction amounts and dates, and applicable taxes.

If you submit a Fee Waiver Application, we collect the information needed to evaluate it. That includes the state, county, and court handling your family law matter and, if you choose to provide them, your case number and the name of the judge. It may also include whether you receive certain means-tested government benefits, whether you are a survivor of domestic violence or the co-parent of a survivor, whether you are an active-duty service member or veteran, and any supporting documents you provide. We treat this information as sensitive, we use it only to evaluate and administer your application, and we do not share it with your co-parent or any other User.

2.3 Account Activity. We collect and store the information you provide or create when you use the Services, including:

messages (including messages with a family law professional you link to) and photos;
requests and expense entries;
calendar entries, events, and notes;
Call Detail Records for audio and video calls, and Call Recordings and transcripts where every participant has consented (Section 4);
check-ins you create using Location Services (Section 2.6);
records of ipayou transactions (Section 7.4);
health information, PHI, and emergency contacts you choose to enter, including information about your children;
contacts you choose to import from your address book, and information about pets; and
any other information you upload to use a feature of the Platform.

This information is encrypted when it is created. Chats (including their text and images), Call Detail Records, requests, expenses, check-ins, and the in-app session records for your Account are stored as Exportable Records, which no User can modify or delete (Section 9). Calendar entries, notes, profile information, child profiles and child information, and imported contacts are not Exportable Records, and you may edit or remove them. Call Recordings and transcripts are not Exportable Records either; Section 4 describes how they are kept and deleted.

2.4 Information About Children. No one under 18 may create an Account, and the Platform is not designed for use by children. Parents and legal guardians do, however, provide information about their children when they use the Services. By registering, each parent or legal guardian confirms that they have the legal authority to provide that information and consents to our processing of it.

A child profile contains only the child’s name, gender, and date of birth. Each co-parent creates their own profile for a child, only the parent who created a profile can edit or delete it, and a profile is never shared. Separately, you may choose to keep child information for your own use, such as reminders, medical information, measurements, education, childcare providers, and notes. Only you can see, edit, or delete your child information unless you choose to share all or part of it with your co-parent or others in your circle. A person you share it with may accept all, some, or none of it into their own version, which they then control. Child profiles and child information are not Exportable Records and are not included in any records export.

We use children’s information only to provide the Services, and we do not sell it or use it for marketing or advertising. A parent may edit or delete the information in a child profile and in the child information they created at any time. We cannot, however, remove information about a child from a communication. Messages, photos, requests, expenses, and check-ins that mention or include a child are Exportable Records that belong to both co-parents, and no User can alter them. Sections 9, 11, and 12 describe the limited circumstances in which we can quarantine or delete an Exportable Record.

2.5 Information We Collect Automatically. When you use the Services, we collect IP addresses, device operating system, App version, and session logs, and when you visit the Site, information such as the pages you view and the site that referred you. We also keep your communications with our support team, which are handled through Zendesk. The App uses a small number of resettable identifiers that do not contain your name or contact details: an installation identifier generated by Firebase, used to deliver the push notifications you enable, keep the App working, and produce aggregated usage statistics; on iOS, an identifier for vendor, used for analytics, fraud prevention, and App functionality; and, only if you permit it in your device settings, your device’s advertising identifier, used only for basic measurement, fraud prevention, and security. We do not use these identifiers to deliver, target, or measure advertising, and we do not disclose them to advertisers. You can reset or restrict them in your device settings. None of them is linked to your Exportable Records or included in any records export.

Our Site uses cookies and similar technologies, including analytics tools and advertising measurement tags provided by third parties such as Google and OpenAI. We use them to operate the Site, understand how it is used, and measure the performance of the ads we place for AppClose on other websites and platforms (we do not display any advertising on the Site or in the App), and the providers may also use the information they collect under their own privacy policies. These technologies do not run in the App or within your Account. You can manage them through the cookie preferences link on the Site or your browser settings, and we honor Global Privacy Control signals, which are browser settings that tell websites you want to opt out of the sale or sharing of your personal information.

2.6 Location Information. Some features, such as check-ins at pick-ups and drop-offs, use the precise location of your device. We collect it only after you enable Location Services and give the App permission, and you can turn that permission off at any time in the App or in your device settings. A check-in records your device’s location at the time of the check-in; you may add a different location, but the recorded location remains part of the record. Check-ins are Exportable Records, but they are not shared with your co-parent or anyone else in your circle. We never sell your location or show it to others in your circle, and we disclose it only in response to legal process (Section 7.5).

3. Sensitive Information and Consent

Some information in the Platform is treated as sensitive under privacy laws, including health information and PHI about you, your co-parent, or your children; precise location; information about children; the contents of Call Recordings; and the eligibility information in a Fee Waiver Application. Where the law requires your consent before we process this information, we ask for it in the Platform, separately from your acceptance of the Terms of Service, and you may withdraw it at any time. Withdrawing consent stops future processing, but it does not delete Exportable Records that already exist.

HIPAA generally does not apply to AppClose. We are not a health care provider, health plan, or health care clearinghouse, and we do not act on behalf of one. Health information you enter is protected by this Privacy Policy and by the privacy laws that apply to us, including the consumer health data laws described in Section 14. Please remember that information you share in a circle is visible to the people you share it with and that any User can export their own records, so sensitive information you enter may be disclosed by your co-parent or by a professional that you or your co-parent authorize.

4. Recorded Audio and Video Calls

Calling, Call Recording, and transcription are provided through Twilio Inc. (“Twilio”), which processes calls, Call Detail Records, and recordings on our behalf and receives the Call Recording and the participants’ names to produce transcripts. Every participant must consent before a call is recorded, and a recorded call begins with an announcement that it will be recorded. If you do not want to be recorded, hang up and change the setting that allows recorded calls from that person. Withdrawing your consent applies only to future recordings.

A participant may request a transcript within the time allowed in the App, if transcription is available for the language of the call. Call Recordings and transcripts are available only to the participants in the call, who may download them; AppClose Pro Users cannot access them. They are not certified records, they are not included in any records export, and the foundation required for their admissibility is determined by the court or tribunal.

Retention. While your Account is open or in Read-Only Mode, each Call Recording and its transcript is deleted on the last day of the calendar month two years after the month in which the call was made. For example, a call recorded in March 2027 is deleted on March 31, 2029. If your Account is closed or terminated, the recordings held for your Account are deleted 365 days after closure or termination. A recording made before this version of this Privacy Policy took effect is treated as if it had been made in the month in which this version took effect. Retention is determined separately for each participant based on that participant’s own Account, and we will notify each participant whose Account is open or in Read-Only Mode at least 30 days before deletion. You can download recordings and transcripts at any time before deletion while your Account is open or in Read-Only Mode, but not after your Account is closed, so download anything you want to keep first. A deleted recording cannot be recovered for your Account. We keep a copy only while it remains within the retention period for another participant’s Account, or while we ourselves are required to preserve it under a litigation hold, court order, or other legal obligation that applies to us, and we delete it promptly once that obligation ends. A preservation obligation that applies only to a User does not stop deletion; if you are under one, download the recording before it is deleted. We delete recordings earlier where the law requires.

5. Artificial Intelligence

Co-Parent Assist. Co-Parent Assist is an optional assistant that you choose to turn on. Before you send a message, it reviews the message as you wrote it, including any names it contains, and it may use recent messages in the same chat as context, to give you feedback on tone and clarity and suggest an alternative. You decide what to send, and only the message you send becomes an Exportable Record. We may retain your draft, the suggestion, and related scores to provide the feature, and a message you send may be scored for toxicity and similar categories. Those scores are not part of any Exportable Record and are not used to make decisions about you.

Where AI processing happens. Co-Parent Assist and the other AI features available to AppClose Users run on models hosted on our own infrastructure, and no message content, records, or prompts from those features are sent to any third-party AI provider. Transcripts of recorded calls are produced by Twilio (Section 4). AppClose Pro includes AI features that summarize, answer questions about, and search the records a client has chosen to share with an AppClose Pro User, limited to the categories and date range the client selected and to the period in which the client’s authorization is in effect. Those features process the shared records and the professional’s prompts, as written, using a large language model operated by a third-party provider, which processes that content only on our instructions to return a result in AppClose Pro, does not store it beyond the request, and does not use it to train models.

No training on your data. We do not permit any partner or third party to use your data to train its own models, and we do not use your Account Activity or the information stored in AppClose Pro to train artificial intelligence models. We may use aggregated and de-identified data to improve the Services. AI output may be inaccurate or incomplete, and you should not rely on it as a sole source of truth or as professional advice. This Section describes the same practices as Section 24 of the Terms of Service.

6. How We Use Personal Information

We use personal information only as needed to:

verify the identity and eligibility of Users;
create and administer Accounts, Subscriptions, Trial Periods, and fee waivers;
deliver your Account Activity to the people you choose;
create, encrypt, preserve, and produce Exportable Records and records exports;
operate, secure, maintain, and improve the Services, including diagnosing problems and preventing fraud and abuse;
communicate with you (Section 8); and
comply with legal, regulatory, tax, and accounting obligations and respond to legal process.

If you import contacts, we use them only for the feature you requested. We may use and share aggregated or de-identified information that cannot reasonably identify you.

Legal bases. Where data protection law requires a legal basis for processing (Section 15), we rely on performance of our contract with you to provide the Services, process payments, administer fee waivers, and send Transactional Communications; on your consent for Call Recordings, Location Services, non-essential cookies, and any promotional Communications we may send in the future; on your explicit consent for health information and other special category data that you choose to enter, including in a Fee Waiver Application; on our legitimate interests, and those of the other co-parent, in establishing, exercising, or defending legal claims, for retaining Exportable Records and Sign-up Data, and on our legitimate interests in operating and securing the Services; and on our legal obligations when we respond to legal process.

7. How We Share Personal Information

7.1 Information Shared Within a Circle. Your information is shared with the members of your circle you choose to share it with, and with a family law professional whom you or your co-parent adds to a circle in which you participate (Section 7.2). Information you share only with your co-parent is not visible to others in the circle. Anyone in a circle who has an active Account can retrieve the Account Activity shared in that circle, and either co-parent may export shared chats and other Account Activity and give them to an attorney, a court, a mediator, or anyone else. Child profiles are never shared, and child information is shared only as described in Section 2.4. We do not view or monitor communications, and we decrypt them only on the grounds in Section 9.

If your co-parent is not connected to you on the Platform, you may share a request, calendar event, or expense entry by sending a link outside the Platform. Anyone with the link can open the item in a web browser without signing in, download a calendar event, and approve or decline a request. A link expires 10 days after it is sent, and a link sent before this version of this Privacy Policy took effect expires 10 days after this version took effect. A link cannot be revoked before it expires.

7.2 AppClose Pro Users. When a professional registers for AppClose Pro, we collect their name, work email address, phone number, city, state, zip code, and occupation, and any practice information they choose to add. Each AppClose Pro User decides whether their profile is visible to and searchable by AppClose Users. We store the information AppClose Pro Users create, including the names of clients who connect with them (“Connected Clients”), their chats with Connected Clients (visible only to the professional and that client), requests from Connected Clients, and calendar entries and notes.

A professional invited to a co-parent circle may view, but not participate in, the chats in that circle through the date the inviting co-parent designates, and may participate in a group chat if all of its parties agree. That access does not extend to one-to-one chats between a co-parent and a professional that co-parent has linked to directly, to Call Recordings or transcripts, or to child profiles or child information, and it depends on the consents described in Sections 4.2 and 4.6 of the Terms of Service. Because any User can export their own records, a professional’s access speeds up sharing that the User could do in any event.

7.3 Service Providers. We share personal information with service providers that perform services for us, and with partners whose services you choose to use. Our service providers act under written terms that limit their use of the information to the services we engaged them to provide. Our principal providers are:

Twilio, for calling, recording, and transcription;
a third-party large language model provider, for the AI features in AppClose Pro (Section 5);
Dwolla and Plaid, for ipayou (Section 7.4);
Stripe, for Subscriptions purchased on the Site, and Apple or Google, for Subscriptions purchased in the App;
Zendesk, for customer support;
Amazon Web Services, Inc., for hosting, data storage, and infrastructure;
providers of website and product analytics and of survey and research tools; and
our professional advisers, including auditors and legal counsel.

Stripe, Apple, and Google also process payment information for their own purposes, such as calculating taxes, handling chargebacks, screening for fraud, and keeping the records financial law requires, under their own privacy policies. We do not share your personal information with third parties for their own marketing.

7.4 ipayou and Dwolla. ipayou, our payment feature, is powered by Dwolla, Inc. (“Dwolla”) and is available only in the United States. To open an ipayou account, you provide Dwolla with information such as your name, address, date of birth, and social security number, and you accept Dwolla’s terms and privacy policy, and Plaid’s privacy policy if you use Plaid to link your bank account. Dwolla shares verification information with us in encrypted form, but we cannot access your social security number, and we do not receive or store your bank account credentials. We keep and display records of your ipayou transactions, including the amount, date, status, account identifiers presented to us, and your notes, as Account Activity. Dwolla may issue you a Form 1099-K; receiving one does not mean the amounts are taxable (see Section 8.1 of the Terms of Service).

7.5 Legal Process. We disclose Account Activity and other information when required or authorized by a proper subpoena, court order, warrant, or other legally binding request, as described in our Subpoena Policy. Those disclosures are made from Exportable Records: chats, Call Detail Records, requests, expenses, check-ins, and session logs, which include IP addresses and device operating system. We do not review, read, or redact your records before producing them; whether anything should be withheld, redacted, or sealed is for the parties and the court or tribunal to decide. If we believe in good faith that a request was not initiated by you or your counsel, we may notify you, or confirm that your counsel has been notified, so that you can seek a protective order. Except where the law requires, we are not obligated to notify you, delay our response, or oppose the request, and some government requests prohibit notice. Where the law permits, we may also disclose Sign-up Data and Account status to law enforcement in response to a valid request where we reasonably believe it is necessary to prevent an imminent risk of death or serious physical injury, or to investigate fraud against or unlawful use of the Platform. Disclosing the content of Account Activity requires legal process.

7.6 Change of Ownership. If we are involved in a merger, an acquisition, or a sale of all or substantially all of our assets, we may share information with the other party.

7.7 No Sale; No Advertising. We do not sell your personal information, we do not use it for targeted advertising, and we do not display third-party advertising in the App or on the Site.

8. Communicating With You

We send Transactional Communications about your Account and the Services, such as security alerts, payment confirmations, Subscription and fee waiver status, and updates to the Terms of Service or this Privacy Policy, through the AppClose Official Chat, email, text message, or push notification. You cannot opt out of them while your Account is active. We do not currently send promotional Communications. If we do so in the future, we will obtain any consent the law requires, and every promotional message will include a free way to opt out. If you give us a mobile phone number, reply STOP to any text message to stop text messages; Transactional Communications will then reach you by email, through the Official Chat, or by push notification. Message and data rates may apply.

9. Encryption, Decryption, and Exportable Records

Account Activity is encrypted when it is created and when it is stored, and Exportable Records are preserved with a documented chain of custody intended to support their use as evidence. No User, including you, can modify or delete an Exportable Record. A User who shared an expense entry may withdraw it, but the original entry remains in the record, shown with a line through it. This is a deliberate design choice: records that either parent could alter or erase would not serve the purpose of the Platform. We can decrypt an Exportable Record only:

to comply with a proper subpoena, court order, or other legally binding request;
automatically, at a system level and only for as long as the operation takes, to display a record to a person entitled to see it in the Platform or in AppClose Pro, to produce a records export requested by an authenticated User entitled to it, or to process records through the AI features in Section 5 at the direction of a User or AppClose Pro User entitled to view them, in which case the decrypted copy is not retained and the stored record remains encrypted; or
to quarantine or delete an Exportable Record (i) where a court order or other legally binding request requires it, (ii) where both co-parents ask in writing, in a form we designate, for the removal of an image and we determine that we are legally permitted to remove it, or (iii) where we must do so to give effect to a valid request under data protection law.

Apart from these grounds, we do not decrypt, view, or monitor your communications, and we never decrypt them for advertising, profiling, or training artificial intelligence models. A quarantine or deletion is noted in the record itself, including in any Certified Records Export. A quarantined record is held separately and produced only on a court order or other legally binding request. We will not act on a request under clause (ii) if we know the record is subject to a litigation hold or other obligation to preserve it, and we are not obligated to act on any particular request. We delete a record from the system entirely only if we are not legally permitted to quarantine it. This Section describes the same practice as Section 3 of the Terms of Service.

10. Where Your Information Is Processed

We are based in the United States, and our servers and principal service providers are located there. If you use the Services from another country, your information will be transferred to and processed in the United States, and possibly in other countries where our providers operate, and information held in the United States may be accessed by courts and authorities there under U.S. law. We protect your information with contractual, technical, and organizational safeguards wherever it is processed.

11. How Long We Keep Personal Information

We keep personal information for as long as needed for the purposes described in this Privacy Policy. In deciding how long to keep information, we consider the purpose for which it was collected, its sensitivity, whether it is part of an Exportable Record, and whether we have a legal, regulatory, tax, or accounting obligation to keep it. Because Exportable Records document your interactions with others and may be needed in legal proceedings, we keep Exportable Records and other Account Activity, and the Sign-up Data needed to locate them, for as long as reasonably necessary to protect against, exercise, or respond to legal claims and to meet our legal obligations. That period may be indefinite, and it continues after your Account is closed, subject at all times to applicable law and your data protection rights. This is the same rule stated in Section 3 of the Terms of Service. Call Recordings and transcripts are kept and deleted as described in Section 4. We also keep the email address associated with a closed Account so that it cannot be used to register another Account. When we no longer need personal information, we dispose of it securely.

12. Your Choices; Access, Correction, and Account Closure

Updating your information. You can change your email address or phone number in your Account settings after verifying your identity, and AppClose Pro Users can update their profiles the same way. If you lose access to your registered email address, we can restore your access only by verifying your identity through the mobile phone number or recovery email address on file.

Read-Only Mode. If you cancel your Subscription, your Subscription Period ends without renewal, or a payment is not made, your Account moves to Read-Only Mode. Your Account stays open: you can sign in, view and export your records, and reactivate at any time, but you cannot communicate with other Users. Your records continue to be kept as described in Section 11.

Closing your Account. You may close your Account in your Account settings or by writing to support@appclose.com. Closing is permanent: the Account cannot be reopened, and its email address cannot be used to register again, although you may register with a different email address. Closing cancels your Subscription under the Refund Policy; if you bought through Apple or Google, you must also cancel with them. Closing does not delete your Exportable Records or Sign-up Data, and your co-parent keeps access to the communications you shared for as long as their Account is active. You cannot download Call Recordings or transcripts after closing, so download them first. To obtain the records of a closed Account, contact support@appclose.com. After we verify your identity, we send a PDF copy to the email address associated with the Account or, if you cannot access it, to a recovery email address that was on file when the Account was closed. If neither is available but a mobile phone number was on file, we may use it to verify your identity and set a replacement email address for the PDF. An Account that we terminate under Section 2.2 of the Terms of Service is treated the same way.

Deletion requests. Where the law gives you a right to have personal information deleted, write to privacy@appclose.com, and we will honor your request to the extent the law requires. We often must or may keep Exportable Records despite a deletion request, for example because they may be needed for legal claims (including the other co-parent’s), are subject to a legal hold or court order, or must be kept by law. If we cannot delete information, we will tell you why and, where the law provides, restrict further processing instead. If we must give effect to a request, we quarantine the affected record as described in Section 9 and delete it only if the law requires.

13. U.S. State Privacy Rights

Residents of California and other states with comprehensive privacy laws have the following rights, subject to the exceptions in applicable law. Before acting on a request, we will verify that it comes from you or from someone authorized to act for you.

to know and access the personal information we hold about them, and to obtain a portable copy;
to correct inaccurate personal information;
to request deletion, subject to Section 12;
to opt out of the sale or sharing of personal information, targeted advertising, and certain profiling (we do not engage in these activities, and we honor Global Privacy Control signals);
to limit the use of sensitive personal information (we use it only to provide the Services you request, to comply with law, and for other purposes the law permits);
to withdraw consent to the processing of sensitive personal information; and
not to be treated differently for exercising these rights.

We collect information these laws treat as sensitive, including health information, precise location, the contents of communications, information about a known child, and, in some states, a person’s status as a victim of a crime. Where your state requires consent to process it, we ask for it in the Platform (Section 3). The categories of personal information we collect, their sources, our purposes, and the categories of recipients are described in Sections 2, 6, and 7, and our retention periods in Section 11.

To make a request, email privacy@appclose.com or write to us at the address in Section 20. We will verify your identity using the email address and phone number on your Account, and an authorized agent may act for you with written authorization that we can verify. We respond within 30 days, or within any shorter period the law requires. If we decline your request, you may appeal by replying to our response or writing to privacy@appclose.com with the subject “Privacy Request Appeal,” and if we deny your appeal, you may contact your state Attorney General or, in California, the California Privacy Protection Agency. We do not respond differently to Do Not Track signals, and we do not share personal information with third parties for their direct marketing. California residents may also contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs at 1625 North Market Blvd., Suite N-112, Sacramento, California 95834, or (800) 952-5210.

14. Consumer Health Data

Health information that you or others in your circle enter about you, your co-parent, or your children is consumer health data under the laws of several states, including Washington, Nevada, and Connecticut. We do not sell consumer health data, use it for marketing or advertising, use it to build profiles, or use it, or let any third party use it, to train artificial intelligence models. We share it only with the people you or your co-parent select, with our service providers, and in response to legal process, and we ask for any consent those laws require. If you live in Washington, or if your consumer health data is collected there, our Consumer Health Data Privacy Policy describes our practices and your rights. Residents of other states may exercise their consumer health data rights as described in Section 13.

15. Users in Ireland and the United Kingdom

If you are in Ireland or the United Kingdom, the General Data Protection Regulation or the UK GDPR applies to our processing of your personal data. AppClose, Inc., 5000 Plaza on the Lake, Suite 300, Austin, TX 78746, United States, is the controller, except that Stripe, Apple, Google, Dwolla, and Plaid determine their own purposes for the payment information described in Sections 7.3 and 7.4. You may contact our Data Protection Officer at privacy@appclose.com.

Representatives. As required by Article 27 of the GDPR and of the UK GDPR, we have appointed the following representatives, who may be contacted at gdpr@euverify.com or through their portal at https://gdpr.euverify.com/verify/72fc648d-4736-4d4b-8016-b915d2a0a8fb. You may also contact us directly, and contacting a representative does not affect your right to complain to a supervisory authority.

EU representative: Euverify Ltd, registered in Ireland under company number 781168, Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork, T23 AT2P, Ireland.
UK representative: Euverify Ltd, registered in the United Kingdom under company number 16146525, 3rd Floor, 86-90 Paul Street, London, EC2A 4NE, United Kingdom.

Your rights. You may request access to, correction of, or erasure of your personal data; restrict or object to our processing; receive your data in a portable format; and withdraw your consent at any time, without affecting earlier processing or deleting Exportable Records that already exist. You can update your account and profile information yourself in the App. Because Exportable Records are a record of what was actually communicated and also belong to the other co-parent, we do not edit them, and we may keep them where they are needed to establish, exercise, or defend legal claims. You have an absolute right to object to direct marketing. We do not make decisions with legal or similarly significant effects based solely on automated processing. Where a child is below the age of digital consent, we rely on the consent of a parent or guardian. You may complain to the Data Protection Commission in Ireland or the Information Commissioner’s Office in the United Kingdom. Our legal bases are described in Section 6, and international transfers in Section 10.

16. Users Outside the United States

The Services are offered in the United States, Canada, the United Kingdom, Ireland, Australia, New Zealand, South Africa, and Trinidad and Tobago. ipayou and Certified Records Exports are available only in the United States. If you live outside the United States, the data protection laws of your country may give you rights in addition to those described in this Privacy Policy, including the right to raise concerns with your national data protection authority. Nothing in this Privacy Policy limits any right you have under the law of your country that cannot be waived, and we will honor those rights to the extent they apply to us. Your information is protected by the safeguards described in Sections 10 and 17. To ask how a right applies to you, or to make a complaint, write to privacy@appclose.com.

17. Security; Breach Notification

We use industry-standard technical, administrative, and organizational safeguards, including encryption of data in transit and at rest, firewalls, and access controls, and we maintain a written information security program that we review periodically. No method of transmission or storage is completely secure. If a breach affects your personal information, we will notify you and the appropriate regulators as the law requires, without undue delay.

18. Third-Party Websites

The Platform may link to third-party websites, including the websites of family law and mental health professionals. We are not responsible for their privacy practices, and this Privacy Policy does not apply to them.

19. Staying Signed In

You stay signed in to the App until you log out. Anyone using a device on which you are signed in may be able to view your Account and send messages, invites, or payments without signing in again, so please log out when you use a shared device. Changing your email address, phone number, or linked bank account requires you to verify your identity. Keep your login credentials confidential, and tell us at support@appclose.com if you believe your Account has been compromised.

20. Contact Us

If you live in the United States, you are contracting with AppClose, Inc. and, for ipayou, also with Dwolla, Inc. For questions, concerns, or complaints about this Privacy Policy or our practices, contact us:

by email: privacy@appclose.com;
by mail: Attn: Office of the Data Protection Officer, AppClose, Inc., 5000 Plaza on the Lake, Suite 300, Austin, TX 78746;
by phone, for ipayou activity and to leave a message for the Privacy Office: 888-567-0727; or
for customer service: support@appclose.com.

We respond within thirty (30) days, or sooner where the law requires.