Privacy Policy

1. Who we are

Conrado Maggi (hereinafter ExpirationPilot) operates the ExpirationPilot.com service. For the purposes of the EU General Data Protection Regulation (GDPR) and the Spanish data protection law (LOPDGDD), the controller of the data described in section 3 is:

Write to the email address above about anything in this policy. We do not have a data protection officer; the operator handles privacy questions directly.

2. Two kinds of data, two roles

• Account and website data (section 3): who signs up and signs in, how they use their account, and visits to our website. We are the controller.
• Data our customers put into ExpirationPilot (section 4): their team members, their contacts, the expirations they track and the documents they collect. The customer (the business using ExpirationPilot) is the controller, and we are its processor under the Data Processing Agreement.

3. Data we are responsible for

What we collect

• Account details: your name, email address, company name, password, the time zone of your browser at sign-up, and when you agreed to our terms. Passwords are stored only as a one-way hash (bcrypt); we cannot read them.
• Sign-in sessions: while you are signed in, we keep a session record with your IP address and your browser's description (user agent), to keep you signed in and to protect the account.
• Security data: IP addresses are used briefly to limit repeated sign-in attempts and other abuse.
• Messages to us: what you write when you email support, and our replies.
• Billing: paid plans are not on sale yet. When they are, we will keep the billing details the law requires (company name, address, tax number, invoices). We will update this policy before a payment provider receives any data.

We do not use analytics, advertising or tracking tools on our website or in the app. The Cookie Policy lists the few cookies we set, all strictly necessary.

Why we use it, and the legal basis

• To provide the service you signed up for: create and run your account, sign you in, send the emails the service needs (team invitations, password resets, reminders, daily digests and weekly summaries). Basis: the contract with you (GDPR art. 6(1)(b)).
• To keep the service secure and prevent abuse and fraud. Basis: our legitimate interest in protecting the service and its users (art. 6(1)(f)).
• To answer your questions and tell you about important changes to the service or these documents. Basis: the contract, and our legitimate interest in keeping you informed (art. 6(1)(b) and (f)).
• To keep accounting and tax records once billing starts. Basis: legal obligation (art. 6(1)(c)).
• Product news or offers by email, only if you have opted in, and you can opt out at any time. Basis: consent (art. 6(1)(a)). We do not currently send any.

4. Data our customers put into ExpirationPilot

Businesses use ExpirationPilot to track expirations and collect renewed documents. To do that, they store in their account:

• Team members: name and email address of each colleague who signs in, and which reminders they receive.
• Contacts: name, email address, phone number, company, and whether the person is an employee or an outside contact.
• Expirations: what is tracked (for example a license, an insurance policy or a person's certificate), its dates, notes, who is responsible and the reminder settings.
• Documents and answers: the files uploaded by the team or by contacts, and the answers to any questions on the request.
• Email log and activity history: which emails were sent to whom, whether they were delivered or bounced, when an upload link was first opened, and who did what in the account (for example, approved a document).

We process this data only to provide the service to that business, on its instructions, as set out in the Data Processing Agreement. We do not use it for our own purposes.

If you received a document request

A business you work with uses ExpirationPilot to ask you for a document. That business added your details, decides which emails you receive, and decides what happens to the documents you upload. It is the controller of your data.

• The request email comes from us on that business's behalf, in its name. Replies go to the business, not to us.
• Your upload link is private and random. It stops working when the request is closed, for example when the business approves your document, cancels the request or sends a new link.
• The files you upload are visible only to the people at that business who sign in to its account. They are never public.
• If you click "Not the right person?" and give a colleague's name and email address, the request is passed to them.
• To see, correct or delete your data, or to stop receiving requests, contact the business that sent the request. If you write to us instead, we will pass your request to that business and help it answer you.

5. Who we share data with

We use a small number of service providers (sub-processors) to run ExpirationPilot: hosting in Frankfurt, Germany; a network provider that carries every request to the site securely; an email delivery service; and a font service. The current list, with what each one does and where, is in the Data Processing Agreement. Each is bound by a contract to protect the data and use it only to provide its service to us.

The fonts on our pages are loaded from Bunny Fonts (BunnyWay d.o.o., Slovenia, EU). Your browser connects to it to fetch them, which shares your IP address with it; Bunny Fonts sets no cookies.

We may also disclose data when the law requires it, for example to a court or a public authority with a valid order, or to protect our rights. We never sell personal data, and we never give it to advertisers.

We do not use personal data or uploaded documents to train artificial intelligence models, and we do not let our providers do so.

6. International transfers

Our servers and the uploaded files are in the EU (Frankfurt, Germany). Some of our providers are companies based in the United States or operate global networks, so personal data may be accessed from or passed outside the European Economic Area. When that happens, the transfer is covered by the EU–US Data Privacy Framework, where the provider is certified, and/or the European Commission's Standard Contractual Clauses.

7. How long we keep data

• Account data is kept while the account exists. When a person deletes their login (Profile → Delete account) or is removed from the team, their user record is deleted straight away; the account's activity history keeps a note of the removal (name and email address) for as long as the account exists.
• Deleting an account: when the last person on an account deletes their login, the account is deleted at once with all of its data: expirations, contacts, document requests, uploaded files, the logo, email templates, the email log and the activity history.
• Replaced and rejected documents are deleted automatically once a day after the period the business chose in Settings → Data retention. By default, a document that a newer renewal replaced is kept for 365 days, and a rejected upload for 30 days. The current document of each expiration is kept until the business removes it from the expiration or the account is deleted.
• Spreadsheets uploaded for "Import from Excel" are deleted as soon as the import is done, and in any case within two hours of the upload.
• Sign-in sessions end after 2 hours without activity, or when you log out.
• Backups: we make nightly backups, sent encrypted to their storage, and keep them for 30 days. Deleted data disappears from the backups when they are overwritten, within 30 days.
• Support emails are kept for as long as needed to help you, and billing records for as long as tax law requires (in Spain, generally up to six years).

8. How we protect data

• All traffic to the site is encrypted with TLS (HTTPS), and browsers are told to use HTTPS only.
• Passwords are stored only as bcrypt hashes. Invitation and upload links are long random tokens. Invitation links are stored only as hashes; upload links are looked up by their hash and otherwise kept only in encrypted form, so the emails can carry them.
• Uploaded files are kept on private storage, never in a public folder, and are served only through the app to signed-in members of the account they belong to.
• Each account's data is kept apart from every other account's; the app checks this on every request.
• Sign-in, upload pages and other public forms are rate-limited against guessing and abuse, and every page is sent with strict browser security headers.
• Only the operator has administrative access to the servers.

No system is perfectly secure. If a personal data breach affects you, we will inform you and, where required, the supervisory authority, as the law requires.

9. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you and get a copy of it;
• have inaccurate data corrected;
• have your data deleted;
• restrict or object to how we use it, including to processing based on our legitimate interests;
• receive the data you gave us in a portable format;
• withdraw consent at any time, where we rely on it.

Much of this you can do yourself: change your name and email in Profile, export lists to Excel, and delete your login. For anything else, email [email protected]. We answer within one month. For data a business put into its account (section 4), we will forward your request to that business.

If you think we have not handled your data properly, you can complain to the Spanish data protection authority, the Agencia Española de Protección de Datos (AEPD), at www.aepd.es, or to the authority of the EU country where you live or work. We would appreciate the chance to address your concern first.

10. Children

ExpirationPilot is a service for businesses and is not meant for children. We do not knowingly collect data from anyone under 16 for our own purposes.

11. Changes to this policy

We will update this policy when our services or the law change; the date at the top shows the latest version. If a change materially affects how we use your data, we will email account users before it takes effect.