Privacy Policy
Effective date: [DATE] Last updated: [DATE] Controller/Operator: [LEGAL ENTITY NAME], d/b/a AXIS Launch ("we," "us"), jonathanarvay.com (the "Site"). Contact: [CONTACT EMAIL], [MAILING ADDRESS].
1. Defined Terms
- "Intake Data" — information submitted through Site forms: listing submissions, thread submissions, bidder applications, contact forms, and newsletter signups.
- "Member Account Data" — profile and authentication data for registered Site accounts (hosted by Squarespace).
- "Verification Data" — documents and live evidence reviewed for verification badges: government ID, LinkedIn profiles, financial statements, bank/brokerage statements, revenue-dashboard screen-shares or read-only invites.
- "Listing Content" — content published on the public Site (app listings, auction listings, forum threads, comments).
- "Service Providers" — third parties that process data for us (Section 6).
2. The Short Version
Plain English: We collect what you type into our forms, basic analytics, and — if you seek a verification badge — we look at your documents but do not keep them. IDs and financial statements are reviewed, never retained, and never shown to anyone else; only the resulting badge or verified amount is shared. Newsletter signup is opt-in with one-click unsubscribe. You can ask us to delete your data. We don't sell personal information.
3. What We Collect and Why
3.1 Intake Data
When you submit a listing, forum thread, bidder application, or contact form, we collect what the form asks for — typically name, email, links (product URL, LinkedIn), listing text and media, and for bidder applications: entity, budget band, acquisition experience, and target categories. Purpose: operating the directory, forum, and marketplace; reviewing submissions; contacting you about them. Where it lives: Squarespace form storage/Contacts, our intake spreadsheet (Google Drive), and email.
3.2 Verification Data — reviewed, never retained
For verification badges we review, but do not keep:
- Identity Verified: we view your government ID and LinkedIn during the check. We do not store copies of your ID. We record only: that the check passed, the date, and the reviewer.
- Metrics Verified: we observe a live screen-share of, or hold a read-only invite to, your revenue dashboard (Stripe, RevenueCat, PAID, analytics). We record only the verified figures and the verification date. Screenshots you upload for a listing become Listing Content only with your approval.
- Buyer Funds Verified: you email a redacted bank or brokerage statement; we reply with a "Verified up to $X" note and delete the statement. Sellers may see the verified amount on request — never the documents.
Hard rule (also in our Terms): verification documents are reviewed, never retained, and never shown to counterparties. Only the resulting badge, date, and verified amount are shared. Documents received by email are deleted from our mailbox (including trash) within [7] days of the check.
3.3 Member Account Data
Member accounts (for commenting and, later, member areas) are provided through Squarespace's member system: email, display name, password (held by Squarespace — we never see it), and comment history. Purpose: authentication, moderation, and member features.
3.4 Newsletter
We collect your email (and optional name) when you subscribe, with your consent. Every issue includes a one-click unsubscribe. We may see per-campaign open/click statistics from our email provider. We do not enroll you in the newsletter merely because you submitted a listing, unless the form says so and you opt in. [OWNER DECISION: confirm listing form does NOT auto-subscribe — checkbox required.]
3.5 Analytics and Technical Data
We use [Squarespace native analytics / Google Analytics 4] to collect standard usage data: pages viewed, referrer, approximate location (from IP), device/browser type, and cookie identifiers. Purpose: understanding traffic and improving the Site. See Section 8 (cookies). We do not run third-party advertising trackers.
3.6 Marketplace and Moderation Records
We keep operational logs: bid logs, NDA execution records, escrow transaction references (no fund custody — Escrow.com holds all funds and its own records), moderation logs (action, reason, date), and badge-audit results. Purpose: running auctions and the community with an audit trail; enforcing our Terms.
4. What We Publish
Listing Content is public by design: app listings, maker bylines and stories, auction listings (anonymized — the seller's identity and app name appear only in the gated data room), forum threads, and approved comments. Do not put anything in a public submission you don't want published. Auction data rooms are gated and shared only with NDA-signed, approved bidders.
5. Legal Bases (where applicable law requires one)
Performance of our Terms with you (accounts, listings, auctions); consent (newsletter, optional cookies); legitimate interests (analytics, fraud prevention, moderation records, defending claims); legal obligations (tax records for paid tiers and success fees). [ATTORNEY: confirm whether GDPR/UK GDPR framing is needed given US-targeted service, and adjust.]
6. Who We Share With
Plain English: No selling of data, no ad brokers. We share only with the services that run the platform — and with a counterparty, only the badge/verified amount, never your documents.
- Service Providers: Squarespace (hosting, forms, commerce, member accounts, email campaigns), Google Workspace/Drive (intake sheets), Zapier (form/order routing), payment processing via Squarespace Commerce's processors ([Stripe/PayPal] — we never see full card numbers), Escrow.com (transaction parties' own escrow accounts), e-signature provider ([Dropbox Sign]) for NDAs, [Google Analytics], and email delivery providers.
- Counterparties: only as described in Sections 3.2 and 4 — badges, verification dates, and verified amounts; never underlying documents.
- Legal: when required by law, subpoena, or to protect rights, safety, or the integrity of the marketplace.
- Business transfer: if the platform is sold or reorganized, data transfers to the successor under this policy.
- We do not sell or share personal information for cross-context behavioral advertising (as those terms are defined in the California Consumer Privacy Act).
7. Retention
| Data | Retention |
|---|---|
| Verification documents (ID, financial/bank statements) | Not retained. Deleted within [7] days of review |
| Verification outcomes (badge, date, verified amount) | Life of the listing/badge + [2] years |
| Intake Data (unpublished/rejected submissions) | [12] months, then deleted |
| Published Listing Content | Indefinitely (permanent directory), subject to deletion rights below |
| Member Account Data | Until account deletion + [30] days |
| Newsletter list | Until unsubscribe/deletion request |
| Bid logs, NDA records, moderation logs | [6] years [ATTORNEY: align with limitations periods] |
| Commerce/tax records | As required by tax law ([7] years) |
8. Cookies
Squarespace sets strictly-necessary cookies (session, security, checkout). Analytics cookies are set [only after consent via banner / on load — ATTORNEY: decide banner requirement given CA/EU exposure]. You can control cookies in your browser; the Site works without non-essential cookies.
9. Your Rights and Choices; Data Deletion Requests
Plain English: Email us and we'll show you what we have, fix what's wrong, or delete it. Published forum posts and listings can be anonymized (byline removed) where full deletion would break public records — personal data still comes out.
9.1. Requests. Email [PRIVACY EMAIL] to request: access to your personal data, correction, deletion, a copy (portability), or newsletter/marketing opt-out. We will verify the request against your account or submission email and respond within [30/45] days.
9.2. Deletion specifics. On a verified deletion request we delete Intake Data, Member Account Data, and newsletter data. For published Listing Content and forum posts, we will remove or anonymize personal identifiers (byline, contact details); the non-personal body of a published listing or thread may remain as part of the public record where permitted by law. Verification documents require no deletion — we never keep them.
9.3. State privacy rights. Residents of California, Colorado, Connecticut, Virginia, Texas, and other states with comprehensive privacy laws may have specific rights (know, delete, correct, opt out of sale/share, non-discrimination, appeal). We honor these via [PRIVACY EMAIL]. We do not discriminate against you for exercising rights. Appeals: reply to our decision and we will re-review within [45] days. [ATTORNEY: confirm which state statutes actually apply given operator size/thresholds — likely below CCPA thresholds; decide whether to voluntarily comply.]
9.4. Do Not Track / opt-out signals. [Honor Global Privacy Control? — ATTORNEY/OWNER decision; recommended if analytics cookies used.]
10. Security
TLS on all pages; access to intake sheets and mailboxes limited to the admin and named moderators; verification checks performed only by the admin; page passwords for data rooms rotated when an auction closes or a bidder is removed; secrets kept out of client-side code. No method is 100% secure; we will notify affected users and authorities of breaches as required by law.
11. Children
The Site is not directed to children under 18 [ATTORNEY: 13 vs 16 vs 18 — Terms require 18+]. We do not knowingly collect children's data; contact us for removal.
12. International Users
The Site is operated from the United States and data is processed in the US. If you access it from elsewhere, you consent to US processing. [ATTORNEY: add SCCs/transfer language only if EU targeting is intended — currently it is not.]
13. Changes
We will post updates with a new date and announce material changes by [site notice / email]. Continued use after the effective date constitutes acceptance where permitted.