Privacy Policy

# Privacy Policy

Effective Date: [YYYY-MM-DD]

Silver Agency ("we", "us", or "our") provides the Cylvy Analysis platform ("Cylvy", the "Service"). This Privacy Policy describes how we process personal data when you visit our websites, create an account, or use the Service. Capitalized terms not defined here have the meanings in the Terms of Service.

If you are a Customer, you are typically the controller of personal data in Customer Data, and we act as your processor under the Data Processing Addendum (DPA). For our own business operations (e.g., account administration, billing, security), we act as an independent controller.

## 1. Data We Process
- **Account Data**: name, business email, company, role, authentication identifiers.
- **Usage Data**: logs, device/browser information, IP address, time zone, language, feature usage, performance metrics.
- **Customer Data**: data you or your users submit to the Service (which may contain personal data). We do not intend for sensitive/regulated data; see Beta Addendum and AUP.
- **Support Data**: communications with us (e.g., support tickets, surveys, feedback).
- **Cookies/Tracking**: see Cookie Policy for details on our use of cookies and similar technologies.

## 2. Purposes of Processing
- Provide, maintain, and secure the Service
- Authenticate users and manage accounts
- Prevent, detect, and investigate security incidents and abuse
- Analyze service performance and improve features
- Provide support and communicate about the Service
- Comply with legal obligations

## 3. Legal Bases (EEA/UK)
We rely on: (a) performance of a contract (to provide the Service), (b) legitimate interests (service improvement, security, fraud prevention), (c) compliance with legal obligations, and (d) consent for non-essential cookies/marketing where required.

## 4. Sharing and Disclosure
We share personal data with: (a) subprocessors who assist in providing the Service; (b) professional advisers; (c) authorities where required by law; and (d) a successor in connection with a corporate transaction. We do not sell personal data.

## 5. International Transfers
We may transfer personal data internationally, including to countries that may not provide the same level of protection as your jurisdiction. Where required, we use appropriate safeguards such as the EU Standard Contractual Clauses (2021/914), the UK Addendum/IDTA, and supplementary measures.

## 6. Retention
We retain personal data for as long as necessary to fulfill the purposes above or as required by law. Criteria include account status, contractual obligations, and legal requirements. Upon termination, we delete or return Customer Data per the DPA.

## 7. Security
We maintain appropriate technical and organizational measures as described in our Security Overview, including encryption in transit and at rest, access controls, logging, and vulnerability management.

## 8. Your Rights
Subject to applicable law, you may have rights to access, correct, delete, restrict, object to processing, and data portability. Where we process based on consent, you may withdraw consent at any time. To exercise rights, contact privacy@silveragency.example. We will direct data subject requests regarding Customer Data to the relevant Customer where we act as processor.

## 9. Cookies
See our Cookie Policy for details and controls. In regions where consent is required, we honor your choices via our consent manager.

## 10. Children
The Service is not directed to children under 16. We do not knowingly collect personal data from children.

## 11. Changes
We may update this Policy from time to time. If we make material changes, we will provide notice (e.g., via the Service or email) and update the Effective Date at the top of this Policy.

## 12. Contact
Silver Agency — Privacy
privacy@silveragency.example
[Postal Address]

Cylvy™ is a trademark of Silver Agency.