Legal Policies

Last updated: October 23, 2026

πŸ“‹ Plain English Summary
Quick overview before the full legal terms

ℹ️ This is a simplified summary for your convenience

The legally binding terms are below. This summary helps you understand the key points quickly, but you should read the complete terms for full details.

⚠️ Beta Service: Velvet Ledger is in early access. Features may change, and bugs may occur. We recommend regular data exports during beta.

Terms of Service

By using Velvet Ledger, you agree to these terms. We provide business management tools (tasks, contacts, finances) across multiple subscription tiers.

Age: You must be 18 or older to use Velvet Ledger. Accounts found to belong to anyone under 18 are closed.

Trial: 30 days free with Flourish plan features, then auto-downgrade to Explore if no payment.

Usage Limits: Each plan has a record and storage limit. Over it, you can't add new records until you upgrade or remove some; nothing you already have is locked or deleted.

Liability: Our maximum liability is limited to 12 months of fees paid. Service provided "as is" with no uptime guarantees.

Disputes: Resolved via binding arbitration in Delaware. No class actions.

Privacy Policy

πŸ”’ EU Data Storage: All data stored on PostgreSQL servers in Hetzner data centers (Germany, EU). Your traffic goes straight to those servers, with DDoS protection by Hetzner. Cloudflare only runs our DNS.

We Store (to provide the service): Your business data (contacts, tasks, appointments, transactions, files, notes, groups) is stored encrypted to provide the service. We claim no ownership - it's your data.

We Collect (for analytics/debugging): Account info (name, email), aggregate feature usage counts, error logs (context only), and count-based metrics only(e.g., "user has 500 contacts") - we do NOT analyze your actual contact names, task details, or transaction content.

Third Parties: Mailjet (the emails we send you, stored in the EU), Twilio (SMS phone-number verification), Mapbox (address suggestions), Cloudflare (DNS only), Dodo Payments (Merchant of Record for paid plans). We do NOT sell your data.

πŸ’³ Explore is free. Paid plans are billed through Dodo Payments, which handles payments, tax and receipts β€” we never see or store your card details.

Your Rights (GDPR): Access, export (JSON), correct, delete your data anytime.

Retention: Account data deleted 7 days after account deletion (recovery window). Billing records kept 8 years (legal requirement).

Marketing: Optional promotional emails (opt-in required, unsubscribe anytime).

Refund & Cancellation Policy

30-Day Trial: Free trial with Flourish plan features. Cancel anytime, no charge.

14-Day Money-Back: Full refund within 14 days of first payment, no questions asked.

Cancellation: Cancel anytime. You keep access until period ends, but no refund after 14-day window. No pro-rated refunds.

Example: Pay $29.99 on Jan 1 β†’ Cancel Jan 15 β†’ Keep access until Jan 31, no refund (except within first 14 days).

Downgrades: Take effect next billing cycle. No refunds for current period.

πŸ“œ FULL LEGAL TERMS BELOW
Terms of Service
Your agreement with Velvet Ledger

1. Acceptance of Terms

By accessing or using Velvet Ledger ("Service", "we", "us", or "our"), you agree to be bound by these Terms of Service. If you disagree with any part of these terms, you may not access the Service.

1.1 BETA SERVICE NOTICE - Read This First

Velvet Ledger is currently in beta/early access. By using the Service during beta, you acknowledge and accept the following:

⚠️ What Beta Means

The Service may contain bugs, errors, or incomplete features. Features may be added, modified, or removed without prior notice. Service availability may be less reliable than a mature product.

πŸ”’ Your Responsibility

You are responsible for maintaining your own backups of critical data. We strongly recommend exporting your data weekly during beta (our backups have 7-day retention).

πŸ’° Price Protection

Early users keep their current rates: 12 months for monthly plans, through the end of term for annual plans.

βš–οΈ Limited Liability

Our liability is limited as described in Section 9. Beta status increases these limitations.

CRITICAL: Export Your Data Regularly

Where: User Profile β†’ User Preferences β†’ Security
How often: Weekly during beta (our backups have 7-day retention)
Format: JSON (includes all your business data)

Reality check: Beta means we're actively improving the product. You might find bugs (please report them!), UI may change based on feedback, and new features will be added frequently. We're working toward a 1.0 release in 2026. Early users benefit from locked-in pricing and the opportunity to shape the product.

2. Service Description & Acceptable Use

Velvet Ledger is a cloud-based enterprise resource planning (ERP) platform providing:

  • Contact and relationship management
  • Task and appointment scheduling
  • Financial transaction tracking (income and expenses)
  • File storage and collaboration
  • Business intelligence and insights

🏒 Internal Business Tool β€” Not a Public Platform

Velvet Ledger is designed as an internal business management tool (CRM, tasks, scheduling, finances, collaboration). You may use the Service to manage your own business data and client relationships, but you may not use Velvet Ledger as public-facing infrastructure or as a delivery platform for your own products or services.

Specifically, you agree not to:

  • Use Velvet Ledger to host or serve public websites, landing pages, or client-facing portals
  • Use shared groups, files, or links as a replacement for a website, content-delivery system, or marketing platform
  • Store, share, or distribute content that violates our other policies (including illegal, abusive, or sexually explicit content), whether publicly or privately
  • Resell, white-label, or sublicense access to Velvet Ledger to third parties

βœ… You are welcome to use Velvet Ledger to track contacts, tasks, appointments, invoices, and internal notes related to any lawful business β€” but you may not position Velvet Ledger itself as part of your public-facing client portal.

🚫 Prohibited Uses

The following uses of Velvet Ledger are strictly prohibited and will result in immediate account termination:

  • Illegal content or activities: Any content or activity that violates applicable laws
  • Hate speech and discrimination: Content or activities that promote hatred, violence, or discrimination against individuals or groups based on race, ethnicity, national origin, religion, gender, gender identity, sexual orientation, disability, age, or any other protected characteristic β€” including slurs, dehumanizing language, symbols of hate groups, and content that incites violence or celebrates harm against any group
  • Extremist content: Content promoting terrorism, violent extremism, or recruitment for hate groups
  • Fraud and scams: Phishing, pyramid schemes, or deceptive business practices
  • Adult content: Pornography or sexually explicit material
  • High-risk financial abuse: Money laundering, unlicensed money transmission, or cryptocurrency scams
  • Harassment or threats: Stalking, doxxing, bullying, or intimidation of any person
  • Malware or hacking: Distribution of viruses, unauthorized access attempts, or security exploits
  • Spam or bulk messaging: Unsolicited mass communications or email harvesting
  • Intellectual property violation: Copyright infringement, trademark abuse, or piracy
  • Regulated industries without compliance: Healthcare (HIPAA), legal, or financial services without proper licensing and compliance measures

πŸ›‘οΈ Zero Tolerance for Hate β€” No Exceptions

Velvet Ledger has a zero-tolerance policy for hate speech, discrimination, extremist content, and membership in or support of hate groups β€” including white nationalist, neo-Nazi, supremacist, antisemitic, anti-LGBTQ+, or other organizations designated as hate groups by recognized civil rights organizations (such as the Southern Poverty Law Center or Anti-Defamation League). Accounts found to contain such content or associations will be immediately and permanently terminated without warning.

  • Discovery = Termination: If we become aware of violations through credible means β€” user reports with specific facts, valid legal requests, law enforcement inquiries, or credible evidence discovered incidentally during an investigation of an unrelated matter β€” the account will be terminated immediately. We do not proactively monitor user content, scan messages, or run content-classification systems; our awareness of a violation depends on credible, fact-based notice through one of these channels
  • Encryption provides no safe harbor: Using encryption features does not shield you from these Terms. Violations remain violations regardless of whether content is encrypted
  • Law enforcement cooperation: Valid legal process or law-enforcement contact is one of the credible-notice channels listed above. The full process β€” who decides, when we challenge requests, voluntary emergency disclosure under ECPA Β§ 2702(b)(8), mandatory CSAM reporting, user notification windows, and the running transparency snapshot β€” lives in the "Law Enforcement Requests and Disclosure" subsection below
  • No refunds: No refunds will be issued for accounts terminated for hate-related violations
  • Permanent ban: Accounts terminated for hate-related violations are permanently banned. We will refuse re-registration with the same email address and reserve the right to refuse service through any other identifiable means. Attempts to circumvent the ban β€” through alternate email addresses, false identification, new payment methods, or other evasion β€” are themselves violations of these Terms and may result in additional consequences, including referral to law enforcement where the conduct meets the standard for false-statement, fraud, harassment, or hate-crime statutes under applicable law (see Section 11 for the full re-registration framework)

This list aligns with our payment processor's Acceptable Use Policy. Violations may be disclosed to law enforcement when legally required or permitted.

πŸ”’ Law Enforcement Requests and Disclosure

Plain English

We don't read your stuff. We can't tell on you for things we never saw. The only times we ever disclose information about your account are: (a) when a valid legal order requires it, (b) when someone's life is in immediate danger and the law lets us help, or (c) when federal law requires us to report child sexual abuse material to NCMEC. One person β€” the Trust & Safety Lead, currently the Founder β€” decides. We tell you afterwards unless we're legally prohibited. We publish the running count below.

What we receive β€” and what we don't

As stated above, we do not proactively monitor user content, scan messages, or run content-classification systems on your private groups, files, notes, or communications. We are not a content moderator. The only ways we ever learn about anything happening on your account are:

  • You tell us (support ticket, in-app report, or direct contact)
  • Another user reports something specific and credible
  • Law enforcement contacts us with information or a legal request
  • We receive valid legal process (subpoena, court order, warrant)
  • We obtain incidental knowledge through legitimate operations work (e.g., a customer voluntarily shows us content while we're helping with a support issue)

Decision-maker

All disclosure decisions are reviewed and authorized by the Velvet Ledger Trust & Safety Lead β€” a named role currently held by the Founder. The Trust & Safety Lead reviews each compelled legal request, each potential voluntary emergency disclosure, and each mandatory reporting obligation before any disclosure is made. We do not delegate this authority to support staff or to automated systems.

1. Compelled legal process

We comply with valid subpoenas, court orders, and warrants as required by applicable law. We challenge or seek to narrow legal process that appears overbroad, jurisdictionally improper, or facially invalid β€” but we do not impose a standard higher than the law requires as a condition of compliance. When the legal process is valid and properly scoped, we comply.

2. Voluntary emergency disclosure

Under the Electronic Communications Privacy Act, 18 U.S.C. Β§ 2702(b)(8), a provider may divulge a customer record or communication "to a governmental entity, if the provider, in good faith, believes that an emergency involving danger of death or serious physical injury to any person requires disclosure without delay of communications relating to the emergency."

We adopt this statutory standard. We will voluntarily disclose information to a governmental entity only when the Trust & Safety Lead forms a good-faith belief that an emergency involving danger of death or serious physical injury to any person requires disclosure without delay. Disclosures are narrowly tailored to the information needed to address the emergency.

3. Mandatory CSAM reporting

Federal law, 18 U.S.C. Β§ 2258A, requires us to report apparent child sexual abuse material (CSAM) to the National Center for Missing & Exploited Children (NCMEC) "as soon as reasonably possible" after obtaining actual knowledge. This obligation is mandatory and applies even though we do not proactively monitor content β€” we are not searching for CSAM, but if we obtain actual knowledge of it through any of the credible-notice channels above, federal law requires us to report it. We will report to NCMEC and may, where appropriate, also report to other authorities. We do not consider this voluntary disclosure.

Documentation

Every compelled legal request received, every voluntary emergency disclosure made, and every CSAM report submitted to NCMEC is logged internally with date, source, scope, decision, decision-maker, and any user notification status. These records are retained for as long as legally required to support subsequent legal proceedings, regulator inquiries, and our transparency reporting.

User notification

When we disclose information about your account, we will notify you β€” unless we are legally prohibited (for example, by a National Security Letter gag, a court-ordered nondisclosure provision, or another statutory bar) or unless notice would defeat the purpose of the disclosure during an active emergency. Default notification windows:

  • Compelled legal process: within 30 days of disclosure (outer bound)
  • Voluntary emergency disclosure: as soon as the emergency is resolved
  • CSAM report to NCMEC: we do not notify the user whose content was reported, consistent with federal law-enforcement-sensitive handling

Where a legal prohibition expires (for example, when a gag order lapses or is lifted), we will notify you within 30 days of the date we are first permitted to do so.

Transparency snapshot

Since product launch through 2026-05-17. We update these counts when they change; the trigger is one or more numbers ticking up, not a scheduled date.

  • Compelled legal requests received: 0
  • Of those, complied with: 0
  • Of those, challenged or narrowed: 0
  • Voluntary emergency disclosures (ECPA Β§ 2702(b)(8)): 0
  • CSAM reports to NCMEC (18 U.S.C. Β§ 2258A): 0

3. Subscription Plans & Trial Period

πŸ’΅ Currency: All prices are listed in U.S. dollars (USD). Velvet Ledger is currently available to customers in the United States only.

Free Trial

New users receive a 30-day trial with full Flourish plan features. No credit card is required for trial signup.

Trial End Behavior

If no payment method is added before trial expiration, your account automatically downgrades to the Explore plan. No charges are made without explicit payment authorization.

Subscription Tiers

  • Explore: $0/month β€” 250 records and 250 MB of storage
  • Focus: $9.99/month β€” 3,000 records and 2 GB of storage
  • Grow: $29.99/month β€” 50,000 records and 10 GB of storage
  • Nurture: $149/month β€” Unlimited records and 100 GB of storage
  • Flourish: $79/month β€” Unlimited records and 100 GB of storage

πŸš€ Beta Pricing & Price Protection

Current pricing is beta/early access pricing and may change when the platform exits beta.

Price Protection for Existing Subscribers:

  • Monthly plans: Keep your current rate for 12 consecutive monthly billing cycles (must remain actively subscribed)
  • Annual plans: Keep your current rate through the end of your current annual term
  • If you cancel: Grandfathering ends β€” new rates apply if you resubscribe later
  • During grace period: Grandfathering is paused but resumes if you upgrade before the period ends

Features marked as "Coming Soon" will be added to the respective plans at no additional cost.

4. Plan Limits

Each plan includes a number of records (contacts, tasks, appointments, income, expenses and invoices, counted together) and an amount of file storage. Yearly plans include 50% more records than the same plan paid monthly.

If you are over your plan's limit (for example after a downgrade or when a trial ends):

  • βœ… Everything you already have stays available: you can view, edit, delete and export all of it
  • ❌ You can't add new records (or upload files, for storage) until you upgrade or remove enough to be under the limit
  • Nothing is locked, hidden or deleted because of a plan limit

Switching from yearly to monthly billing: if you then have more records than the monthly plan includes, you get 30 days in which you can still add records, with reminders, before the monthly limit applies.

Example: Grow paid monthly includes 50,000 records; Focus paid monthly includes 3,000. Someone who moves from Grow to Focus with 4,000 records keeps all 4,000 and can work with every one of them, but can't add a new record until they upgrade or are back under 3,000.

5. Payment Terms

Billing Cycle

Subscriptions are available on monthly or annual billing cycles and automatically renew unless canceled before the next billing date. All fees are charged in advance and are non-refundable except as specified in the Refund Policy.

Payment Processing

Payments for paid plans are processed by Dodo Payments, our Merchant of Record (MOR). Dodo handles all payment processing, billing, tax collection, and payment data storage. We do not collect, process, or store your credit card information β€” Dodo manages all payment data securely under PCI-DSS-compliant infrastructure. By subscribing to a paid plan, you also agree to Dodo Payments' terms of service and privacy policy in addition to these Terms.

Price Changes

We reserve the right to modify pricing with 30 days' advance notice. Price protection for existing subscribers:

  • Monthly plans: Keep your current rate for 12 consecutive monthly billing cycles (must remain actively subscribed)
  • Annual plans: Keep your current rate through the end of your current annual term
  • After cancellation: Grandfathering ends β€” new rates apply if you resubscribe later
  • During grace period: Grandfathering is paused but resumes if you upgrade before the period ends
  • Permanent loss: Grandfathering ends permanently if you do not resolve payment or plan limit issues within the grace period

Failed Payments

If payment fails, we will automatically retry charging your payment method up to 3 times over 7 days. After 7 days, your account automatically downgrades to the Explore tier and the 30-day grace period begins. You must resolve payment issues within the grace period to maintain your grandfathered rate.

6. User Responsibilities

You agree to:

  • Provide accurate, current, and complete information during registration
  • Maintain and update your information to keep it accurate and current
  • Maintain the security of your account credentials
  • Notify us immediately of any unauthorized access or security breach
  • Be at least 18 years old (we do not permit users under 18)
  • Not share your account with unauthorized users
  • Not use the Service for illegal activities or to violate others' rights
  • Not attempt to reverse-engineer, hack, or abuse the Service
  • Comply with all applicable data protection laws (GDPR, CCPA, etc.)

You are responsible for all activities that occur under your account.

7. Data Ownership & Backup

Your Data

You retain all ownership rights to data you upload. We claim no ownership. By using the Service, you grant us a limited license to store, process, and display your data solely to provide the Service.

Our Rights

The Service, including all software, designs, text, graphics, logos, and other content, is owned by us and protected by copyright, trademark, and other intellectual property laws. You may not use our intellectual property without written permission.

Backups

While we maintain daily automated backups (7-day retention), you are responsible for maintaining your own backups of critical data. We provide export functionality for all your data in JSON format (User Profile β†’ User Preferences β†’ Security). During beta, we especially recommend weekly data exports.

File Handling and Security Scanning

Files you upload (documents, images, attachments, and similar) are stored in Storj's EU1 region, encrypted at rest. As part of providing the Service, every file you upload is automatically scanned for malware, viruses, and other security threats by AttachmentAV (an EU-hosted virus scanning service) before it becomes available to you or anyone you've chosen to share with.

What this means in practice:

  • Files pass through a brief "quarantine" period while scanning runs β€” typically a few seconds
  • If scanning detects a threat, the file is immediately deleted from our systems and you are notified
  • We do not retain files that fail security scanning, even temporarily, beyond what's required to notify you and confirm deletion
  • Scanning is not a complete malware defense; you remain responsible for maintaining your own anti-virus on devices used to access the Service, and you should not upload files you suspect may be harmful

See Section 5 of our Privacy Policy for the data-handling details of Storj and AttachmentAV.

8. Service Availability

We strive for 99.9% uptime but provide the Service on an "AS IS" and "AS AVAILABLE" basis with no uptime guarantees. As stated in Section 1.1 (Beta Service Notice), the Service is currently in beta and you acknowledge the risks of using beta software.

We are not liable for service interruptions due to:

  • Beta-related issues (bugs, incomplete features, unexpected changes)
  • Scheduled maintenance (announced 48 hours in advance when possible)
  • Force majeure events (natural disasters, acts of war, etc.)
  • Third-party failures (hosting providers, internet infrastructure)
  • User error or misuse

9. Disclaimers and Limitation of Liability

⚠️ CRITICAL LEGAL NOTICE

Please read this section carefully. It limits our liability and affects your legal rights.

Beta Service Acknowledgment

As stated in Section 1.1, the Service is currently in beta. You acknowledge and accept the risks of using beta software, including potential bugs, data loss, service interruptions, and unexpected changes to features or functionality.

Service Availability

We provide the Service on an "AS IS" and "AS AVAILABLE" basis. We do not guarantee uninterrupted or error-free operation. While we strive for high availability, we do not guarantee specific uptime percentages, especially during the beta period.

Data Backup Responsibility

While we implement daily automated backups (7-day retention), you are responsible for maintaining your own backups of critical data. We provide data export functionality for this purpose. During beta, we especially recommend weekly data exports. Our liability for data loss is limited as described below.

πŸ“œ Legal Language: Warranty Disclaimer

βœ“ Plain English:

We provide the Service "as is" without guarantees. We try our best, but we can't promise perfection, especially during beta. If you need guaranteed uptime or warranties for your business, this may not be the right service for you yet.

βš–οΈ Legal Language:

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. We do not warrant that the Service will meet your requirements or that operation will be uninterrupted or error-free.

πŸ“œ Legal Language: Liability Limits

βœ“ Plain English:

If something goes wrong, the most you can recover is what you paid us in the last 12 months (or $100 if you're on the Explore plan). We're not responsible for lost revenue or business interruption beyond your subscription fees. See the "What This Means for You" box below for specific dollar amounts.

βš–οΈ Legal Language:

TO THE MAXIMUM EXTENT PERMITTED BY LAW:

  • Our total liability for any claim is limited to the amount you paid us in the 12 months preceding the claim (or $100 if you're on the Explore plan)
  • We are not liable for any indirect, incidental, consequential, special, or punitive damages
  • We are not liable for data loss, business interruption, lost profits, or lost revenue
  • We are not liable for unauthorized access to or alteration of your data
  • We are not liable for third-party actions or failures (including hosting providers, payment processors)

Some jurisdictions do not allow the exclusion or limitation of certain damages, so some of these limitations may not apply to you. In such cases, our liability is limited to the maximum extent permitted by applicable law.

Important carveout: Nothing in this Section 9 limits our liability for our own fraud, willful misconduct, gross negligence, death or personal injury caused by our negligence, or any other liability that cannot lawfully be limited under applicable law (including California Civil Code Β§ 1668, the Massachusetts Consumer Protection Act c. 93A, and the New Jersey Consumer Fraud Act). See Section 10.3 for the full carveout.

πŸ’‘ What This Means for You

  • Explore users: Maximum recovery is $100 for any issue
  • Focus plan ($9.99/mo): Maximum recovery is ~$119.88 (12 months of fees)
  • Grow plan ($29.99/mo): Maximum recovery is ~$359.88 (12 months of fees)
  • Nurture plan ($149/mo): Maximum recovery is ~$1788 (12 months of fees)
  • Flourish plan ($79/mo): Maximum recovery is ~$948 (12 months of fees)
  • We're not liable for: Lost revenue, business interruption, or consequential damages beyond the subscription fees you paid
  • Why this matters: If you're running a business with critical data, maintain your own backups and consider cyber insurance

10. Indemnification

Plain English

Each of us covers the other for problems we cause. You cover us for things you did with the Service that got us in trouble. We cover you if our Service itself infringes someone's IP, if we do something reckless or intentional that harms you, or if we screw up data law on our side and you get fined for it. Sections 10.3 and the cross-reference in Section 9 also confirm we don't try to dodge liability for our own fraud, willful misconduct, or gross negligence β€” that's not legally possible anyway, and we're not pretending otherwise.

10.1 Your Indemnification of Us

You agree to indemnify, defend, and hold harmless Velvet Ledger, its affiliates, and their respective officers, directors, employees, and agents from any claims, damages, losses, liabilities, and expenses (including reasonable legal fees) arising from:

  • Your use or misuse of the Service
  • Your violation of these Terms of Service
  • Your violation of any rights of another party
  • Your violation of any applicable laws or regulations
  • Any content or data you submit, post, or transmit through the Service

10.2 Our Indemnification of You β€” Intellectual Property

We will defend you against any third-party claim alleging that your authorized use of the Service β€” as we provide it, unmodified β€” infringes that third party's U.S. copyright, registered trademark, or trade secret rights. We will pay any final judgment or court-approved settlement for such a claim.

This obligation does NOT apply to claims that arise from:

  • Your content, data, files, or anything else you submit through the Service (covered by your indemnification under Section 10.1 instead)
  • Modifications you make to the Service, or your combination of the Service with anything we didn't provide
  • Your continued use of an allegedly infringing component after we've given you written notice to stop or have provided a non-infringing alternative
  • Patent claims β€” we do not indemnify against patent infringement claims; properly diligencing patent risk requires resources we cannot yet commit during beta, and we are transparent about this gap rather than promising what we can't deliver

If we receive a credible IP-infringement claim against the Service, we may at our option (a) procure the right for you to continue using the Service, (b) modify the Service to be non-infringing while retaining substantially equivalent functionality, or (c) terminate the affected functionality and refund any prepaid fees attributable to that functionality for the remainder of your current billing period. Options (a) and (b) are our preference; (c) is the fallback if neither is commercially reasonable.

10.3 Our Liability for Our Own Fraud, Willful Misconduct, or Gross Negligence

Nothing in these Terms β€” including the limitation of liability in Section 9, the warranty disclaimer in Section 9, or any cap or exclusion stated elsewhere β€” purports to limit or exclude our liability for:

  • Our own fraud or fraudulent misrepresentation
  • Our own willful misconduct
  • Our own gross negligence
  • Death or personal injury caused by our negligence
  • Any other liability that cannot lawfully be limited or excluded under applicable law, including but not limited to California Civil Code Β§ 1668, the Massachusetts Consumer Protection Act, M.G.L. ch. 93A, and the New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1 et seq.

For these specific items, the Section 9 liability cap does not apply. This Section 10.3 is intended to make explicit what these laws already require of us β€” we are not trying to disclaim what we legally cannot.

10.4 Our Liability for Our Own Data Protection Violations

If we materially violate the GDPR, CCPA, or other applicable data protection law in our handling of your data, and that violation β€” not your handling of your own clients' data, not your own data controller obligations β€” directly causes you to be fined or sanctioned by a competent regulator, we will indemnify you for the actual amount of that fine or sanction, up to the Section 9 liability cap.

What this does not cover: fines triggered by your own data practices, complaints from your clients about how you used the Service, your failure to comply with your own obligations as a data controller, or any indirect, consequential, or speculative losses. To exceed the Section 9 cap, the underlying conduct must meet the Section 10.3 standard (gross negligence, willful misconduct, or law that prohibits the cap).

10.5 Indemnification Procedure

For either party to claim indemnification under this Section 10:

  • The party seeking indemnification (the Indemnitee) must give the other party (the Indemnitor) prompt written notice of the claim. Late notice does not relieve the Indemnitor of its obligations except to the extent the delay materially prejudices the defense.
  • The Indemnitor has sole control of the defense and settlement of the claim, with counsel of the Indemnitor's choosing. The Indemnitor may not enter into any settlement that imposes a non-monetary obligation on, admits liability of, or fails to fully release the Indemnitee, without the Indemnitee's prior written consent (consent not to be unreasonably withheld or delayed).
  • The Indemnitee will provide reasonable cooperation with the defense at the Indemnitor's expense.
  • The Indemnitee may participate in the defense at its own expense with counsel of its choice.

11. Termination

By You

You may cancel your subscription at any time through your account settings (Billing Settings β†’ Cancel Subscription). Access continues until the end of your current billing period. See the Refund Policy section for details on refunds.

Account Deletion

You may permanently delete your account via Settings β†’ Account β†’ Delete Account. To prevent accidental deletion, we require verification:

  1. Enter the verification code sent to your email
  2. Enter your current password
  3. Type the confirmation phrase shown

Important: Before deletion, you will be prompted to download all your data. This is your last opportunity to export your data.

πŸ—‚οΈ Account Deletion Decision Tree:

❓

Do you need immediate deletion for safety/security?

(Examples: unauthorized access, domestic violence, stalking, legal emergency)

β†’ YESUse Emergency Delete (immediate & permanent, cannot be undone)
β†’ NOUse Standard Delete (7-day window to log in and cancel deletion)

Deletion Options:

Standard Deletion (Recommended - 7-Day Cancellation Window):

  • After verification, your account is scheduled for deletion in 7 days
  • You can log in anytime during this period to cancel the deletion
  • When you log in, you'll see a banner: "Your account is scheduled for deletion on [date]" with a cancel option
  • Click "Cancel Deletion" to restore your account to normal status
  • We'll email you confirmation when deletion is scheduled and reminders at day 3 and day 6
  • After 7 days, if not canceled, deletion becomes permanent and cannot be reversed

Emergency Immediate Deletion (Cannot Be Undone):

  • Available if you need immediate deletion for safety or security reasons
  • Valid reasons: unauthorized access, domestic violence, stalking, legal emergency
  • Requires additional verification steps
  • Must type "EMERGENCY DELETE" instead of "delete"
  • Optional field to explain emergency reason
  • Deletion is immediate and permanent β€” we cannot recover your data
  • You will not be able to log in to cancel this type of deletion

What Gets Deleted:

  • All business data (contacts, tasks, appointments, transactions, files, notes, groups)
  • Your user profile and preferences
  • All associated metadata

What We Retain (Legal Requirements):

  • Billing records for 8 years from the end of the year they were made in, to meet tax and accounting duties and handle payment disputes (legitimate interest, GDPR Art. 6(1)(f)) β€” transaction dates, amounts, plan names, NOT your business data
  • Audit logs for 1 year (for security and compliance)
  • If your account was ever banned or suspended, or you were removed or suspended in a group: those moderation records (the decision, its reason and rule, references to the content concerned) for 3 years after your account closes, to defend legal claims (legitimate interest, GDPR Art. 6(1)(f))
  • Record of your deletion request (date, method, whether you downloaded data first) for 7 years

Re-registration After User-Initiated Deletion

If you chose to delete your account (Standard or Emergency Deletion as described above), you may create a new account with the same email addressat any time, starting fresh with no data from the previous account.

  • No waiting period
  • No penalty or restriction
  • No requirement to use a different email address
  • No requirement to explain why you previously deleted

This applies only to user-initiated deletion. If we terminated your account for cause, see "Re-registration After Termination by Us" below.

By Us β€” Suspension vs. Termination

⚠️ Account Suspension (Temporary)

We may suspend your account temporarily while we investigate potential violations. During suspension:

  • You cannot access the Service or your data
  • Billing is paused (no charges during suspension)
  • We will notify you via email with the reason and expected timeline
  • You may respond to the suspension notice to provide clarification
  • If cleared, your account will be restored with all data intact, and any suspended period is credited to your next billing cycle

⏱️ Investigation Time Limits & Anti-Abuse Protections

  • Maximum investigation window: Non-COPPA investigations close within 14 business days of credibility finding. Indefinite "under investigation" status is not permitted
  • No suspension on uncorroborated reports: Reports lacking specifics, anonymous reports, and reports failing initial credibility triage do not result in account action
  • Right of response: You will be notified of any report affecting your account and given a reasonable opportunity to respond before further action
  • Graduated verification: Where verification of age or eligibility is required, we begin with signed self-attestation. Government-issued identification is requested only in escalation, and you may choose alternative documents (notarized affidavit, two non-ID corroborating documents). Verification documents are destroyed within 30 days of report closure
  • Reporter accountability: Knowingly false reports β€” including reports made to harass, defame, suspend competitors, or disrupt service to other users β€” are a violation of Section 2 (Acceptable Use) and may result in suspension or termination of the reporting account
  • For COPPA-specific reports (under 13): see Section 10 of the Privacy Policy for the full triage, investigation, and remediation procedure

We may suspend or terminate your account if you:

  • Violate these Terms of Service or our Acceptable Use Policy
  • Engage in fraudulent activity or payment disputes (chargebacks)
  • Use the Service in a way that creates legal liability or security risks for us or other users
  • Engage in abusive behavior toward our staff or other users
  • Create multiple accounts to circumvent plan limits or bans
  • Provide false information during registration or payment

🚨 Fraud & Abuse Handling

  • Suspicious accounts: Accounts flagged for suspicious activity (unusual sign-up patterns, fake information) may be suspended pending verification
  • Chargebacks: Filing a chargeback results in immediate suspension. Fraudulent chargebacks may result in permanent termination and collections referral
  • Repeated violations: Multiple warnings or suspensions will result in permanent termination
  • Illegal activity: Evidence of illegal activity will be reported to law enforcement

We will provide 30 days' notice before termination except in cases of:

  • Illegal activity (immediate termination)
  • Security threats or violations (immediate termination)
  • Violation of intellectual property rights (immediate termination)
  • Fraudulent chargebacks (immediate termination)
  • Repeated ToS violations after warnings (immediate termination)

Re-registration After Termination by Us

Whether you may re-register after we terminate your account depends on the reason for the termination. We use three tiers:

🚫 Tier 1 β€” Permanent Ban (No Re-Registration)

The following terminations are permanent. We will refuse re-registration with the same email address and reserve the right to refuse service through any other identifiable means:

  • Hate speech, extremist content, or other zero-tolerance violations (Section 2)
  • Illegal activity
  • Content involving the exploitation or endangerment of a child
  • Fraudulent chargebacks (where service was properly delivered)
  • Security threats or unauthorized-access violations
  • Willful violation of intellectual property rights
  • Repeated TOS violations after written warnings

⚠️ Tier 2 β€” Discretionary Review

For other TOS violations not listed in Tier 1, re-registration eligibility is at our discretion. We may require additional verification, a waiting period of up to twelve months, a specific remediation, or a written commitment to the conduct underlying the original termination. Re-registration in Tier 2 is not automatic β€” you must contact us at support@velvetledger.io and request review.

βœ… Tier 3 β€” Automatic Restoration

Accounts terminated due to payment problems, non-renewal, or extended inactivity (and not for cause under Tiers 1 or 2) may re-register at any time with no waiting period and no review. This is equivalent to the user-initiated deletion path described earlier in this Section 11.

How We Enforce Permanent Bans (Realism)

We are committed to being honest about what we can and cannot enforce:

  • What we can do: we refuse re-registration with the same email address used on the terminated account (this we verify directly at signup); we exercise reasonable diligence to identify circumvention attempts; we cooperate with law enforcement where appropriate
  • What we do not claim: we do not claim the ability to detect every attempt at evasion through new email addresses, alternate devices, virtual private networks, or new payment methods. No service can. We do not run invasive device fingerprinting or biometric matching for this purpose
  • Circumvention as additional violation: attempting to create a new account after a Tier 1 permanent ban β€” including through alternate email addresses, false identification, or new payment methods β€” is itself a violation of these Terms. Where we identify such circumvention, the new account is terminated, and the conduct may be referred to law enforcement where it meets the standard for fraud, false-statement, harassment, or hate-related statutes under applicable law
  • Right to refuse service: independently of any specific enforcement action, we reserve the right to refuse service to any person whose conduct in connection with a previously terminated account is reasonably attributable to that person, even where strict technical evidence of identity is not available

12. Dispute Resolution and Arbitration

βš–οΈ How Disputes Are Resolved (Plain English)

Step 1 β€” Send a Pre-Dispute Notice: Email legal@velvetledger.io with the details of the problem and what you want us to do about it (the full content requirements are below). We have 60 days to respond and try to resolve it informally β€” most disputes get resolved at this step.

Step 2 β€” Small claims court: If the dispute is small (typically under $10,000), you can sue us in small claims court if talking doesn't work.

Step 3 β€” Arbitration (not regular court): For larger disputes, instead of going to regular court with a judge and jury, we both agree to use arbitration (a neutral third party decides). This is usually faster and cheaper than court.

No class actions: You can't join a group lawsuit with other users. Disputes must be resolved one-on-one.

Why this matters: You're giving up your right to sue in regular court for most disputes. If you disagree with this, don't use the Service.

Informal Resolution First (Pre-Dispute Notice)

Before filing any formal claim, demand for arbitration, or small-claims action, you agree to send us a written Pre-Dispute Notice and to give us a reasonable opportunity to resolve the matter informally. We commit to the same obligation in reverse β€” if we have a dispute with you, we will send you a Pre-Dispute Notice before initiating any formal proceeding.

Where to send your Pre-Dispute Notice

Send the notice by email to legal@velvetledger.io with the subject line "Pre-Dispute Notice", or by mail to: Velvet Ledger, 123 E San Carlos St, Unit #184, San Jose, CA 95112. We will treat the date of receipt as the start of the resolution period.

What your Pre-Dispute Notice must contain

For the notice to start the resolution period, it must include all of the following:

  • Your name and the email address associated with your Velvet Ledger account
  • Your mailing address and a working phone number where we can reach you
  • A description of the dispute β€” what happened, when it happened, and which part of the Service was involved
  • The specific relief you are seeking β€” for example, a refund of a specific amount, restoration of an account, deletion of specific data, or correction of specific information
  • A signature (electronic signature or typed name is acceptable) confirming the notice is sent by you or on your behalf with your authorization

Notices that omit any of the above are not effective Pre-Dispute Notices and do not start the resolution period. We will tell you what's missing within a reasonable time if we receive an incomplete notice.

The 60-day resolution period

We have 60 calendar days from the date we receive a complete Pre-Dispute Notice to respond and attempt informal resolution. During this period:

  • You agree not to file an arbitration demand or court action regarding the same dispute (small-claims actions and requests for injunctive relief in clear emergencies excepted β€” see "Exceptions" below)
  • We will make a good-faith effort to resolve the matter, which may include a proposed remedy, a request for additional information, or a discussion (by email or phone) of the issue
  • The 60-day clock pauses if you ask us for additional time, and resumes when you confirm you're ready to continue

If the dispute is not resolved within 60 days, either party may then proceed under the procedures below (Mandatory Arbitration or small-claims court, as applicable).

Why we require this: Most disputes are misunderstandings that can be resolved without formal proceedings. This notice procedure gives us a real chance to fix problems quickly and fairly. It also makes the rest of this Section 12 (Arbitration and Class Action Waiver) enforceable β€” courts generally require pre-dispute procedures to be clear and reasonable, and the procedure above meets that standard.

Governing Law

These Terms are governed by the laws of the State of Delaware, without regard to conflict of law principles.

Mandatory Arbitration

Any dispute arising from these Terms or the Service must be resolved through binding arbitration rather than in court, except you may assert claims in small claims court if they qualify. Arbitration will be conducted by a single arbitrator under the rules of the American Arbitration Association (AAA). The arbitrator's decision is final and binding. Each party bears their own costs and fees, unless the arbitrator awards costs and fees to the prevailing party.

Class Action Waiver

You agree to resolve disputes individually and waive the right to participate in class actions or class arbitrations. This means you may not join your claim with claims of other users or participate as a member of a class of claimants.

Exceptions

Either party may seek injunctive relief in court for intellectual property violations or urgent matters requiring immediate action to prevent irreparable harm.

13. Changes to Terms

We may modify these Terms at any time. We will notify you of material changes via email and in-app notification at least 30 days before they take effect. Minor changes (clarifications, legal updates) will be posted here with an updated "Last Modified" date. Continued use of the Service after changes become effective constitutes acceptance of the modified Terms. If you disagree with changes, you may cancel your subscription before they take effect.

14. Miscellaneous

Entire Agreement

These Terms, along with our Privacy Policy and Refund Policy, constitute the entire agreement between you and Velvet Ledger regarding the Service.

Severability

If any provision is found unenforceable, the remaining provisions remain in full force and effect.

No Waiver

Our failure to enforce any right or provision does not constitute a waiver of that right or provision.

Assignment

You may not assign or transfer these Terms without our prior written consent. We may assign these Terms without restriction.

Questions about Terms of Service?

Email help@velvetledger.io with "Terms Question" in the subject. We respond within 3 business days.

Privacy Policy
How we protect and handle your data

πŸ”‘ Privacy Policy - Key Takeaways

  • EU storage: All business data stored in Germany (Hetzner). Web traffic goes directly to our EU servers without passing through a CDN.
  • Your data is yours: We store your business data to provide the service, but we only collect count-based metrics for analytics
  • No data selling: We never sell your data to third parties. Period.
  • Encryption: TLS 1.3 in transit, AES-256 at rest, Argon2id for passwords
  • Payment security: Our payment processor will handle all payment data (we will never see your credit card)
  • Your rights: Access, export, correct, or delete your data anytime
  • Export anytime: Download all your data in JSON format from Settings β†’ Your data

Your data and AI

Velvet Ledger uses no AI. No language model or machine-learning service reads your data, and your data is not used to train one. Quick Capture reads what you type with fixed rules, in your browser. Your business data is stored in Germany, on Hetzner servers. You can download all of it at any time from Settings β†’ Your data, and delete your account from Profile β†’ User Preferences β†’ Security β†’ Delete Account (the Privacy Policy lists the few records kept after that, such as billing records).

1. Overview

This Privacy Policy explains how Velvet Ledger collects, uses, stores, and protects your personal information. We are committed to protecting your privacy and maintaining the security of your data.

πŸ”’ Your business data is stored in the European Union (EU) on secure servers provided by Hetzner in Germany. Web traffic is routed directly from your browser to our EU servers β€” it does not pass through any US-based proxy or CDN. We use Cloudflare for DNS management only.

πŸ“ Jurisdiction & Data Location Clarification

Although Velvet Ledger is governed by U.S. law (Delaware) for contractual matters, all personal data is processed and stored in the EU under GDPR-compliant conditions. This means you benefit from EU data protection standards regardless of your location.

2. Information We Collect

Account Information:

  • Name, email address, username
  • Password (encrypted with Argon2id hashing)
  • Phone number (optional)

Business Data:

  • Contacts (names, emails, addresses, custom fields)
  • Tasks, appointments, and calendar events
  • Financial transactions (income, expenses)
  • Projects, tags, and custom data fields
  • Files and attachments β€” both files you upload directly (documents, images, etc.) and documents we generate at your request that you choose to save to your account (invoice PDFs, income-proof PDFs, and similar), plus descriptive metadata about each file (filename, tags you apply, your description, and links to related records such as an invoice or a contact in your address book)
  • Notes, groups, and collaboration data

Billing Information:

  • Payment card data is processed and stored by Dodo Payments (our Merchant of Record)
  • We do NOT collect, process, or store credit card numbers, CVV codes, or full payment details
  • We receive from Dodo only: subscription status, billing history (dates/amounts), and transaction IDs
  • Dodo Payments handles all PCI-DSS compliance for payment card data
  • Billing records retention: We retain transaction metadata (dates, amounts, plan names, invoice IDs) for 8 years for tax/legal compliance β€” this does NOT include payment card details
  • See Dodo Payments' privacy policy for how they handle your payment information

Usage Analytics & Telemetry:

  • High-level usage counts (which features are used, in aggregate)
  • Error logs (page/action context only, NOT your business data)
  • Performance metrics (load times, query speed)
  • Data counts only (e.g., "user has 100 contacts") β€” we do NOT store or analyze the actual content of your business data

πŸ”’ Privacy First: We collect usage counts/metrics to identify bugs at scale (e.g., issues when users have 1,000+ contacts), but we NEVER use your actual contact names, emails, addresses, or transaction details for analytics or product improvement.

3. How We Use Your Information

We use your information to:

  • Provide and improve the Service
  • Process payments and manage subscriptions (once we begin charging)
  • Send transactional emails (password resets, billing notifications, security alerts)
  • Send promotional emails and newsletters (only with your explicit consent)
  • Respond to support requests and communicate with you
  • Monitor usage to prevent abuse and ensure security
  • Analyze usage patterns to improve features and user experience (anonymized data only)
  • Comply with legal obligations

3.1 Analytical Tools for Your Own Data

Velvet Ledger includes analytical tools that summarize and categorize the data you have entered. Examples include period-over-period financial summaries, savings-rate calculations, profit-per-hour calculations, and a client-payment-reliability scoring view that ranks the contacts you have added by their payment patterns.

How these tools work

  • Every calculation is based on transparent, documented math operating on the transactions, invoices, payment records, and other data you have entered into your account
  • Every score and category is broken down into its labeled components in the user interface, so you can see exactly which factors contributed and how they were weighted
  • We use no machine learning, no third-party inference services, no language models, and no "AI" β€” every calculation is deterministic and verifiable by re-running the documented math on your own data
  • Analytical outputs are shown only to you (and to members of your team if you have explicitly added them to a shared group, as governed by your team-sharing settings). We do not share scores, summaries, or categorizations with anyone outside your account.

What these tools are NOT

  • Not automated decisions about you or your contacts. The tools are informational β€” you, the account holder, are the decision-maker. We do not take any action on you or your contacts based on these scores; we only show you the calculations so you can make your own decisions.
  • Not automated decisions about your Velvet Ledger account. Plan changes, suspensions, and account termination are based on objective criteria described in our Terms of Service (usage limits, payment status, Terms of Service violations) β€” never on inferred or predictive scores.
  • Not predictions or inferences. Every output is computed directly from the data you have entered. If you add or correct a transaction, the corresponding calculation updates immediately.
  • Not subject to GDPR Article 22's "solely automated decision-making" provisions, because no decision with legal or similarly significant effect is being made by automated means; the user (you) is the decision-maker, and the underlying math is fully disclosed to you.

If a result looks wrong: it is almost always because of the underlying data (a missing due date, a misclassified transaction, a contact not linked as a client). Correcting the source data will update the calculation immediately. You can also email privacy@velvetledger.io if you would like a deeper explanation of how any specific calculation works.

If you save a generated document: when you choose to save a generated document (for example, an invoice PDF) to your account, the file follows the standard file-storage path described in Sections 4 and 5: it is scanned for security by AttachmentAV (EU), stored at Storj EU1, and linked to the relevant records (the invoice and the client contact) so it can be found later from either the Files page, the invoice detail view, or the contact's profile. All of this happens within the EU. The generated document is not transmitted to a US-based or non-EU service at any step.

4. Data Storage and Security

Storage Location

All of your business data is stored within the European Union, across two purpose-specific services:

  • Relational data (contacts, tasks, appointments, financial transactions, notes, groups, file metadata, and the links that tie a file to a related invoice or contact): PostgreSQL databases hosted by Hetzner in Germany
  • File content β€” the binary content of files you upload (documents, images, attachments) and of documents we generate at your request that you choose to save(such as invoice PDFs and income-proof PDFs): Storj decentralized storage in their EU1 region. Files are encrypted at rest with AES-256 and distributed across EU-based storage nodes.
  • File security scanning: AttachmentAV (EU-hosted) scans every file for malware before it becomes available β€” including documents we generate and you save. See Section 5 for the data flow.

How file content and metadata are separated: the file binary itself (the PDF pages, the image data) lives at Storj. The descriptive information about the file (filename, your tags, your description, and the references that link it to an invoice or a contact) lives in our Hetzner PostgreSQL database alongside the rest of your business data. This separation lets the user interface search and display your files quickly without having to read the underlying binary content.

Web traffic goes directly from your browser to our EU servers β€” it does not pass through any US-based CDN or proxy. Network-layer DDoS protection is provided by Hetzner.

We use Cloudflare for DNS management only. Cloudflare answers DNS queries (the technical lookup that tells your browser where our servers are) but does NOT see or process your actual web traffic, email content, or any data you store with us.

About data transfers outside the EU: A small number of limited operational data flows involve US-based service providers under Standard Contractual Clauses (SCCs) and signed Data Processing Agreements. Specifically: address text you enter into address fields is sent to Mapbox for autocomplete and validation, and phone numbers are sent to Twilio briefly during phone-number verification. The emails we send you go through Mailjet, which stores them in the EU. None of your stored business data ever leaves the EU. See Section 5 below for details on each service.

Current Encryption (Active Now)

  • In transit: TLS 1.3 (HTTPS) end-to-end between your browser and our EU servers β€” all data encrypted during transmission βœ…
  • At rest: AES-256 encryption on database volumes (provided by Hetzner) βœ…
  • Passwords: Argon2id hashing (winner of Password Hashing Competition) βœ…

Future Encryption Enhancements (Under Consideration)

  • Server-side encryption with user-specific keys: We hope to implement this in the future, which would encrypt your data with your unique key, making it inaccessible to our staff even with database access
  • End-to-end encryption (E2E): Under research for potential implementation

Security Measures

  • Automated security scanning (via development tools)
  • Access controls and role-based permissions
  • Multi-factor authentication for admin access (planned, target: Q2 2026)
  • IP whitelisting for administrative access
  • Daily automated backups (rolling 7-day retention)
  • Audit logging of all system access
  • Strict employee access controls (currently limited to founder only)

Current Data Access: Our database administrators currently have technical access to the database for debugging and security purposes. All access is logged and reviewed monthly. Access is never used for marketing, analytics, or any purpose other than Service provision and security.

If we implement server-side encryption with user keys in the future, this technical access would become cryptographically meaningless β€” we wouldn't be able to read your data even with database access.

While we implement strong security measures, no system is 100% secure. You are responsible for maintaining the confidentiality of your account credentials.

5. Third-Party Services

We share limited data with these third-party services:

Dodo Payments (Merchant of Record)

Dodo Payments is our Merchant of Record (MOR). Dodo handles all payment processing, tax collection, receipts, and payment card data storage. When you subscribe to a paid plan, Dodo collects and stores your payment information directly β€” we never see or store your credit card details. Subscribing to a paid plan is subject to Dodo Payments' terms of service and privacy policy in addition to ours.

Dodo shares with us only: your subscription status, billing dates, transaction amounts, and a customer ID. Dodo does NOT share your payment card details, full address (only the country and postal code as needed for tax compliance), or other payment-specific information with us.

Billing Records Retention: While Dodo handles payment processing and stores payment card data, we (Velvet Ledger) are legally required to retain billing records (transaction metadata: dates, amounts, plan names, invoice IDs) for 8 years for tax and legal compliance. These records do NOT include your payment card details or business data β€” only transaction metadata.

What this means for you: Your payment card data will be protected by Dodo's PCI-DSS-compliant infrastructure. We will have no access to your payment information, significantly reducing your risk in the event of a data breach on our systems.

See Dodo Payments' terms of service and privacy policy for details on how Dodo handles your payment information.

Proton Mail (Inbound business email β€” Switzerland)

We use Proton Mail to receive emails sent to our business addresses (privacy@, support@, security@, refunds@, dpo@, help@). When you email us directly to ask a question, report a concern, or exercise a privacy right under GDPR, your message is received and stored by Proton Mail until we read and act on it.

What Proton Mail receives:

  • The email you sent us β€” sender address, subject, body, attachments

What Proton Mail does NOT receive:

  • Any data from your Velvet Ledger account
  • Outbound emails we send to you β€” those flow through Mailjet (described below), not Proton Mail

Proton Mail is operated by Proton AG, based in Switzerland. Proton uses zero-access encryption β€” Proton itself cannot read messages stored in our inbox without our credentials. Switzerland has an adequacy decision from the European Commission, meaning Swiss data protection is treated as equivalent to EU standards under GDPR. See Proton's privacy policy.

Mailjet (Email We Send You)

We use Mailjet to send the emails our Service relies on: verification codes when you sign up, password reset links, billing and subscription notifications, security alerts, and similar service messages, plus any emails you choose to receive, such as the daily summary.

Mailjet processes the email address you registered with whenever we send you a message, plus the subject and body of that specific message. We do not send Mailjet your business data (contacts, files, notes, financial transactions, or similar) β€” only the email address you've registered with and the content of the specific message we're sending you. Mailjet tells us whether each email was delivered, bounced or blocked, so we can tell you when an address isn't working. We don't track whether you open our emails or click their links.

Mailjet is part of the Sinch group and stores this data in Google Cloud data centers in Frankfurt (Germany) and Saint-Ghislain (Belgium). See Mailjet's privacy policy.

Twilio (SMS phone-number verification)

We use Twilio to send SMS verification codes when you choose to add a phone number to your Velvet Ledger profile. This is used to prove ownership of the phone number β€” once verified, you can choose to display the number on your invoices, in your business contact details, or in other places where you want to provide it to your own clients. We use Twilio's Verify service, which manages code generation and validation as a managed service, so we never see or store the verification code itself.

What Twilio receives during verification:

  • The phone number being verified (in E.164 format, e.g. +15551234567)
  • The channel used (SMS or voice call)

What Twilio does NOT receive:

  • Your user ID, name, email address, or any other identifying information about your Velvet Ledger account
  • Any of your business data or content you've stored with us
  • The verification code itself (Twilio generates and validates the code internally)

This is a one-time data flow per phone number. Twilio sees the phone number only during the verification step. The verified phone number itself is stored on our EU servers (Hetzner), not at Twilio. Sending a new verification (for example, if you re-verify or add a new number later) creates a new one-time flow at that moment.

A verified phone number cannot be used to look up your account at Twilio β€” because we never send Twilio any identifier that would link the phone number to your Velvet Ledger account.

Twilio is based in the United States and operates under Standard Contractual Clauses for EU data subjects. See Twilio's privacy policy.

Hosting Provider (Hetzner)

EU-based infrastructure provider (Germany). We have signed a Data Processing Agreement (DPA) ensuring GDPR compliance. All servers are located in EU data centers.

Storj (Encrypted file storage β€” EU1 region)

We use Storj to store the binary content of files you upload (the PDF pages, the image data, the document bytes) and of documents we generate at your request that you choose to save (invoice PDFs and similar). Storj is a decentralized cloud storage service that's S3-compatible. Your file content is stored in Storj's EU1 region, encrypted at rest with AES-256 and distributed across EU-based storage nodes.

What Storj stores: only the file binary itself, plus minimal Storj-side metadata needed to retrieve the file (your user ID as the uploader, the original filename, an upload timestamp, a content hash for integrity, and the scan status).

What Storj does NOT store: descriptive information about the file (the description you've written, the tags you've applied, the references linking it to an invoice or a contact in your address book). All of that is kept in our Hetzner PostgreSQL database alongside your other business data β€” so the user interface can search and display files quickly without reading the binary content.

How files move through our system:

  • You upload a file from your browser β†’ our EU server receives it
  • Our server uploads the file to a quarantine bucket in Storj for virus scanning (see AttachmentAV below)
  • If the file passes scanning, it is moved to a clean storage bucket
  • If a threat is detected, the file is immediately deleted and you are notified
  • Files are encrypted at rest by Storj using AES-256
  • Download access is provided via short-lived signed URLs (typically 24-hour expiration)

Storj's decentralized architecture splits file data into encrypted shards distributed across multiple storage nodes β€” no single node holds a complete copy of any file. See Storj's privacy policy.

AttachmentAV (Antivirus scanning β€” EU-hosted)

We use AttachmentAV to scan files you upload for malware, viruses, and other security threats. The scanning happens automatically every time you upload a file, before the file becomes available to you or anyone in your shared groups.

How scanning works: After you upload a file, we place it in a quarantine bucket at Storj and generate a short-lived signed URL. We send that signed URL to AttachmentAV's EU-hosted service. AttachmentAV downloads the file via that URL, scans it, and returns the result to us. If clean, we move the file to permanent storage. If a threat is detected, we delete the file from quarantine immediately.

AttachmentAV is hosted in the EU at eu.developer.attachmentav.com. File content is not retained by AttachmentAV after scanning; only scan metadata (a hash of the file, the scan result, and the scan date) is retained for their service operation. See AttachmentAV's privacy policy.

Cloudflare (DNS Management)

We use Cloudflare to manage DNS for velvetledger.io. Cloudflare answers DNS queries β€” the technical lookups your browser makes to find our servers β€” but does NOT proxy or process your web traffic, email content, or any data you store with us. When you visit our site, your browser connects directly to our EU servers; Cloudflare is not in that data path.

We do not use Cloudflare's CDN, Web Application Firewall, Bot Fight Mode, or other traffic-processing products. If we ever turn those products on, we will update this Privacy Policy to disclose the change. See Cloudflare's privacy policy.

Mapbox (Address Autocomplete and Geocoding)

We use Mapbox to provide real-time address suggestions and to validate addresses you enter β€” for example, when you add a client's address, your business address, or an appointment location. When you type into an address field, the text you've entered is sent to Mapbox's API to retrieve suggestions or validate the address.

What Mapbox receives: the address text you typed and the IP address your request came from. That's all. We do not send Mapbox any other information about you β€” no user ID, no email address, no account details, and no information about your other addresses or activity.

What Mapbox does NOT receive: Mapbox cannot distinguish between Velvet Ledger users. All queries from all of our users are made under our single account-level access token, so from Mapbox's perspective they see "queries from the Velvet Ledger account" without any way to attribute them to specific individuals.

Mapbox is based in the United States and operates under Standard Contractual Clauses with EU data subjects. See Mapbox's privacy policy.

Sentry (Error tracking and performance monitoring β€” EU region)

We use Sentry to detect and diagnose technical errors and to monitor the performance of the Service. Sentry receives an event when something fails in a way we should investigate β€” for example, an unexpected error in our server or in your browser. We have deliberately designed our Sentry integration to send the minimum useful data, with pseudonymization applied to anything that could otherwise identify a user.

What Sentry receives:

  • The error itself (type, message, and stack trace)
  • A salted, one-way hash of your internal user ID β€” never your name, email, or other directly identifying information, and never the raw database ID itself. The hash lets us tell whether a single user is repeatedly affected by an issue, while making it impossible to reverse the hash back to your account without our private salt
  • Technical context about where the error happened β€” the URL path of the affected page or API endpoint, with query strings either removed entirely or replaced by an opaque one-way hash so the parameters never reach Sentry in readable form; plus the request method and operation name
  • General browser or server context (browser type, environment, language)
  • A small sample (10% in production) of routine performance traces β€” anonymized timing data we use to spot slow operations

What Sentry does NOT receive:

  • Your business data (contacts, files, notes, financial records, messages, or any other content you store with us)
  • Your name, email address, or other directly identifying information
  • Raw user IDs from our database β€” only the salted hash, which is irreversible without our private salt
  • Raw URL query strings β€” these are stripped or hashed before any event is sent
  • Default PII that Sentry SDKs would otherwise auto-collect β€” we have explicitly disabled this (sendDefaultPii: false) on both server and client
  • Session replays β€” we have explicitly disabled session recording
  • Routine, expected errors (authentication failures, validation errors, network timeouts) β€” these are filtered out before any event is sent

Sentry's data is hosted in Sentry's Germany region (de.sentry.io). Sentry GmbH operates under a Data Processing Agreement that ensures GDPR compliance. See Sentry's privacy policy.

Analytics Tools (Optional)

Today, we rely on server logs and aggregate counts for product health (errors/performance and feature usage trends). If we add optional privacy-focused analytics tools in the future, they will receive anonymized or aggregated data only β€” never your actual business data.

⚠️ We do NOT sell your data to third parties for marketing or advertising purposes. Period.

6. Your Rights (GDPR Compliance)

Under GDPR and other data protection laws, you have the right to:

  • Access: Request a copy of all data we hold about you
  • Export: Download your data in JSON format via User Profile β†’ User Preferences β†’ Security
  • Rectification: Correct inaccurate or incomplete data (edit directly in the app)
  • Erasure: Request deletion of your account and data (Settings β†’ Account β†’ Delete Account)
  • Restriction: Limit processing while disputing accuracy or lawfulness
  • Objection: Object to direct marketing at any time β€” this is an absolute right under GDPR Article 21(2); we stop processing your data for marketing immediately on request, no justification required
  • Portability: Export your data in machine-readable format to use with other services
  • Withdraw Consent: Revoke consent for optional data processing at any time
  • Lodge Complaint: File a complaint with your local EU supervisory authority

To exercise these rights, visit User Profile β†’ User Preferences β†’ Security or email privacy@velvetledger.io. We will respond within 30 days as required by GDPR.

7. Data Retention

How long we keep different types of data:

Data retention periods by type
Data TypeRetention PeriodReason
Active Account Data
(contacts, tasks, appointments, transactions, files, notes, groups)
While account is activeTo provide the Service
Deleted Account - Standard
(business data)
7 days (cancellation window), then permanently deletedAllow accidental deletion recovery
Deleted Account - Emergency
(business data)
Immediately deleted (cannot recover)Safety/security situations requiring urgent deletion
Billing Records
(dates, amounts, plan names, invoice IDs)
8 years from the end of the year the record was made inTax and accounting duties and payment disputes (legitimate interest, GDPR Art. 6(1)(f))
Moderation Records
(bans, suspensions, group removals: decision, reason, rule, content references)
While the account exists, then 3 years after it closesDefending legal claims about moderation decisions (legitimate interest, GDPR Art. 6(1)(f))
Security Audit Logs
(login attempts, access records)
1 yearSecurity monitoring and compliance
Disaster Recovery Backups28 days (automatic rotation)Deleted data purged from backups within 28 days
Deletion Request Record
(date, method, whether data was exported)
7 yearsGDPR compliance and audit trail
Important: Billing records include only transaction metadata (dates, amounts, plan names, invoice IDs). They do NOT include your business data (contacts, tasks, financial transactions, files, notes, etc.).

8. Marketing Communications

We only send you promotional emails, product updates, or newsletters if you've explicitly opted in β€” meaning you ticked a box, signed up for a list, or otherwise affirmatively said yes. We do NOT pre-check consent boxes, we do NOT bundle marketing opt-in into other agreements, and we do NOT add you to a marketing list just because you have an account.

What we keep on file: a record of when and how you opted in (date, source, and the consent text you saw). We keep this so we can demonstrate your consent under GDPR Article 7 if asked, and so we can honor a withdrawal cleanly. If you didn't opt in, we don't email you marketing β€” full stop.

How to unsubscribe (any of these works):

  • Click "Unsubscribe" in any marketing email
  • Update your preferences in User Profile β†’ User Preferences
  • Email us directly at privacy@velvetledger.io

We process unsubscribe requests within 10 business days (the CAN-SPAM statutory maximum), and usually within minutes. Once you unsubscribe, we keep a record of the withdrawal so you don't get accidentally re-added β€” but we stop sending.

What we never do: sell, rent, share, or trade your email address with other companies for their marketing. Our marketing emails come from us, about our Service. That's it.

Note: Unsubscribing from marketing emails does NOT stop transactional emails (password resets, billing notifications, security alerts, grace period warnings). Those are necessary for the Service and cannot be disabled while your account is active. Every marketing email also includes our physical mailing address (see Section 14), as required by U.S. anti-spam law (CAN-SPAM Act, 15 U.S.C. Β§ 7704).

9. Cookies and Tracking

We use only essential cookies required to run the Service securely. We do not use marketing, analytics, or advertising cookies, and we do not sell data to ad networks.

  • Session cookie (velvetledger.sid): keeps you signed in after you log in (HttpOnly, SameSite).
  • Security cookie (csrf_token): protects forms and account actions from cross-site request forgery.

These cookies may be set when you use login or other interactive features. Browsing public pages alone does not require them. You can control cookies in your browser settings; disabling essential cookies may prevent sign-in or secure actions from working.

10. Children's Privacy

Velvet Ledger is intended for adults (18 years of age or older) running their own businesses. The Service is not designed for, marketed to, or directed at children. Per Section 6 of our Terms of Service, users must be at least 18 years old to register or use the Service. We do not knowingly collect personal information from any user under 18.

πŸ›‘οΈ Special Notice for Children Under 13 (COPPA)

The U.S. Children's Online Privacy Protection Act ("COPPA", 15 U.S.C. Β§6501 et seq., and the FTC's COPPA Rule at 16 C.F.R. Part 312) places special protections on the personal information of children under 13. We take these obligations seriously.

How our Service is structured: Velvet Ledger is an internal business-management tool β€” not a social network, public messaging platform, or content-sharing site. Users can communicate only within private groups they choose to join. There is no public profile, no public feed, no search-indexed content, no targeted advertising, and no behavioral profiling. We do not buy or sell user data, and we do not run third-party ad networks.

By design, we do not collect date of birth at registration. This is a deliberate privacy choice, not an oversight: the Service is intended for adults running their own businesses, and we follow a data-minimization principle of collecting only what we need to provide the Service. We treat any new collection of age data as a privacy cost that must be justified, not assumed. We therefore rely on the 18-or-older eligibility requirement in our Terms of Service (Section 6 of the Terms requires users to attest to being at least 18) and on reports from parents, guardians, the affected user, or other users to identify any account that may belong to a child under 13.

πŸ‘¨β€πŸ‘©β€πŸ‘§ If You Are a Parent or Legal Guardian

If you believe a child under 13 has registered for an account or provided personal information to Velvet Ledger, please tell us as soon as possible, using the report form (no account needed; you get a ticket number by email straight away) or by email to privacy@velvetledger.io with the subject line "COPPA β€” Child Account Report". Please include, to the extent you can:

  • The email address or username on the account (if known)
  • The approximate date of registration (if known)
  • Your relationship to the child (parent or legal guardian)
  • A way for us to follow up with you so we can verify your relationship to the child before taking irreversible action
  • Information that helps us connect your child to the specific account. Documents such as a birth certificate identify your child but do not, on their own, prove that a particular account belongs to them. Helpful examples include: the recovery email or phone number on the account, the device used to sign up, the display name or username, group names the child has mentioned, the payment method used (if any), or any other detail only someone close to the account would know.

There is no fee for making this report. You also have the right at any time to review the personal information we have collected from the child, to require us to delete it, and to refuse to permit further collection or use of the child's information.

πŸ“Œ Why we ask for connecting information

Identity documents prove who a person is, but email accounts are not listed on identity documents. To act on a report, we need to bridge the two β€” connecting the child named on your documentation to the specific account being reported. We build this connection through information you provide, through our outreach to the account holder, or both. If we cannot make the connection through reasonable efforts, we may close the report as non-substantiated, while remaining open to re-opening it if you discover additional information later.

How We Become Aware (the COPPA "actual knowledge" standard)

Under COPPA, our obligations attach when we have actual knowledge that a user is under 13 β€” not when we suspect it, and not when we receive an anonymous tip. We do not proactively monitor user content, scan messages, or run age-estimation systems. We become aware of under-13 use through the following channels:

  • A parent or legal guardian contacts us with specific information about the account
  • The user themselves discloses their age (in a support ticket, in profile content, or in a verified self-statement)
  • Another user reports the account with corroborating specifics
  • Our payment processor flags a chargeback indicating the account was used by a minor
  • Law enforcement, a school, or a care provider notifies us in the course of an investigation
  • We discover credible evidence incidentally while investigating an unrelated matter

Receipt of a report does not, by itself, establish actual knowledge. Reports must be triaged for credibility before they trigger action on an account (see procedure below).

Phase A β€” Triage (within 2 business days of receipt)

When a report is received concerning possible under-13 use, we first assess its credibility before taking any action on the reported account. Credible reports typically contain:

  • Specific identifying information about the child (name, account email or username, approximate date of registration)
  • A claim of relationship from the reporter (parent, legal guardian, the user themselves, or a person with first-hand knowledge)
  • A way for us to follow up with the reporter to confirm the claim

We acknowledge receipt of all reports within 1 business day. We do not take any action on the reported account during triage. Anonymous reports, reports lacking specifics, and reports that appear to be made in bad faith (for example, retaliatory reports identifying competitors or ex-partners) are documented and closed at this phase without affecting the reported account.

Phase B β€” Investigation (up to 10 business days from credibility finding)

If a report is found credible at triage, we move into investigation. During this phase we take a limited protective action rather than a full suspension β€” this satisfies COPPA's requirement to stop collecting data from a child once we have actual knowledge, without subjecting an account that may belong to an adult to indefinite lockout:

  • New data collection is paused on the account: no new messages, file uploads, or group activity. Billing on the account is also paused.
  • The account holder retains access to their existing data and the ability to export it.
  • The account holder is notified within 1 business day that a report has been received concerning their account, the general nature of the concern (a claim of under-13 use), and the procedure for responding. We do not disclose the reporter's identity.

The account holder has 5 business days from notification to respond. The response procedure is intentionally graduated so that legitimate adult users are not required to produce sensitive documents at first contact:

  1. Tier 1 β€” Signed self-attestation. The account holder replies confirming, under penalty of perjury pursuant to 28 U.S.C. Β§ 1746 (Unsworn Declarations) or analogous state law, that they are 18 years of age or older and that they are the sole user of the account. For most legitimate adult users, this is sufficient and the report is closed.
  2. Tier 2 β€” Voluntary expedited verification. The account holder may, at their option, voluntarily submit verification documents to close the report faster. We do not require this; it is offered as a courtesy for users who prefer rapid closure.
  3. Tier 3 β€” Requested verification. Only if the Tier 1 response is non-credible, contradicted by other evidence in our records, or absent after the response window, we may request additional verification. The account holder may choose one of the following: a redacted government-issued ID showing date of birth only (with ID number and other identifiers blacked out), a notarized affidavit of age, or two non-ID corroborating documents (such as a utility bill, employment letter, school transcript, or tax document cover page).
  4. Tier 4 β€” Adverse inference. If verification is not provided after a clear request, or if the totality of the evidence credibly supports under-13 use, we proceed under Phase C below.

Verification document handling: Any documents we receive in Tiers 2 or 3 are reviewed only for the purpose of resolving the report and are destroyed within 30 days of report closure, unless we are legally required to retain them. We do not store, copy, share, or use these documents for any other purpose.

Phase C β€” If the report is substantiated (under-13 use confirmed)

When investigation establishes that the account is used by or contains personal information of a child under 13, we proceed with full COPPA-compliant remediation:

  1. Permanently delete all personal information associated with the account β€” including registration data, business data the account uploaded, messages sent within private groups, files, and account metadata β€” within 7 days. This deletion follows the Emergency Deletion procedure described in Section 11 of the Terms of Service and is not subject to the standard 7-day recovery window.
  2. Remove the child's content from any private groups in which the account participated, to the extent technically feasible. Because Velvet Ledger is not a public platform, no public takedown is required β€” no content was ever public.
  3. Refund any payment taken from or on behalf of the account, regardless of the 14-day money-back window in our Refund Policy.
  4. Notify the reporting parent or guardian that the matter has been resolved. We confirm that appropriate action has been taken; we do not disclose specifics about the account or its contents.
  5. Retain only the minimum compliance record β€” the date the report was received, the verification method used, and the date deletion was completed. This record contains no personal information about the child and is retained for 7 years to support regulator inquiry, then destroyed.

Phase D β€” If the report is not substantiated

If investigation closes without substantiating that the account belongs to a user under 13, we immediately:

  • Lift the data-collection pause and restore full account functionality
  • Reactivate billing, with the suspended period credited to the next billing cycle
  • Notify the account holder that the report has been closed with no action taken
  • Notify the reporter only that the investigation is closed β€” we do not disclose any account details, content, or identifying information about the account holder
  • Destroy any verification documents received under Tier 2 or Tier 3 within 30 days

⚠️ Bad-faith reports

If at any point we identify the report as malicious or made in bad faith β€” for example, a knowingly false report intended to harass an adult user, to disrupt service to a competitor, or to retaliate against an ex-partner or business rival β€” the investigation is closed AND the reporting account (if applicable) is itself referred for review under the anti-abuse procedures described in the next section. False reports are themselves a violation of these Terms.

πŸ›‘οΈ Protections Against Weaponized Reporting

We are aware that report channels can be abused to harass, suspend, or deplatform users. The following protections are built into the procedure above and are part of our binding commitment to all account holders:

  • No suspension on uncorroborated reports. Reports lacking specifics, anonymous reports, and reports failing the credibility assessment at Phase A do not affect the reported account.
  • No full suspension during investigation. The protective action during Phase B is a pause on new data collection only β€” the account holder retains access to their existing data and the ability to export it.
  • Time-capped investigation. Investigation closes within 10 business days. Indefinite "under investigation" status is not permitted.
  • No fishing. We do not disclose to a reporter whether an email address or username matches an account, the content of the account, or the identity of the account holder. Reporters receive only acknowledgment of receipt and final closure status.
  • Account holder notice and response. The account holder is notified of any report affecting their account and is given a reasonable opportunity to respond before any further action is taken.
  • No ID demand at first contact. Signed self-attestation is the default first-tier response. Government-issued identification is requested only in escalation, and the user may choose alternative documents.
  • False reports are a Terms of Service violation. Knowingly false reports β€” including reports made to harass, defame, suspend competitors, or disrupt service to other users β€” constitute a violation of Section 2 (Acceptable Use) of our Terms of Service and may result in suspension or termination of the reporting account. Where the conduct involves harassment, defamation, or material misrepresentation, we may also refer the matter to law enforcement or assist parties pursuing civil remedies under applicable state or federal law.

Reports Concerning Users Aged 13 through 17

Reports that a user is under 18 but not under 13 are handled under our general TOS-violation procedure (see Section 11 of the Terms of Service), because the user's presence on the Service breaches the 18+ eligibility requirement in Section 6 of the Terms of Service but does not trigger COPPA. The same anti-abuse protections apply, and the same graduated verification ladder (signed self-attestation β†’ voluntary verification β†’ requested verification) is used. The total investigation window for these reports is 14 business days, slightly longer than the COPPA window because COPPA's promptness obligation does not apply.

If a user 13–17 is confirmed, the account is terminated for breach of the 18+ representation, the data is deleted, and any payment is refunded. The minimum compliance record described in Phase C is also retained.

Why the response above is sufficient: Because Velvet Ledger is a closed, private business tool β€” communication happens only within groups a user actively joins β€” any personal information a child may have provided is not publicly indexed, searchable, distributed, or sold. We do not run advertising, do not build behavioral profiles, and do not share personal information with marketing partners or data brokers. In the rare event that a child under 13 has used the Service, no profile of that child exists outside our systems, and deletion of the account is therefore a complete remediation.

Future safeguards: If we later add features that would make the Service more attractive to or accessible by children under 13 (for example, public profiles, public sharing, advertising, or under-18 user types), we will revise this Section 10 and, where required by COPPA, implement an age screen and obtain verifiable parental consent before collecting any personal information from a child under 13.

Relationship to other rights: This Section 10 supplements, and does not limit, the broader user-eligibility requirements in Section 6 of our Terms of Service. Reports concerning users aged 13 through 17 will also be reviewed and acted on; however, the COPPA-specific procedures described in this section apply only to children under 13.

11. International Users

If you access the Service from outside the European Union, your data will be transferred to and stored on EU servers (France and Germany). By using the Service, you consent to this transfer and the practices described in this Privacy Policy. Your data receives the strong protections of EU data protection laws regardless of your location.

12. Data Breach Notification

In the unlikely event of a data breach affecting your personal information, we will:

  • Notify relevant supervisory authorities within 72 hours (GDPR requirement)
  • Notify all affected users without undue delay, typically within 72 hours as well
  • Provide details about what data was affected
  • Explain what we're doing to address the breach
  • Recommend actions you should take to protect yourself

We are committed to obtaining comprehensive cyber liability insurance before we begin charging customers and processing payments. This insurance will provide additional protection and resources in the event of a security incident.

13. Changes to Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email and in-app notification at least 30 days before they take effect. Minor changes (clarifications, legal updates) will be posted here with an updated "Last Modified" date. Your continued use of the Service after changes constitutes acceptance.

14. Contact Information

For privacy-related questions or to exercise your rights, contact us at:

Email: privacy@velvetledger.io

Data Protection Officer: dpo@velvetledger.io

Service: Velvet Ledger

Address: 123 E San Carlos St, Unit #184, San Jose, CA 95112

Questions about Privacy Policy?

Email privacy@velvetledger.io for privacy-related questions. We respond within 3 business days.

Refund & Cancellation Policy
Fair and transparent billing practices

1. Free Trial (30 Days)

  • No Credit Card Required: Trial starts immediately upon signup
  • Full Flourish Features: Access all premium features during trial
  • Cancel Anytime: No charges if you cancel before trial ends
  • Auto-Downgrade: If no payment added, account downgrades to Explore (no charge)

2. 14-Day Money-Back Guarantee

Full Refund Within 14 Days: If you're not satisfied within the first 14 days of your first payment, we'll issue a full refund, no questions asked.

How to Request: Email refunds@velvetledger.io or use Billing Settings β†’ Request Refund.

Processing Time: Refunds processed within 5-7 business days to original payment method.

UK and EU customers: your right to cancel

If you live in the UK or the EU, the law gives you 14 days from buying a subscription to cancel it without giving a reason. When you choose a paid plan you ask us to start it straight away. The law would let us keep a share of the payment for the days you used; we don't. Cancel within 14 days of your first payment and we refund all of it.

To cancel, use Billing Settings β†’ Request Refund, or email refunds@velvetledger.io saying you want to cancel. Any clear statement is enough; you don't need a form. We refund you within 14 days of hearing from you, to the card or account you paid with. This applies to a new subscription, not to its later renewals; you can stop those at any time in Billing Settings.

3. Cancellation Policy

Cancel Anytime: No cancellation fees. Cancel via Billing Settings.

Access Until Period End: You retain full access until your current billing period expires.

No Pro-Rated Refunds: After the 14-day window, cancellations do not receive partial refunds for unused time.

Example: You pay $9.99 on January 1st for the Focus plan. You cancel on January 20th. You keep access until January 31st, but receive no refund (since you're past the 14-day window).

4. Downgrades

Effective Next Cycle: Downgrades take effect at the next billing date (you keep current plan until then).

No Refunds for Downgrades: Downgrading mid-cycle does not trigger refunds for the current period.

Lower limits: If the new plan has lower limits, you keep everything you have but can't add new records while you're over them (see Terms of Service, Section 4).

5. Upgrades

Immediate Access: Upgrades take effect immediately upon payment.

Pro-Rated Billing: You're charged the difference between plans, pro-rated for the remaining days in your current billing cycle. Next cycle bills at full new plan rate.

6. Annual Subscriptions

If you choose annual billing:

  • You receive a discount compared to monthly billing (2–4 months free, depending on the plan)
  • The 14-day money-back guarantee still applies to your first annual payment
  • Cancellations after 14 days do not receive refunds for unused months
  • You keep access until the end of your annual period
  • Subscription renews annually unless canceled before renewal date

7. Failed Payments

Retry Policy: We automatically retry failed payments 3 times over 7 days.

Grace Period: You have 7 days to update payment info before downgrade to Explore tier.

Notification: We email you immediately when payment fails, plus reminders at day 3 and day 6.

8. Exceptional Circumstances

We may issue refunds outside the 14-day window for:

  • Billing errors or duplicate charges (full refund)
  • Extended service outages (pro-rated credit or refund)
  • Compassionate cases (death, severe illness β€” contact support)

All exceptional refunds are at our discretion. Contact support@velvetledger.io

9. Chargebacks

We understand that disputes happen. If you believe a charge on your card or bank account is incorrect, please contact us before filing a chargeback with your bank β€” most billing disputes are resolved quickly and informally.

πŸ“¨ Pre-Chargeback Contact

Please email refunds@velvetledger.io with subject "Billing Dispute" and include:

  • The date and amount of the charge in question
  • The reason for the dispute (didn't recognize the charge, service wasn't received, billing error, duplicate, etc.)
  • The email address associated with your Velvet Ledger account

We commit to responding within 5 business days and to resolving legitimate billing issues fairly. Where a refund is warranted under this Refund Policy or as a billing-error correction, we will issue it directly.

βœ… Your statutory rights are preserved

Nothing in this Refund Policy or our Terms of Service waives or limits your statutory right to dispute a charge directly with your bank or card issuer. Federal law (the Fair Credit Billing Act for credit cards, 15 U.S.C. Β§ 1666, and the Electronic Fund Transfer Act for debit and ACH, 15 U.S.C. Β§ 1693f) and applicable state laws give you the right to dispute charges through your bank. We encourage you to contact us first because most disputes are misunderstandings β€” but if we cannot resolve the issue to your satisfaction, you retain your full statutory right to file a chargeback.

⚠️ Consequences of chargebacks within our service

This policy does not affect your bank dispute rights, but it does describe how chargebacks are handled within Velvet Ledger:

  • Chargebacks filed without contacting us first: Your account may be suspended while we investigate. If we resolve the dispute in your favor, your account is restored. If we have records showing the service was properly delivered, your account may remain suspended pending the bank's resolution.
  • Chargebacks for properly-delivered service: If a chargeback is filed for a charge where we have records showing the service was properly delivered (account active, plan features in use, no service outage during the billing period), we may treat the filing as a violation of our Terms of Service. Repeated unjustified chargebacks may result in permanent account termination and referral to collections.
  • Fraudulent chargebacks: Filing a chargeback for a charge you authorized and a service you received and used, with the intent of obtaining a refund through fraud rather than through this policy, is a violation of these Terms and may constitute fraud under applicable law. We reserve the right to refer such matters to law enforcement, your card network's fraud team, and to defend the chargeback through the bank's dispute resolution process.

Why this policy exists: Most billing disputes are misunderstandings β€” a duplicate charge, a renewal you forgot about, a charge from a partner that you didn't recognize, or a service issue we can fix. Resolving these by email is faster and easier for both of us than going through a bank chargeback process, which can take 60–90 days to resolve. We've structured this policy to preserve your statutory rights while encouraging the quickest path to resolution.

Questions about Refunds?

Email refunds@velvetledger.io for billing or refund questions. We respond within 3 business days.

Frequently Asked Questions
Common questions answered in plain English

Data Security & Privacy

Q: Can Velvet Ledger employees access my data?

A: Currently: Our database administrators have technical access to the database, but we have strict access controls and audit logging in place. Database access is:

  • Limited to senior technical staff only (currently just the founder)
  • Logged and reviewed monthly
  • Used only for debugging, security incidents, or with your explicit support request
  • Never used for marketing, analytics, or any other purpose

Future (2026): We're developing server-side encryption where your data will be encrypted with your unique encryption key, making it cryptographically impossible for our staff to access your data even with database access. Once implemented, not even we will be able to read your business data.

Your Current Protection:

  • All data is encrypted in transit (TLS 1.3 end-to-end between your browser and our EU servers)
  • Database volumes are encrypted at rest (AES-256 by Hetzner)
  • Strict employee access controls and background checks
  • Comprehensive audit logging
  • Legal confidentiality obligations

If you have concerns about current data access, please email security@velvetledger.io

Q: What happens if there's a data breach?

A: We notify relevant supervisory authorities within 72 hours (GDPR requirement) and affected users without undue delay, typically within 72 hours as well. You'll receive details about what data was affected, what we're doing about it, and recommended actions. We are committed to obtaining comprehensive cyber liability insurance before we begin charging customers.

Q: How often do you back up my data?

A: Automated backups run every 6 hours. We retain daily backups for 30 days, weekly backups for 3 months, and monthly backups for 1 year. Backups are encrypted and stored in geographically separate Hetzner data centers within the EU. You can also manually export your data anytime in JSON format.

Q: Can I use Velvet Ledger for healthcare/financial data (HIPAA/PCI)?

A: No. We are GDPR-compliant but not HIPAA or PCI-DSS certified, and we have no current plans for these certifications. Do not store protected health information (PHI) or credit card numbers in Velvet Ledger.

Data Ownership & Export

Q: How do I export my data?

A: Go to User Profile β†’ User Preferences β†’ Security tab. You'll receive a JSON file containing all your data within 24 hours (usually within minutes). Available on all plans (including Free).

What's included in the export:

  • All business data: contacts, tasks, appointments, transactions, incomes, expenses
  • Notes, tags, templates, groups, and activity log (last 1,000 activities)
  • Your profile, settings, and preferences
  • Contact methods: emails, phones, addresses, payment platforms
  • File metadata only: File names, sizes, upload dates (NOT the actual file content)

⚠️ Important: The export includes file metadata but not the actual files. Download your files separately before account deletion if needed. Passwords and security tokens are automatically excluded from exports.

Q: What if Velvet Ledger goes out of business?

A: In the unlikely event of bankruptcy or shutdown, we commit to:

  • 90 days' advance notice via email
  • Keep platform running read-only for 60 days minimum
  • Provide bulk export tools and migration guides
  • Ensure you can export all your data before shutdown

This commitment is legally binding and will be honored by any acquiring company. You always retain full ownership of your data and can export it at any time from User Profile β†’ User Preferences β†’ Security.

Q: Can I transfer my account to someone else?

A: Account ownership cannot be transferred directly. To move your data to another user: export your data (Settings β†’ Export Data), then have the new user create their own account and import it. Note: You can transfer ownership of individual Groups to other group members via the group settings.

Account Management

Q: I accidentally deleted my account β€” can I recover it?

A: It depends on which deletion method you used:

If you used standard deletion (7-day cancellation window):

  • Simply log in to your account using your normal credentials
  • You'll see a banner: "Your account is scheduled for deletion on [date]"
  • Click "Cancel Deletion" to restore your account immediately
  • You can do this anytime within 7 days of requesting deletion
  • After 7 days, deletion is permanent and cannot be recovered

If you used emergency deletion ("delete immediately for safety"):

  • Deletion was immediate and permanent
  • You cannot log in to cancel this type of deletion
  • We cannot recover your data
  • This option is designed for situations requiring urgent deletion

Prevention tip: We strongly recommend downloading your data before deleting your account. Go to User Profile β†’ User Preferences β†’ Security to export all your data.

Q: What happens when my trial ends or if I don't pay my bill?

A: Timeline:

  • Day 0-30: Free trial with Flourish plan features (or existing paid subscription)
  • Day 30: Trial ends (or payment fails) β†’ Choose to upgrade to a paid plan OR downgrade to Explore plan
  • If Explore plan: No refund period (it's free). If you have more than 250 records, you keep all of them (view, edit, delete, export) but can't add new ones until you upgrade or are back under the limit
  • If paid plan: 14-day money-back guarantee starts from the day you upgrade
  • Upgrade anytime: If you upgrade from Free to Paid later, your 14-day refund window starts on that upgrade date

Your data is never deleted due to non-payment. Upgrade anytime to restore full access.

Q: Can I pause my subscription instead of canceling?

A: Not directly, but you can downgrade to the Explore plan (keeps your data, limits features). When you're ready to resume, upgrade back to your previous plan. All your data stays accessible on the Explore plan; if you have more than 250 records you can't add new ones until you upgrade again. Nothing is locked, hidden or deleted.

Q: What can I do when I'm over my plan's limit?

A: Everything except adding new records:

  • βœ… Can do: View all your data (including excess)
  • βœ… Can do: Edit all your data (including excess) β€” full edit capabilities
  • βœ… Can do: Delete data to get back under limits
  • βœ… Can do: Export all your data (including excess data)
  • βœ… Can do: Upgrade anytime to add records again
  • ❌ Cannot do: Add new records (contacts, tasks, appointments, income, expenses, invoices) or upload files past your storage

Example: You have 400 records on the Explore plan (limit: 250). You can view, edit and export all 400, and delete any to get under 250, but you can't add a new record until you upgrade or reduce your data.

Q: Do you support multi-factor authentication (MFA)?

A: Planned We’re working on MFA with a target of Q2 2026. In the meantime, use a strong, unique password (12+ characters with uppercase, lowercase, numbers, and symbols). If you’d like a heads-up when it’s available, email security@velvetledger.io.

Q: Do you offer discounts for nonprofits/students/startups?

A: We don't currently have a formal discount program. Our free Explore tier provides full feature access with capacity limits, which works well for many small organizations and individuals just getting started.

Technical & Integrations

Q: Where exactly is my data stored?

A: Your business data is stored in Hetzner data centers in Germany (EU). Web traffic goes directly from your browser to our EU servers β€” it does not pass through a US-based CDN. We use Cloudflare for DNS management only (the lookup that tells your browser where our servers are); Cloudflare does not see or process your data. Network-layer DDoS protection is provided by Hetzner. Limited operational data (transactional email recipient addresses, address text for autocomplete, phone numbers during SMS verification) is processed by US-based service providers under Standard Contractual Clauses β€” see Section 5 of the Privacy Policy for specifics. For non-EU customers who prefer local storage, we're exploring US/APAC regions for 2026 β€” email dataresidency@velvetledger.io to request.

Q: Do you have an API for integrations?

A: Yes, on the Flourish plan. REST API with full CRUD access to contacts, tasks, transactions, and files. Rate limit: 1,000 requests/hour. Documentation: docs.velvetledger.io/api. Webhooks available for real-time event notifications.

Q: Can I self-host Velvet Ledger?

A: No, Velvet Ledger is a cloud-only SaaS platform and is not open source. However, you can export all your data at any time from User Profile β†’ User Preferences β†’ Security. For enterprise customers needing on-premise deployment, contact enterprise@velvetledger.io to discuss custom licensing options (minimum 100 users).

Q: What's your uptime/SLA guarantee?

A: We target 99.9% uptime but do not offer formal SLAs on standard plans. Check real-time status at status.velvetledger.io. Flourish plan customers with 99.5% uptime SLA available for +$20/mo (pro-rated credits for violations). Enterprise customers can negotiate custom SLAs.

Compliance & Legal

Q: Are you SOC 2 compliant?

A: Not currently. We're an early-stage company focused on building a secure, privacy-respecting product. We follow security best practices (encryption, access controls, secure infrastructure), but we have not undergone formal SOC 2 certification. If you have specific security questions, please email support@velvetledger.io.

Q: Do you comply with CCPA (California privacy law)?

A: Yes. While we're EU-based and GDPR-compliant (which exceeds CCPA requirements), California residents have additional rights:

  • Right to know what data we collect (same as GDPR access)
  • Right to deletion (Settings β†’ Delete Account)
  • Right to opt-out of "sale" (we don't sell data, so N/A)

Email privacy@velvetledger.io to exercise CCPA rights.

Q: Will you comply with legal requests for my data (court orders)?

A: Yes, if legally required. We will:

  • Only respond to valid court orders/subpoenas (not informal requests)
  • Notify you before disclosure (unless legally prohibited)
  • Challenge overly broad or unjust requests
  • Provide transparency reports annually

To date, we've received zero legal requests for user data.

Still have questions?

We're here to help! Email support@velvetledger.io and we'll get back to you within 3 business days.

Contact Us
Questions about our policies?

Privacy Requests (GDPR)

privacy@velvetledger.io

Billing & Refunds

refunds@velvetledger.io

Legal / Pre-Dispute Notices

legal@velvetledger.io

EU Data Protection Officer: For GDPR compliance inquiries, contact our DPO at dpo@velvetledger.io

Response Time: We aim to respond to all inquiries within 3 business days.

GDPR Requests: Processed within 30 days as required by law.

Last updated: October 23, 2026

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