Privacy Notice

Last updated: May 22, 2026

1. Who we are

Pace Yourself Online LLC ("we", "us") operates the TrueFile platform and acts as the data controller for personal information processed through the Service. TrueFile™ is a trademark of Pace Probity LLC (USPTO registration pending).

2. What we collect

Account data: name, email, firm name, state, metro region, login credentials, team-seat membership and permissions.
Cost Intelligence inputs: P&L data, file volumes, BPO inputs, wizard responses, and other figures you enter or upload.
Hub operational data: property addresses, AM and client names, lifecycle status, inspection photos and reason tags, utility status, vendor contacts, transaction milestones, critical dates, tasks, and notes.
Reimbursement documents: invoices, checks (with MICR lines and signatures automatically redacted before display), W-9s, vendor certifications, and photo addenda.
Marge chat data: messages you exchange with Marge, stored per account for context continuity. Not used to train any AI model.
AM form field-maps (shared library) vs. your fills (private). See Section 11.
Integration metadata: when you connect a third-party service (e.g. a future QuickBooks or email integration), we store OAuth tokens (encrypted) and the minimum metadata needed to operate the integration on your behalf.
Usage data: pages viewed, features used, calculation history, device and browser type, IP address.
Support communications: messages and attachments you send us.
Payment data: handled by Paddle (see Section 4); we receive only subscription status, plan, and billing metadata — never full card numbers.

3. Why we use it

To create and operate your account and seats (legal basis: contract).
To provide the platform's core functions — cost modeling, Hub operations, Reimbursement Package Builder, Client Book, Marge responses (contract).
To prevent fraud, abuse, and secure the Service (legitimate interests).
To improve the product through aggregate, de-identified analytics (legitimate interests).
To send transactional emails (contract) and, with your consent, product updates.
To comply with legal obligations (legal obligation).

4. Who we share with

Paddle.com Market Limited — our Merchant of Record. Paddle handles checkout, payments, tax compliance, invoicing, and subscription management.
Hosting & infrastructure providers — for application hosting, database, and file storage.
AI model providers — accessed via the Lovable AI Gateway (currently Google and OpenAI models) to power Marge chat responses, OCR of uploaded documents, and AM form field detection. Only the data needed for each request is sent. These providers do not train models on your data.
ElevenLabs — used to generate Marge's audio walkthroughs. Audio is pre-rendered from approved scripts; we do not stream your chat content to ElevenLabs.
Analytics & error monitoring providers — to operate and improve the Service.
Email delivery providers — for transactional and account emails.
Professional advisers — legal and accounting, where necessary.
Authorities — when required by law or valid legal process.

We do not sell personal information.

5. AI processing & the no-training commitment

Marge personalizes her responses by pulling from your account data at the moment of each request, scoped to your row-level data only. This is per-turn context injection — not model fine-tuning. We do not train, fine-tune, or otherwise build AI models on Your Content, your chat transcripts, your P&L, your Hub data, or your reimbursement documents.

When the Service makes an AI request on your behalf (chat, OCR, AM form detection), only the data required to fulfill that specific request is sent to the underlying model provider via our AI gateway. Providers in scope are bound by their gateway terms not to retain or train on that data.

6. Check images & redaction

Checks uploaded to the Reimbursement Package Builder are processed with automatic redaction: MICR lines (routing and account numbers) and signatures are always redacted before any image is displayed inside the Service or included in a package PDF. The bank name and logo remain visible so the check is recognizable. We do not retain unredacted images.

7. Retention

We keep account, Hub, and reimbursement data for as long as your account is active. After cancellation, data is retained for up to 90 days to allow reactivation, then deleted or anonymized, except where longer retention is required for legal, tax, or accounting obligations. Audit logs and integration revocation records are retained for security purposes.

8. Your rights

Depending on your jurisdiction, you may have the right to:

Access the personal data we hold about you;
Correct inaccurate data;
Delete your data ("right to erasure");
Restrict or object to certain processing;
Receive your data in a portable format;
Withdraw consent where processing is based on consent;
Lodge a complaint with your local data protection authority.

9. U.S. state privacy rights (CCPA / CPRA and similar)

This section supplements Section 8 for residents of California, Virginia, Colorado, Connecticut, Utah, Texas, and other U.S. states with comprehensive privacy laws.

Categories of personal information we collect (cross-referenced to Section 2): identifiers (name, email, IP address), commercial information (subscription and billing metadata), internet and other electronic activity (usage data), professional or employment-related information (firm, role, REO operating data), and inferences drawn from your data (e.g., portfolio reads Marge produces from your inputs).

Sources: directly from you, automatically from your use of the Service, from Paddle (billing metadata), and from third-party integrations you authorize.

Business purposes (cross-referenced to Section 3): operating the Service, security and fraud prevention, support, billing, and product improvement. Recipients are listed in Section 4.

No sale and no share. We do not sell personal information and we do not share personal information for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA. We do not use sensitive personal information to infer characteristics about you beyond what is necessary to provide the Service.

Your California rights include the right to know/access, delete, correct, portability, opt out of sale or share (not applicable — we do neither), limit use of sensitive personal information, and the right to non-discrimination for exercising your privacy rights. Virginia, Colorado, Connecticut, Utah, and Texas residents have substantively similar rights under their respective state laws.

How to exercise your rights: submit a request through the in-app support form. We verify your identity through your authenticated session. We respond within 45 days, extendable by an additional 45 days with notice, in accordance with the CCPA.

Authorized agents may submit requests on your behalf with written authorization and identity verification.

Appeals. Virginia, Colorado, and Connecticut residents may appeal a denied request through the same support channel. We will respond within 60 days.

Shine the Light (Cal. Civ. Code §1798.83): we do not disclose personal information to third parties for their own direct marketing purposes.

10. Security

We use appropriate technical and organizational measures to protect your data, including: encryption in transit (TLS), database row-level security on every table, per-account RLS-scoped data access (including in AI requests), encrypted OAuth tokens for third-party integrations, automatic redaction of MICR and signatures on uploaded checks, and a leaked-password check at sign-up against the HIBP database. We honor Global Privacy Control (GPC) signals as an opt-out of sale/share where applicable (noting that we do not sell or share personal information in the first place). No system is 100% secure; we will notify you of incidents affecting your data as required by law.

11. International transfers

Your data may be processed in the United States and other countries where our service providers operate. Where applicable, we rely on Standard Contractual Clauses or other lawful transfer mechanisms.

12. Shared template library vs. your fills

The Reimbursement Package Builder uses a shared library of AM reimbursement form templates (the structural field-map of a blank form). When you map a new blank form, the resulting field-map is added to that library so other brokers can auto-fill the same form. The values you fill into any form, your tax ID, addresses, vendor lists, AM contacts, invoice contents, and all other broker-specific data are private to your account and are never shared with other users.

13. Cookies & similar technologies

We use a small number of cookies and similar browser storage, grouped as follows:

Strictly necessary — authentication session, CSRF protection, and load balancing. Required for sign-in and core functionality; cannot be disabled.
Functional — UI preferences such as theme, sidebar state, dismissed in-app banners, Marge wellness-ping timing, and add-on nudge dismissals. Used to remember how you've set up your account between sessions.
Analytics & product — aggregate usage telemetry and error monitoring, used to operate and improve the Service.

We do not use advertising cookies, retargeting pixels, third-party ad networks, or any cross-site tracking. We do not sell or share personal information for cross-context behavioral advertising. You can clear or block cookies in your browser; disabling strictly-necessary cookies will break sign-in.

14. Children

TrueFile is not directed to children under 16. We do not knowingly collect data from children.

15. Changes

We may update this notice. Material changes will be communicated by email or in-app notice.

16. Contact

Pace Yourself Online LLC — privacy questions can be sent through the in-app support form.