Account Portability Request Policy

Short description: This policy explains Tanqory’s secure, globally compliant process for account and data portability, including scope, formats, verification, timelines, limitations, and appeals under major privacy laws.

1) Purpose and scope (Purpose & Scope)

This policy sets the steps and boundaries for requesting account and data portability from Tanqory. It covers personal data and account-level information you provided or generated through our services, delivered in a structured, machine-readable format. It aligns with GDPR/UK GDPR, Singapore PDPA, and U.S. state portability laws. Verified users and authorized agents may use this process. Some data cannot be delivered if it would infringe others’ rights, expose trade secrets, or breach law or contract. The English version controls, and we update this policy when laws change.

2) Eligibility and guiding principles (Rights & Principles)

• Requesters: Verified account holders, team owners, or authorized agents with valid authority. Minors may need guardian approval where law requires.
• Data in scope: Personal data you supplied or generated through the service, provided in CSV/JSON/XML or via API where feasible and secure.
• Protecting others: We avoid disclosing other individuals’ data without consent or legal basis, using redaction or aggregation as needed.
• Fair use: Unfounded, excessive, or repetitive requests may be delayed, narrowed, or charged where law permits. We explain any limit or fee.
• No automatic closure: Portability does not close or delete your account.
• Non-discrimination: We do not penalize you for exercising portability.

3) How to submit and how we verify (Channels & Verification)

• Where to submit: Email privacy@tanqory.com with the subject "Account Portability Request" (primary channel). A self-service web portal is on Tanqory's data-rights roadmap; until it launches, all portability requests are handled manually by the Privacy team with the statutory timelines below.
• Information needed: Account identifier (sign-up email), request scope (e.g., full export, API logs), preferred format and delivery channel, and destination controller for direct transfers.
• Identity verification: MFA plus checks against registered email/phone. Higher-risk cases may require extra proof (e.g., government ID, domain control) to prevent misdelivery.
• Authorized agents: Provide authority plus ID for the account holder and the agent. Incomplete or mismatched documents pause or deny the request with reasons.
• Secure delivery: One-time links with short expiry, dedicated SFTP, or scoped API endpoints with limited privileges, sent only to verified channels.

4) Data contents and exclusions (Data Contents & Exclusions)

Typical data we provide (subject to scope and feasibility): account profile/preferences, workspace or store settings, orders/transactions owned by the requester, integrations created by the requester, billing summaries (no full card details), API usage logs, and security settings such as MFA devices and abbreviated login history.

Data we do not provide (or will redact/aggregate):

• Full payment card numbers (PAN), CVV/CVC, secret API keys, encryption material.
• Data revealing other users, buyers, or third parties without consent or legal basis.
• Proprietary algorithms, source code, internal security controls, or information under NDAs.
• Data whose disclosure would breach law, legal hold, court order, or third-party duties (e.g., PCI DSS).
• Derived analytics that cannot be isolated without exposing others or confidential information.

Where only part of a dataset is permissible, we provide that portion and, where possible, a summary or aggregated output. We explain omissions and the reasons.

5) Formats and delivery methods (Formats & Delivery)

• Formats: CSV for tabular data, JSON for structured data, XML on request, plus optional PDF summaries with brief import instructions.
• Encryption and transfer: HTTPS downloads with time-bound, single-use links. SFTP or API delivery uses least-privilege credentials revoked after use. Higher-risk datasets can be encrypted (e.g., AES-256) and PGP is available on request. Checksums support integrity checks.
• Controller-to-controller transfer: Where feasible and lawful, we transfer directly via a tokenized, scope-limited API endpoint once you confirm the destination accepts secure delivery.
• Large or staged deliveries: Large exports may be split into several files or batches; we coordinate timing with you.
• Expiry controls: Default link expiry is 7 days; alternatives can be set with justification. We do not deliver to unverified or high-risk domains.

6) Timelines and service levels (Timelines & SLA)

• Acknowledgment: We aim to confirm receipt within 7 calendar days.
• Fulfillment: Target delivery is within 30 calendar days after verification unless a shorter legal deadline applies. Under GDPR/UK GDPR we may extend by up to 2 months for complex or large requests, with notice.
• Enterprise contracts: Order-form SLAs supersede this baseline for covered services.
• Status updates: Complex requests receive periodic updates and revised estimated completion dates.
• Delays and fees: Manifestly unfounded or excessive requests may incur lawful fees or extended timelines; we explain rationale before applying a fee.
• Safety pauses: Overlapping data rights requests may be paused to reduce security or privacy risk.

7) Security, privacy, and misuse safeguards (Security & Privacy)

• MFA-based verification and access checks precede any release.
• Data is encrypted in transit (TLS) and at rest (e.g., AES-256) in export systems.
• Audit trails cover export creation, access, download, and delivery.
• We use data minimization and redaction to limit third-party exposure.
• Suspicious requests may be halted pending extra checks or denied with reasons.
• You must secure exported data after receipt; if a breach occurs during or after delivery, we follow our Incident Response Plan (IRP) and applicable notification rules.
• Temporary credentials follow least privilege and are revoked after completion.

8) Fees, frequency limits, and acceptable use (Limitations)

• No fee for a first reasonable request. Where law allows, repetitive, excessive, or clearly unfounded requests may incur a fee or be declined; we explain any fee or refusal.
• We may space similar requests over time to protect system stability and others’ privacy.
• Portability must not be used to remove intellectual property, trade secrets, or others’ data. Misuse may trigger denial, safeguards, or regulatory notice.

9) Appeals and supervisory channels (Appeals & Oversight)

• Appeal by emailing privacy@tanqory.com within 30 days, citing your request ID and reasons.
• We aim to review appeals within 15 business days and will issue a written decision; we will notify you if more time is needed.
• If unresolved, you may contact the relevant supervisory authority (e.g., EU/UK/SG authority or applicable U.S. state regulator). We will share contact details on request.
• For arbitration requirements with Tanqory Inc., see the preamble and your service agreement.

10) Recordkeeping and audit (Recordkeeping & Audit)

• We log request details, verification steps, approvals/denials, delivery dates, formats, channels, file sizes, and any limits or fees.
• Records are retained for at least 3–5 years or longer if required by law, contract, or litigation hold. Access is restricted and protected with encryption and role-based controls.
• We review this process under our ISMS and, where applicable, SOC 2 controls, and track remediation actions.

11) Policy updates and language (Policy Updates)

• Reviewed at least annually or sooner when laws, platform requirements, audits, or security events require changes.
• Significant updates appear at https://legal.tanqory.com and via registered email. We note effective date, version, and change summary.
• The English version is authoritative. Translations are for convenience only.
• Questions: privacy@tanqory.com.

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Appendix A: Illustrative data elements we may provide (without harming others’ rights or IP)

• Account profile: name, registered email, verified phone, language, timezone.
• Store/domain settings: store name, key configuration values, currency, enabled features.
• Orders/transactions: IDs, totals, status, timestamps, with third-party data redacted.
• API usage, integrations, and security: non-secret keys, endpoints invoked, integration name/status/scopes, MFA devices, abbreviated login history.
• Billing summaries: billing dates, amounts, currency, tax summary (no PAN/CVV or secret keys).

Appendix B: Do Not Sell/Share rights (U.S. states)

• For marketing or sharing data that may qualify as “sale/share/targeted advertising” under U.S. state laws (e.g., CPRA, CPA, VCDPA), Tanqory offers a “Do Not Sell/Share” opt-out and honors Global Privacy Control (GPC). Portability is limited to the requester’s data and excludes third-party or de-identified analytics unless law requires; we explain any limits.

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Glossary

• API: Interface for programmatic system-to-system exchange.
• MFA: Authentication using two or more factors.
• CSV: Tabular file format using commas.
• JSON: Structured human- and machine-readable data format.
• XML: Markup format for structured documents.
• PGP: Encryption standard for securing files or email.
• SFTP: Encrypted file transfer protocol using SSH.
• PAN: Full payment card number.
• IRP: Documented process for handling security incidents.
• ISMS: Framework for managing information security risks.
• SOC 2: Audit framework for security, availability, confidentiality, processing integrity, and privacy controls.