Trogon Code LLC Privacy Policy

Version and effective date: 2026-08-21-r1

Status: PUBLISHED

This Policy explains how Trogon Code LLC (“Trogon Code,” “we”) processes information about visitors, prospects, business clients, and authorized users on trogoncode.com, SIMA, and portal.trogoncode.com (the “Services”).

1. Roles and scope

Trogon Code determines purposes and means for prospect, account, contract, security, support, and payment administration and acts as controller. When it processes project data on a client’s documented instructions, it acts as processor and the Data Processing Addendum incorporated into the Offer applies.

The Services are for businesses and authorized adults and are not directed to children under 18. We do not knowingly collect children’s data.

2. Information, sources, and purposes

We may process name, email, company, role, and authentication identifiers; inquiries, language, proposals, acceptances, approvals, support, and communications; project business information, content, and files; amounts, currency, tax address, and Stripe transaction identifiers/status, but not PAN or CVV; IP, browser, device, routes, timestamps, and security/audit events; and public commercial evidence with provenance used to prepare demos subject to verification.

We use it to answer inquiries; authenticate and authorize; prepare, contract, and perform services; process and reconcile payments; meet tax and legal duties; secure the Services; handle rights, support, and disputes; preserve evidence; and compatibly improve the Services. We do not sell personal data, use it for targeted advertising, or make legally significant decisions through profiling.

3. Cookies and external links

We use the functional tc-locale cookie for up to one year to remember language. Authentication providers may use strictly necessary cookies to sign in and protect sessions. We use no advertising cookies and no first-party visitor analytics platform.

A WhatsApp link opens Meta’s service and transmits technical data inherent in external navigation. Its policies apply when visited. We do not embed a Meta pixel.

4. Providers and disclosures

We share the minimum needed with Hostinger (hosting, API, protected files, email, backups, and domain), MongoDB Atlas (multi-tenant operational database), Clerk (authentication), Stripe (checkout, payment, tax, and billing when activated), GitHub (private repository, CI, and deployment without raw client data), and Vercel (DNS and temporary rollback; no analytics or ordinary commercial hosting).

We may also disclose to confidential advisers, under valid legal process, to protect rights or safety, or in a corporate transaction with equivalent protection. We do not authorize providers to use data for their own advertising. Providers may process data outside Texas or the United States under contracts and lawful mechanisms; we assess access, purpose, minimization, and terms before enabling them.

5. Retention

Unless a dispute, security, audit, or legal hold applies, our maximums are: prospects without contract, 12 months; inactive identity and membership, immediate deactivation and removal of unnecessary links after 90 days; project, contract, Offer, and acceptance, 4 years; payment, tax, refund, and dispute records, 7 years; technical, audit, and security logs, 12 months; support and communications, 24 months; protected files, active relationship plus 90 days; logical and external backups, 7 and up to 35 days; privacy requests and appeals, 4 years.

At expiry we delete, anonymize, or isolate. Deleted primary data may remain temporarily in a backup until expiry; after restoration we reapply completed deletions. Legally required records remain solely for that purpose.

6. Rights and requests

You may request confirmation, access, correction, deletion, and a portable copy, and opt out of sale, targeted advertising, or profiling; we currently conduct none of those activities. You may withdraw consent where applicable.

Email privacy@trogoncode.com. We do not require an account for a relationship begun online, but will reasonably verify identity and authority without excessive information. We respond within 45 days and may extend once by 45 days with notice. If denied, appeal by replying to the same email; we respond within 60 days. We may retain minimal evidence. Rights depend on law and exceptions; we do not discriminate for exercising them.

7. Security and incidents

We apply tenant and role access, authentication, encryption in transit, protected files, separated secrets, mutation logs, minimization, backups, and recovery tests. No system is infallible. If an incident requires notice, we notify affected people and authorities within applicable deadlines.

8. Changes and contact

We publish a new version before a material change and obtain renewed acceptance where appropriate. A new version does not retroactively alter an accepted contract.

Controller: Trogon Code LLC. Privacy: privacy@trogoncode.com. Legal notices: legal@trogoncode.com. The current legal address will appear in Offers and communications where legally required.