Privacy Policy
This Privacy Policy explains how UpDoc, Inc. ("UpDoc," "we," "us") handles personal data in connection with the Hiyer product ("Hiyer" or the "Service"). It applies to owners, administrators, and viewers who sign in to the Service, and to survey respondents who submit responses through a single-use access code.
Hiyer is a workforce-intelligence product: customer organizations run structurally anonymous employee surveys, and Hiyer aggregates the responses and compares them against UpDoc's industry benchmark dataset. This policy is specific to Hiyer. Other UpDoc products have their own notices.
1. Who we are
The data controller is UpDoc, Inc., a Maryland corporation, with its principal place of business at 9200 Old Annapolis Road, Columbia, MD 21045.
Questions about this policy, data subject requests, or privacy complaints can be sent to gene@updocmedia.com or by mail to the address above, attention: Privacy.
2. What is and is not personal data
Hiyer distinguishes between two categories of data, and that distinction is enforced at the database schema, not only in our application code.
Personal data we do collect
We collect and process the following categories of personal data:
- Account data for owners, administrators, and viewers: email address, bcrypt-hashed password (if set), sign-in timestamps, sign-in provider (magic link, Google, Microsoft), and the email domain derived from the address.
- Organization data: the organization's legal or trade name, domain, Stripe customer identifier, Stripe subscription identifier, and plan tier.
- Team data: membership role (owner, admin, viewer), invited-at and accepted-at timestamps, and the email addresses we sent invites to until the invite is accepted.
- Billing data: we never see your card number. Stripe is the processor for payment card data; we hold only a customer identifier that points at Stripe's vault.
- Support and audit data: every state-changing action on your organization is recorded in an append-only audit log along with the actor's user identifier, action name, and a small metadata payload. We use it for support, security, and SOC 2 evidence. The log cannot be rewritten by any role, including our own service role.
Data that is not personal data, by schema design
Survey response data is not personal data. The responses table in our database has no user_id column and never will. It stores the cycle identifier, cohort identifier, question identifier, a numeric score from zero to ten, a salted SHA-256 token that links together the answers within one sitting but is not reversible, and a submission timestamp bucketed to 15-minute windows to prevent correlation attacks. We do not store your name, email, IP address, device fingerprint, or any other identifier in this table.
Because Hiyer cannot link a response to an identified or identifiable person, we do not treat response data as "personal data" under the GDPR, or "personal information" under the CCPA, VCDPA, CPA, CTDPA, UCPA, or other US state laws. A customer organization running Hiyer may still have obligations under those laws depending on how they distribute access codes; see the Data Processing Addendum for details.
3. How we use personal data
We process personal data for the following purposes:
- To operate the Service: authenticate you, keep you signed in, enforce tenant isolation, show you your organization's data.
- To bill you: deliver invoices, handle subscription events, send dunning email on failed payments.
- To communicate with you: sign-in links, welcome email, survey invitations on your behalf, at-risk alert notifications, cycle summary reports.
- To generate AI-narrated insight text for customers on Signal and Enterprise plans. The data sent to our AI subprocessor is aggregate scores, not raw responses. See Section 6.
- To keep Hiyer secure: rate-limit abuse, detect suspicious sign-ins, record an audit trail for SOC 2 evidence.
- To meet our legal obligations: tax, anti-fraud, law-enforcement requests that are validly served.
4. Legal bases under the GDPR
For individuals in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following Article 6 bases:
- Contract. To provide Hiyer to you and the organization you belong to.
- Legitimate interests. Operating the Service securely, preventing fraud, improving the Service in ways that do not materially change respondent anonymity.
- Legal obligation. Billing records, audit trail retention, responding to valid legal process.
- Consent. For any optional marketing email. Account and Service messages are not marketing and are not consent-based.
5. Who sees your data
Your data is seen by the smallest set of parties we can practically involve:
- Other members of your organization at the role their owner granted. Role-based access is enforced at the database layer through Postgres row-level security, not in application code.
- UpDoc staff, and only in narrow circumstances: responding to a support request you raised, investigating a security incident, or providing onboarding with your consent. Access is audited.
- Subprocessors we engage to run the Service. Current list and each one's role, region, and retention at hiyer.updocmedia.com/legal/subprocessors.
- Authorities that serve us with a valid subpoena, court order, or equivalent legal process. We do not volunteer customer data to law enforcement without process, except when we are required to by law.
6. International data transfers
Hiyer is hosted in the United States. The Supabase Postgres instance and all subprocessors we currently engage are US-based. If you are in the European Economic Area, the United Kingdom, or Switzerland, your personal data will be transferred to and processed in the United States. Where required, we execute Standard Contractual Clauses with subprocessors and rely on the UK Addendum / Swiss IDTA equivalents.
We do not currently offer EU data residency. If that changes, we will update this policy and the subprocessor page.
7. Retention
Personal data is retained while your organization's subscription is active and for a reasonable period after termination for dispute resolution, tax and compliance, and backup rotation. Specifically:
- Account records are retained while the subscription is active. When you close your account, we delete or de-identify personal data within 90 days, except where we must keep it for billing records (7 years) or audit evidence (append-only and retained while the audit_log table exists).
- Email delivery logs at Postmark are retained for 45 days.
- Hosting request logs at Vercel are retained for 30 days.
- Benchmark data derived from aggregated, de-identified responses is retained indefinitely. It does not identify any person.
8. Your rights
Depending on where you live, you may have rights to access, correct, delete, export, restrict, or object to our processing of your personal data. You may also have a right to not be discriminated against for exercising those rights.
To exercise a right, email gene@updocmedia.com from the account associated with the request, or by mail to the Columbia, MD address above. We will verify your identity before acting on a request. We respond within 45 days and will tell you if we need more time.
EU, UK, and Swiss residents may also lodge a complaint with their local supervisory authority.
9. Security
Security controls built into Hiyer, enforced at the schema layer, are documented at hiyer.updocmedia.com/legal/security. In brief: structural anonymity on the responses table, Postgres row-level security for tenant isolation, an append-only audit log, bcrypt-hashed PINs with HMAC lookup indexes, encryption in transit via TLS 1.2+, and encryption at rest via Supabase's platform encryption.
SOC 2 Type I is in progress. Until the attestation completes, we will not claim SOC 2 certification.
10. Children
Hiyer is a workforce product sold to businesses. It is not intended for individuals under 18 and we do not knowingly collect data from children. If you believe a child has provided us personal data, contact gene@updocmedia.com and we will delete it.
11. HIPAA
Hiyer is not a HIPAA covered entity or business associate. The Service is not designed to collect Protected Health Information, and by the structural anonymity of the response schema (Section 2) survey responses cannot identify an individual. We do not sign Business Associate Agreements for Hiyer, and customers must not use the Service to transmit PHI.
12. California, Colorado, Connecticut, Utah, Virginia
If you are a resident of a US state with a comprehensive privacy law, you have substantially the same rights described in Section 8. We do not sell personal data and we do not process personal data for targeted advertising. Survey responses fall outside the definition of personal information under each of these laws (see Section 2).
13. Cookies
Hiyer uses strictly necessary cookies only: an authentication cookie so you stay signed in, and an organization-selection cookie for users who belong to more than one organization. We do not use advertising or analytics cookies on the authenticated product. The marketing site uses the same strictly-necessary set.
14. Changes to this policy
We will update this policy when the Service or our data practices change materially. The last-updated date at the top reflects the most recent change. For material changes we will email active owners and administrators at least 14 days before the change takes effect.
15. Contact
Privacy and data-subject matters: gene@updocmedia.com
Mail: UpDoc, Inc., Attn: Privacy, 9200 Old Annapolis Rd, Columbia MD 21045, USA.