Privacy policy

DRAFT, not legal advice. This is a working draft for attorney review and has not been adopted. Items marked TODO need decisions before launch.

Last updated: TODO · Company: [LEGAL NAME] TODO, [ADDRESS] TODO · Contact: [EMAIL] TODO

1. Who we are and whose data this is

Paperless Pool provides pool check-in and pool record-keeping software to homeowners associations (“HOAs”) and the pool management companies they hire (together, “Customers”). Customers decide what their pools collect and own that data. We process it on their behalf to run the service. Questions about a specific pool’s records should go to that HOA or its pool management company. TODO: confirm the controller/processor roles with an attorney.

2. What we collect

Resident check-in: the pool, date and time, home address, the name of the adult checking in (as typed), the number of children, the number of guests, and confirmation that the pool rules were accepted.
Lifeguard and staff records: names or initials, certification type and expiration date, and entries they make (water tests, incidents, closures).
Incident notes: a short description and the action taken. Staff are told not to enter children’s names and to describe people by approximate age.
Customer and website contacts: name, company, email, phone, and messages you send us, for example through the demo request form.
Basic technical data: standard server and security logs (such as IP address and browser type) kept by our hosting provider. TODO: list the provider and retention.

3. What we do not collect

Children’s names. Kids are a count only.
Precise location / GPS. A daily code posted at the gate is used instead.
Photos, face scans, fingerprints, or other biometric identifiers.
Payment card data at check-in.

4. How it is used

To run check-in and headcounts, keep pool logs, show dashboards and reports to the Customer, provide support, and secure the service. We do not sell personal data and do not use it for advertising.

5. Stored on your phone

To speed up the next visit, the check-in page may remember your address and name in your browser’s local storage on your own device. You can clear it with “Not you?” or by clearing site data.

6. Sharing

With the HOA and its pool management company for that pool; with service providers that host and operate the service under contract (TODO: list, e.g. hosting provider); and when required by law. Customers may give pool logs to health inspectors.

7. Retention

Customers set retention. Texas rules require certain pool logs and lifeguard records to be kept at least 3 years. TODO: set a default for resident check-in records (for example, end of season plus a fixed period) and deletion on contract end.

8. Security

Encrypted connections (HTTPS), role-based access for staff, and limited collection by design. TODO: describe backups, access controls, and the breach-response plan, including Texas notice duties (Tex. Bus. & Com. Code §521.053).

9. Children

The service is used by adults. It is not directed to children, and we do not knowingly collect personal information from children under 13. Children are recorded only as a number. TODO: attorney to confirm the COPPA analysis.

10. Your choices

Ask your HOA or pool management company to access, correct, or delete check-in records about you, or contact us and we’ll route the request. TODO: confirm the obligations under applicable state privacy laws.

11. Changes

We’ll post updates here with a new date.