Veracly is a B2B SaaS that scans publicly accessible web pages for compliance issues. We process limited personal data — names, work emails, billing addresses, and audit logs — to deliver the service. We do not sell your data, and we do not share it with advertisers. We process personal data in five distinct activities described below.
- 01
Who we are
RR Sols Pty Ltd (ABN 56 672 722 486, ACN 672 722 486), trading as Veracly. Registered office: 136 Arthur Allen Drive, Bardia, NSW 2565, Australia. Director and authorized representative: Purushotham Reddy Pamuluru.
- 02
EU and UK GDPR representative
Because RR Sols Pty Ltd is established outside the EU and the UK, we have appointed representatives under Article 27 GDPR and Article 27 UK GDPR. EU residents may contact our EU representative: Prighter EU Rep GmbH, Schellinggasse 3/10, 1010 Vienna, Austria. UK residents may contact our UK representative: Prighter Ltd, 20 Mortlake Mortlake High Street, London, SW14 8JN, United Kingdom. To exercise your data subject rights or to lodge a complaint, you can submit a request through Prighter's portal at https://app.prighter.com/portal/11399422438. Please reference ID-11399422438 in any correspondence.
- 03
How we use personal data — five activities
We process personal data in five distinct activities, each with its own legal basis, data categories, and retention window. Sections 4–8 below are the Art. 13/14 GDPR records for each activity. Cross-cutting matters — automated processing, international transfers, your rights, and security — follow in sections 9–13.
- 04
Activity 1 — veracly.app visitors
Data processed: daily-rotated hashed IP address (not stored raw), browser metadata, page views, referrer, and contact-form submissions (name, email, message — only if you use the form). Purpose: serve the site, respond to enquiries, and monitor performance. Legal basis: Art. 6(1)(f) legitimate interest (site operation and cookieless aggregate analytics). We use Vercel Web Analytics and Speed Insights — no cookies, no device fingerprinting, no consent required. Contact-form data retained 24 months then deleted; performance logs rotated within 30 days. Recipients: Vercel, Inc. (hosting and analytics). Complaint right: your national supervisory authority or the Austrian DSB (competent for our EU representative).
- 05
Activity 2 — free-scan requesters
Data processed: email address you enter at scan time, scanned domain, scan timestamp, IP address at request time, and scan findings (public page content only — no account is created). Purpose: run the requested scan, enforce the one-free-scan-per-email-per-7-days rate limit, detect and prevent abuse. Legal basis: Art. 6(1)(b) (steps at your request before a contract) for the scan itself; Art. 6(1)(f) legitimate interest for rate-limiting and abuse prevention. Retained 30 days then auto-deleted by a scheduled job. Recipients: Vercel (hosting), Clerk (authentication infrastructure), AWS EU-West-1 Frankfurt (worker compute). No marketing use; no sharing for advertising purposes.
- 06
Activity 3 — outbound prospects (Art. 14 disclosure)
If you received a cold email from puru@veracly.app: your contact email was collected from your website or a publicly accessible business directory. Data processed: business email address, business name, publicly visible domain, one or more compliance findings from a public crawl. Legal basis: Art. 6(1)(f) legitimate interest — sending a single informational email about a technical compliance finding on your publicly accessible site. Balancing test on file: the finding is self-verifiable in DevTools; you are contacted as a business operator, not as a private individual; processing is limited to publicly available contact data and findings. Right to object (Art. 21): reply with any refusal wording, or email privacy@veracly.app — we will suppress your address immediately and permanently and delete all associated data. Retained until you object or 6 months from collection, whichever is earlier. No profiling; no automated decision-making with legal or significant effects.
- 07
Activity 4 — account holders and paid customers
Data processed: name, work email, organisation name, billing address, VAT ID, subscription tier, scan history, PDF reports, invoices, and payment-method metadata (Stripe handles card data — we never store raw card numbers). Purpose: deliver the scanning service, bill you, send service notifications, comply with tax obligations. Legal basis: Art. 6(1)(b) contract performance; Art. 6(1)(c) legal obligation (tax records, Australian Corporations Act 2001). Retention: account data for the life of the account (you can delete at /account/profile); scan results 12 months after each scan; billing records 7 years (Australian tax-record obligation). Recipients: Stripe, Inc. (billing, US — SCCs in place); Clerk, Inc. (authentication, US — SCCs); AWS EMEA SARL (hosting, Frankfurt for EU customers — DPA + SCCs); Revenue Commissioners, Ireland (VAT OSS reporting — name, country, transaction amount only, no scan content). Complaint right: your national DPA or the Austrian DSB.
- 08
Activity 5 — subprocessor list
Current subprocessors: Vercel, Inc. (web hosting and analytics, US — DPA, SCCs); Clerk, Inc. (authentication, US — DPA, SCCs); Amazon Web Services EMEA SARL (compute and storage, EU-West-1 Frankfurt for EU customers and US-East-1 Virginia for US customers — AWS DPA, SCCs); Stripe, Inc. (payment processing, US — DPA, SCCs); Anthropic PBC (AI text generation in scan reports, US — DPA, SCCs; we send only technical violation data and a short HTML snippet — no account or billing data); Revenue Commissioners, Ireland (OSS VAT filing — name, country, and transaction amount only). Full list with effective dates is published at veracly.app/subprocessors. We give 14 days' notice before adding a new subprocessor; you may object within 10 days per the DPA terms.
- 09
Automated processing and AI
Some text in your compliance report — plain-English explanations of violations, the executive summary, suggested remediations, and translations into the languages we support — is generated by an AI model run by Anthropic (Claude) acting as a sub-processor on our instructions. We send the AI the technical violation data and a short HTML snippet of the offending element; we do not send your organisation name, contact details, or any other personal data we hold about you. AI-generated text is reviewed against deterministic fallback copy, and if the AI is unavailable we fall back to that copy automatically. We are not making decisions that produce legal or similarly significant effects about you (GDPR Art 22), and you can ask for human review of any AI-written passage by emailing privacy@veracly.app.
- 10
How long we keep it
We keep personal data only as long as it's needed for the purpose it was collected. Scan results — including findings, the underlying raw data, jurisdiction verdicts, and generated PDF reports — are deleted 12 months after the scan completed. Free-scan PDF reports and their cryptographic verification record are kept for 60 days (2 months) from issuance, then removed. AI-usage records (model name, token counts, cost) are kept for 24 months so we can answer billing or audit questions. Free-scan history (used to enforce the one-free-scan-per-email-per-7-days limit) is kept for 30 days. Public contact-form submissions are kept for 24 months for sales follow-up, then deleted. Account data — your profile, your organization, and the link to your authentication provider — is kept for the life of the account; you can delete it yourself any time from /account/profile or by emailing privacy@veracly.app. Billing records held by Stripe and our accounting software are retained for 7 years to meet Australian tax-record obligations on RR Sols Pty Ltd. A daily automated job enforces these windows.
- 11
Your rights (Art. 15–22 GDPR)
Access (Art. 15): obtain a copy of personal data we hold about you. Rectification (Art. 16): correct inaccurate data. Erasure (Art. 17): delete your data where no legal obligation requires retention — self-serve at /account/profile for account data. Restriction (Art. 18): pause processing while a dispute is resolved. Portability (Art. 20): receive account data in a machine-readable format. Object (Art. 21): object to processing on legitimate-interest grounds; we will cease unless we demonstrate compelling overriding grounds. Withdraw consent (Art. 7(3)): where consent is the legal basis, withdraw at any time without affecting prior processing. No solely automated decisions (Art. 22): we do not make decisions about you based solely on automated processing with legal or similarly significant effects. Lodge a complaint: contact your national supervisory authority, or for EU subjects the Austrian DSB (Datenschutzbehörde) as the authority competent for our EU representative Prighter EU Rep GmbH. To exercise any right, email privacy@veracly.app or use the self-service tools at /account. We respond within one month, extendable by two months for complex requests.
- 12
International transfers and safeguards
EU customer data is hosted in AWS EU-West-1 Frankfurt. Australia does not have an EU adequacy decision: any transfer of EU personal data to RR Sols Pty Ltd's systems in Australia (for engineering access, audit, and finance) is governed by Standard Contractual Clauses (EU Commission Decision 2021/914, Module 3). Transfers from the UK rely on the UK International Data Transfer Addendum (IDTA) to the EU SCCs. US-based subprocessors (Vercel, Clerk, Stripe, Anthropic) are covered by controller-to-processor SCCs under 2021/914 Module 2. Transfer impact assessments are conducted before engaging each non-adequate-country subprocessor. Copies of applicable SCCs and IDTAs are available on request from legal@veracly.app. For EU VAT compliance, RR Sols Pty Ltd is registered under the Non-Union OSS scheme in Ireland (EU372098920); transaction records required for VAT returns are reported to the Irish Revenue Commissioners as the OSS Member State of Identification.
- 13
How we protect data
Encryption in transit and at rest, role-based access control, audit logging, and routine penetration testing. SOC 2 Type II is in progress.
- 14
Changes to this policy
Material changes will be announced by email at least 30 days before they take effect. Non-material changes will be reflected in the Last updated date above.