Gear Handoff — Privacy Policy

Effective date: November 3, 2026 Last updated: November 3, 2026

This Privacy Policy explains how Free The Oppressed Studios LLC ("FTO," "we," "us") collects, uses, and shares personal information through Gear Handoff (gearhandoff.app and the Gear Handoff iOS and Android apps) (the "Service").

United States business customers. The Service is offered only to customers established in the United States, for business use. Authorized members of a U.S.-established customer may use the Service while traveling outside the United States. This Policy is written for U.S. law, including the California Consumer Privacy Act as amended by the CPRA (CCPA) and other U.S. state privacy laws.

1. Data We Handle and How It Is Protected

Account Data: name, email address, phone number, Org name, role, login credentials (passwords are hashed by our authentication provider), billing details, and similar.

Org and Asset Data: gear and asset records, handoff and assignment history, incident reports, and other content your Org enters. This includes work-related records about members (such as who held which gear and when), photos (condition and incident photos), and precise geolocation (GPS coordinates recorded with condition photos). Precise geolocation is sensitive personal information under some state laws, even though we encrypt it.

Roles. For Org and Asset Data, your Org generally decides why the data is processed, and we process it on the Org's instructions as its service provider. We act on our own behalf for account administration, billing, and specified security purposes. A data processing agreement (DPA) is available on request.

Protection. Data is encrypted in transit (TLS) and at rest by our infrastructure providers. In addition, each organization has its own data encryption key, wrapped by AWS Key Management Service (KMS), so our database does not hold a usable key. The following are encrypted with the organization's key when created: condition, handoff, and reservation notes; incident descriptions, locations, and resolution notes; status report notes; photo waiver reasons; GPS coordinates on condition photos; free-text fields in internal event and notification records; and condition photo files and billing-proof files, which are encrypted before upload. Asset serial numbers are also encrypted, with a keyed (HMAC) blind index so exact-match lookups still work. Some data stays readable so we can run the service: organization ID and name, memberships, member email addresses, timestamps, Stripe identifiers, asset tags, and organization logos. Organization logos are stored in a public storage bucket and are publicly accessible. Within the app, access to an organization's data is restricted to its authorized members, who must use multi-factor authentication. Integration credentials (Slack and webhook secrets) are additionally encrypted at the application layer, under a separate application key rather than the per-organization keys. The running service, and a small number of authorized FTO personnel, can decrypt data when needed to operate, secure, support, and bill the service; that access is limited and logged, and decryption of billing-proof files is recorded in our admin access log. Access to the AWS KMS keys is limited to FTO's owner and the app's narrowly scoped service credential. The service decrypts content automatically to send digests and, if an organization connects Slack, to post to Slack. Slack receives decrypted notes and photo links, and Slack's own terms and privacy policy govern that content once it is delivered.

2. Information We Collect

You provide:

• Account Data as described above.
• Billing data: payment details are collected and processed by Stripe on our website. We do not store full card numbers, and there are no in-app purchases in the iOS or Android apps. We receive limited billing information from Stripe, such as name, billing address, the last four digits of the card, and subscription status.
• Documentation you submit to verify eligibility for the veteran-owned or nonprofit discount (a redacted DD-214, a SAM.gov, SBA, or IRS record, or a redacted VA letter). We use it only to verify eligibility, once per business, and delete it immediately after verification. We keep only the entity name, our decision, the proof source and date, and the discount dates.
• Support communications sent through in-app help tickets or to support@fto-studios.com.
• Org and Asset Data as described in Section 1, including photos attached to incident and condition reports. GPS coordinates recorded with condition photos are encrypted when created, and photo files, including any location metadata embedded in them, are encrypted before upload (see Section 1).

Collected automatically:

• Device and log data: IP address, browser or device type, timestamps, and error logs.
• Cookies or local storage used for authentication and sessions, plus a first-party activity cookie (gh_active) that stores only a timestamp, used to limit how often activity is recorded. We use no third-party analytics or advertising trackers, and no email open or click tracking.

The Service is meant for users aged 18 and older. We do not knowingly collect personal information from children.

Usage and Activity Data. We collect usage and activity data: each user's last-active time, one daily-activity record per user per day they use the Service, and a count of security-notice emails our email provider accepted or rejected. The email log records only the type of notice, whether the send succeeded, and the time. It does not record content or recipients. We use this data to operate, secure, and improve the Service. We report it internally only in aggregate. We never sell it or use it for advertising, and we use no third-party analytics or advertising trackers. Raw per-person daily-activity records and email logs are kept for 90 days, then reduced to daily aggregate totals with no person or organization identifier. The last-active timestamp is a single value per user that is overwritten as you use the Service. Person-level activity data is deleted when the user's account is deleted. When an Org is deleted or purged, it is deleted for members who don't belong to any other Org.

3. How We Use Account Data

We use Account Data, and Org and Asset Data where needed, to provide and operate the Service; manage accounts, Orgs, and subscriptions; process payments through Stripe; send transactional notices (trial reminders and expiry, payment-failure and lockout notices, read-only and deletion warnings, renewal notices, receipts), which come from no-reply@gearhandoff.app, an address that is not monitored; provide support; secure the Service and prevent abuse; and comply with law.

4. No Selling or Sharing

FTO does not sell your personal information (Account Data or Org and Asset Data), does not "share" it for cross-context behavioral advertising, and does not disclose it to third parties for their own purposes. We disclose Account Data only:

• to service providers needed to run the Service, under contracts that restrict their use of the data: Vercel (hosting; app servers in the Washington, D.C. / Northern Virginia area), Supabase (database, file storage, authentication; hosted on AWS in Ohio, us-east-2), Stripe (payments), Resend (security and account emails), Inngest (scheduled background jobs, such as billing reconciliation and reminders, which mostly handle job metadata), and Amazon Web Services (AWS) (key management through AWS KMS);
• to Slack, only if an Org chooses to connect its Slack integration, in which case the content described in Section 1 is sent to the Org's Slack workspace;
• to comply with law or valid legal process, or to protect rights and safety, only as required or permitted by applicable law. For legal process, we verify the requesting authority, scope, and legal basis, seek to narrow overbroad requests, and notify the affected customer when lawful and practicable; and
• to a successor in a merger, acquisition, or asset sale, subject to this Policy.

Inside your Org, authorized users can see Org data according to Org permissions.

5. Where Data Is Stored

Our primary database is hosted in the United States (Supabase on AWS, Ohio), and our application servers are in the United States (Vercel, Washington, D.C. / Northern Virginia area). Our service providers listed in Section 4 may process data as described in this Policy.

6. Retention

See our Data Retention Policy. In short: unpaid Orgs are locked 72 hours (3 days) after a failed payment and deleted 30 days after the first failed payment, with their encryption key destroyed, unless paid. Canceled Orgs are read-only for 30 days after the paid period ends, then purged. Expired trials are not locked; they are read-only for 30 days from the expiry date, then purged with their encryption key destroyed, with a warning email 7 days before. An Owner's Org deletion removes the Org's data from live systems immediately. Limited billing and tax records are kept as required by law. Disaster-recovery database backups are kept for 7 days, so deleted data may remain in backups for up to 7 days before it ages out.

7. Deleting Your Account

You can delete your own account in the app: open Account, then choose Delete my account. You will need a recent authenticator code and must re-type your email address to confirm. We send a confirmation email. If you can't sign in, including if you are locked out, email support@fto-studios.com to ask us to delete your account. We complete account deletion within 30 days of the request. Instructions are also at gearhandoff.app/account-deletion.

Deleting your account removes your login and the account information described in Section 1. Your Org may retain limited records of gear assignments and handoffs you took part in, where permitted by applicable law and its retention requirements; these show you as "Deleted user". A "Deleted user" label does not by itself make a record anonymous. Identifiable records remain subject to applicable privacy rights and lawful retention exceptions. We also keep billing, security, and legal-hold records as described in the Data Retention Policy. We will explain any denial or partial denial of a covered deletion request. If you are the only Owner of an Org, you must transfer ownership or delete the Org before you can delete your account. Deleting your account after transferring ownership does not cancel the new Owner's subscription.

Three different outcomes:

• Account deletion (you delete your own account): your login and account information are deleted; Org history may be retained as described above.
• Member removal (an Owner removes you from an Org): your access to that Org ends. Your account is not deleted, and you keep access to any other Org you belong to.
• Org deletion (an Owner deletes the Org): the Org's data is removed from our live systems immediately (see the Data Retention Policy). It cannot be undone.

Residual copies in our restricted database backups expire within 7 days.

8. Security

We use reasonable administrative, technical, and physical safeguards, including per-organization encryption as described in Section 1. No system is perfectly secure. We do not promise compliance with FedRAMP, CMMC, NIST SP 800-171, or similar government security programs. The Service must not be used for classified information, Controlled Unclassified Information (CUI), covered defense information, export-controlled technical data, criminal justice information (CJI), or regulated health data, unless a signed addendum expressly permits it (see the Terms).

9. Your U.S. State Privacy Rights

Residents of California and other states with comprehensive privacy laws (for example Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and others) may have the right to:

• Know or access the personal information we hold about you;
• Correct inaccurate information;
• Delete your information;
• Get a portable copy of your information;
• Opt out of sale, sharing, targeted advertising, or profiling (we do none of these);
• Limit the use of sensitive personal information (we use it only for permitted purposes);
• Appeal a denied request, where state law provides for appeals;
• Exercise these rights without discrimination.

California notice (CCPA/CPRA). In the past 12 months we collected these categories: identifiers (name, email, phone, IP address), commercial information (subscription and billing history), internet and network activity (logs), and account login credentials (a category of sensitive personal information, used only to authenticate you). We collected them for the purposes in Section 3 and disclosed them only to the service providers in Section 4. We have not sold or shared personal information. You may use an authorized agent.

How to exercise your rights: email Legal@fto-studios.com. We will verify your identity and respond within the time the law requires (generally 45 days, which can be extended where permitted). We handle requests about personal information for which we determine the purposes of processing (such as account and billing data). Where we process information on an Org's instructions (such as a member's records entered by their Org), we promptly route the request to that Org and assist it as required by applicable law and our processing agreement. A suspended, locked, or unpaid subscription does not prevent you from submitting a privacy request. Appeals: if we deny your request, you may appeal by emailing Legal@fto-studios.com with "Appeal" in the subject line. Where state law provides, we will respond in writing and tell you how to contact your state attorney general if the appeal is denied.

10. Changes

We will post updates here and notify Owners of material changes by email or in the app at least 30 days before they take effect.

Marketing email. We do not currently send marketing email. If we do in the future, every marketing email will include an unsubscribe link and we will honor opt-outs. Service and account emails (such as billing, security, and deletion notices) are not marketing.

11. Contact

Free The Oppressed Studios LLC (FTO Studios) 10205 US Highway 15 501 Unit 26-289 Southern Pines, NC 28387

Privacy and legal: Legal@fto-studios.com Support: in-app help tickets (preferred) or support@fto-studios.com

Emails from no-reply@gearhandoff.app are not monitored; please don't reply to them.