Smart Banner Hub LLC ("we," "us," "our") respects your privacy. This Privacy Policy explains what data we collect for our Clustrolin™ creative services, StrokeSense Academy educational platform, Clustrauth™ document authentication services (including the Clustrauth API and White-Label Studio), how we use it, and your choices.
2. Our Services
Clustrolin™ Creative Studios: Portrait Studio, Typography Studio Pro, Signature Studio, Doodle Animation Studio, StrokeSense Studio, and Video E-cards.
StrokeSense Academy: Learning management system for handwriting education with real-time stroke scoring, teacher-created courses, and student progress tracking.
Clustrauth™ Document Authentication: Quantum Auth Forge™ for consumer document verification, the Clustrauth API for programmatic access, and the White-Label Studio for branded platform deployments. Powered by our Encapsulated Multi-Vector Authentication (EMVA™) architecture.
3. Information We Process
3.1 Creative Studios (Clustrolin™)
Image Uploads: Images are converted to point cloud data and immediately discarded. We do NOT store original images.
Generated Animations: MP4 files stored for 24 hours (single purchase) or 30 days (pro packages), then permanently deleted.
Signature Studio: Generated signatures include embedded authentication data. We retain verification capability.
StrokeSense Studio: Stroke recordings are converted to animation data. Original stroke data is processed and stored as MP4 output.
Order Data: Color selections, order details, and payment confirmation stored temporarily.
3.2 StrokeSense Academy
Teacher Data:
Account Information: Name, email address, password (hashed), profile information you provide.
Course Content: Stroke recordings, lesson structures, module organization, course descriptions, and instructional materials you create.
Payout Information: Payment details required for revenue sharing (e.g., PayPal email, bank information). We may share this with payment processors to facilitate payouts.
Tax Information: Tax documentation (e.g., W-9 forms) as required by law for earnings reporting.
Account Information: Name, email address, password (hashed), profile information you provide.
Enrollment Data: Courses enrolled, enrollment dates, payment history.
Progress Data: Stroke practice attempts, scores across four dimensions (path accuracy, stroke order, direction, completion), lesson completion status, time spent practicing.
Certificates: Records of certificates earned upon course completion.
Children's Data: For students under 13, we collect only information necessary for the educational service with verifiable parental consent. See Section 11 for COPPA compliance details.
3.3 Document Authentication (Clustrauth™)
What We Do NOT Store:
Your Documents: We do NOT store, read, view, or interpret your documents. Files are hashed in-memory and never persisted to disk. No human reviews your documents.
What We Store:
Certificate Records: Certificate ID, SHA3-256 document hash, Ed25519 and ML-DSA-65 digital signatures, signing timestamp, filename, file size, MIME type, and issuing authority. Certificate records are retained permanently for verification purposes and survive account or tenant cancellation.
Chain of Custody Records: For each signing operation, we record a forensic handling record including: submitter identity (user ID or API key ID), IP address, user agent, upload method, filename, file size, document hash, processing environment (infrastructure region, storage backend), signing algorithms and key references, and millisecond-precision timestamps for each processing stage. Each record carries a SHA3-256 integrity hash for tamper detection.
Audit Trail Events: A tamper-evident log of authentication lifecycle events (document signed, certificate generated, verification attempted, certificate viewed, PDF downloaded) including actor identity, IP address, user agent, and timestamps. Events are linked in a SHA3-256 hash chain.
RFC 3161 Timestamps: For each signing, we submit the document's SHA3-256 hash to DigiCert's Timestamp Authority to obtain an independent trusted timestamp. The hash (not your document) is shared with DigiCert for this purpose. The DER-encoded timestamp token is stored with the certificate record.
Sandbox/Test Flags: Whether a certificate was created in sandbox (test) mode or production mode.
3.4 Clustrauth API
API Key Data: API key identifiers, key type (sandbox or live), creation date, and usage counters (sandbox calls used, sandbox call limits).
Subscription Data: Plan type (Developer, Business, Enterprise), billing period, signature quota, signatures used, overage counts, and pricing.
Usage Records: For each API signing operation, we record: subscription ID, API key ID, certificate ID, filename, file size, processing time, price charged, and whether the operation was a sandbox or production signing.
Rate Limit Data: Per-key and per-IP request counts stored temporarily in Redis for rate limit enforcement.
Idempotency Keys: Optional idempotency keys you provide are stored in Redis for 24 hours to prevent duplicate billing.
3.5 White-Label Studio
Tenant Data:
Account Information: Company name, contact email, tenant slug, onboarding progress.
Branding Assets: Logo images, color schemes, typography settings, and studio configuration you upload or configure.
Custom Domain Configuration: Domain names, DNS verification records, and SSL certificate status.
Audit Logs: Platform activity logs available to Scale and Enterprise tenants.
Tenant End-User Data:
When end-users authenticate documents through a white-label deployment, we process the same data described in Section 3.3 (certificate records, chain of custody, audit trail, RFC 3161 timestamps). This data is accessible to the white-label tenant who operates the platform.
End-user email addresses may be collected if the tenant's signing flow includes an end-user email field.
3.6 Platform Usage Telemetry
Feature Usage Events: We collect telemetry across all Platform services for operational purposes, including: feature name, user identifiers (for authenticated users), anonymous session identifiers (for unauthenticated visitors, tracked as ephemeral IDs), timestamps, and error status.
Payment Funnel Metrics: Aggregated data about user progression through payment flows (e.g., upload, authenticate, payment, download stages).
No Content in Telemetry: Usage telemetry does not include the content of your documents, images, course materials, or branding assets.
3.7 Other Data
E-card Data: Sender/recipient info, message text, and delivery logs stored up to 30 days.
Payment Processing: Handled by third-party processors (Stripe, PayPal). We do not store payment card details.
Analytics: Google Analytics collects aggregated usage data (pages visited, device info, general location). IP addresses are anonymized.
Technical Logs: Minimal server logs (IP, timestamp) for reliability and abuse prevention. Not linked to user profiles.
4. How We Use Your Information
Create your requested animations and provide download access
Process document authentication and enable verification, including generating the four-part EMVA™ evidence package (Certificate of Authenticity, Chain of Custody, Audit Trail, RFC 3161 Timestamp)
Operate StrokeSense Academy, including delivering courses, scoring strokes, and tracking progress
Process teacher payouts and revenue sharing
Issue certificates upon course completion
Provide teachers with analytics on their courses and students
Operate white-label deployments, including rendering tenant branding on certificates and verification pages
Enforce API rate limits and subscription quotas
Deliver webhook notifications to tenant-configured endpoints
Deliver E-cards and provide open/viewed statistics to senders
Process payments via third-party processors
Monitor platform health and improve services through usage telemetry
Prevent abuse and ensure platform stability
Comply with legal obligations (tax reporting, law enforcement requests)
5. Data Retention
Creative Studio Animations: 24 hours (single) or 30 days (pro), then permanently deleted.
Original Uploaded Images: Never stored. Discarded after processing.
Document Authentication Certificates: Retained permanently for verification purposes. Certificates survive account cancellation and tenant offboarding.
Chain of Custody and Audit Trail: Retained permanently alongside their associated certificates.
API Usage Records: Retained for billing and compliance purposes for the duration of the subscription plus 12 months.
Rate Limit Data: Temporary, stored in Redis with automatic expiry (minutes to hours).
Teacher Accounts: Account and course content retained while account is active. Upon account deletion, content removed within 30 days. Tax records retained as required by law (typically 7 years).
Student Accounts: Account and progress data retained while account is active. Upon account deletion or request, data removed within 30 days. Certificate records retained for verification.
White-Label Tenant Data: Upon subscription cancellation, a 7-day grace period applies. After the grace period, branding assets, webhook configurations, email templates, and audit logs are archived to cloud storage and removed from the active platform. Archived data is permanently deleted 90 days after archival (Enterprise tenants may negotiate extended retention). Certificate records are never deleted.
E-cards: Up to 30 days, then deleted.
Usage Telemetry: Aggregated and retained for operational analysis. Individual event records retained for up to 12 months.
Analytics: Per Google's retention policies (26 months default).
6. Data Sharing
We do not sell or rent your data. We share only what is necessary with:
Payment Processors: Stripe, PayPal (payment data only, including teacher payout information and tenant subscription billing)
DigiCert Timestamp Authority: For each Clustrauth signing operation, we submit the document's SHA3-256 hash (not the document itself) to DigiCert's RFC 3161 Timestamp Authority to obtain an independent trusted timestamp
White-Label Tenants: Tenants can access certificate records, chain of custody reports, audit trails, and usage data for documents authenticated through their platform. Tenants may also receive end-user email addresses if collected during signing
Webhook Recipients: When white-label tenants or API users configure webhook endpoints, we deliver signing and verification event data to those third-party URLs. We are not responsible for how webhook recipients handle the data they receive
Email Service: For E-card delivery, account notifications, and white-label branded email delivery
Cloud Infrastructure: Google Cloud Platform for processing, storage, and key management (Cloud KMS for signing keys, Cloud SQL for certificate storage, Cloud Storage for tenant branding assets and archived data)
Google Analytics: Aggregated usage data only
Teachers (Academy): Teachers can see enrolled student names, progress scores, and completion status for their courses. Teachers cannot see student email addresses, payment details, or data from other courses.
Legal Requirements: We may disclose information when required by law, court order, or government request.
7. Data Security
We implement industry-standard and advanced security measures:
Encrypted transmission (HTTPS/TLS)
Secure password storage (hashing)
Access controls and authentication
Automated processing without human review of uploaded content
Hybrid cryptographic signing (Ed25519 + ML-DSA-65) for document authentication
Google Cloud KMS for signing key management (keys never exported or exposed to application code)
AES-256 encryption at rest for all database records via Google Cloud SQL
Database-level INSERT-only constraints on authentication records to prevent retroactive modification
SHA3-256 integrity hashing on Chain of Custody records for tamper detection
Regular security assessments
No system is perfectly secure—you acknowledge inherent risks of using online services.
8. Cookies
We use:
Essential Cookies: For authentication and session management (Academy accounts, white-label tenant dashboards)
Analytics Cookies: Google Analytics to understand site usage
You can opt out of analytics via browser settings or the Google Analytics opt-out extension. Disabling essential cookies may affect Academy login and tenant dashboard functionality.
9. Your Rights
Request deletion of animation data before automatic purge
Request deletion of your Academy account and associated data
Request a copy of your data (progress scores, account information, usage records)
Opt out of Google Analytics tracking
Withdraw consent for data processing where applicable
Exercise rights under CCPA, OCPA, GDPR, or other applicable privacy laws
For Teacher Data: You may request export of your course content and student analytics. Note that tax records may be retained as legally required.
For Student Data: You may request export or deletion of your progress data and account information.
For API Users: You may request export of your usage records and subscription data. Certificate records are retained permanently for verification purposes and cannot be deleted, as they may be relied upon by document holders for ongoing verification.
For White-Label Tenants: You may request export of your branding configuration, webhook logs, and usage data. Upon offboarding, your data follows the lifecycle described in Section 5. Certificate records created under your deployment are retained permanently and cannot be deleted.
For White-Label End-Users: If you authenticated a document through a white-label platform, your certificate and chain of custody data is accessible to both Smart Banner Hub LLC and the white-label tenant. To exercise data rights, contact either the tenant or Smart Banner Hub directly.
For Children's Data: Parents or guardians may review, request deletion of, or refuse further collection of their child's personal information at any time.
The following third parties process data as part of our services:
Google Cloud Platform: Infrastructure provider. Processes and stores data in the United States (us-central1 region). Subject to Google Cloud's data processing terms.
DigiCert: RFC 3161 Timestamp Authority. Receives SHA3-256 document hashes (not documents) to issue trusted timestamps. Subject to DigiCert's privacy policy.
Stripe: Payment processing for consumer purchases, API subscriptions, and white-label tenant billing. Subject to Stripe's privacy policy.
PayPal: Alternative payment processing. Subject to PayPal's privacy policy.
Email Providers (SendGrid/Mailgun/AWS SES): Transactional email delivery for account notifications, E-cards, and white-label branded emails. Subject to the respective provider's privacy policy.
Google Analytics: Website usage analytics. Subject to Google's privacy policy.
Cloudflare: Bot protection (Turnstile) and content delivery. Subject to Cloudflare's privacy policy.
11. Children's Privacy (COPPA Compliance)
StrokeSense Academy may be used by children under 13 with verifiable parental consent. We comply with the Children's Online Privacy Protection Act (COPPA).
For children under 13:
We require verifiable parental consent before collecting personal information
We collect only information necessary for the educational service (name, progress data)
We do not condition participation on disclosure of more information than necessary
Parents may review their child's information, request deletion, or refuse further collection at any time
We do not share children's personal information with third parties except as necessary to provide the service
Our other services (Creative Studios, Document Authentication, Clustrauth API, White-Label Studio) are not intended for children under 13. We do not knowingly collect information from children under 13 for these services.
Contact us immediately at [email protected] if you believe we have inadvertently collected information from a child without proper consent.
12. International Users
Our services are provided from the United States. By using our services from outside the U.S., you consent to data transfer and processing in the United States in accordance with U.S. law.
For users in the European Economic Area (EEA) or other jurisdictions with data protection laws, your use of our services constitutes consent to processing in the United States. You may have additional rights under local law—contact us to exercise them.
Note for White-Label End-Users: If you use a white-label platform operated by a tenant outside the United States, your document authentication data is still processed and stored in the United States by Smart Banner Hub LLC.
13. California Privacy Rights (CCPA)
California residents have the right to:
Know what personal information we collect and how it's used
Request deletion of personal information (subject to exceptions for certificate records retained for verification)
Opt out of the sale of personal information (we do not sell personal information)
We may update this policy periodically. The "Last Updated" date will change. Continued use constitutes acceptance. We will provide prominent notice for material changes, including email notification for registered Academy users and white-label tenants.