Privacy notice

Privacy notice

This notice explains what information Varuna collects, why, who it is shared with, how long it is kept, and the choices you have. The document reader page, shown with this notice, is part of it.

Who we are

Varuna is operated by John Barlow, an individual doing business as Varuna, 2677 Stone Lane, Placerville, CA 95667, telephone (801) 824-4232. Questions or requests about your information go to john@stubbornfact.com.

What we collect, and why

We ask for the fields the product actually uses and no others:

• who you are: your name, any names you have been known by, and your email address;
• the licenses, certifications, degrees and continuing education you hold or are working toward, and the answers you give in the setup wizard;
• the documents you choose to upload, and the details read from them or typed by you;
• if you run courses: your courses, the people enrolled, their progress and evaluations, and the certificates you issue;
• if you supervise, belong to a practice or connect with others: what you choose to share or send;
• billing information (see "Payments").

We use this to provide Varuna to you: to keep your records, check them against the rules we have recorded, remind you of deadlines, issue and verify certificates, take the payments you authorize, keep the service secure, and answer you when you write to us. We do not use your records to advertise to you, and we do not sell them.

What we collect automatically. When you use Varuna, our hosting and database providers record technical information such as your IP address, browser type, and the time of each request, to keep the service running and secure. We use cookies only to keep you signed in and to make the site work. We use no advertising or analytics cookies, and no other company tracks you across sites through Varuna. Because we do no cross-site tracking, we treat every visitor the same whether or not their browser sends a "Do Not Track" or Global Privacy Control signal. If you sign in with Google or Apple, they tell us your name and email address.

Social Security numbers. We do not ask for a Social Security number. If a document you upload shows one, the document is kept intact and private to you and marked as containing one. Before a document is sent to an outside company to be read, we check it for such a number and black out any we find; the document reader page explains how. The number never appears in our logs, error reports, emails or search.

Client information. Varuna is not designed to hold your clients' or patients' health information, and the Terms ask you not to upload it. We are not a HIPAA business associate and do not sign business associate agreements. If client information reaches Varuna, tell us and we will help you remove it.

Varuna is not for children, and we do not knowingly collect information from anyone under 18.

Who handles your information for us

We do not sell your personal information, and we do not share it for advertising. We share it only with the service providers below, who handle it for us under contract and only to run Varuna, and with the people you choose to share with (see "Who can see your records").

• Supabase: our database, file storage and sign-in. Your records and documents are stored here, in the United States.
• Vercel: hosts the website and keeps short-lived technical logs.
• Resend: sends our emails.
• Stripe: payments and sales tax (see "Payments").
• Anthropic: reads a document's contents when you put it in the drop area, after any Social Security number is blacked out (see "The document reader").
• Google and Apple: only if you choose to sign in with them.

We may disclose information if the law or valid legal process requires it, or to protect someone's safety, and we will tell you unless the law forbids it. If Varuna is sold or merged, your information moves to the new owner only under this notice, and we will tell you first.

Payments

Payments are handled by Stripe, our payment processor. Your card number goes to Stripe, not to us; we keep only what we need to show you your membership, such as the card's brand and last four digits and the dates and amounts of your charges. Stripe calculates sales tax from your billing address. Stripe also uses payment information for its own purposes, such as preventing fraud, under Stripe's own privacy policy (stripe.com/privacy).

We keep a record of each charge you authorize: what it was for, the amount and price shown to you, the card, the period it paid for, when you authorized or withdrew it, and which version of the Terms was in force. That record is how we prove that every charge was one you approved. We keep billing and authorization records for seven years after each charge, even after you close your account or delete everything (longer only if a legal claim requires it), because tax and consumer-protection law require us to be able to show every charge and your consent to it.

Your free trial

Each email address gets one free trial. To enforce that, when a trial starts we keep a coded version of your email address, made with a secret key after ignoring capital letters, and dots and "+" tags in Gmail-style addresses. We cannot read your address from it, but if the same address is used to start another trial, the codes will match: that is its only purpose. It is stored separately from your account and is not used for anything else. We keep it even after you delete everything, because otherwise deleting and signing up again would restart the trial.

Who can see your records

By default, only you. Other people see something only when you choose it, or when it is the point of a feature:

• a practice whose seat you accept sees only what you agreed to share, and nothing after you leave;
• a supervisor, connection or signer sees only what you send or share with them;
• your public profile, if you turn it on, shows what you put on it;
• anyone holding a certificate's verification address can see that certificate: your name, the course, the provider, the date and the hours;
• a course provider sees your progress, evaluation and certificate for their course.

Varuna's own staff can access account data only to keep the service running, to answer a support request you make, to keep it secure, or when the law requires it. We look at your account as you see it only after you have given us permission, for no more than 30 minutes at a time, and each such look is logged against your account.

Your documents are stored privately. Opening one creates a link that works for a few minutes and only after you have signed in. The database refuses to hand another account your rows, and we test that on every change rather than promising it. No system is perfectly secure; if a breach affects your information, we will tell you as the law requires.

The document reader

When you put a document in the drop area, its contents are sent to Anthropic to be read, after any Social Security number has been blacked out. The document reader page says exactly what that means, including how long Anthropic keeps what it is sent. It is the only time a document's contents are sent to an outside company to be read.

Keeping and deleting

You can export everything by yourself, whether or not you are paying: at any time while you have access, and for 12 months after your access ends or you close your account. After that we still keep it: write to customer support at support@stubbornfact.com from your account's email address and we will reopen your export, free of charge. You then sign in and download it yourself; we do not send your documents by email.

While your account is open, we keep your records for as long as you keep them. When you close your account, we keep your records and documents so that you can sign in to export them or rejoin. After 12 months we still keep them, until you delete everything or we delete the account as the Terms allow, so that customer support can reopen your export when you ask. Closing never lets anyone see more than before: your documents stay private to you (documents that show a Social Security number included), you leave any practice you were a member of, your public profile is turned off, you no longer appear in name searches, and we send you no reminders (only notices about a payment, a refund or your card). Anything you already shared with a supervisor or a connection stays visible to them until you stop sharing it or withdraw the connection. To have everything deleted, use Delete everything now in your account settings: we then delete your records and documents from Varuna at once (this cannot be undone), and they leave our backups as those backups expire, within 7 days. You can also ask us by email (see "Your choices and rights"), and we do it within 30 days of confirming the request is yours. When you delete everything, some things are kept, and here is which and why:

• certificates issued to you and their verification pages, which show your name, the course, the provider, the date and the hours;
• a course provider's own record of your attendance, evaluation and certificate, which they must keep for their approval bodies;
• statements you signed for someone else, which belong to their record;
• messages you sent to other people, which stay in their conversations without your name attached;
• a course provider's list of the people they invited or reminded, which keeps the name and email address they entered;
• our security log of sign-in events, which keeps the email address used, so that we can investigate misuse of an account; we keep these entries while your account exists, closed or not, and delete them within 12 months after the account is deleted;
• billing and authorization records (see "Payments");
• the coded email (see "Your free trial").

Stripe keeps its own payment records under its own privacy policy, and Anthropic keeps what it was sent for the period the document reader page states.

Your choices and rights

You can see and correct almost everything in the app, export all of it (by yourself while you have access and for 12 months after it ends or you close your account; after that customer support reopens your export), and close your account or delete everything from your account settings. For anything else, including a request to know what we hold about you, to correct it, or to delete it, write to john@stubbornfact.com from your account's email address. We may ask you to confirm the request from that address so that we know it is you. We answer within 30 days, and we will not treat you differently for making a request.

Some states give their residents specific privacy rights, such as California, Colorado, Connecticut, Utah and Virginia. Whether or not those laws apply to a business of our size, we give everyone the rights above: to know, to correct, to delete, to take a copy of your information, and not to have it sold or used for targeted advertising (we do neither). If we refuse a request, we tell you why, and you can ask us to look at it again by replying.

Emails

We email you about your account: sign-in links, password resets, reminders you have chosen, and notices about your money. Notices about your money (a trial starting or ending, an authorization you made, a charge coming up, a failed payment, a membership starting, and a yearly reminder of any module) cannot be switched off, because you need them before anything is charged. Reminders about your licenses can be switched off in your notification settings or from the link in any reminder.

If you ticked the box for it when you started, we may email you the renewal dates of licenses you recorded after your access ends, with a link to rejoin. These emails never include your compliance status. Every one has a one-click stop link, and they stop when you close your account.

Changes to this notice

When this notice changes, we publish a new version with its date and keep the old ones. Before a change that affects how we use information you have already given us takes effect, we tell you in the app and by email.