Privacy Policy
1. Introduction
At Fctr Identity ("Company," "we," "our," or "us"), we prioritize your privacy and are committed to protecting the data processed through the Fctr Identity Portal ("Portal"). This Privacy Policy explains what information is collected, how it is used, and your rights regarding it.
2. Zero-Data Architecture
The Portal is built on a strict Zero-Data architecture.
We do not retain raw end-user identity data, credentials, SSNs, dates of birth, or other sensitive identity attributes at rest as part of normal operations.
- PII Shielding: User data retrieved from your Identity Provider (Okta or Microsoft Entra ID) is processed in-memory for real-time verification and is discarded immediately after the session ends. We do not store raw identity records or credentials at rest.
- No Admin Credentials Stored: We never store Identity Provider administrator passwords. All access is handled via scoped API tokens or OAuth2/OIDC flows controlled by your organization.
- Limited Operational Retention: Fctr retains only limited operational metadata needed for troubleshooting, auditability, and billing under defined retention schedules.
3. Logging Practices
The Portal retains a limited set of operational records to support reliability, verification traceability, and billing:
3a. Application Runtime Logs (Ephemeral)
- The Portal writes diagnostic and error logs to stdout/stderr only (console output).
- These logs are retained in managed Google Cloud logging for approximately 1 day and are automatically purged thereafter.
- These logs may transiently contain technical metadata such as timestamps, request paths, and error messages. They are retained for short-lived operational troubleshooting and are automatically deleted after approximately 1 day.
3b. Audit and Request Metadata
- The Portal retains structured, PII-masked audit and request metadata in Fctr-managed Google Cloud services.
- Audit logs record: date and time of actions, Admin UserID, target End-user UserID (masked or hashed), action type (e.g., "password reset initiated," "session revoked"), verification status, and error metadata.
Retention Period: Audit and request metadata are retained for approximately 30 days and then automatically deleted.
3c. Usage and Billing Metrics
- Fctr retains limited usage-based billing records using hashed, non-PII identifiers rather than raw end-user identity records.
- These records are retained for approximately 3 years for billing support and financial recordkeeping.
4. Purpose of Data Collection
We collect and log the metadata described above to:
- Generate audit records of actions performed within the Portal for compliance reviews, verification traceability, and support operations.
- Troubleshoot errors and improve the functionality and reliability of the Portal.
- Maintain the security and operational integrity of the service.
- Support billing, invoicing, and financial recordkeeping using hashed or pseudonymous usage metrics.
5. SMS and Email Verification Data
When SMS or email verification is enabled, we and our delivery service providers may process the destination phone number or email address, message delivery metadata, verification request metadata, and related audit records for the purpose of authentication, fraud prevention, account security, operational support, and compliance logging.
Phone numbers and email addresses used for authentication are typically sourced from your organization's connected identity provider or authentication enrollment system. We do not use this information for advertising or promotional messaging.
Where these messaging features are enabled, delivery providers may process limited data necessary to transmit the message and report delivery status, subject to applicable contractual and privacy obligations.
6. Sub-Processors
We use the following third-party sub-processors as part of the current standard Portal delivery model. Relevant purpose and compliance information is summarized below.
| Sub-Processor | Purpose | Certifications |
|---|---|---|
| Google Cloud Platform | Application hosting, operational logging, and encrypted storage | SOC 2 Type II, ISO 27001 |
| Cloudflare | DNS and edge security | SOC 2 Type II, ISO 27001 |
We do not share data with any party beyond these operational sub-processors. We never sell or share data with third parties for marketing, analytics, or advertising purposes.
7. Data Sharing
- Data may be disclosed to law enforcement or regulatory authorities only when required by a valid legal process (e.g., subpoena, court order) and only to the minimum extent required.
- We will notify you of such requests unless legally prohibited from doing so.
8. Your Rights
- You may request access to, correction of, or deletion of the audit log data within the retention period.
- For GDPR-covered individuals: You have the right to access, rectification, erasure, restriction of processing, data portability, and the right to object. Given our limited retention windows and minimized data model, most operational data is automatically purged on a short schedule.
- To exercise any right, contact us at [email protected].
9. Cookies
The Portal uses only essential, session-based cookies to maintain authenticated sessions and CSRF protection. We do not use tracking cookies, advertising cookies, or third-party analytics cookies.
10. International Data Transfers
The Portal is hosted on Google Cloud Platform in the United States. If you are accessing the Portal from outside the United States, you acknowledge that your data will be processed in the United States. Fctr will cooperate with customers requiring additional transfer safeguards or contractual documentation.
11. Updates to This Policy
This Privacy Policy may be updated periodically to reflect changes in our practices, technologies, or applicable regulations. Material changes will be communicated via email or a prominent notice within the Portal. Continued use of the Portal constitutes acceptance of the revised policy.
12. Contact Information
For questions or concerns about this Privacy Policy, contact us at: