PRIVACY POLICY

My Record Locker

Effective Date: October 13, 2026

1. Introduction

This Privacy Policy describes how Kryptomneme LLC, doing business as My Record Locker ("We," "Us," "Our"), collects, uses, stores, and discloses personal information through the My Record Locker platform (the "Platform"), accessible at MyRecordLocker.com.

My Record Locker turns approved content into quizzes and keeps tamper-evident Completion Records of the training. It also gives Customers tools to run their workplace: a time clock, an expense log, a record of inspector visits, and, when a Customer turns them on, resident logs. My Record Locker stores a tamper-evident record of the training. It does not create or certify the training itself, and it does not guarantee, certify, or ensure regulatory compliance.

By using the Platform, you agree to the collection and use of information as described in this Privacy Policy. This Privacy Policy is incorporated into and subject to Our Terms of Service.

2. Information We Collect

2.1 Information Provided by Customers (Organization Administrators)

When a Customer organization creates an account, We collect:

• Administrator name and email address.
• Organization name and billing contact information.
• Payment information — collected and processed entirely by Stripe (see Section 5); Kryptomneme LLC never receives, processes, or stores raw credit card numbers or bank account details.
• Plan selection and the quantity purchased.

2.2 Information Provided About or by Learners

When a Customer invites Learners to complete training, We collect:

• Full name (as provided by the Customer or Learner).
• Email address (used for invitation and, where configured, for one-time-password identity verification).
• Employer reference or employee identifier, if provided by the Customer.
• Other details the Customer chooses to keep about a Learner, such as date of birth, phone number, address, job title, department, start date, license or certification number, emergency contact, and Social Security or other national ID number. These are off unless the Customer turns them on, and they never appear on a Completion Record or the public verification page.
• Certificates and training records from other sources that the Customer uploads.

2.3 Information Generated During Training Sessions

When a Learner completes a training module, the Platform automatically collects and records:

• Training-session events: module start, segment progress, quiz responses (including incorrect attempts and retries), navigation actions (such as seeking forward or backward), timestamps, and completion status.
• Identity-verification events: the fact that an identity check (for example, a one-time code sent by email) was presented and passed, and the method used. We do not store the one-time-password codes themselves after verification.
• Session duration and active time.
• Quiz results (questions presented, responses given, pass/fail outcome, number of attempts).

This information is kept in a tamper-evident form and becomes part of the Completion Record when it is issued.

2.4 Technical and Usage Information

In the course of operating the Platform, standard technical data may be processed, including:

• Technical request data such as IP address and browser type, as processed in standard server and infrastructure logs.
• Pages visited and actions taken within the Platform.
• Error and diagnostic logs.

This technical data is used to operate, secure, and troubleshoot the Service, and is not used to track Learners across other websites or for advertising.

2.5 Information From Workplace Tools

When a Customer uses the Platform's workplace tools, We collect:

• Time clock: the name and email address of each person who clocks in or out, and the time of each clock.
• Expenses: the date, amount, category, vendor, and notes for each expense, any receipt photo or file, and who added or changed it.
• Inspector visits: when a visit opened and closed, who opened and closed it, any photo taken of the inspector's card, and the inspector's name and agency if the Customer adds them.
• Uploaded files: the documents, web pages, and text a Customer uses to build quizzes, and the Customer's logo.

2.6 Resident Logs

Resident logs are off unless a Customer turns them on. Before they open, the Customer and Kryptomneme LLC sign a Business Associate Agreement. When resident logs are on, We collect, on the Customer's behalf:

• Each resident's name and move-out date, and the care logs staff write, such as medications given, meals, vital signs, sleep, mood, falls, and changes in condition.
• Each resident's medications and medication orders, and the history of changes to them.
• Paper records and spreadsheets the Customer scans or imports.
• The name and email address of each staff member who writes or reads a log, and a record of each time they open, add, or export resident information.

Resident information is kept apart from the rest of the Platform and is handled under the Business Associate Agreement as well as this Policy.

2.7 People Who Contact Us

When someone signs up, sends Us a question, or sends feedback, We collect their name, email address, company name, and message, and whether they agreed to be contacted back.

2.8 Text Messages

If an employer turns on text messages, we collect employees' mobile phone numbers for the sole purpose of sending sign-in codes, clock-in and clock-out confirmations, and alerts that need attention. The system sends these automated messages on behalf of employers, through our text message provider. These communications are covered by a separate agreement between employers and employees. We never sell mobile phone numbers or share them with anyone for marketing. Message and data rates may apply. Reply HELP for help or STOP to stop at any time.

2.9 Information We Do NOT Collect

• We do not collect biometric data.
• We do not use the Platform's training sessions to collect data unrelated to training delivery and record issuance.
• We do not collect raw payment-card data (all payment processing occurs on Stripe's hosted checkout page).
• We do not send your files or personal information to any AI service.

3. How We Use Information

We use the information We collect for the following purposes:

(a) Delivering the Service. Processing training-module delivery, recording session events, issuing Completion Records, and enabling record verification.

(b) Identity Verification. Checking a Learner's identity during training (for example, by sending a one-time code to the Learner's email address). These checks are not continuous, and the Platform does not claim continuous identity assurance.

(c) Account Administration. Managing Customer accounts, processing payments (via Stripe), managing Learner invitations and the locations covered by a plan, and enabling Customers to export their data.

(d) Record Integrity. Keeping each Completion Record tamper-evident and independently verifiable.

(e) Communication. Sending transactional emails, including invitation emails, one-time-password codes, and account-related notifications.

(f) Service Improvement and Security. Diagnosing technical issues, monitoring for unauthorized access, and improving the Platform's reliability and functionality.

(g) Workplace Tools. Keeping time clock entries, expenses, inspector visits, and, when a Customer turns them on, resident logs for the Customer.

We do not sell personal information. We do not use personal information collected through the Platform for advertising purposes.

4. Completion Records

Completion Records are tamper-evident: a change to an issued record can be detected. Once a record is issued, it is not deleted or retroactively altered under normal operation.

The verification endpoint (publicly accessible) displays only whether the record is valid, and non-personally-identifiable context (issuing organization, course, outcome, dates). The verification endpoint does not display the learner's name or employer reference.

Completion Records that name the Learner can be seen by the issuing Customer when signed in, and by the Learner through the link in their email. A Customer may also share a binder of records with others, such as an inspector, by a link or QR code, and chooses how much of each person's name that link shows.

A record reaching the end of its retention period, or subject to a valid request, undergoes Disposal: information identifying an individual is removed from the record and from the associated records we hold, such that the record no longer identifies the individual who completed the training. The record itself is retained and remains verifiable, and continues to identify the Customer that issued it and the person named as having approved the training. Disposal is irreversible once executed. See Section 8 (Data Retention and Deletion).

5. Third-Party Service Providers

We use the following third-party service providers to operate the Platform. Each provider processes data only as necessary to perform its specific function:

5.1 Stripe (Payment Processing)

Stripe, Inc. processes all payments on Our behalf through hosted checkout. Kryptomneme LLC never receives or stores raw credit card numbers. Stripe's handling of payment data is governed by Stripe's own privacy policy and PCI DSS compliance.

Website: https://stripe.com/privacy

5.2 Resend (Transactional Email)

Resend is used to deliver transactional emails, including Learner invitations and one-time-password codes for identity verification. Resend processes recipient email addresses and email content as necessary to deliver these messages.

Website: https://resend.com/legal/privacy-policy

5.3 Render (Hosting Infrastructure)

The Platform is hosted on Render, in Oregon, in the United States. Render provides the server infrastructure and persistent storage on which the Platform and its database operate. Render may process IP addresses, request metadata, and other technical data in the course of providing hosting services.

Website: https://render.com/privacy

5.4 Backblaze B2 (Encrypted Off-Site Backup)

Encrypted backups of the Platform's data are stored off-site on Backblaze B2, under Kryptomneme LLC's sole control. Backup files are encrypted before upload; Backblaze receives and stores only the encrypted backup files and does not have the keys needed to open them.

Website: https://www.backblaze.com/company/privacy.html

5.5 Cloudflare R2 (Document Storage)

Files uploaded by a Customer are stored on Cloudflare R2. These include the documents used to build quizzes, the Customer's logo, photos of inspector cards, and expense receipts. Cloudflare stores and returns these files at Kryptomneme LLC's direction and receives no Completion Records, no resident information, and no billing data. Files are encrypted at rest by Cloudflare, and the storage is restricted to the United States for the life of the store.

Website: https://www.cloudflare.com/privacypolicy/

5.6 Google Cloud (Resident Logs)

When a Customer turns on resident logs, resident information is stored and processed on Google Cloud, in Oregon, in the United States. Google Cloud hosts the resident logs service, its database, and its encrypted backups, and processes this information only to provide that service. Google Cloud is not used for any other part of the Platform.

Website: https://cloud.google.com/terms/cloud-privacy-notice

5.7 Sign by My Record Locker

Agreements We ask a Customer to sign, such as the Business Associate Agreement, are sent through Sign by My Record Locker, which Kryptomneme LLC also runs. Sign keeps the signer's name, email address, and signing details, as described in its own privacy policy at https://sign.myrecordlocker.com/privacy.

We do not share personal information with any third party for advertising, marketing, or any purpose unrelated to the operation of the Service. We may disclose information if required by law, regulation, legal process, or enforceable governmental request.

6. Cookies and Tracking

6.1 Essential Cookies

The Platform uses essential cookies and session identifiers necessary for the operation of the Service (for example, maintaining login sessions, tenant context, and recognizing a tablet the customer set up for staff to share). These cookies are strictly functional and are not used for advertising or cross-site tracking.

6.2 No Third-Party Tracking

The Platform does not use third-party advertising cookies, tracking pixels, social-media widgets, or analytics services that track Learners across other websites. We do not participate in behavioral advertising networks.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, alteration, disclosure, or destruction. These safeguards include:

• Tamper-evident Completion Records: a change to an issued record can be detected.
• Resident logs kept apart from the rest of the Platform, with a record of every time resident information is opened, added, or exported.
• Encryption of data in transit using industry-standard TLS, and encryption of data at rest, including infrastructure snapshots.
• Encrypted off-site backups stored on Backblaze B2, with decryption keys held solely by Kryptomneme LLC.
• Logical tenant isolation — each Customer's data is stored and accessed within a scoped Tenant Workspace; cross-tenant data access is treated as a critical defect.

No system can be guaranteed secure against every threat, and We do not represent that the Platform is impervious to unauthorized access. We review and improve Our security practices over time and will update this Policy to reflect material changes.

8. Data Retention and Deletion

8.1 Retention Period

Completion Records and their training-session data are kept for the retention period the Customer sets. Unless the Customer sets one, they are kept indefinitely. The Customer can set a period for each record, for each course, or by rule, can change it later, and can place a hold that stops records from being disposed of. Customers are responsible for choosing the retention period that fits their own legal and business needs.

8.2 Deletion Requests

Upon a record reaching the end of its retention period, or upon a valid deletion request, we perform Disposal of that record. The record itself is retained and remains verifiable; it no longer identifies the individual who completed the training, and the change is irreversible once executed.

8.3 Account Termination

Upon termination of a Customer's account, the Customer may request a full export of their data. Following export (or after a reasonable period), the Tenant Workspace is marked as terminated. Previously issued Completion Records remain verifiable through the verification endpoint for the remainder of the applicable retention period. Except for resident logs (see Section 8.5), data is not destroyed when an account ends; it is kept according to the retention policy.

8.4 Workplace Tools

Time clock entries, expenses, and inspector visits are kept while the Customer's workspace exists. When an expense is changed or deleted, its earlier version is kept in that expense's history.

8.5 Resident Logs

Resident information is not deleted on a schedule and is not subject to Disposal. It is kept until the Customer's use of resident logs ends. The Customer can then download a full copy, and We delete the resident information, including from Our backups, within 30 days after that date. We keep a log of who opened, added, or exported resident information, without resident names or log contents, for six years, and a record of the closing itself.

9. Data Subject Rights

Depending on applicable law, individuals may have the following rights with respect to their personal information:

(a) Right of Access. The right to request a copy of the personal information We hold about you. Customers may access and export their data, including Completion Records, through the Platform. Learners may request access through their employing Customer or by contacting Us directly.

(b) Right of Rectification. The right to request correction of inaccurate personal information. Corrections are recorded as amendments rather than by altering prior entries.

(c) Right of Deletion. The right to request deletion of personal information. We honor deletion requests through Disposal, as described in Section 8.2 above. Resident log entries cannot be changed or deleted while resident logs are in use; a correction is added as a new entry, and resident information is deleted as described in Section 8.5.

(d) Right to Restrict Processing. The right to request that We limit the processing of your personal information under certain circumstances.

(e) Right to Data Portability. The right to receive your personal information in a structured, commonly used, machine-readable format. The Platform supports export in CSV and JSON formats.

(f) Right to Object. The right to object to processing of your personal information under certain circumstances.

To exercise any of these rights, contact Us at the address provided in Section 15. We will respond within the timeframe required by applicable law. We may require verification of identity before processing a request.

Because training records serve a legitimate business purpose for the employing Customer (documenting that training occurred), deletion requests from individual Learners may be subject to the Customer's own data-retention obligations and policies. We will work with the Customer and the requesting individual to find a resolution that respects both parties' rights and obligations.

10. Multi-Tenant Architecture and Data Isolation

The Platform operates as a multi-tenant service. Each Customer's data is logically isolated within its own Tenant Workspace. We implement technical controls designed to prevent cross-tenant data access. Nobody in one Customer's Tenant Workspace can access another Customer's data through the Platform.

11. Children's Privacy

The Platform is not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16. If a Customer invites a Learner who is under 16 to use the Platform, the Customer is responsible for ensuring that any required parental or guardian consent has been obtained in accordance with applicable law. If We become aware that We have collected personal information from a child under 16 without appropriate consent, We will take steps to anonymize or delete that information.

12. International Data Transfers

The Platform is hosted in the United States, in Oregon. If you access the Platform from outside the United States, your personal information may be transferred to and processed in the United States. Where a legal transfer mechanism is required, we rely on the safeguards described in the DPA, including the Standard Contractual Clauses referenced there, rather than on individual consent.

13. Breach Notification

In the event of a data breach that affects the security of personal information, We will notify affected Customers and, where required by applicable law, affected individuals and relevant supervisory authorities, within the timeframe required by applicable law. Notification will include a description of the nature of the breach, the categories of data affected, the measures taken to address the breach, and recommendations for affected individuals.

14. Changes to This Privacy Policy

We may update this Privacy Policy at any time. The current version is the one posted at myrecordlocker.com/privacy/, and the "Effective Date" at the top shows when it last changed. Continued use of the Service after that date constitutes acceptance of the revised Policy.

15. Contact Information

For questions or to exercise your data-subject rights, email hello@myrecordlocker.com

Our Data Processing Addendum (DPA), which is part of Our Terms of Service for every Customer, is at /dpa/.