Privacy Policy

Tower Privacy Policy and Data Safety Disclosure

1. Introduction, Operating Entity & Regulatory Baselines

In the critical domain of cryptographic security and credential management, digital sovereignty, systemic transparency, and strict zero-knowledge isolation are foundational prerequisites rather than mere compliance formalities. Tower operates on the fundamental legal and technological principle that sensitive digital credentials, master secrets, cryptographic keypairs, and personal identity records belong exclusively to the end user. As the developer and operating entity of Tower, Datasirpi maintains a rigorous, auditable data protection framework engineered to insulate user secrets, eliminate unauthorized data exposure, and comply with the most stringent data protection authorities globally.

Datasirpi FZC-LLC is a limited liability company incorporated under the laws of the United Arab Emirates, maintaining its registered corporate address at Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates (hereinafter referred to as "Datasirpi", "Company", "we", or "us"). Datasirpi operates under the primary regulatory oversight of the UAE Data Office, strictly observing UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (UAE PDPL). To govern cross-border data flows and protect a global user base across disparate legal jurisdictions, Tower maintains a synthesized compliance matrix that harmonizes international statutory mandates into a singular operational standard.

Legal Bases for Processing Across Multi-Tenant User Roles

To maintain strict alignment with Article 11 of the UAE PDPL and equivalent international legal frameworks, Tower differentiates the legal necessity of processing across three discrete classes of platform participants:

• Enterprise and Organization Administrators:  The processing of corporate identifiers, administrative billing records, domain verification records, and seat allocations is grounded in the  Performance of Contract , as these records are indispensable for provisioning team vaults, enforcing corporate single sign-on (SSO), and executing enterprise subscription agreements.

• Individual Vault Holders and Team Members:  Authentication metadata, account verification tokens, and subscription billing statuses are processed under the  Performance of Contract . Any technical processing involving mobile hardware permissions, system-level AutoFill integrations, or diagnostic crash telemetry is governed strictly by the user's affirmative, unbundled  Explicit Consent .

• Emergency Contacts and Digital Legacy Beneficiaries:  The handling of external contact details and delegated authorization tokens during emergency access or digital inheritance workflows is anchored in  Explicit Consent  and verified bilateral authorization executed between the primary vault holder and the designated recipient. Zero-knowledge access during inheritance workflows is enforced using client-side cryptographic secret sharing (such as Shamir's Secret Sharing), ensuring decrypted master keys are never exposed to or escrowed on Datasirpi servers.

2. Data Inventory, Privacy Nutrition Labels & Zero-Knowledge Architecture

Tower is architected upon an uncompromising Zero-Knowledge, End-to-End Cryptographic Framework. Under this structural design, all sensitive vault entries—including login credentials, cryptographic seeds, financial account numbers, identity documents, and secure notes—are encrypted and decrypted strictly client-side on the user's local hardware device. Encryption keys are derived directly from the user's Master Password and unique secret salts using memory-hard key derivation algorithms (Argon2id). Consequently, Datasirpi servers function solely as a blind synchronization conduit; plaintext credentials are never accessible, readable, or derivable by Datasirpi personnel, automated systems, or third-party service providers.

In strict compliance with the "Privacy Nutrition Label" disclosure mandates enforced by the Apple App Store and Google Play Store, Tower defines "Collection" as the transmission of data off the user's local hardware for a period extending beyond the immediate, instantaneous window required to service an active network request.

Datasirpi enforces an absolute prohibition against commercial data exploitation. User account metadata, device telemetry, and synchronization records are never commercialized, rented, exchanged, or disclosed to advertising exchanges or third-party data brokers.

3. Platform-Specific Privacy & Hardware-Enforced Consent Mechanisms

Modern desktop and mobile operating environments provide low-level access APIs that necessitate granular, context-aware privacy safeguards. In contrast to broad-brush, all-or-nothing permission requests, Tower implements a "Just-in-Time" disclosure sequence, triggering operating system authorization prompts solely at the exact instant an advanced feature is initiated by the user.

Contextual Permission Flow

The deployment of system-level permissions adheres to a structured, auditable lifecycle designed to preserve user autonomy:

1. Functional Trigger:  The user initiates an explicit security action requiring OS-level privileges, such as activating biometric unlocking or configuring automated form completion.

2. Contextual Transparency Disclosure:  Prior to displaying system-level prompts, Tower presents an in-app explanatory modal detailing the specific technical utility, data boundary, and isolation guarantees associated with the permission.

3. Active User Assent:  The user provides affirmative authorization through the native operating system security interface.

4. Isolated Local Execution:  The platform executes the requested operation within local device memory, without transmitting hardware data or system credentials to external servers.

Biometric Authentication & Secure Enclave Isolation

When users enable biometric verification (such as Apple Touch ID, Apple Face ID, or Android BiometricPrompt) to unlock their local Tower vault, all biometric computations are executed exclusively within the physically isolated hardware environment of the host device's Secure Enclave or Trusted Execution Environment (TEE).

• Biometric facial meshes, fingerprint images, and raw mathematical representations remain permanently confined to the local hardware; they are never accessible to the Tower application layer, never exposed to the operating system at large, and never transmitted across network channels to Datasirpi infrastructure.

• Biometric verification generates an ephemeral, local cryptographic key that unlocks the Master Password or symmetric vault key cached in volatile system memory (RAM). Terminating the application, restarting the operating system, or experiencing an authentication timeout immediately purges this ephemeral key from memory.

AutoFill Services and Operating System Accessibility Guardrails

Tower interfaces with native operating system AutoFill frameworks and accessibility service APIs to automatically detect and populate credential fields across web browsers and native third-party applications. To prevent privacy intrusion, Tower establishes rigid technical guardrails:

• Restricted Application Sandboxing:  Tower is technically restricted from indexing, scraping, or logging screen text, keystrokes, or background interactions in third-party applications. The AutoFill service remains passive until an interactive input field matching recognized credential patterns is focused.

• Domain and Package Signature Verification:  Prior to presenting stored credentials for auto-completion, Tower cryptographically validates the target website's Fully Qualified Domain Name (FQDN) or the native mobile application's digital signing certificate. This verification prevents credential harvesting, cross-site scripting vulnerabilities, and mobile phishing schemes.

• Automated Clipboard Sanitization Protocol:  In scenarios where a user manually copies a password, recovery code, or TOTP seed to the system clipboard, Tower activates a hardware-timed memory sanitization process. The clipboard content is completely purged from device volatile memory within a default window of thirty to sixty seconds, precluding unauthorized exfiltration by predatory background processes.

4. User Dashboards, Data Subject Access Rights (DSAR) & Cryptographic Erasure

Datasirpi provides comprehensive tools for the execution of global Data Subject Access Rights through a self-service Privacy Dashboard embedded directly within the Tower user account portal. In adherence to Section 1798.130(1)(2)(A) of the California Consumer Privacy Act (CCPA) and the statutory frameworks established under the UAE PDPL and GDPR, Datasirpi guarantees a complete response and fulfillment of all formal requests for Access, Rectification, Restriction, Portability, and Erasure within a mandatory period not to exceed  45 calendar days .

DSAR Operational Workflow

The lifecycle of a Data Subject Access Request within Tower follows four sequential stages:

1. Authenticated Request Submission:  The data subject submits a verified DSAR via the self-service dashboard or directly to the Data Protection Officer using cryptographically signed credentials to eliminate identity spoofing.

2. Comprehensive Scope Compilation:  Datasirpi automated systems compile an export of all non-encrypted account metadata, billing history, and administrative activity logs associated with the user account.

3. Data Portability Delivery:  The compiled records are transmitted to the user in a standardized, machine-readable JSON format, enabling friction-free portability.

4. Enforcement of Rectification or Erasure:  Upon validated request, incorrect account records are corrected, or the account is queued for cryptographic destruction across production and backup environments.

Account Termination & Cryptographic Purging Protocol

Because vault contents are secured via client-side zero-knowledge encryption, the deletion of a Tower account requires a specialized cryptographic purging protocol to guarantee complete data destruction:

• Session Termination and Invalidation:  Initiating account deletion instantly revokes all active session tokens, OAuth grants, and multi-factor authorization states across all connected client applications and background synchronization workers.

• Permanent Cryptographic Shredding:  Server-side database records containing the user's encrypted vault ciphertext, master key salts, and public key pairs are immediately purged using cryptographic shredding algorithms, rendering any legacy system snapshots or encrypted backups mathematically unrecoverable.

• Production Purge Timeline:  All associated account identifiers, diagnostic linkages, and access logs are permanently eliminated from active production databases within the statutory  45-day window .

• Statutory UAE Financial Retention Carve-Outs:  Pursuant to United Arab Emirates commercial, corporate governance, and tax auditing statutes, financial transaction logs (including invoices, payment receipts, subscription tiers, and corporate tax identifiers) are excluded from immediate deletion. These records are transferred into an encrypted, isolated, non-production archive, retained solely for the statutory duration mandated by UAE tax authorities, and legally quarantined from any analytical, commercial, or operational processing.

5. Third-Party Data Disclosure, Sub-Processors & Security Protocols

Tower enforces a zero-trust supply chain security model. Any third-party infrastructure partner, cloud hosting provider, or payment processor integrated into the platform ecosystem must successfully pass rigorous cybersecurity assessments and execute binding Data Processing Agreements (DPAs) incorporating standard contractual safeguards.

Cryptographic and Network Transfer Standards

• Data in Transit:  All network communication between Tower client applications and cloud synchronization endpoints is fortified using  TLS 1.3 , configured exclusively with high-strength cipher suites supporting Perfect Forward Secrecy (PFS). Unencrypted HTTP traffic is categorically rejected.

• Data at Rest:  All ciphertext vault blobs and secondary storage entities are encrypted using  AES-256  standards, backed by robust client-side key derivation functions (including Argon2id) that prevent brute-force attacks.

• Payment Gateway Isolation:  Subscription billing and transactional workflows are executed via  Stripe/Connect  over isolated, PCI-DSS Level 1 compliant server-to-server endpoints. Datasirpi servers never process, capture, or store raw credit card Primary Account Numbers (PAN) or sensitive cardholder verification values.

• Cross-Border Data Transfers:  Operating from the United Arab Emirates, any cross-border transmission of operational metadata to sub-processors outside the UAE or the European Economic Area is governed by European Commission  Standard Contractual Clauses (SCCs)  and bilateral data transfer agreements guaranteeing an equivalent standard of protection.

• Cross-Border Data Transfers & Data Privacy Framework:  Operating from the United Arab Emirates, any cross-border transmission of operational metadata to sub-processors outside the UAE or the European Economic Area is governed by European Commission  Standard Contractual Clauses (SCCs) , participation in the EU-U.S. Data Privacy Framework (and UK Extension) for US-based sub-processors, and bilateral data transfer agreements guaranteeing an equivalent standard of protection.

• Sub-Processor Transparency & Trust Center:  Datasirpi maintains an active public registry of all authorized infrastructure sub-processors accessible via our online Trust Center, where users can review current processing vendors and subscribe to update notifications.

• Independent Security Attestations:  Tower undergoes periodic third-party security audits, independent penetration testing, and maintains formal compliance attestations including SOC 2 Type II and ISO/IEC 27001 certifications.

• Incident Response & Breach Notification Timelines:  In the event of a confirmed personal data breach affecting non-encrypted metadata or system infrastructure, Datasirpi commits to notifying relevant supervisory authorities without undue delay and within 72 hours under GDPR and statutory UAE PDPL mandates, alongside prompt direct disclosures to impacted users.

6. Regional Opt-Outs & Protected Populations

California Privacy Rights (CCPA / CPRA)

California residents are hereby advised of their statutory rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CPRA). Under the CPRA, the historical thirty-day statutory grace period allowing businesses to cure alleged violations prior to administrative enforcement has been formally eliminated. Datasirpi maintains proactive, auditable controls to eliminate liability under statutory penalties, which mandate fines of  $2,500 per non-intentional violation and up to ****$  7,500 per intentional violation or violations involving minor consumers .

• Absolute Prohibition of Sale and Sharing:  Tower does not sell personal identifiers or metadata, nor does it share user records for cross-context behavioral advertising.

• Limitation on the Processing of Sensitive Personal Information:  Because Tower operates under zero-knowledge encryption, sensitive personal records (such as stored financial credentials, identity records, and passwords) are unreadable by Datasirpi. Furthermore, users retain the explicit right to restrict the use of any non-encrypted sensitive metadata exclusively to operations that are reasonably necessary to deliver the password management service.

Age Restrictions & Protection of Minors

Tower is engineered exclusively for adult enterprise administrators, professionals, and individual account holders possessing full legal capacity. In alignment with UAE statutory standards and international minor protection benchmarks (including COPPA and GDPR Article 8):

• The minimum age requirement to establish an independent Tower account is  18 years of age  within the United Arab Emirates.

• For users located in international jurisdictions where statutory frameworks permit lower thresholds (such as 13 years under COPPA or 16 years under GDPR), Tower strictly prohibits the registration of accounts by minors without verified parental or legal guardian consent.

• In the event Datasirpi identifies that personal data belonging to an individual below the applicable legal age threshold has been inadvertently collected, the Company executes immediate, irreversible cryptographic erasure of all associated records.

7. Policy Governance, Non-Silent Updates & Regulatory Contacts

Datasirpi upholds an open governance policy regarding regulatory and operational updates. The practice of executing "Silent Updates"—wherein contractual terms or privacy practices are amended without proactive notification—is strictly prohibited.

• Advance Notification Window:  In the event of material modifications that alter data handling practices, introduce new processing categories, or impact statutory user rights, Datasirpi will deliver a prominent  30-day advance notice  via in-app dashboard alerts and direct electronic mail.

• Mandatory Click-to-Accept Re-Affirmation:  Any modification that expands data collection or diminishes existing privacy protections mandates an affirmative  Click-to-Accept  user interaction. Continued usage of Tower following a material modification without an affirmative confirmation shall not constitute legally binding consent.

Data Protection Officer and Corporate Inquiries

For the submission of formal Data Subject Access Requests (DSAR), legal inquiries, or communications regarding compliance under the UAE PDPL, GDPR, or CCPA, users and regulatory authorities may contact the Datasirpi Data Protection Office:

• Operating Legal Entity:  Datasirpi FZC-LLC

• Corporate Registration Address:  Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates

• Data Protection Officer Contact:  dpo@datasirpi.com

• Legal Affairs and Compliance Desk:  legal@datasirpi.com

Tower and Datasirpi remain steadfast in their commitment to cryptographic excellence, user digital sovereignty, and the unyielding protection of your private security credentials.