Privacy Policy

1. Information We Collect

Account information. Name, email address, and password (stored hashed) when you create an account.

Eligibility screener responses. Answers you provide in the free screener, such as prior Puerto Rico residency history, general income profile, and relocation timeline. You may complete the screener without creating an account; if you provide an email to receive your results, we store it with your responses.

Application documents. Documents you upload to the application wizard or evidence vault, which may include government identification, proof of address, financial declarations, sworn statements, leases or deeds, utility bills, bank statements, and similar compliance records. These may contain sensitive personal and financial information. We process them solely to provide the Service.

Location data. If you enable day tracking, the mobile app uses background location to determine which jurisdiction you are in each day. We store the jurisdiction and date — not your precise coordinates or movement history. See Section 3 for details.

Travel history you import. Flight confirmations, calendar entries, or CSV files you choose to import to reconstruct past presence days.

Payment information. Payments are processed by a third-party payment processor. We do not store full card numbers; we retain transaction records (amount, date, product purchased, last four digits).

Usage and device data. Standard technical data such as browser type, device type, pages visited, and interactions with the Service, collected via cookies and similar technologies (see Section 8).

2. How We Use Information

We use your information to:

• Provide the Service: run the screener, assemble application packages, count presence days, classify and organize vault documents, generate deadline reminders, and produce audit-response exports
• Process payments and manage your subscription
• Send transactional messages (deadline alerts, threshold warnings, filing reminders) and, with your consent, product and educational emails (you can unsubscribe at any time)
• Improve the Service, including OCR classification accuracy and reliability
• Detect fraud, enforce our Terms, and comply with legal obligations

We do not sell your personal information. We do not share it with advertisers. We do not use the contents of your documents or your location history for advertising or marketing purposes.

3. Location Data

Day tracking is the heart of the Service and involves background location access. Our approach:

• Explicit opt-in. Background location is off until you enable it, and the app explains what is collected before you do.
• Minimal storage.We resolve your location to a jurisdiction (e.g., “Puerto Rico” or a U.S. state) and store only the jurisdiction and date. We do not retain GPS coordinates, routes, or a map of your movements.
• Your control. You can pause tracking, manually override any day, disable location access in your device settings, or delete your location history entirely at any time.
• No third-party sharing. Jurisdiction/date records are never shared with third parties except at your direction (e.g., when you export your own audit log) or as required by law (Section 5).

4. Document Storage and Security

• Vault contents and application documents are encrypted at rest and in transit.
• The Service runs on Google Cloud Platform infrastructure in the United States.
• Access to production data is restricted, logged, and limited to what is necessary to operate the Service.
• No system is perfectly secure; we cannot guarantee absolute security, but we treat your compliance file with the sensitivity it deserves. We will notify you of any breach affecting your personal information as required by applicable law.

5. When We Share Information

We share personal information only with:

• Service providers that help us operate the Service (cloud hosting, payment processing, email delivery, OCR processing), bound by contractual confidentiality and data-protection obligations
• Professional partners, only at your request. If you purchase an attorney review add-on or ask for a referral, we share the relevant application materials with the reviewing attorney with your authorization. Attorneys are independent professionals, not our employees.
• Legal requirements. We may disclose information if required by law, subpoena, or court order, or to protect the rights, safety, or property of users or the public. Where legally permitted, we will notify you before disclosing your information in response to legal process.
• Business transfers. If we are involved in a merger, acquisition, or sale of assets, your information may be transferred; this policy will continue to apply and you will be notified of any material change.

6. Data Retention

• Account, vault, and tracking data are retained while your account is active. Compliance records are intentionally long-lived — that is the point of the vault — but they are retained for you, at your direction.
• If you delete your account, we delete or de-identify your personal information within 30 days, except records we must keep for legal, tax, or fraud-prevention purposes.
• Screener responses without an account are retained for 12 months, then deleted or de-identified.

7. Your Rights and Choices

Regardless of where you live, you can:

• Access and export your data, including a complete export of your vault and day-tracking log, from within the Service
• Correct inaccurate information
• Delete your account and associated data
• Opt out of marketing emails (transactional compliance alerts continue while your account is active)

Residents of California and other U.S. states with comprehensive privacy laws have additional statutory rights (access, deletion, correction, portability, non-discrimination). We honor these rights for all users. We do not sell or “share” personal information as those terms are defined under the California Consumer Privacy Act. To exercise any right, use the in-app controls or contact contact@act60ready.com.

8. Cookies and Analytics

We use essential cookies (login sessions, security) and privacy-respecting analytics to understand aggregate site usage. We do not use third-party advertising cookies or cross-site tracking. You can control cookies through your browser settings; disabling essential cookies may break login functionality.

9. Children

The Service is not directed to anyone under 18, and we do not knowingly collect information from minors. If you believe a minor has provided us information, contact contact@act60ready.com and we will delete it.

10. Users Outside the United States

The Service is operated from the United States and Puerto Rico and intended for people relocating to Puerto Rico. If you access it from elsewhere, your information will be transferred to and processed in the United States.

11. Changes to This Policy

We will post any changes here and update the “Last updated” date. For material changes, we will notify you by email or in-app notice before they take effect.

12. Contact

Garita Labs LLC
c/o Northwest Registered Agent
1654 CALLE TULIPAN
STE 100
SAN JUAN, PR, 00927-6242

contact@act60ready.com