1. Texas Privacy Rights
Texas residents may have rights under the Texas Data Privacy and Security Act, including rights to know whether personal data is processed, access data in a readable format, correct inaccuracies, delete personal data, opt out of certain targeted advertising/sale/profiling uses, and avoid discrimination for exercising rights.
Source: https://www.oag.state.tx.us/consumer-protection/file-consumer-complaint/consumer-privacy-rights/texas-data-privacy-and-security-act
2. Request Process
Users and former users may submit privacy requests through the in-app privacy request flow or by emailing legal@completa.io. State the right requested and information sufficient to locate the relevant account or records. Completa uses proportionate identity and authority verification and requests additional information only when reasonably necessary. Authorized agents must establish the required authority.
Completa responds to authenticated requests within 45 days, with one additional 45-day extension when reasonably necessary and explained within the initial response period, or sooner where law requires. A denial explains its basis and the appeal process. To appeal, reply to the decision or email legal@completa.io with the request reference and reasons for review. Completa responds to an appeal in writing within 60 days after receipt, stating the action taken or not taken and the reasons. If a Texas privacy appeal is denied, the response provides the Texas Attorney General online complaint mechanism at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint. These contact routes remain available after closure or loss of account access. Applicable statutory exceptions, including properly established exemptions, may limit a particular right; they do not remove this request channel.
3. Categories of Personal Data
Completa processes account data, contact data, project data, property data, photos/videos, receipts/invoices, material records, payment details, tax/payout details, contractor credential data, background-check status, insurance/license records, messages, support records, warranty/dispute evidence, device/log data, and legal acceptance records.
4. Sensitive Data
Sensitive data may include precise geolocation if retained from photos or service logistics, government IDs or background-check information where used for verification, financial/payment details, and other categories treated as sensitive under applicable law. Completa processes sensitive data only for disclosed and necessary platform, verification, safety, fraud, legal, payment, tax, or support purposes, and obtains specific informed affirmative consent before processing where applicable law requires it. Accepting general terms is not a substitute for such consent. Completa evaluates the actual processing and applicable company-size, data, and context exceptions and completes required sensitive-data or heightened-risk assessments before the covered processing.
5. Biometric Disclaimer
Completa does not currently use biometric identification, face recognition, voiceprint recognition, identity-recognition technology, or hand-geometry or face-geometry extraction from photos, audio, or video. Texas Business and Commerce Code Section 503.001 treats a retina or iris scan, fingerprint, voiceprint, or record of hand or face geometry as a biometric identifier. Project photos and videos may incidentally include faces, hands, bystanders, children, or other personal features. Completa's AI/OCR processing is limited to project understanding, scope, materials, dimensions, classification, quality, dispute, warranty, fraud/safety, support, and recordkeeping purposes, not biometric identification, face recognition, voiceprint recognition, identity recognition, or biometric capture for a commercial purpose.
Users must not intentionally upload unnecessary photos or video of people, children, bystanders, or unrelated personal spaces. Completa does not create or store a separate biometric template, biometric identifier database, faceprint, voiceprint, or hand/face-geometry record from approved AI/OCR processing. If Completa later adds biometric capture, biometric identification, face recognition, voiceprint recognition, identity recognition, or hand/face geometry use for a commercial purpose, it must provide required notice, consent, retention, protection, and destruction controls before use.
6. Children and Age
The platform is intended for users age 18 or older. Completa does not knowingly collect personal data from children under 13. If Completa learns that a child under 13 has provided personal information without verifiable parental consent, Completa will promptly delete the information except as legally required to retain it, attempt to provide parental notice and review where Completa can identify a parent or guardian, and not condition participation in services on a child's disclosure of more information than reasonably necessary.
Completa does not knowingly create accounts for users under 18. If Completa learns that a Texas user is under 18, Completa applies required protections under applicable youth online-safety and privacy laws, including the Texas Securing Children Online through Parental Empowerment Act, Tex. Bus. & Com. Code Chapter 509, parental notice/consent, restrictions on targeted advertising or sale of data to known minors, and account-management features where legally required.
7. Data Portability and Export
Completa provides account and email channels for export requests concerning account, project, payment, SOW, change-order, warranty, dispute, and Home Passport records, including saved-home assets, room and capture records, access grants, invitations, and sharing/access-request history attributable to the requester. Identity verification, third-party privacy, security, legal holds, and applicable statutory exceptions limit disclosure. A recipient's export does not expand the grantor's authorized fields or disclose another person's private content. Contact legal@completa.io for records unavailable in an automated download, correction or annotation, or former-user retrieval. Retained original transaction evidence may be annotated instead of overwritten when integrity or law requires.
8. Retention and Deletion Exceptions
Completa does not promise immediate deletion of project, payment, tax, SOW, dispute, warranty, fraud, safety, security, audit, or legal records when a deletion request is submitted. Completa may retain records as needed for tax, accounting, payment processing, payment-network reconciliation, contractor payout and 1099 support, sales/use tax support, dispute and warranty administration, fraud prevention, safety, legal compliance, audit, litigation, chargebacks, refunds, reserves, offsets, and unresolved claims.
The default retention period is seven years for transactional tax/accounting support records. Certain legal, tax, accounting, security, audit, settlement, litigation, unresolved-claim, and major-dispute records may be retained longer where required or permitted by law.
9. Deidentified, Aggregated, and Pseudonymized Data
Pseudonymization replaces identifying fields or separates identifying information as a safeguard; pseudonymous records may remain personal data and do not automatically escape retention, security, or rights duties. Any statutory pseudonymous-data exception requires its specific conditions, including effective separation and controls, to be satisfied. Aggregation is not deidentification if a person can still reasonably be identified.
For legally deidentified data, Completa takes reasonable measures to prevent association with an individual and publicly commits to maintaining and using the data without attempting to reidentify it. Completa contractually requires recipients to preserve these protections and comply with applicable deidentification duties, exercises reasonable oversight of recipient commitments, and addresses breaches. Deidentified data may be used for analytics, estimation, quality, fraud prevention, and platform improvement within those limits. Keeping identifiable or pseudonymous data for a live purpose must separately satisfy the retention rules above.
10. Security Measures
Completa maintains administrative, technical, and organizational safeguards appropriate to the data processed, including access controls, least-privilege permissions, authentication controls, encryption in transit, encryption at rest where supported by platform infrastructure, vendor review for processors, audit logging for legal acceptance and sensitive admin actions, and incident-response procedures.
11. Breach Notice
If a reportable security breach occurs, Completa will notify affected individuals and regulators without unreasonable delay and within the time required by applicable law. For Texas residents, Completa will provide individual notice not later than the 60th day after determining that a breach occurred where Tex. Bus. & Com. Code §521.053 requires notice, subject to legally permitted delay or investigation exceptions.
12. Service Providers and Transfers
Completa uses service providers for payment processing, payout onboarding, AI/OCR processing, property and address enrichment, contractor screening, identity verification, cloud hosting, databases, communications, analytics, support, fraud/security, and professional services. Completa will provide current service-provider information through the privacy request channel or a published provider page when available.
Completa currently operates in the United States. Material international transfers, new processing regions, or broader state/international privacy-law coverage require updated disclosures or transfer mechanisms where required before expansion.
13. Home Passport Data and Recipients
Home Passport data may include saved-home associations and relationship labels, service and ownership-period records, household assets and identifiers, manuals and warranties, interior and exterior media, room measurements and client-declared scans, capture and location information supplied with content, costs, source/provenance and verification dates, access invitations and acceptances, permission scopes, sharing links, historical-record requests, expiry, revocation, and consent evidence. We use these records to provide the selected household-record, history, access, reporting, security, support, and rights-request features. A saved address or room diagram alone is not a biometric identifier; media location information may be precise geolocation when it identifies an individual's location.
Recipients include the verified people a user authorizes and, if the user creates a bearer share, anyone who obtains its valid link within the selected scope. Service providers process the information for the disclosed operational purpose. Saving a home does not give a later resident access to earlier residents' personal data. Historical disclosure needs the applicable record-specific authorization or other lawful basis, subject to third-party rights. Optional sharing, public marketing, and processing that legally requires consent need their own informed affirmative authorization; general acceptance alone does not supply it. The Home Passport and Authorized Access Addendum governs permission limits and link-copying risks.
14. Optional Household Content and Closure
The seven-year transaction-record schedule does not automatically apply to all optional Home Passport inventory, scans, or household media. Optional content is deleted or minimized when no longer necessary for its disclosed purpose, subject to a specific lawful retention need. On closure, access and sharing authorizations are revoked and optional personal household records are deleted or minimized; records needed for a surviving transaction, security investigation, dispute, warranty, tax obligation, or legal hold are restricted to that purpose. Retention requires a documented purpose and periodic review, not an indefinite household-history license. Saved copies already disclosed to recipients cannot be recalled; applicable requests and processor instructions address downstream data to the extent required by law.