# PRUFLOW — Privacy Policy **Last updated: April 10, 2026** --- ## 1. Who We Are PRUFLOW is developed by **Prukario Inc.**, a corporation incorporated under the laws of the State of Delaware, United States. PRUFLOW is a free application that turns your mobile device into a virtual camera and microphone for your computer via local Wi-Fi or USB connection. For privacy inquiries: **privacy@prukario.ai** --- ## 2. Our Privacy Principle PRUFLOW was designed with privacy as a core principle. We do not require registration, we do not serve advertisements, and we do not monetize your data in any way. The sections below describe exactly what data exists, where it goes, and what controls you have. --- ## 3. Data We Do NOT Collect - **No personally identifiable information (PII):** We never ask for your name, email, phone number, or any personal details. - **No usage analytics:** We do not use Google Analytics, Firebase Analytics, Mixpanel, Sentry, or any third-party analytics or crash-reporting service. - **No cookies or trackers:** The Application does not use cookies, web beacons, tracking pixels, or advertising identifiers. - **No video or audio content:** Your camera and microphone streams travel directly between your mobile device and your computer over your local network. They never pass through our servers. - **No advertising data:** We do not collect, share, or sell data for advertising purposes. We have no advertisers. --- ## 4. Local Operation PRUFLOW operates primarily on your local network: - **Video and audio streams** travel directly from your mobile device to your computer via Wi-Fi (or USB). They never leave your local network and never pass through any external server. - **Pairing** uses a randomly generated session code that exists only in memory and is discarded when the application closes. - **Preferences** (such as resolution or audio settings) are stored locally on your device and are never transmitted externally. --- ## 5. Device Permissions PRUFLOW requests the following permissions, all of which are used exclusively for the application's core functionality: | Permission | Purpose | Data Destination | |---|---|---| | **Camera** | Capture video from your mobile device to use as a virtual webcam on your PC | Local network only (device to PC) | | **Microphone** | Capture audio from your mobile device to use as a virtual microphone on your PC | Local network only (device to PC) | | **Local Network / Wi-Fi** | Discover and communicate between your mobile device and PC | Local network only | These permissions are used solely to deliver video and audio from your mobile device to your computer. The captured content **never** leaves your local network. --- ## 6. Diagnostic Reports ### 6.1 What They Contain PRUFLOW generates local diagnostic logs in a proprietary binary format (.pflg) that contain **only technical information**: - Application version and platform (Windows, Android, iOS) - Operating system version - Hardware specifications (CPU model, RAM, GPU — no serial numbers or hardware IDs) - Performance metrics (frame rates, latency, bandwidth) - Error messages and stack traces - Module identifiers (e.g., video, audio, network) - A random session identifier (generated fresh each time the app starts) Diagnostic reports **do not contain**: your name, email, IP address, location, video or audio content, file contents, browsing history, or any other personally identifiable information. ### 6.2 Local Storage Diagnostic logs are stored on your device in the application's private data directory. They are **automatically deleted after seven (7) days**. The maximum size of a single log file is 5 MB. ### 6.3 Voluntary Upload You may choose to send a diagnostic report to Prukario by pressing the **"Send Report"** button. This action is **entirely voluntary** — PRUFLOW never transmits diagnostic data automatically. No diagnostic data leaves your device unless you explicitly choose to send it. When you upload a report, the following is transmitted to our server: - The .pflg binary file (containing only the technical data described in Section 6.1) - Your **erase token** (a random UUID generated on your device — see Section 7.1) - Your **install token** (a random UUID issued by our server for rate limiting — see Section 7.2) - An integrity signature (HMAC-SHA256) to verify the report has not been altered ### 6.4 What Happens on Our Server When we receive your diagnostic report: - Your **IP address is anonymized** before any logging or storage: IPv4 addresses are truncated to /24 (e.g., 192.168.1.x becomes 192.168.1.0/24), and IPv6 addresses are truncated to /48. The full IP address is used only in-memory for rate limiting and is **never persisted** to storage or logs. - The report is stored on cloud infrastructure operated by a reputable third-party service provider, with servers physically located in the **United States**. - The following metadata is associated with the stored report: platform, application version, log entry count, session start timestamp, and your erase token (if provided). - **No personal data** is stored alongside the report. ### 6.5 Data Retention Uploaded diagnostic reports are **automatically deleted after ninety (90) days** via an automated lifecycle policy. A short soft-delete grace period is maintained for data-integrity purposes, after which deletion is permanent and irreversible. You may delete your reports at any time before the 90-day period — see Section 8 (Right to Erasure). --- ## 7. Tokens and Identifiers PRUFLOW uses several tokens for security and privacy purposes. **None of these tokens constitute personally identifiable information.** ### 7.1 Erase Token - **What it is:** A random UUID (version 4) generated on your device the first time PRUFLOW launches. - **Where it is stored:** Locally on your device only. - **Purpose:** It is sent as a header with each diagnostic report upload so that you can later request deletion of all your reports without needing an account. It is your anonymous "key" to exercise your right to erasure. - **Your control:** You can view, copy, and regenerate your erase token in the application's settings. Regenerating the token means previous uploads will no longer be linked to your new token (and thus cannot be erased using the new token). ### 7.2 Install Token - **What it is:** A random UUID issued by our server when your PRUFLOW installation first registers. - **Where it is stored:** Locally on your device and on our backend, associated with your erase token, platform, and application version. - **Purpose:** Rate limiting — ensures each installation can upload at most one diagnostic report per 24-hour period, preventing abuse. - **What it is NOT:** It is not a user identifier. It contains no personal information. It cannot be used to identify you. - **Your control:** The install token is automatically regenerated if you regenerate your erase token. ### 7.3 Session Token (Pairing) - **What it is:** A 16-byte random value generated each time the PC application starts. - **Where it is stored:** In memory only — never written to disk, never sent to external servers. - **Purpose:** Authenticates your mobile device when it connects to your PC over the local network. ### 7.4 Device Attestation Token (Future) PRUFLOW may use platform-provided device attestation mechanisms (Google Play Integrity on Android, App Attest on iOS, or TPM-based attestation on Windows) to verify that diagnostic report uploads originate from genuine devices running authentic copies of the application. Attestation tokens are: - **Ephemeral:** Generated per-request and not stored. - **Non-identifying:** They verify device integrity, not user identity. They contain no personal information. - **Exchanged for a short-lived JWT** (15 minutes) signed by our server, used only to authenticate upload and erasure requests. --- ## 8. Your Right to Erasure (GDPR Article 17) You can delete **all** diagnostic reports you have uploaded at any time, without needing an account or contacting us: 1. Open PRUFLOW settings. 2. Go to the Privacy section. 3. Copy your **erase token** (or use the "Erase All Reports" button directly). 4. The application will send a deletion request to our server, which will locate and permanently delete all reports associated with your erase token. The server responds with the number of reports deleted. Deletion is **permanent** — deleted reports cannot be recovered after the 7-day soft-delete grace period. You may also contact us at **privacy@prukario.ai** to request erasure. --- ## 9. Data Retention Summary | Data | Location | Retention | |---|---|---| | Diagnostic logs (.pflg) | Your device | 7 days (auto-deleted) | | Uploaded reports | Our cloud infrastructure (United States) | 90 days (auto-deleted) | | Install token records | Our cloud infrastructure (United States) | Tied to erase token lifecycle | | IP addresses (full) | Server memory only | Duration of a single request (never persisted) | | IP addresses (anonymized to /24 or /48) | Operational server logs | Up to 90 days | | Video/audio streams | Local network only | Not stored | | Pairing tokens | Device memory | Until app closes | | Preferences | Your device | Until you uninstall | --- ## 10. International Data Transfers Prukario Inc. is based in the United States. When you voluntarily upload a diagnostic report, the data is processed and stored on cloud infrastructure located in the **United States**. If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, this constitutes a transfer of data outside your jurisdiction. Such transfers are carried out under appropriate safeguards that include **Standard Contractual Clauses (SCCs)** approved by the European Commission, as incorporated into our data processing agreement with our cloud infrastructure provider. These contractual safeguards are designed to ensure that your data receives a level of protection equivalent to that required under EU law. You may request information about the safeguards in place by contacting us at **privacy@prukario.ai**. --- ## 11. Service Providers We engage a limited number of third-party service providers to operate PRUFLOW's diagnostic reporting backend. These providers act strictly as **data processors** on our behalf and only process data to the extent necessary to deliver the services we have contracted from them. They are bound by written agreements that include confidentiality, security, and data-protection obligations. | Category | Purpose | Data Processed | |---|---|---| | Cloud infrastructure provider | Storage and processing of voluntarily uploaded diagnostic reports; authentication token signing; operational logging | .pflg files, request metadata, anonymized IP (no PII) | We do **not** use any analytics providers, advertising networks, social media SDKs, tracking pixels, or data brokers. We do not share data with any party for commercial, advertising, or profiling purposes. You may request the identity of our current service provider(s) by contacting **privacy@prukario.ai**. We reserve the right to change service providers at any time, provided that any new provider offers equivalent or stronger data-protection guarantees. --- ## 12. Data Security ### 12.1 Technical and Organizational Measures - All external communications use **HTTPS/TLS** encryption in transit. - Diagnostic reports include an **HMAC-SHA256 integrity signature** to detect tampering before they are accepted by our backend. - Server-side access to storage is controlled via short-lived, managed credentials — no long-lived connection strings or secrets are embedded in code. - Cryptographic keys used to sign authentication tokens are held in a hardware-backed key management service and are never exported from it; signing operations are performed remotely. - Upload idempotency prevents duplicate storage of the same report. - Rate limiting is enforced at multiple levels (per-IP and per-installation) to prevent abuse and denial-of-service attacks. - The full, unanonymized IP address is used only in volatile memory for rate limiting and is never written to persistent storage. - Diagnostic report contents are sanitized to redact known prompt-injection and control-sequence patterns before any internal review. - All storage of uploaded reports benefits from encryption at rest provided by our cloud infrastructure provider. ### 12.2 No Security Is Absolute While we implement commercially reasonable administrative, technical, and physical safeguards designed to protect the data described in this policy, **no system is completely secure** and we cannot guarantee absolute security. You acknowledge that you use the Application and upload any diagnostic report at your own risk. ### 12.3 Data Breach Notification In the unlikely event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, Prukario will: - **(a)** notify the competent supervisory authorities without undue delay and, where feasible, **within seventy-two (72) hours** of becoming aware of the breach, as required by Article 33 GDPR; - **(b)** communicate the breach to affected users without undue delay where the breach is likely to result in a **high risk** to their rights and freedoms, as required by Article 34 GDPR; - **(c)** comply with equivalent breach-notification obligations under other applicable laws (such as state breach-notification statutes in the United States). **Because PRUFLOW does not collect email addresses, phone numbers, or other direct contact information**, individual notification to users is not technically possible. Instead, notification to affected users will be provided through a combination of: - **(i)** prominent in-application notices within PRUFLOW on next launch; - **(ii)** a dedicated security notice published on our official website; and - **(iii)** any other public official channels we maintain. You are therefore advised to periodically open the Application and to check our website for security notices. --- ## 13. No Monetization of Data Prukario does not sell, rent, share, trade, or otherwise monetize your data — diagnostic or otherwise. We have no business model based on user data. PRUFLOW is and will remain free. --- ## 14. Children and Minors PRUFLOW is not directed at children under **13 years of age** (pursuant to the Children's Online Privacy Protection Act, COPPA, of the United States). If you reside in the European Economic Area (EEA), United Kingdom, or Switzerland, the minimum age is **16 years** (pursuant to GDPR). Since PRUFLOW does not collect personal data and does not require registration, we have no mechanism to determine user age. Parents and guardians are responsible for supervising the use of the Application by minors under their care. If we learn that we have inadvertently received diagnostic data from a child below the applicable minimum age, we will delete such data promptly. --- ## 15. Changes to This Policy We may update this Privacy Policy from time to time. Changes will be published in updated versions of the Application. The "Last updated" date at the top of this policy indicates when the most recent changes were made. Your continued use of the Application after the publication of an updated policy constitutes your acceptance of the changes. For material changes (such as new categories of data collection or new third-party processors), we will provide prominent notice within the Application. --- ## 16. Contact For privacy-related inquiries or to exercise your rights: - **Email:** privacy@prukario.ai - **Legal inquiries:** legal@prukario.ai - **Company:** Prukario Inc., State of Delaware, United States --- ## 17. Legal Basis for Processing (EEA, UK, and Swiss Users) For users in the European Economic Area, United Kingdom, and Switzerland, our legal bases for processing under Articles 6 and 9 of the GDPR (and the equivalent provisions of the UK GDPR and the Swiss Federal Act on Data Protection) are as follows: - **Consent — Article 6(1)(a) GDPR.** The voluntary upload and subsequent storage of diagnostic reports is based exclusively on your **explicit consent**. The upload occurs only when you manually press the "Send Report" button and complete any associated confirmation dialog. You may withdraw your consent at any time by (a) simply not uploading further reports, and/or (b) deleting previously uploaded reports using your erase token as described in Section 8. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. - **Legitimate interests — Article 6(1)(f) GDPR.** The brief, **in-memory-only** processing of your full IP address for the sole purpose of rate limiting uploads and protecting our backend against abuse, denial-of-service, and misuse is based on our legitimate interests in maintaining the security, availability, and integrity of the Application and its backend. The full IP is **never persisted** and is anonymized (truncated to /24 for IPv4 or /48 for IPv6) before any logging or storage. You have the right to object to this processing under Article 21 GDPR; however, objection may result in your uploads being rejected, as rate limiting cannot otherwise be enforced. - **Legal obligation — Article 6(1)(c) GDPR.** We may process data to the extent necessary to comply with legal obligations to which Prukario is subject, such as responding to valid legal process or complying with tax, accounting, or other regulatory requirements. We do **not** rely on contract performance (Article 6(1)(b)) as a legal basis, because no commercial contract for services exists between you and Prukario that would require the processing of personal data. We do **not** process any special categories of personal data (Article 9 GDPR). --- ## 18. Your Rights Under GDPR, UK GDPR, and Equivalent Laws If you reside in the European Economic Area, United Kingdom, Switzerland, or another jurisdiction that grants equivalent data subject rights, you have the following rights in relation to any personal data we hold about you. Because PRUFLOW is designed to collect the absolute minimum amount of data and does not associate uploads with any direct identifier, several of these rights may have a limited or null material application in practice — but we disclose them here in full for transparency. ### 18.1 Your Rights - **Right of access (Art. 15 GDPR):** You may request confirmation of whether we process data relating to you and, if so, a copy of that data and information about the processing. Because we only hold technical diagnostic data linked to a pseudonymous erase token, you will need to provide us with your erase token to help us locate any data associated with you, pursuant to Art. 11(2) GDPR. - **Right to rectification (Art. 16 GDPR):** You may request correction of inaccurate data concerning you. Because uploaded diagnostic reports reflect an immutable snapshot of a past technical state of your device, rectification is generally not materially applicable, but we will honor any legitimate request. - **Right to erasure ("right to be forgotten") (Art. 17 GDPR):** You may delete all your diagnostic reports at any time using your erase token, as described in Section 8. You may also contact us at privacy@prukario.ai to request erasure. - **Right to restriction of processing (Art. 18 GDPR):** You may request that we restrict processing of your data under certain circumstances (for example, while the accuracy of the data is contested). - **Right to data portability (Art. 20 GDPR):** You may request a copy of your uploaded diagnostic reports in a structured, commonly used, machine-readable format. The .pflg binary format used for diagnostic reports is openly documented and can be exported on request. - **Right to object (Art. 21 GDPR):** You may object, on grounds relating to your particular situation, to processing based on our legitimate interests (see Section 17). - **Right to withdraw consent (Art. 7(3) GDPR):** Where processing is based on your consent, you may withdraw that consent at any time, without affecting the lawfulness of processing based on consent before the withdrawal. - **Right not to be subject to automated decision-making (Art. 22 GDPR):** We do **not** engage in any automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you. ### 18.2 How to Exercise Your Rights To exercise any of these rights, contact **privacy@prukario.ai**. We will respond to your request **within one (1) month** of receipt in accordance with Art. 12(3) GDPR. This period may be extended by up to two further months where necessary, taking into account the complexity and number of requests; in such cases we will inform you of the extension and the reasons for the delay within the first month. There is no charge for exercising your rights, except where requests are manifestly unfounded or excessive, in particular because of their repetitive character, in which case we may either charge a reasonable fee or refuse to act on the request, in accordance with Art. 12(5) GDPR. We may need to verify your identity before responding. Because we do not hold direct identifiers, verification will typically take the form of confirming possession of the relevant erase token or install token. ### 18.3 Right to Lodge a Complaint with a Supervisory Authority **You have the right to lodge a complaint with a data protection supervisory authority**, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that our processing of data relating to you infringes data protection law (Article 77 GDPR). - A list of EU data protection supervisory authorities is available at: **https://edpb.europa.eu/about-edpb/about-edpb/members_en** - For residents of the **United Kingdom**, the supervisory authority is the **Information Commissioner's Office (ICO)**: https://ico.org.uk - For residents of **Switzerland**, the supervisory authority is the **Federal Data Protection and Information Commissioner (FDPIC)**: https://www.edoeb.admin.ch Exercising your right to lodge a complaint with a supervisory authority does not affect any other administrative or judicial remedy you may have, and we encourage you to contact us first at privacy@prukario.ai so that we can attempt to resolve your concerns directly. --- ## 19. California Residents — CCPA / CPRA If you are a California resident, the **California Consumer Privacy Act of 2018**, as amended by the **California Privacy Rights Act of 2020** (together, the "**CCPA**"), provides you with specific rights regarding "personal information" as defined by Cal. Civ. Code § 1798.140(v). This Section 19 supplements the other sections of this Privacy Policy with information required by the CCPA. ### 19.1 Categories of Information We Collect In the twelve (12) months preceding the "Last updated" date of this Privacy Policy, we have collected the following categories of information from California residents: | Category (Cal. Civ. Code § 1798.140(v)) | Collected? | Source | Purpose | |---|---|---|---| | Identifiers (name, address, email, IP, government ID) | **No** identifiers are collected, with the limited exception of **anonymized IP** (/24 or /48) in server logs | Directly from your device when you voluntarily upload a report | Security, fraud prevention, rate limiting | | Personal information under Cal. Civ. Code § 1798.80(e) | **No** | — | — | | Protected classifications (age, race, gender, etc.) | **No** | — | — | | Commercial information | **No** | — | — | | Biometric information | **No** | — | — | | Internet or network activity information | **Limited** — anonymized IP and technical diagnostic metadata only | Voluntary diagnostic uploads | Debugging, security | | Geolocation data (precise or approximate) | **No** | — | — | | Sensory data (audio, video, electronic) | **No** — audio/video streams never leave your local network | — | — | | Professional or employment information | **No** | — | — | | Education information | **No** | — | — | | Inferences drawn from the above | **No** | — | — | | Sensitive personal information (as defined by CPRA) | **No** | — | — | ### 19.2 Your Rights Under the CCPA - **Right to Know / Access.** You may request disclosure of: (i) the categories and specific pieces of personal information we have collected about you; (ii) the categories of sources; (iii) the business or commercial purpose for collection; and (iv) the categories of third parties with whom we share it. Our answer will generally be: **we do not collect personal information as defined under the CCPA**, with the limited exception of your anonymized IP address. - **Right to Delete.** You may request deletion of any personal information we have collected from you. To delete all uploaded diagnostic reports, use your erase token as described in Section 8, or contact **privacy@prukario.ai**. - **Right to Correct.** You may request correction of inaccurate personal information. Because we do not collect personal information to correct, this right will typically not have a material application. - **Right to Opt Out of Sale or Sharing.** **WE DO NOT SELL OR SHARE PERSONAL INFORMATION AS THOSE TERMS ARE DEFINED BY THE CCPA.** We have never sold or shared personal information for monetary consideration or for cross-context behavioral advertising, and we have no plans to do so. There is accordingly nothing to opt out of. Our website and Application do not display a "Do Not Sell or Share My Personal Information" link because we do not engage in any sale or sharing that would require one. - **Right to Limit Use of Sensitive Personal Information.** We do not collect sensitive personal information as defined by the CPRA, so there is nothing to limit. - **Right to Non-Discrimination.** We will not discriminate against you, deny you services, charge different prices, or provide a different level or quality of service because you exercised any CCPA right. ### 19.3 Retention As disclosed in Section 9 of this Privacy Policy, uploaded diagnostic reports are automatically deleted after ninety (90) days, and anonymized IP addresses are retained in operational server logs for up to ninety (90) days. ### 19.4 How to Exercise Your California Rights To submit a verifiable consumer request under the CCPA, contact **privacy@prukario.ai**. We will respond within the **forty-five (45) days** required by Cal. Civ. Code § 1798.130(a)(2). The response period may be extended by an additional forty-five days when reasonably necessary and with notice to you. Verification will typically take the form of confirming possession of the relevant erase token or install token, since we do not hold direct identifiers. You may also designate an authorized agent to make a request on your behalf, in which case we will require written proof of the agent's authority. ### 19.5 "Shine the Light" (Cal. Civ. Code § 1798.83) California Civil Code § 1798.83 permits California residents to request information regarding disclosure of personal information to third parties for those third parties' direct marketing purposes. **We do not disclose personal information to third parties for their direct marketing purposes.** --- *© 2026 Prukario Inc. All rights reserved.*