Privacy Policy

scomm.ai Applications and Related Services

Effective Date: February 06, 2026

Last Updated: ___________________

INTRODUCTION

This Privacy Policy explains how scomm.ai ("Company," "we," "us," or "our") collects, uses, discloses, and protects personal information when you use:

Static website (https://www.scomm.ai)

Related services and applications

By using our services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this policy, please do not use our services.

DEFINITIONS

For the purposes of this Privacy Policy:

Paying Party
The individual or entity that holds an active paid subscription and is responsible for payment.
Using Party
An individual authorized by a Paying Party to use the services. One Paying Party may add multiple Using Parties.
Provider Node
A device or server running the SComm Connect product that provides connectivity services.
User ID
A unique identifier assigned to each user account for authentication and service access.
Device Identifier
A unique identifier assigned to each device (desktop, mobile, browser) used to access our services.
SSO (Single Sign-On)
Authentication through third-party identity providers (Google, Microsoft, etc.).
OTP (One-Time Password)
A temporary password sent via email for authentication.
P2P (Peer-to-Peer)
Direct communication between two devices without routing through our servers.
SDP (Session Description Protocol)
WebRTC protocol used to establish peer-to-peer connections.
ICE (Interactive Connectivity Establishment)
Protocol for finding the best path for peer-to-peer communication.
DTLS-SRTP
Encryption protocol used to secure peer-to-peer data transfers.
Canonicalized Email Address
Email address converted to a standard format before hashing.

SHA-256 Hash: A one-way cryptographic function that creates a unique fingerprint of data (non-reversible).

WHO WE ARE

scomm.ai is operated by:

Legal Entity Name
Media Routes Inc.
Registered Address
86-50 Burnhamthorpe Rd., W., Mississauga ON L5B 3C2
Province/Territory
Ontario
Country
Canada
Contact Email
privacy@scomm.ai

Website: https://www.scomm.ai

For data protection purposes, we act as a Data Controller for personal information collected through our applications and services.

OVERVIEW OF OUR SERVICES

Our service ecosystem consists of:

Infrastructure Servers:

Client Applications:

STATIC WEBSITE (scomm.ai)

Data Collection

Our static website collects minimal technical data:

Infrastructure-Level Data (Automatic):

CDN-level analytics (CloudFlare)

What We Do NOT Collect:

No advertising trackers

Purpose

Infrastructure data is collected for:

DDoS protection

Data Retention

Server logs
7 days

No long-term user tracking

Legal Basis

Legitimate interest in maintaining website security and performance.

BILLING PORTAL

Authentication Methods

Users can access the billing portal through:

Single Sign-On (SSO):

Other third-party identity providers

Email OTP (One-Time Password):

Valid for 10 minutes

Data Collected

Upon successful login, we create and store:

Paying Party Information:

Payment history (transaction IDs, amounts, dates)

Using Party Information:

Association with Paying Party

Multi-User Management:

Each Using Party receives independent access credentials

Purpose of Data Processing

Manage multi-user access

Payment Processing

PCI DSS compliance maintained through payment processors

Data Retention

Active subscriptions
Duration of subscription
Cancelled subscriptions
7 years (tax and accounting requirements)
Payment transaction records
7 years

Using Party associations: Until removed by Paying Party or account deletion

Legal Basis

Legal obligation (tax and financial record-keeping)

PUBLIC KEY SERVER (pubkey.scomm.ai)

Data Stored

This server stores cryptographic public keys for email encryption:

Key expiration date (if applicable)

Plain email addresses are stored to associate public keys with users and to ensure interoperability with standard email encryption systems. Hashes are used to support privacy-enhanced lookup mechanisms.

Public keys stored on our servers are intended for distribution and do not grant access to private communications.

Purpose of Data Processing

Support key rotation and updates

Email Hash Explanation

Why SHA-256 Hashes:

SHA-256 is a one-way cryptographic hash (cannot be reversed to obtain original email)

How It Works:

Hash is stored alongside the plain email address and public key

Data Retention

Public keys
Indefinitely until user deletes them
Email addresses
Indefinitely until user requests deletion

Expired keys: Marked as expired but retained for 90 days for verification purposes

Data Deletion

Users can delete their public keys at any time through:

Email request to privacy@scomm.ai

Legal Basis

Legitimate interest (secure communications)

CONNECT SERVER (connect.scomm.ai)

Data Stored

This server manages connections for the SComm Connect product:

Provider Node Information:

Geographic location (inferred from IP, for routing optimization)

User Access Control:

Multiple devices per user support

Connection Metadata:

WebRTC connection state

Purpose of Data Processing

Optimize connection routing based on geographic location

How Connections Work

Peer-to-Peer (P2P) Communication:

Once connected, data flows directly without passing through our servers

When Relay is Used:

Data is routed through relay.scomm.ai (see Section 9)

Encryption:

End-to-end encryption ensures we cannot read the content

Data Retention

Active Provider Node IP addresses
While Provider Node is online
Offline Provider Nodes
IP address deleted after 24 hours
Access Control Lists
Until user modifies or deletes
Connection metadata (SDP/ICE)
Deleted immediately after connection established

Device identifiers: Until user removes device or deletes account

Legal Basis

Legitimate interest (network security and optimization)

RELAY SERVER (relay.scomm.ai)

When Relay is Used

The Relay Server is used only when direct peer-to-peer communication is not possible due to:

Network topology restrictions

Data Handled

When data passes through our Relay servers:

Encrypted Data:

Data is immediately forwarded to destination

All data transmitted between systems is encrypted in transit using industry-standard protocols, and any stored data is protected using appropriate security measures

Metadata Collected:

Geographic location of relay server used

Purpose of Data Processing

Ensure service availability

What Relay Servers Do NOT Do

Do NOT share data with third parties

Data Logging

Temporary Handling:

Encrypted data is immediately forwarded

Metadata Logging:

Using Party ID and Paying Party ID
Logged for billing
Data volume
Logged for billing

Connection logs: Retained for 90 days for troubleshooting

Usage-Based Billing

Detailed usage reports available to Paying Party

Geographic Distribution

This may involve international data transfers (see Section 24)

Data Retention

Real-time data
Not stored (immediate forwarding)
Billing metadata (data volume, party IDs)
7 years (accounting requirements)
Connection logs
90 days

Usage reports: 7 years

Legal Basis

Legal obligation (billing and accounting records)

PUBLIC INFO SERVER (public.scomm.ai)

Data Served

This server hosts publicly accessible information:

.well-known Folder:

Authentication endpoints

Version Information:

Download links

Privacy Policy:

Historical policy versions

Other Public Resources:

Public announcements

Data Collection

What We Collect:

Request frequency (for abuse detection)

What We Do NOT Collect:

No behavioral analytics

Purpose

Abuse prevention and DDoS protection

Data Retention

HTTP request logs
7 days

Public content: Indefinitely (publicly accessible)

Legal Basis

Legitimate interest in providing public information and maintaining security.

DOWNLOAD SERVER (d.scomm.ai)

Service Description

The download server facilitates distribution of:

Desktop Applications:

Linux packages

AI Models:

Model updates and improvements

How It Works

AI models are hosted on CloudFlare CDN account

Data Collected

By Our Server:

Timestamp

By CloudFlare CDN:

Per CloudFlare's privacy policy

Purpose

Bandwidth optimization

AI Model Usage

Local Processing:

No user data is sent to remote AI servers

Currently, no third-party AI services are used for processing user data. If this changes in the future, this Privacy Policy will be updated accordingly.

Model Updates:

No personal data transmitted during update checks

Data Retention

Download request logs
30 days
Aggregate statistics
Indefinitely (anonymized)

CloudFlare logs: Per CloudFlare's retention policy

Legal Basis

Legitimate interest in software distribution and service improvement.

CLIENT APPLICATIONS (Desktop, Mobile)

Platform Availability

Desktop Applications:

Mobile Applications:

Email Service Integration

Our client applications integrate with:

Microsoft Mail APIs:

Custom domains hosted on Microsoft 365

Google APIs:

Custom domains hosted on Google Workspace

IMAP Access:

Custom IMAP configurations

For IMAP-based accounts, data is accessed only for user-requested operations and is not permanently stored on our servers unless explicitly required for functionality.

Authentication

Users may log into client applications when they need to:

Sync settings across devices

Authentication Methods:

OAuth tokens

Data Stored Locally

Client applications store on user's device:

Application Data:

Application logs (local only)

AI Models:

Updated periodically

Data NOT Stored on Our Servers

Email Content:

Processed entirely on user's device

Email Metadata:

Remain on user's device only

Email Account Credentials:

OAuth tokens managed locally

Local AI Processing

Models are updated via download server

Version Update Checks

No logging of individual update checks

Platform-Specific Privacy

Desktop Applications:

Use OS keychain/credential manager for secrets

Mobile Applications:

Comply with App Store/Play Store policies

GOOGLE API USAGE AND RESTRICTED SCOPES

For Google email services (Gmail, custom domains hosted on Google Workspace):

Scopes Used

scomm.ai uses the following Google API scopes:

How These Scopes Are Used

All data accessed through these scopes is processed primarily on the user’s device. We do not store email or contact content on our servers.

Access to this data occurs only when the user actively uses related features within the application.

These scopes are used ONLY for:

Local AI-powered search

These scopes are NEVER used for:

Any purpose unrelated to core application functionality

OAuth Permissions

When you grant OAuth permissions:

Revoking access will disable certain features but not delete your account

Microsoft Mail API Usage

For Microsoft email services (Outlook, Hotmail, Live, custom domains hosted on Microsoft 365):

Permissions Requested:

Contacts.Read

Usage:

Can be revoked through Microsoft Account settings

DATA USE RESTRICTIONS

In compliance with Google API Services User Data Policy, we declare:

What We DO:

What We DO NOT DO:

Limited Use Disclosure

scomm.ai's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

PURPOSE OF DATA PROCESSING

Authentication and Account Management

Data Collected: Email, name, SSO identifiers, login credentials

Purpose:

Enable SSO functionality

Billing and Payment

Data Collected: Billing address, payment tokens, transaction history

Purpose:

Comply with tax regulations

Encryption Services

Data Collected: Public keys, email addresses, SHA-256 hashes

Purpose:

Verify sender identity

Network Connectivity (SComm Connect)

Data Collected: IP addresses, device IDs, connection metadata

Purpose:

Optimize routing

Relay Services

Data Collected: Party IDs, data volume, connection metadata

Purpose:

Ensure service availability

Software Distribution

Data Collected: Download requests, IP addresses (temporary)

Purpose:

Prevent abuse

Security and Abuse Prevention

Data Collected: IP addresses, request metadata, logs

Purpose:

Maintain service integrity

Data Minimization We collect and process only the minimum amount of personal data necessary to provide, secure, and improve our services.

HOW WE USE YOUR INFORMATION

No Profiling or Behavioral Tracking We do not use your personal data for profiling, behavioral tracking, or cross-service tracking. We do not build user profiles for advertising or data monetization purposes.

Service Delivery

Distribute software updates and AI models

Account Management

Maintain access control lists

Billing and Subscriptions

Provide usage reports to Paying Parties

Communication

Provide service announcements

Analytics and Improvement

Improve AI models (using only aggregated, anonymized data)

Security

Enforce access controls

Data Minimization We collect and process only the minimum amount of personal data necessary to provide, secure, and improve our services.

No Automated Decision-Making We do not use your personal data for automated decision-making that produces legal or similarly significant effects.

Data Breach

In the event of a data breach affecting personal data, we will take appropriate steps to investigate, mitigate, and notify affected users and relevant authorities as required by applicable laws.

DATA RETENTION POLICY

Account Data

Active accounts
Duration of account relationship
Inactive accounts
2 years after last login

Deleted accounts: 30 days for recovery, then permanently deleted

Billing Data

Transaction records
7 years (tax and accounting requirements)
Payment tokens
Until subscription ends or updated
Invoices
7 years

Usage data (relay billing): 7 years

Public Keys

Active keys
Indefinitely until user deletes
Expired keys
Marked expired, retained 90 days for verification

Deleted keys: Immediately upon user request

Email Hashes

SHA-256 hashes
Retained while associated public key exists

Deleted: When user deletes public key or account

IP Addresses

Connect server (active nodes)
While Provider Node is online
Connect server (offline nodes)
24 hours after disconnection
Download server
30 days
Static website
7 days

Public info server: 7 days

Connection Metadata

SDP/ICE candidates
Deleted immediately after connection established
Connection logs
90 days

Relay metadata (billing): 7 years

Device Identifiers

Active devices
Until user removes device

Removed devices: Immediately deleted

Application Logs

Client-side logs
Stored locally, user controls retention
Server logs
90 days

Error logs: 90 days

Version Check Logs

Individual checks
Not logged

Aggregate statistics: Indefinitely (anonymized)

Marketing Preferences

Until user unsubscribes

DATA SECURITY

We implement industry-standard technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration.

Encryption

Data in Transit:

Perfect forward secrecy

Data at Rest:

Encrypted backups

Access Controls

Automated access revocation for terminated employees

Key Management

Private Keys:

Zero-knowledge architecture

Public Keys:

Integrity verified through cryptographic signatures

Authentication Tokens:

Secure storage and transmission

Authentication Safeguards

Device tracking and suspicious login detection

Network Security

Vulnerability scanning

Payment Security

Secure payment processor integration

Infrastructure Security

Incident response plan

Organizational Security

We do not allow human access to user email.

SECURITY & COMPLIANCE

Our services are built using privacy-by-design principles. This means we minimize data collection, process data locally on user devices wherever possible, and implement strong encryption and access controls to protect user information by default

Google OAuth Compliance

scomm.ai maintains compliance with Google's OAuth app verification requirements:

Limited Use requirements adherence

Industry Standards

CIS benchmarks for server hardening

Data Breach Response

In the event of a data breach:

Transparent communication throughout process

Vulnerability Disclosure

Regular security updates

CONTENT PRIVACY - WHAT WE NEVER ACCESS

Email Content

We NEVER:

Use email to train AI models

Your emails:

Are subject to your email provider's privacy policy

Email Metadata

We do not access or store [data] as part of normal operations and system design:

Folder/label information

Relay Server Content

Relay servers transmit encrypted data and do not have access to decryption keys or the ability to decrypt user communications.

Even when data passes through relay servers:

Only metadata is logged for billing (party IDs, data volume)

Connection Content

For SComm Connect peer-to-peer connections:

End-to-end encryption prevents us from reading data

Local AI Processing

Your data stays on your device

DATA SHARING AND THIRD PARTIES

Providers such as Cloudflare act as data processors on our behalf and process limited technical data (such as IP addresses and request metadata) to provide content delivery, caching, and security services. These providers operate under contractual data protection obligations.

Service Providers

We share limited data with trusted third-party service providers:

Payment Processors:

Who
Stripe, PayPal
What
Billing information, payment tokens, transaction details
Why
Process payments and subscriptions

Safeguards: PCI DSS compliance, contractual data protection

Cloud Infrastructure:

Who
CloudFlare (CDN), cloud hosting providers
What
IP addresses, download requests, CDN logs
Why
Distribute software, host services, DDoS protection

Safeguards: Data processing agreements, encryption in transit

Analytics Providers:

Who
Anonymous aggregate analytics only
What
Anonymized usage statistics (e.g., download counts)
Why
Service improvement

Safeguards: No personally identifiable information shared

Email Service Providers:

Who
Transactional email service (for OTPs, receipts)
What
Email addresses, transactional message content
Why
Send OTPs, receipts, notifications

Safeguards: GDPR-compliant providers, minimal data sharing

What We NEVER Share

Personally identifiable relay data

Legal Requirements

We may disclose information when legally required:

Enforce our terms of service

Transparency Where permitted by law, we may publish aggregated transparency information regarding government or legal data requests.

Legal Request Process:

We cannot disclose data we don't have (e.g., email content, private keys)

Business Transfers

In the event of merger, acquisition, or asset sale:

Encrypted private key backups remain encrypted (new entity still can't decrypt without your password)

No Data Sales

We do NOT allow third-party tracking on our services

COOKIES AND WEBSITE TRACKING

Static Website (scomm.ai)

Cookies Used:

None
We do not use cookies on our static website

Tracking:

No third-party analytics cookies

Billing Portal

Essential Cookies:

Cannot be disabled (necessary for functionality)

Optional Cookies:

Server Logs

What We Log:

Referrer (source page)

Purpose:

Performance optimization

Retention:

Static website
7 days
Download server
30 days

Billing portal: 90 days

We may collect limited technical logs (such as IP address, timestamps, and connection status) for security, debugging, and performance purposes. These logs do not include the content of communications.

CDN-Level Data Collection

CloudFlare (CDN Provider):

We receive only aggregate statistics

Your Controls

Ad blockers (though we don't have ads)

Do Not Track

Our minimal tracking approach means there's little to track anyway

INTERNATIONAL DATA TRANSFERS

Data Storage Locations

Primary Storage: Canada

Distributed Servers:

Relay servers
Multiple geographic locations (US, EU, Asia)
CDN
CloudFlare global network

Cloud infrastructure: May span multiple regions

Cross-Border Transfers

Your data may be transferred to and processed in countries other than your country of residence:

Other countries where relay servers are located

Safeguards

For transfers outside Canada/EU/UK:

Legal Mechanisms:

Contractual commitments from service providers

Technical Safeguards:

DTLS-SRTP encryption for relay data

Relay Server Locations

To optimize performance, relay servers are geographically distributed:

Asia-Pacific

When data passes through relay servers:

No content is stored (immediate forwarding)

Your Rights

You have the right to:

Request data be stored in specific regions (may limit functionality)

YOUR PRIVACY RIGHTS

Rights Under PIPEDA (Canada)

Access:

Request information about stored public keys and encrypted backups

Correction:

Request corrections to your records

Withdrawal of Consent:

May limit service availability

Complaint:

Rights Under GDPR (EU/UK)

Access (Article 15):

Understand how data is used

Rectification (Article 16):

Complete incomplete data

Erasure (Article 17) - "Right to be Forgotten":

Includes deletion of public keys, encrypted private key backups, authentication tokens

Restriction of Processing (Article 18):

Applicable in specific circumstances

Data Portability (Article 20):

Export public keys and encrypted private key backups

Objection (Article 21):

Object to direct marketing at any time

Automated Decision-Making (Article 22):

We do not use automated decision-making

Rights Under CCPA (California)

Right to Know:

Third parties with whom information is shared

Right to Delete:

Subject to exceptions (legal retention)

Right to Opt-Out:

Right to Non-Discrimination:

Rights Specific to Google Data

For data accessed via Google APIs (Gmail, Contacts):

Access:

Request copies of data we have about you (note
email content stays on Google's servers)

Deletion:

Revoke Google OAuth access anytime in Google Account settings

Portability:

Withdrawal:

Access Google Account → Security → Third-party apps → scomm.ai → Remove access

Complaints:

Response time: 30 days

Rights Specific to Microsoft Data

For data accessed via Microsoft APIs (Outlook, Hotmail, Live):

Withdrawal:

Access Microsoft Account → Apps and services → scomm.ai → Remove

How to Exercise Your Rights

Email
privacy@scomm.ai

Subject Line: Privacy Rights Request - [Type of Request]

Include:

Verification information (for security)

Response Time:

Extensions communicated if needed

Verification
We may request additional information to verify your identity before fulfilling requests (to protect your data from unauthorized access).

No Fee: Requests are processed free of charge (unless manifestly unfounded or excessive).

Special Notes:

Cryptographic Data:

We can delete all cryptographic data upon request

What We Cannot Provide:

Decrypted private key backups (we don't have your password)

DATA DELETION PROCESS

For comprehensive information on how to delete your account and manage your data, please see our dedicated Delete Account page.

CHILDREN'S PRIVACY

Age Restriction

Users must be of legal age to form a binding contract

Parental Notification

If we discover we have collected information from a child:

Account will be terminated

Parental Rights

Parents or legal guardians may:

Contact us to exercise these rights

Contact Us

If you believe a child has provided information:

Email
privacy@scomm.ai
Subject
Child Privacy Concern

Include: Details of the situation

MARKETING COMMUNICATIONS

Types of Communications

Transactional Messages (cannot opt out):

Subscription expiration notices

Marketing Messages (can opt out):

Company news

Consent and Opt-Out

CASL Compliance (Canada):

We honor opt-out requests within 10 business days

You can opt out by:

Adjusting notification settings in the application

What Happens When You Opt Out

You can opt back in at any time

CALIFORNIA-SPECIFIC DISCLOSURES

Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information (as defined by CCPA):

Identifiers:

User IDs

Commercial Information:

Transaction records

Internet Activity:

Connection logs

Geolocation Data:

What We Do NOT Collect

Browsing history outside our services

Sources of Information

We collect personal information from:

Third parties (payment processors, identity providers)

Business Purposes

We use personal information for purposes described in Section 17 (How We Use Your Information).

Sharing for Business Purposes

We share information with service providers for business purposes as described in Section 22 (Data Sharing and Third Parties).

No Sale of Personal Information

We have not sold personal information in the past 12 months

California Shine the Light Law

California residents may request information about disclosure of personal information to third parties for direct marketing purposes.

Our Disclosure:

You may still request this information annually

How to Request:

Email
privacy@scomm.ai

Subject: California Shine the Light Request

CHANGES TO THIS PRIVACY POLICY

Updates and Modifications

We reserve the right to update this Privacy Policy at any time to reflect:

Changes to third-party services

Notice of Changes

Material Changes:

Continued use after effective date constitutes acceptance

Examples of material changes:

Changes to data retention periods

Non-Material Changes:

Continued use constitutes acceptance

Examples of non-material changes:

Minor edits for clarity

How We Notify You

Notice in client applications

Review and Acceptance

Continued use of our services after changes become effective constitutes acceptance of the updated policy.

If you do not agree with changes:

You can export your data before deletion

Version History

Previous versions of this Privacy Policy are available upon request:

Email
privacy@scomm.ai

Subject: Privacy Policy Version History Request

CONTACT INFORMATION

Privacy Inquiries

For privacy-related questions, concerns, or requests:

Email
privacy@scomm.ai

Subject Line: Privacy Inquiry

Mailing Address:

Security Concerns

For security-related reports:

Email
security@scomm.ai

Subject Line: Security Report

Data Protection Officer

If required by applicable law, you may contact our Data Protection Officer at:

Regulatory Authorities

You have the right to lodge a complaint with relevant supervisory authorities:

Canada
Office of the Privacy Commissioner of Canada Website: www.priv.gc.ca Phone: 1-800-282-1376
EU/UK
Your local data protection authority EU list: https://edpb.europa.eu/about-edpb/board/members_en

California: California Attorney General Website: oag.ca.gov California Privacy Protection Agency: cppa.ca.gov

Response Time

We strive to respond to all inquiries within:

Acknowledgment
5 business days
Complete response
30 days

Complex requests: 60 days (with notification of extension)

Business Hours

Support available:

Monday - Friday
9 AM - 5 PM EST

Emergency security issues: 24/7 response

ACCESSIBILITY

We are committed to ensuring this Privacy Policy is accessible to everyone.

Alternative Formats

If you have difficulty accessing this policy or require it in an alternative format, contact us:

Email
privacy@scomm.ai

Available formats:

Other formats as requested

Response Time

We will provide reasonable accommodations within 10 business days.

Website Accessibility

Our website follows WCAG 2.1 Level AA guidelines where possible.

If you encounter accessibility barriers:

Email
accessibility@scomm.ai

We will work to provide alternative access

LANGUAGE

This Privacy Policy is provided in English.

If translated versions are made available in the future, the English version prevails in case of conflicts or discrepancies.

Translation requests:

Email
privacy@scomm.ai

SUMMARY OF OUR PRIVACY COMMITMENTS

Privacy-First Architecture

What We Actually Collect

Account & Authentication
Billing (Paying Parties Only)
Encryption Services
Connectivity (SComm Connect)
Usage & Billing
What We Never Collect
Google API Compliance
Your Rights
Security Measures

Data Retention

ACKNOWLEDGMENT

By using scomm.ai applications and services, you acknowledge that you have read, understood, and agree to this Privacy Policy.

If you do not agree with this policy, please do not use our services.

Please also review our Terms of Service for additional information about your use of scomm.ai services.

Your Consent:

END OF PRIVACY POLICY