Smufye Agent — Privacy Policy (FIRST DRAFT)

IMPORTANT — READ THIS FIRST. This is a strong first draft prepared as part of an internal design review. It has NOT been reviewed by a licensed attorney and is NOT legal advice. Smufye Agent / RodwellHQ must have a licensed attorney review, finalize, and approve this Privacy Policy before it is relied on or published.

Last updated: September 26, 2026

This Privacy Policy describes how RodwellHQ, the parent company operating Smufye Agent ("RodwellHQ," "we," "us," or "our"), collects, uses, and shares information when you use the Smufye Agent website at agentsmufye.com and the API at api.agentsmufye.com (collectively, the "Service").

1. Information we collect

We collect the minimum information needed to operate the Service:

• Agent registration data. When you issue a passport (including through

the free live demo), we store the agent name you provide and any optional owner email address you submit. Agent names may be publicly visible through our verification and identity endpoints.

• Audit-log entries. Every passport issuance and revocation is written to

an audit log with a timestamp. Verifications are logged in limited form only (at most one verification record per passport per day). Entries include the event type, the agent identifier, any reason codes (for example, "bad_signature," "revoked," "expired"), and details needed to operate the Service. We do not store the contents of your agents' conversations or activities — only the issuance and verification events described above.

• Waitlist emails. If you join our billing waitlist, we store your email

address solely to notify you when billing launches. You can ask to be removed at any time.

• Usage and rate-limit data. To prevent abuse, we record IP addresses

(including IPv6 network prefixes), request timestamps, and endpoint hit counts. Rate-limit records are deleted automatically after the rate-limit window expires.

• Technical data. Our hosting provider may log standard request metadata

such as IP address, user agent, and request time for security and operations.

We do not intentionally collect government IDs, financial information, precise geolocation, or other sensitive personal data. If you provide personal information inside an agent name or optional email field (for example, using your real name as an agent name), that information will be stored and may be publicly visible — choose your agent names accordingly.

2. How we use information

We use the information we collect to:

• operate, maintain, and secure the Service, including issuing, verifying,

and revoking passports;

• maintain the audit log and investigate abuse, fraud, or security incidents;
• enforce rate limits and our Terms of Service;
• notify waitlist members when billing launches (waitlist emails are used

for this purpose only);

• respond to your requests and provide support;
• comply with legal obligations and respond to lawful requests from

authorities;

• improve the Service (in aggregate or de-identified form where feasible).

We do not sell your personal information, and we do not use it for advertising.

3. How we share information

• Public by design. Agent names, agent identifiers, verification results

(valid: true/false with reasons), and our issuer public key are public through the API. Do not put anything in an agent name that you would not want the public to see.

• Service providers. We use Cloudflare, Inc. to host the Service

(Workers, D1 database). Cloudflare processes request and storage data on our behalf as necessary to operate the Service.

• Legal requirements. We may disclose information if required by law,

court order, or subpoena, or if we believe disclosure is necessary to protect the rights, safety, or property of RodwellHQ, our users, or the public.

• Business transfers. If RodwellHQ is involved in a merger, acquisition,

or sale of assets, information collected through the Service may be transferred as part of that transaction, subject to the commitments in this Policy.

4. Data retention

• Audit-log entries (issuance, verification, and revocation events with

timestamps) are retained indefinitely as the permanent record of the Service, unless we adopt a defined retention schedule in the future.

• Agent and passport records are retained while the agent exists and in

the audit log thereafter.

• Rate-limit records are deleted automatically after the applicable

window expires.

• If a defined deletion or retention schedule is adopted later, we will

update this Policy.

5. Data security

We use reasonable administrative, technical, and organizational measures to protect information, including signing passports with keys held on our infrastructure and rate-limiting API endpoints. No system is completely secure, and we cannot guarantee absolute security. Our audit log is an operational record maintained by us; it is not independently certified, and we make no claim that it satisfies any specific regulation on your behalf.

6. Cookies and tracking

The Service does not currently use cookies, web beacons, or third-party analytics trackers. If we introduce them, we will update this Policy first.

7. Children's privacy

The Service is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us personal information, contact us at the address below and we will take steps to delete it.

8. International users

The Service is operated from the United States. If you access the Service from outside the United States, your information will be transferred to and processed in the United States, where data-protection laws may differ from those in your jurisdiction. By using the Service, you consent to that transfer. EU/UK users: our lawful basis for processing is our legitimate interest in operating the credential service you requested and compliance with legal obligations.

9. Your rights and choices

Depending on where you live, you may have rights to request access to, correction of, or deletion of your personal information, or to object to certain processing. To exercise these rights, contact us at [privacy contact email — to be added]. We will respond as required by applicable law. Note that audit-log entries that are necessary for the integrity and security of the Service may be retained even after a deletion request, to the extent permitted by law.

Because agent names and verification results are public by design, "deletion" of a published agent name may not remove copies already retrieved by third parties.

10. California privacy notice

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) as amended, including the right to know what personal information we collect, the right to request deletion, the right to correct inaccurate information, and the right not to be discriminated against for exercising these rights. We do not sell or share personal information as those terms are defined by the CCPA. To exercise your rights, contact us at [privacy contact email — to be added].

11. Changes to this Policy

We may update this Policy from time to time. We will post the revised Policy on the site with a new "Last updated" date. Material changes will be announced on the site; your continued use of the Service after the effective date constitutes acceptance.

12. Contact

Questions about this Policy or your information: [privacy contact email — to be added], RodwellHQ, [mailing address — to be added].