TurnAndTidy Privacy Policy

Effective Date: [EFFECTIVE DATE]
Last Updated: [MONTH YEAR]

DRAFT — LICENSED ATTORNEY REVIEW RECOMMENDED BEFORE PUBLICATION

This Privacy Policy explains how JHL, LLC (“JHL,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information in connection with TurnAndTidy.

TurnAndTidy is a multi-tenant software platform used by cleaning businesses to manage customers, properties, schedules, cleaners, job checklists, photographs, cleaning reports, invoices, and related business activities.

This Privacy Policy applies to:

cleaning businesses that subscribe to TurnAndTidy (“Subscribers”);
owners, administrators, employees, cleaners, contractors, and other users authorized by Subscribers (“Authorized Users”);
customers of Subscribers who use a TurnAndTidy Customer portal (“Customer Users”); and
visitors to TurnAndTidy websites and Subscriber landing pages.

1. Our Role

The nature of TurnAndTidy means that JHL handles personal information in two different capacities.

1.1 Information We Handle for Our Own Purposes

JHL determines how certain information is used when necessary to operate TurnAndTidy as a business and software platform.

This includes information used to:

create and secure accounts;
administer Subscriber relationships;
bill Subscribers for TurnAndTidy;
provide technical support;
communicate about the Service;
monitor usage and performance;
maintain platform security;
diagnose technical problems;
improve TurnAndTidy; and
comply with legal obligations.

1.2 Information We Process for Subscribers

Much of the information in TurnAndTidy is entered, collected, or generated by a Subscriber in connection with its own cleaning business.

Examples include:

Customer names and contact information;
property addresses and details;
cleaning instructions;
property-access information;
schedules;
cleaner assignments;
checklists;
job photographs and notes;
cleaning reports;
invoices; and
records of payments received by a Subscriber.

For this information, the Subscriber generally determines why the information is collected and how it is used, and JHL processes the information to provide the TurnAndTidy Service.

If you are a Customer User or Authorized User and have a privacy question specifically concerning information maintained by a cleaning business, you should generally contact that cleaning business first. We will cooperate with Subscribers as reasonably necessary to address applicable privacy requests.

2. Information We Collect

Depending on how you use TurnAndTidy, we may collect the following categories of information.

2.1 Account and Contact Information

This may include:

name;
email address;
telephone number;
username or account identifier;
company affiliation;
role and permissions;
login and authentication information; and
account status.

We may also maintain records concerning account creation, acceptance of applicable Terms, security events, account activity, and account administration.

2.2 Subscriber Business Information

For Subscribers, we may collect information such as:

business name;
business address;
contact information;
logos and branding;
subscription information;
administrative users; and
configuration and account settings.

2.3 Customer and Property Information

Subscribers may enter information concerning their Customers and properties, including:

names;
email addresses;
telephone numbers;
service addresses;
billing addresses;
property descriptions;
cleaning preferences;
special instructions;
service history; and
other property-related information.

2.4 Property-Access Information

TurnAndTidy may allow Subscribers to store sensitive property-access information such as:

door codes;
garage codes;
lockbox combinations;
alarm information;
entry instructions; and
similar information.

We refer to this information as “Access Information.”

Access Information is intended to be available only to persons authorized by the applicable Subscriber and only as needed for legitimate business purposes.

Because Access Information could create significant risk if improperly disclosed, Subscribers should collect and store only the Access Information reasonably necessary to provide their services.

2.5 Job, Checklist, Photograph, and Report Information

TurnAndTidy may process information generated in connection with cleaning jobs, including:

scheduled service dates and times;
cleaner assignments;
checklist responses;
job-completion information;
photographs;
notes;
observations concerning property condition;
reports of damage or other issues;
timestamps; and
cleaning reports generated from this information.

TurnAndTidy does not routinely remove metadata embedded in uploaded photographs.

Depending on the photograph and the device that created it, embedded metadata may include information such as:

date and time;
camera or device information;
image dimensions and orientation;
camera settings; and
location information, including geographic coordinates, if the device recorded that information.

This metadata may be retained with the photograph and may be processed, stored, or made available to authorized users along with the photograph.

Users who do not want particular metadata included with a photograph should configure their device appropriately or remove that metadata before uploading the photograph.

2.6 Subscriber Billing and Stripe

JHL uses Stripe to bill Subscribers for their TurnAndTidy subscription. This is the Subscriber's own subscription to the TurnAndTidy platform - separate from any money a Subscriber's Customers pay the Subscriber for cleaning services (see Section 2.7).

Subscribers never enter payment-card information into TurnAndTidy itself. A Subscriber Admin who wants to add or change a payment method, view invoices, or see billing history is redirected to Stripe's own hosted Billing Portal - a page served entirely from Stripe's domain. TurnAndTidy does not embed a payment form, Stripe Elements, Stripe Checkout, or any other card-entry component on its own pages, and JHL's servers do not receive, transmit, or store complete payment-card numbers or card security codes at any point.

JHL's systems communicate with Stripe through Stripe's application programming interfaces to create and manage:

Stripe Customer records (one per Company);
Stripe Subscriptions and the Stripe Price they are billed against;
Stripe Billing Portal sessions; and
discount coupons, when an Operator grants a Subscriber a comp or discount.

JHL's own database retains only:

the Stripe Customer and Subscription identifiers for the Company;
the identifier of the Stripe Price tied to the Company's Plan;
a coarse subscription/billing status (for example, active, past due, in a read-only grace period, suspended, or canceled) and, when applicable, when a grace period ends; and
whether an Operator has granted the Company a comp or discount, and its type.

JHL does not receive or store payment-method identifiers, card brand, card last-four digits, expiration date, or billing name or address - that information exists only within Stripe and is visible to a Subscriber solely through the Stripe-hosted Billing Portal.

Stripe independently processes payment information in accordance with its own privacy, security, and legal obligations.

2.7 Payments Between Subscribers and Their Customers

During the current pilot, TurnAndTidy does not process payments from Customer Users to Subscribers.

Subscribers may manually record payments they receive through cash, check, or other means.

TurnAndTidy may therefore store information such as:

invoice numbers;
service charges;
amounts due;
payment dates;
payment methods recorded by the Subscriber; and
payment status.

These records are supplied by the applicable Subscriber and do not represent independent verification by JHL that funds were transferred, received, cleared, or refunded.

2.8 Communications and Support Information

If you contact JHL, we may collect:

the contents of your communication;
your contact information;
support requests;
troubleshooting information; and
records of our communications with you.

2.9 Technical and Usage Information

When you use TurnAndTidy, our systems may automatically receive or record information such as:

Internet Protocol address;
browser type and version;
device type;
operating system;
referring page;
requested page or application feature;
dates and times of access;
account or session identifiers;
authentication activity;
application errors;
diagnostic information; and
security events.

We use this information for purposes including security, system administration, troubleshooting, performance monitoring, fraud prevention, and understanding how the Service is used.

3. First-Party Traffic and Application Monitoring

TurnAndTidy does not currently use Google Analytics or any other third-party website analytics or advertising-tracking service.

We use first-party traffic and application monitoring operated by or for JHL. This may record information such as:

IP addresses;
request paths;
dates and times;
browser or user-agent information;
referring pages;
account or tenant identifiers;
application events;
response status;
errors; and
performance information.

First-party monitoring is used for security, troubleshooting, performance analysis, capacity planning, fraud and abuse prevention, and improving TurnAndTidy.

If we begin using third-party analytics, advertising, or cross-context behavioral tracking technologies, we will update this Privacy Policy and provide any legally required choices before doing so.

4. How We Use Personal Information

We may use personal information to:

provide, operate, and maintain TurnAndTidy;
create and administer accounts;
authenticate users and manage permissions;
provide scheduling, checklist, reporting, invoicing, and Customer portal functionality;
make Subscriber-authorized information available to Authorized Users and Customer Users;
generate cleaning reports and other requested documents;
send transactional emails and notifications;
bill Subscribers for TurnAndTidy subscriptions;
provide technical and Customer support;
diagnose and correct errors;
measure Service performance and usage;
maintain the security and integrity of the Service;
prevent fraud, unauthorized access, and misuse;
develop and improve TurnAndTidy;
enforce our agreements and policies;
comply with applicable laws and legal processes; and
protect the rights, safety, and property of JHL, our users, Subscribers, Customers, and others.

When we process information on behalf of a Subscriber, we also use that information as reasonably necessary to provide the functionality requested by that Subscriber.

5. Pilot/Beta Data Practices

TurnAndTidy is currently an early-stage pilot/beta product.

Features, workflows, infrastructure, service providers, and technical architecture may change as the Service develops.

Those changes may affect how personal information is processed.

If we materially change our privacy practices, we will update this Privacy Policy and provide additional notice where required by applicable law.

The pilot status of TurnAndTidy does not reduce our obligation to use reasonable measures to safeguard personal information.

6. How We Disclose Personal Information

We may disclose personal information in the following circumstances.

6.1 Subscribers and Their Authorized Users

Information associated with a Subscriber's account may be available to the Subscriber and to Authorized Users whom the Subscriber permits to access it.

For example, a cleaner assigned to a property may be permitted to see information needed to perform that work, including applicable Access Information.

Subscribers control the permissions granted to their personnel, subject to functionality provided by TurnAndTidy.

6.2 Customer Users

TurnAndTidy may make information available through Customer portals, including:

schedules;
cleaning reports;
photographs;
notes;
invoices; and
payment status.

The applicable Subscriber determines what business information is made available to its Customers through the Service.

6.3 Service Providers

We may use third-party providers to help operate TurnAndTidy, including providers of:

hosting and infrastructure;
data storage and backup;
email delivery;
authentication and security;
monitoring and error reporting;
analytics;
customer support; and
subscription payment processing.

These providers may process personal information as appropriate to perform services for us, subject to applicable contractual and legal requirements.

Current material service providers include Stripe for Subscriber payment processing.

6.4 Legal Requirements

We may disclose information where we reasonably believe disclosure is necessary to:

comply with applicable law;
respond to valid legal process;
comply with a court order or governmental request;
investigate fraud or unlawful conduct;
protect the security of TurnAndTidy;
protect the rights or safety of another person; or
establish, exercise, or defend legal claims.

Where legally permitted and reasonably practicable, we may notify the affected Subscriber or user before responding to a legal demand.

6.5 Business Transactions

If JHL or TurnAndTidy is involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction, personal information may be disclosed or transferred as part of that transaction.

6.6 With Your Direction or Consent

We may disclose information when you or the applicable Subscriber directs or authorizes us to do so.

7. Sale of Personal Information and Advertising

TurnAndTidy does not currently sell personal information for monetary consideration.

TurnAndTidy also does not currently use personal information collected through the Service for personalized or cross-context behavioral advertising, and does not currently use any third-party analytics or advertising service.

If these practices materially change, we will update this Privacy Policy and implement any notices or opt-out mechanisms required by applicable law.

8. Artificial Intelligence and Model Training

TurnAndTidy does not use Customer personal information, Subscriber Data, property information, Access Information, uploaded photographs, cleaning reports, or other user content to train general-purpose large language models or foundation models.

If TurnAndTidy later introduces features that send user information to third-party artificial-intelligence services, this Privacy Policy will be updated as appropriate before or when those features are deployed.

Access Information will not knowingly be used to train general-purpose artificial-intelligence models.

9. Cookies and Similar Technologies

TurnAndTidy uses a small number of first-party cookies, all strictly necessary for the Service to function:

an authentication cookie, so you stay signed in as you navigate;
a security cookie used to protect forms and requests against cross-site request forgery; and
a short-lived cookie used to carry a one-time confirmation or error message from one page to the next.

TurnAndTidy does not currently set any analytics, advertising, or cross-site tracking cookies.

We do not currently use cookies for personalized advertising or cross-site behavioral advertising.

Where applicable law requires consent or another privacy choice for particular cookies or tracking technologies, we will provide an appropriate mechanism.

10. Data Security

We use administrative, technical, and organizational measures intended to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

The safeguards appropriate for particular information may vary based on its sensitivity.

Because TurnAndTidy may contain Access Information and other information concerning private residences, we consider this information particularly important to protect.

Payment-card information used for Subscriber billing is collected entirely by Stripe through its own hosted Billing Portal, so JHL never receives or stores complete card numbers or security codes.

However, no Internet transmission, cloud service, computer system, or storage system can be guaranteed to be completely secure.

Subscribers and users also have responsibilities for security, including:

protecting account credentials;
using appropriate permissions;
disabling accounts that are no longer required;
maintaining accurate Access Information; and
avoiding unnecessary collection or disclosure of sensitive information.

If we become aware of a security incident affecting personal information, we will investigate and provide legally required notifications where applicable.

11. Data Retention

We retain personal information for only as long as reasonably necessary for the purposes for which it was collected, subject to legitimate business needs and applicable legal obligations.

Retention periods depend on the type of information and the context in which it is processed.

In general:

Account information may be retained while an account remains active and for a reasonable period afterward for security, support, legal, and administrative purposes.
Subscriber business, subscription, invoice, and billing records may be retained as necessary for accounting, tax, contractual, dispute-resolution, and legal purposes.
Customer, property, job, checklist, photograph, report, and invoice information generally remains associated with the applicable Subscriber account while needed to provide the Service or as directed by the Subscriber.
Photograph metadata generally remains with the associated photograph unless removed through a later processing or deletion process.
Security, server, application, and first-party traffic logs may be retained for a reasonable period necessary for security, fraud prevention, troubleshooting, analytics, and system administration.
Support communications may be retained for support history, training, dispute resolution, and other legitimate business purposes.
Backup copies may remain for a limited period after information is removed from active systems until backups are rotated or deleted.

We may retain information longer where necessary to:

comply with law;
preserve evidence;
resolve disputes;
prevent fraud or abuse; or
establish, exercise, or defend legal claims.

When information is no longer reasonably required, we may delete, anonymize, or aggregate it.

[IMPLEMENTATION REVIEW: Before production launch, establish an internal written retention schedule, particularly for Access Information, terminated Subscriber accounts, uploaded photographs, application logs, and backups.]

12. Privacy Rights

Depending on where you live and which privacy laws apply, you may have rights regarding your personal information.

These may include rights to:

confirm whether personal information is processed;
access personal information;
obtain a copy of certain information;
correct inaccurate information;
request deletion;
withdraw consent where applicable;
opt out of certain sales or disclosures;
opt out of targeted advertising;
opt out of certain profiling; and
appeal certain privacy-request decisions.

We will not unlawfully discriminate against you for exercising applicable privacy rights.

12.1 Information Controlled by a Subscriber

If your request concerns information maintained by your Cleaning Company—for example, your property record, cleaning reports, photographs, service history, or invoice records—the Cleaning Company may be responsible for responding to the request.

You should generally contact the Cleaning Company directly.

Where JHL processes that information on the Subscriber's behalf, we will provide reasonable assistance as required by applicable law and our agreement with the Subscriber.

12.2 Information Controlled by JHL

For requests concerning information JHL maintains for its own purposes, contact:

[PRIVACY REQUEST EMAIL]

We may need to verify your identity before fulfilling a request.

Certain information may be retained or excluded from a request where permitted or required by law.

13. State Privacy Laws

Certain U.S. states provide additional privacy rights when statutory applicability requirements are satisfied.

JHL will honor rights required by applicable state privacy laws.

TurnAndTidy is currently a pilot product, and not every state privacy statute necessarily applies to JHL merely because a resident of that state uses the Service.

As TurnAndTidy grows, we will periodically review applicable requirements and update this Privacy Policy as appropriate.

13.1 Vermont

JHL is based in Vermont.

Vermont has enacted comprehensive consumer privacy legislation scheduled to become effective January 1, 2028 and applicable to businesses meeting specified statutory requirements.

We intend to review TurnAndTidy's practices before that law becomes applicable and implement additional requirements applicable to JHL.

13.2 Other States

Residents of California and certain other states may have additional rights where JHL falls within those states' applicable privacy laws.

If applicable law requires additional notices, request procedures, opt-out mechanisms, or disclosures, we will provide them.

14. Browser Privacy Signals

Because TurnAndTidy does not currently sell personal information or use it for personalized or cross-context behavioral advertising, browser-based opt-out signals do not currently change a sale or targeted-advertising setting within TurnAndTidy.

If our practices change such that applicable law requires recognition of browser-based privacy preference signals, we will implement appropriate support.

15. Minors

TurnAndTidy is not designed or directed to children under 13.

We do not knowingly permit individuals under 13 to create TurnAndTidy accounts.

TurnAndTidy is primarily a business application. In some circumstances, an individual between the ages of 13 and 17 may use TurnAndTidy as an Authorized User in connection with work performed for a Subscriber.

Subscribers are responsible for ensuring that any minor whom they authorize to use TurnAndTidy:

may lawfully perform the applicable work;
may lawfully be given access to the applicable Customer and property information;
receives any notices or permissions required by law; and
uses the Service only for legitimate authorized purposes.

When a minor uses TurnAndTidy as an Authorized User, we may process the same categories of work-related account, scheduling, job, technical, and usage information that we process for other Authorized Users.

We do not intentionally use a minor Authorized User's personal information for personalized advertising.

If we learn that we have collected personal information directly from a child under 13 in circumstances prohibited by applicable law, we will take appropriate steps to address or delete that information.

[ATTORNEY REVIEW: Confirm the treatment of teenage Authorized Users under applicable youth-privacy laws before broader deployment.]

16. Third-Party Websites and Services

TurnAndTidy may contain links to websites or services operated by Subscribers or other third parties.

This Privacy Policy does not govern the independent privacy practices of those third parties.

A Cleaning Company may also collect information from you independently of TurnAndTidy. Questions about a Cleaning Company's independent collection or use of personal information should be directed to that company.

17. Email and Transactional Communications

We may use contact information to send communications necessary to operate TurnAndTidy, including:

account messages;
security notices;
password-related communications;
job or schedule notifications;
cleaning reports;
invoice notifications;
subscription and billing notices;
support communications; and
notices concerning the Service.

Certain transactional communications are necessary to provide the Service and may not offer an unsubscribe option.

Where we send marketing communications subject to an opt-out right, we will provide an appropriate method to unsubscribe.

18. Changes to This Privacy Policy

TurnAndTidy is an evolving pilot product, and our privacy practices may change as the Service develops.

We may update this Privacy Policy from time to time.

When we make material changes, we will provide reasonable notice through TurnAndTidy, by email, or through another appropriate method where required.

The date at the top of this Policy identifies when it was most recently updated.

If a change requires consent under applicable law, we will request that consent as required.

19. Contact Us

Questions about this Privacy Policy or JHL's privacy practices may be directed to:

JHL, LLC
[REGISTERED BUSINESS ADDRESS]
[PRIVACY / CONTACT EMAIL]

Privacy requests may be submitted to:

[PRIVACY REQUEST EMAIL]