Data Policy
Version 2.0 · Last updated: 2026-10-18
Correction, 18 October 2026. The international-transfers paragraph below had said that the 2021 Standard Contractual Clauses are incorporated by reference in each subprocessor's Data Processing Addendum. Not every Addendum does: some apply the clauses only to a transfer that needs them. The paragraph now says so.
Correction, 8 October 2026. The subprocessor list below now names Google Workspace, which hosts our own mailbox and the form behind the site feedback widget, and says that Resend also sends the contact-form email and the guide email series. Both were existing recipients that the list had left out.
Correction, 29 September 2026. We corrected this page to describe what our systems actually do. It had said that API keys were stored hashed, that stored data was encrypted at rest by our database provider, that only shortened IP addresses were kept and that query parameters were never logged, and it gave backup and after-cancellation retention periods that the code does not follow and did not say how long watchlists, webhooks and the Stripe customer reference are kept. We also removed statements we could not check. On the same date, erasure was changed so that it also deletes keys deactivated before the request and reports an erasure it could not finish, watchlists, webhooks and daily RapidAPI counts now expire (if setting an expiry ever fails, a cleanup we run at every deploy sets it, or deletes the record if it should already have expired), and two application log lines stopped recording which record was requested.
This policy explains how Holistic Quality LLC ("HQ," "we," "us") collects, uses, stores, and deletes data across the HQ ecosystem, including holisticquality.io, aletheia.holisticquality.io, api.aletheia.holisticquality.io, safety.holisticquality.io, dimensionalliteracy.org, csl.dimensionalliteracy.org, and related support flows. It is the controller-level source of truth for privacy claims made across our public properties. Where the ALETHEIA website privacy notice or API-served privacy pages provide additional implementation detail, those details must remain consistent with this policy on controller identity, retention, subprocessors, rights, and contact information.
The Short Version
We collect the minimum data required to operate the service. We do not sell it, share it with advertisers, or build profiles on you. Your API usage is yours. Some of what you send us is stored because it is what you ask us to keep: your email address (for a trial, a paid key, key recovery or an erasure request), the record IDs you save to a watchlist, your webhook registrations, enterprise-inquiry messages (kept 30 days), and the email address you give for a free guide or on the contact form (kept 30 days and 24 hours respectively, only to avoid sending twice; a guide request also keeps the schedule of its follow-up emails for 30 days). If you unsubscribe from any of our emails, we keep a record of that (see the retention table). Our hosting provider also logs the path of every request, which names the record requested (see below). We do not use your requests for advertising, model training, or competitive profiling.
Scope and Roles
Holistic Quality LLC is the data controller for the customer and visitor data described in this policy.
- Direct-issued ALETHEIA accounts — Holistic Quality LLC is the controller.
- RapidAPI marketplace users — RapidAPI (R Software Inc.) is an independent data controller for its users' account, billing, and KYC data under its own privacy policy. RapidAPI is not a subprocessor of Holistic Quality. Holistic Quality receives only your RapidAPI username, your subscription tier and usage metadata, which are needed to authenticate, route, secure, and meter API calls; we do not receive your name, email address, or payment details from RapidAPI.
- Website visitors and all other flows — Holistic Quality LLC is the controller.
What We Collect
For direct-issued ALETHEIA trials and subscriptions:
- Email address — used for account setup, key delivery, service notices, and verified privacy requests.
- Organization name (optional) — provided for enterprise or billing context.
- API key record, which holds the key itself — used to authenticate access and manage subscription state.
- Subscription and trial status — plan tier, renewal state, key status.
- Stripe customer reference — used for billing reconciliation. We never receive or store full card numbers.
API request metadata (collected for every call):
Our hosting provider (Vercel) logs every request: the time, the request path including any query parameters, the HTTP status code, your full IP address and your User-Agent. These logs are kept for 30 days. Our own database keeps, for each API key, the time it was last used and the IP address it was last used from, truncated to a /24 subnet for IPv4 (e.g., 203.0.113.0) or a /112 subnet for IPv6; that record is deleted after 90 days. These records are used for rate limiting, abuse detection, security and debugging, and never to profile you or anyone else.
For website visitors:
- Server and security logs processed by Vercel (full IP address, User-Agent, request path including query parameters, timestamp, error details). For holisticquality.io, aletheia.holisticquality.io, api.aletheia.holisticquality.io and safety.holisticquality.io, these logs are kept for 30 days.
- Privacy-respecting aggregated analytics (Vercel Analytics) used only to understand page usefulness. No advertising pixels or cross-site tracking.
What We Do Not Collect
- Full payment card numbers or bank account credentials (handled directly by Stripe).
- Advertising identifiers, data-broker segments, or behavioral profiling data.
- Browser fingerprinting for advertising or cross-site profiling.
- Data about the end users of applications you build with our API (unless you send it to us directly in a support workflow).
- Biometric, health, genetic, or government-issued identification data.
How We Use Data
- Service delivery — issuing and validating keys, enforcing plan limits, routing requests.
- Security and abuse prevention — detecting credential abuse, scraping, denial-of-service, and other misuse.
- Operations and reliability — debugging, uptime monitoring, performance improvement via aggregate statistics.
- Billing and account administration — subscriptions, invoices, cancellations, refunds, chargeback reconciliation.
- Communications — service notices, key delivery, security advisories, support responses.
- Legal compliance — responding to lawful requests, enforcing terms, documenting privacy-rights handling.
Legal Bases for Processing
For users located in the European Economic Area, the United Kingdom, and other GDPR-aligned jurisdictions, we process personal data under the following lawful bases (GDPR Art. 6):
- Performance of a contract (Art. 6(1)(b)) — processing your email, API key, and subscription state is necessary to deliver the API service you purchased.
- Legitimate interests (Art. 6(1)(f)) — logging IP addresses and request metadata is necessary for our legitimate interest in securing the API, preventing abuse, enforcing rate limits, and ensuring operational stability. We balance these interests against your rights and limit collection to what is strictly necessary.
- Legal obligation (Art. 6(1)(c)) — retaining financial transaction records to comply with corporate tax, accounting, and dispute-resolution obligations.
- Consent (Art. 6(1)(a)) — where we ask for consent (for example, optional analytics preferences), you may withdraw it at any time without affecting the lawfulness of prior processing.
How Data Is Stored and Shared
Core ALETHEIA account and key records are stored in Upstash Redis hosted on AWS eu-west-1 (Ireland). Website and application infrastructure runs on Vercel. Transactional email is sent through Resend. Our own mailbox and the form behind the site feedback widget are hosted by Google Workspace. Payments are processed by Stripe.
Our canonical subprocessor list (all tiers must mirror this exactly):
- Cloudflare — DNS only. No website traffic, logs or personal data pass through Cloudflare.
- Vercel — website hosting, serverless execution, infrastructure logs. Privacy Policy · DPA
- Upstash — managed Redis (eu-west-1). Privacy Policy · DPA
- Resend — transactional email, contact-form email and the guide email series. Privacy Policy · DPA
- Google Workspace — hosts our own mailbox and the form behind the site feedback widget (contact-form messages, replies to our emails and feedback reports reach it). Not a sub-processor of Customer Personal Data under our DPA. DPA · Subprocessors
- Stripe — payment processing. Privacy Policy · DPA
We do not share personal data with advertisers. We may disclose data to law enforcement or other third parties only when required by law, legal process, or a good-faith need to protect rights, safety, or service integrity.
Regulatory-Currency Data Sources
ALETHEIA checks the California Proposition 65 list automatically each week; the other sources below are consulted when a record is reviewed or corrected. There is no automated monitoring of recalls or enforcement actions. These checks read only public, sanctioned data endpoints under an honest, self-identifying User-Agent, and flag possible changes — they never republish bulk source datasets. Where we surface information derived from these sources, we attribute it as follows. No source listed here endorses Holistic Quality LLC, the ALETHEIA API, or any of our products or findings; attribution does not imply agency endorsement.
- Regulations.gov (US Federal rulemakings) — US Government public-domain material.
- US Food and Drug Administration (openFDA, warning letters, import alerts) — "Source: US FDA (not an FDA endorsement)."
- US Environmental Protection Agency (ECHO enforcement) — "Source: US EPA."
- US Consumer Product Safety Commission (recalls) — "Source: US CPSC."
- European Medicines Agency (direct healthcare-professional communications / safety) — "Source: European Medicines Agency."
- EU Safety Gate / RAPEX (product alerts) — "© European Union — Source: EU Safety Gate (RAPEX)." Reused under the European Commission reuse policy (Decision 2011/833/EU, CC BY 4.0).
- US National Toxicology Program — Report on Carcinogens (RoC), 15th Edition (carcinogen classification status) — "Source: US NTP Report on Carcinogens (public domain)."
- California OEHHA — Proposition 65 list (carcinogen listing status and listing date) — "Source: California OEHHA Proposition 65."
- IARC Monographs (carcinogen group) — cited per compound to its specific monograph as a fact (e.g. "IARC Monographs Vol. 100F: Group 1"); we do not republish IARC's copyrighted List of Classifications.
Of 7,244 regulatory classifications, exposure limits and reference values on our compound records, and regulatory classifications, restrictions and migration limits on our material records, 3,444 cite a source and 1,063 are archived with a fingerprint and a confirming quote from that source. Automated checks only flag candidate changes; they never set a regulatory value on their own.
International Transfers
Holistic Quality LLC is based in Ohio, USA. Upstash processes API key data in the European Union (eu-west-1, Ireland); the other subprocessors above may process data in the United States or across global networks. Where applicable law requires safeguards for a transfer, we rely on the transfer mechanism in the subprocessor's Data Processing Addendum, including the European Commission's 2021 Standard Contractual Clauses where that Addendum provides for them. Some Addenda apply the clauses only to a transfer that needs them (for Google, where Google has not adopted an Alternative Transfer Solution for the transfer). Per-processor transfer-mechanism status (SCC execution, EU-US Data Privacy Framework participation) is tracked at /api/compliance.
Data Retention
We keep identifiable data only for as long as needed for the specific operational, security, or legal purpose that justified collecting it. This is our canonical retention matrix — all other HQ-ecosystem documents must reference this table exactly.
| Data Category | Retention Period | Legal Basis |
|---|---|---|
| Email + API key (active subscription) | Key record: up to 2 years after the key was last used (a paid key that is never used: 2 years after it is issued; a trial key that is never used: 14 days after it is issued). The Stripe customer reference, which holds your email, is kept for up to 5 years from checkout while the subscription is active, and 90 days after cancellation. | Contract performance (Art. 6(1)(b)) |
| Email + API key (post-cancellation) | The key record keeps its remaining time (up to 2 years after the key was last used); cancelling does not shorten it. The Stripe customer reference expires 90 days after cancellation. A verified erasure request deletes both sooner. | Legitimate interest: billing reconciliation, dispute resolution (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) |
| Hosting-provider request logs (Vercel): time, request path with query parameters, status, full IP address, User-Agent | 30 days (holisticquality.io, aletheia.holisticquality.io, api.aletheia.holisticquality.io and safety.holisticquality.io) | Legitimate interest: abuse prevention, debugging (Art. 6(1)(f)) |
| Per-key last-use record (last-used time; IP address truncated to /24 for IPv4 or /112 for IPv6) | 90 days (auto-TTL) | Legitimate interest: abuse prevention, debugging (Art. 6(1)(f)) |
| Saved watchlists, webhook registrations (which include the API key they belong to) and webhook delivery logs (the last 50 deliveries) | Expire with the API key record they belong to (up to 2 years after the key was last used). If setting that expiry ever fails, a cleanup we run at every deploy sets it, or deletes the record if its key record is already gone. You can delete them sooner (a deleted webhook takes its delivery log with it), and a verified erasure request deletes them | Contract performance (Art. 6(1)(b)) |
| Email given for a free guide or on the contact form (duplicate-send check) | 30 days (guide, including the schedule of its follow-up emails); 24 hours (contact form); auto-TTL | Legitimate interest: not sending the same email twice (Art. 6(1)(f)) |
| Rate-limit counters, and the daily request count kept for each RapidAPI username | 24 hours (auto-TTL). If setting a daily count's expiry ever fails, a cleanup we run at every deploy sets it, or deletes the count if its day is already over | Legitimate interest: service operation (Art. 6(1)(f)) |
| Unsubscribe record (email address, which emails you left, and when) | No expiry, so that the unsubscribe keeps being honoured; an erasure request keeps it | Legitimate interest: honouring your unsubscribe (Art. 6(1)(f)) |
| Security audit logs (administrative actions, key rotations and erasures; a key-rotation entry includes the account email and the full IP address) | 90 days | Legitimate interest: fraud prevention (Art. 6(1)(f)) |
| Trial and reminder-email flags (keyed by email address) | 30 days (auto-TTL) | Legitimate interest: trial management (Art. 6(1)(f)) |
| Enterprise inquiry data | 30 days (auto-TTL) | Legitimate interest: sales follow-up (Art. 6(1)(f)) |
| Weekly backup snapshots (API-key, Stripe-customer and webhook records), written to the same Upstash database | Each snapshot expires 30 days after it is taken | Legitimate interest: disaster recovery (Art. 6(1)(f)) |
| Verified erasure requests | Processed without undue delay after verification (typically within 30 days for general requests; California requests under the CCPA follow section 9.8 of the ALETHEIA Privacy Policy); always shorter than the normal post-cancellation window, except where a legal, fraud, or active payment-dispute hold applies | GDPR Art. 17 (right to erasure) |
| Per-client analytics: the daily list of the busiest unauthenticated clients, and the daily count of each client’s rate-limited requests (each client identified by a keyed hash of its IP address or API key) | 30 days (auto-TTL) | Legitimate interest: to see which clients use the API heavily and may need an API key or a paid plan (Art. 6(1)(f)) |
| Aggregated or anonymized analytics | May be retained longer because it no longer identifies a person | Not personal data once anonymized |
Security Measures
Our sites and the API are served over HTTPS using TLS 1.2 or 1.3. Plain-HTTP requests are redirected to HTTPS, and HTTPS responses carry an HSTS header. API keys are generated with high-entropy cryptographic functions. The key store holds each API key itself, not a hash of it, because requests are authenticated by looking the key up. Administrative actions, key rotations and erasures are recorded in an audit log.
Your Rights
You have the right to access, correct, delete, restrict, object to, or port your personal data, and to lodge a complaint with a data-protection supervisory authority where applicable (GDPR Art. 77).
For direct-issued ALETHEIA accounts: Email privacy@holisticquality.io or use the verified deletion flow:
- POST
/api/keys/erasurewith{"email": "you@example.com"} - Check your email for a 6-digit verification code
- POST
/api/keys/erasurewith{"email": "you@example.com", "code": "123456"} - All account records, API keys (active or deactivated), saved watchlists and webhooks are permanently deleted without undue delay; a record of any email unsubscribe is kept, so that it keeps being honoured. Copies in the weekly backup snapshots expire within 30 days; security audit entries and hosting-provider logs expire on the schedules in the retention table above.
We respond to verified rights requests without undue delay, typically within 30 days of verification (or sooner where required by applicable law). California requests under the CCPA follow the response times in section 9.8 of the ALETHEIA Privacy Policy. If you access ALETHEIA through RapidAPI, rights requests about your RapidAPI account or billing should be directed to RapidAPI first; we will cooperate in good faith on any data we directly control.
Children
The ALETHEIA API is a business-to-business service providing chemical and pharmaceutical safety reference; it is not directed to individuals under 18, and we do not knowingly collect personal data from anyone under 18 in connection with ALETHEIA. If you believe a minor has provided personal data through an HQ-ecosystem property, contact privacy@holisticquality.io and we will investigate and delete it where appropriate.
Changes to This Policy
If we change our subprocessor list, retention windows, legal bases, or data collection practices, we will update this page and the Last updated date above. For material changes that affect your rights, we will notify active direct-issued subscribers by email and post an announcement on our platform at least 30 days before the changes take effect. Historical versions are available on request.
What We Will Never Do
- Sell your personal data to third parties.
- Share your email or usage data with advertisers or data brokers.
- Use API request content to train advertising systems or build competitive intelligence profiles.
- Monetize your data in any way other than the service you chose to buy.
Contact
Privacy matters, data-rights requests, and questions about this policy:
privacy@holisticquality.io
Security vulnerability reports: security@holisticquality.io (or /.well-known/security.txt)
Terms of Service and legal notices: legal@holisticquality.io
API trial and key delivery: api@holisticquality.io
Billing, refunds, and support: support@holisticquality.io
Safety database: safety@holisticquality.io
Holistic Quality LLC · Lebanon, Ohio, USA