US Privacy Policy

1. Controller and contact

Phāros Route Check is provided by Duncan Fullarton, sole proprietor.
Duncan Fullarton
c/o POSTFLEX PFX-983-571
Emsdettener Straße 10
48268 Greven
Deutschland
Email: hallo@pharos.guide

This Privacy Policy explains how we process personal information for the English website, US checkout, Route Check flow, digital delivery and related communication.

2. Information we process

We offer the Route Check as a free first assessment (Island Match) and two paid products, the Route Report and the Expert Review & 1:1 Call; the product names are defined in the US Terms of Service.

• Contact details such as name and email address
• Structured Route Check inputs such as islands, travel dates, travel length, group, budget feel, travel pace, existing bookings, structured travel preferences, and your main question
• Order and payment references such as Stripe Checkout Session ID, payment status, amount, currency, order number, and invoice references
• Scheduling and online-consultation information such as Calendly booking details, selected time slot, time zone, meeting link, attendance status, and limited notes needed to prepare or document the consultation
• Technical information such as device, browser, referrer, page path, consent state, GPC signal, and security logs
• Communication records such as support emails, delivery status, refund requests, and privacy requests

The public Route Check flow does not contain an open narrative free-text field for travel or health information. We do not request diagnoses, medical conditions, disability details, or other consumer health data and do not need that information to provide the service.

The structured preferences include whether you want a rental car on the islands (no rental car, rental car, still open) and how much island hopping fits your trip.

Please do not send health information, passport or identity-document data, full payment-card details, or other unnecessary sensitive information by email or through the scheduling tool.

3. Purposes

We process personal information to operate the website, provide the Route Check, prepare checkout, process payment, create and deliver the report, schedule and conduct the included optional online consultation, communicate with you, document legal and payment records, prevent misuse, improve quality, and comply with legal obligations.

We may derive internal, cleaned learning or quality scenarios from Route Check cases. Names, email addresses, phone numbers, payment references, full payment data, health information, unnecessary free-text details, and other direct identifiers are removed or abstracted. Health information is not included in internal learning, RAG, knowledge or quality scenarios. Public references, marketing examples, sample reports, or testimonials are used only anonymously or with additional consent.

3A. Health information and functional mobility preferences

We do not ask for or require diagnoses, medical conditions, disability details or other consumer health data for the Route Check. The flow collects only structured, non-health travel preferences, such as whether you want a rental car on the islands and how much island hopping fits your trip. We do not ask about walking distances, stairs or physical limitations, and we do not ask for or infer the medical reason behind any preference.

Please do not send health information through email, Calendly or other communications. If health information is nevertheless provided without being requested, we do not use it for advertising, targeted marketing, internal learning records, RAG or knowledge systems, model training, or product profiling. We delete or redact it when identified unless limited retention is required for the specific communication or by law.

3B. How the reports are produced (automation and AI)

We use automation and AI systems differently depending on the product.

The free Island Match and the paid Route Report are generated automatically and rule-based from your structured answers, without external AI services and without individual human review.

The Expert Review & 1:1 Call is personally reviewed and finalized by a human expert. Supportive AI tools, in particular services from OpenAI and Anthropic/Claude, may assist with structuring, drafting and quality checks. For this, structured details from your Route Check, internal assessments, permitted working notes and report drafts may be processed. We do not enter names or contact details and use reduced, where possible non-personal parameters.

No decision with legal effect or similarly significant impact on you is made solely by automated means.

4. Service providers and third parties

• Vercel for hosting and infrastructure
• Neon/Postgres for database storage
• Stripe for payment processing
• Resend for transactional email
• Calendly or similar scheduling tools for optional consultation-call scheduling
• OpenAI and Anthropic/Claude for supportive structuring, drafting and quality workflows
• PostHog or similar tools for product analytics
• Meta for advertising measurement and marketing cookies, where enabled

These providers process information for the purposes described in this Privacy Policy and according to their own terms and privacy documentation.

Some third parties, including advertising or analytics providers, may collect information about your online activities over time and across different websites or services when their technologies are active on our website.

5. Cookies, analytics and advertising

Cookies, analytics and advertising: we use necessary cookies and similar technologies for website functionality, checkout, security, fraud prevention and preference storage.

We also use analytics and marketing technologies to understand how visitors use the Phāros Route Check website, measure advertising performance and improve the Route Check flow.

Where enabled, marketing technologies may include Meta Pixel, Meta Conversions API or similar advertising measurement tools. These tools may allow Meta or other advertising providers to collect information about your visit, such as page views, events, browser or device information, referrer information and interactions with our website. These providers may use this information to measure ads, attribute conversions or support advertising on their services.

When marketing measurement is allowed, Meta may receive the event name and time, the page path without query parameters, your IP address and browser user agent, Meta cookie identifiers such as _fbp and _fbc where present, the order value and currency, and, for a completed purchase, your email address in SHA-256-hashed form. We treat hashed values as personal information.

We do not intentionally send full payment card numbers, free-text Route Check notes, report contents, passport information, health information or other sensitive information to Meta Pixel or similar marketing tools.

You can manage non-essential analytics and marketing measurement through our Privacy Choices link.

If your browser sends a Global Privacy Control signal, we turn off marketing measurement for that browser. We currently do not respond to other Do Not Track signals because no uniform industry standard has been adopted.

For the US market, product analytics and marketing measurement may be active by default under an opt-out setup. In California, marketing measurement (Meta Pixel and the Conversions API) stays off unless you enable it in Your Privacy Choices. Session replay is switched off for the US market and is not used.

We do not currently use session replay in the US market. If we introduce session replay later, we will update this Privacy Policy first and describe the recording scope, the masking and your choices before it becomes active.

You can turn optional analytics and marketing measurement off at any time through Your Privacy Choices.

6. Your privacy choices

Your Privacy Choices lets you manage product analytics and marketing measurement. The link is available in the footer of our US pages. Session replay is currently not used and therefore has no switch.

Essential cookies are required for website functionality, checkout, security and preference storage and cannot be disabled through our Privacy Choices page.

You can turn off analytics and marketing measurement at any time. If you turn off marketing measurement, we will not intentionally use Meta Pixel or similar marketing cookies for your browser after your preference has been saved.

If your browser sends a Global Privacy Control signal, we turn off marketing measurement for that browser.

If you opt out after starting a checkout in the same browser, we stop new marketing measurement and also mark the pending order so that its later payment confirmation is not reported to Meta. Events that were already sent cannot be recalled.

7. International processing

Phāros Route Check is operated from Germany, and we use providers that may process information in the European Union, the United States and other countries. Data protection laws may differ from those in your jurisdiction.

Where required, we rely on appropriate transfer mechanisms, provider commitments, contractual safeguards or other legally recognized mechanisms.

8. Retention

We keep an operational Route Check case with personal information for up to 90 days after report delivery or the last activity for an unpaid case. After that period, we remove contact details, support or scheduling message content, consultation notes, free text, case and payment references, exact timestamps, network data and the final report text from the product-learning copy.

Pending checkouts without a successful payment are deleted or anonymized regularly after 7 days unless further processing is required.

Failed or cancelled payments are kept only as long as needed for technical error analysis or support, as a rule no longer than 14 days.

The purchased report and its access record are stored separately from the operational case data so that you can access the report for at least three calendar months from provision. We do not promise availability beyond that period. Other operational case data is retained for up to 90 days after delivery or last activity.

Health information is not transferred into the product-learning copy and is deleted or redacted when identified unless retention is legally required.

We may keep a separate de-identified detailed learning record with structured travel-profile parameters, decision evidence, scores, rules and quality-engine snapshots for up to 24 months from that original retention anchor. We conservatively continue to treat this record as personal information, keep it access-restricted and do not retain a key that links it back to the original case.

After the detailed record expires, we keep only anonymous aggregate statistics. We suppress or combine buckets based on fewer than five cases.

Contract, payment, consent, legal, withdrawal and refund evidence is stored separately for the periods required or permitted by applicable law, as a rule six to ten years where tax or commercial law applies.

9. U.S. state privacy laws

Some U.S. state privacy laws provide residents with specific rights regarding personal information. Phāros Route Check is currently a small service and may not meet statutory thresholds for many of these laws.

Even where a specific state privacy law does not apply to us because of statutory thresholds, you can contact us at hallo@pharos.guide with privacy questions or requests.

We maintain an internal log for requests involving access, deletion, correction or advertising opt-out, including receipt, proportionate identity verification, due date, status and completion.

Where applicable law provides an appeal right, you may appeal a denied privacy request by replying to our decision email with the word "Appeal". We will review and respond within the period required by applicable law and provide information about any further complaint option that applies.

We do not sell personal information for money. Disclosures to Meta for advertising measurement may qualify as "sharing" or "targeted advertising" under some state laws. Where such an opt-out right applies, you can exercise it through the "Your Privacy Choices" link or a supported Global Privacy Control signal.

10. Children and paid orders

The paid Route Check service is for adults who are at least 18 and legally able to enter into a contract. The website is not directed to children under 13, and we do not knowingly collect personal information from a child under 13 through the order process. If you believe that a child has provided personal information to us, please contact hallo@pharos.guide.

11. GDPR information for customers

We process data where necessary to provide the service and take pre-contractual steps, comply with legal obligations, pursue legitimate interests in security, fraud prevention, quality assurance and legal documentation, and, for optional analytics and marketing, based on your consent or applicable opt-out rules. You may request access, correction, deletion, restriction and portability, object to processing based on legitimate interests, and withdraw consent for the future. You may also lodge a complaint with the competent German supervisory authority.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the effective date and post the revised version on this page.

For significant changes affecting paid customers, we may also notify you by email where appropriate.

13. Contact

For privacy questions, contact hallo@pharos.guide.