Terms of Service & License Agreement
This Master Terms of Service Agreement ("Agreement") governs your access to and use of PrivacyScrubber across all four operational environments: the In-Browser Web Workspace, the Manifest V3 Chrome Extension, the PII MCP Server (@privacyscrubber/mcp-server), and the Developer SDK (@privacyscrubber/sdk).
Zero raw data intake or cloud storage
Web, Extension, MCP Server & SDK
Paddle.com (MoR) & PayPal Billing
Full protection on all PRO, TEAMS & Developer SDK plans
1. Scope of Agreement & Zero-Server Operating Model
PrivacyScrubber operates exclusively as an endpoint-executed sanitization software utility. By loading privacyscrubber.com, installing the Chrome Extension, launching the MCP Server daemon, or importing the Developer SDK, you acknowledge and agree that all data processing occurs entirely within your local device's memory.
PrivacyScrubber never sends, receives, inspects, or logs your sanitized text, files, or token maps on any server. Consequently, PrivacyScrubber does not act as a custodian, processor, or transmitter of your raw data.
2. License Grants, Editions & Permitted Use
Subject to your compliance with this Agreement and timely payment of applicable fees, PrivacyScrubber grants you a worldwide, non-exclusive, non-transferable license to use the software under the following tier designations:
Granted for personal, educational, and evaluation purposes. Limited to single-snippet web workspace sanitization (15k chars General, 5k trial on 30 profiles).
Single-user commercial license. Unlocks all 30 specialized industry profiles, batch document OCR (PDF, Word, Excel, CSV), custom regex rulesets, and Chrome Extension MV3 shield.
Unlimited internal staff seats. Unlocks centralized dashboard governance, encrypted team session handoffs (.pssession), and Master Key Isolation.
Headless programmatic runtime (@privacyscrubber/sdk) for internal microservices, ETL pipelines, and internal RAG vector databases. Single-organization internal backend license.
3. Offline Verification & Air-Gapped Deployment Rights
PrivacyScrubber does not utilize phone-home Digital Rights Management (DRM) or heartbeat telemetry. License keys for PRO, TEAMS, and ENTERPRISE tiers are cryptographically verified in-memory using asymmetric JWT signatures.
4. Billing, Merchant of Record (Paddle) & PayPal Payments
All financial transactions for PrivacyScrubber are processed through certified, PCI-DSS Level 1 compliant financial infrastructure:
- Paddle.com (Merchant of Record):Paddle.com Market Ltd acts as our Merchant of Record for credit/debit card transactions and recurring subscriptions. Paddle manages global sales tax, VAT calculation, invoicing, and customer billing support.
- PayPal Direct:PayPal transactions are processed directly by PayPal and verified via our automated subscription verification service. Payment authorization occurs entirely within the PayPal SDK window.
- TEAMS Subscriptions & Cancellations:Recurring TEAMS subscriptions ($99/mo) can be cancelled at any time via the self-service billing portal or PayPal settings. Cancellations take effect at the conclusion of the current prepaid billing cycle.
5. Ephemeral Memory Lifecycle & Cryptographic Reversibility
The translation dictionary linking real PII entities to synthetic tokens (the local ZTDS™ token dictionary) exists solely in volatile random-access memory (RAM).
Reloading or closing your browser tab permanently purges the in-memory translation map. Reversal of masked tokens back to original values cannot occur without an active session or a user-saved encrypted session file.
Exported .pssession files are encrypted client-side using XChaCha20-Poly1305 and Argon2id. You are solely responsible for safeguarding your session passwords.
6. Data Processing Agreements (DPA) & Non-Processor Status
Under global privacy frameworks (including GDPR Article 28, UK GDPR, and CCPA/CPRA), PrivacyScrubber does not act as a "Data Processor", "Service Provider", or "Business Associate" because our infrastructure never ingests, transmits, or stores your personal data.
Your enterprise maintains exclusive, sovereign custody of all customer data as the sole Data Controller. For formal procurement documentation, review our dedicated Zero DPA Guidance Memorandum.
7. Host Security, Third-Party Extensions & User Responsibilities
Because PrivacyScrubber executes on your local workstation, you are responsible for maintaining basic endpoint security hygiene:
- Ensure workstations are free of malware, keyloggers, and unapproved screen-capture utilities.
- Audit installed third-party browser extensions that possess broad DOM read permissions.
- Review visual highlight badges in the interface before copying text into third-party AI interfaces.
8. Warranty Disclaimers, Statutory Non-Reliance & Limitation of Liability
8.1 "AS IS" AND COMPUTATIONAL UTILITY CLASSIFICATION: PRIVACYSCRUBBER IS LICENSED AS A GENERAL-PURPOSE COMPUTATIONAL UTILITY "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS, IMPLIED, STATUTORY, OR ORAL. LICENSOR SPECIFICALLY DISCLAIMS ALL IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.
8.2 Sector-Specific Non-Reliance & Affirmative Warranties: Licensee explicitly covenants and warrants that it does not rely upon PrivacyScrubber, BrandMeWeb, or ZTDS.ai for statutory or regulatory compliance under any jurisdiction. Licensee retains the non-delegable duty to verify that transformed data complies with applicable law prior to external transmission, including but not limited to: (a) HIPAA / HITECH de-identification standards; (b) FRE 502 / ABA Model Rule 1.6 attorney-client privilege protection; (c) GLBA, SEC, FINRA, and IRS Circular 230 tax and fiduciary mandates; (d) FinCEN Suspicious Activity Report (SAR) statutory anti-tipping secrecy under 31 U.S.C. § 5318(g)(2) and AMLD6; (e) EEOC Title VII, ADA, and NYC Local Law 144 automated employment decision tool audits; (f) ITAR (22 CFR § 120.54), EAR (15 CFR § 734.18), CMMC 2.0, and CJIS defense export control requirements; (g) SEC Form 8-K Item 1.05 and GDPR Article 33/34 incident reporting thresholds; (h) FERPA (34 CFR Part 99) and COPPA student/minor protection; and (i) EU AI Act (Regulation 2024/1689) high-risk system compliance.
8.3 Non-Escrow & Non-Custodial Operating Model: Licensor does not receive, store, archive, escrow, or reconstruct Licensee raw inputs, de-identification maps, salt keys, or session tokens. All mappings remain exclusively in volatile endpoint memory or Licensee-controlled persistent storage. Licensor bears no custodial or subprocessor responsibility for data loss, accidental disclosure, or re-identification resulting from unvetted downstream AI prompts, browser tampering, or endpoint malware.
8.4 CUMULATIVE AGGREGATE LIABILITY CAP: TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL PRIVACYSCRUBBER, BRANDMEWEB, ILYA SIBIRYAKOV, OR ITS AFFILIATES, CONTRACTORS, OR SUPPLIERS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES (INCLUDING LOSS OF PROFITS, DATA BREACH FINES, REGULATORY SANCTIONS, REPUTATIONAL DAMAGE, WORK STOPPAGE, OR LOSS OF GOODWILL). LICENSOR'S TOTAL CUMULATIVE AGGREGATE LIABILITY ARISING FROM OR RELATED TO THIS AGREEMENT, REGARDLESS OF THE FORM OF ACTION, SHALL BE STRICTLY LIMITED TO THE GREATER OF: (A) ONE HUNDRED UNITED STATES DOLLARS ($100.00 USD), OR (B) THE TOTAL FEES ACTUALLY PAID BY LICENSEE TO LICENSOR IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE CLAIM.
8.5 Express Indemnification: Licensee agrees to defend, indemnify, and hold harmless Licensor, BrandMeWeb, Ilya Sibiryakov, and their respective officers, agents, and successors from and against any third-party claims, liabilities, damages, losses, civil penalties, regulatory fines, and legal expenses arising out of or related to: (a) Licensee's transmission of unmasked or transformed data to third-party AI models; (b) Licensee's violation of any sectoral data protection statute or privacy regulation; or (c) Licensee's breach of representations regarding data ownership and consent.
8.6 Normative Reference: Licensee agrees to be bound by the statutory demarcation guidelines set forth in the ZTDS Multi-Vertical Statutory Insulation Specification.
9. Governing Law, Severability & Revision Log
This Agreement shall be governed by and construed in accordance with applicable commercial laws. For enterprise licensing disputes, parties agree to first seek informal dispute resolution via written notice to support@privacyscrubber.com.
