Privacy Policy -- Celuvra

Celuvra ("we," "us," or "our") is a product of Smart Technology Investments LLC. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit celuvra.com (the "Site") or use our long-term care planning services.

1. Information We Collect

Information you provide directly:

Email address (if you create an account)
Financial profile data for LTC analysis (age, sex, state, assets, savings rate, health status, family history, marital status, risk tolerance)
Payment information (processed by Stripe; we do not store card numbers)
Communications you send us

Information collected automatically:

IP address and approximate geolocation (country/region level)
Browser type, operating system, device type
Pages visited, time on page, referring URL

2. How We Use Your Information

To run LTC strategy calculations based on your financial and health profile
To generate and deliver strategy comparison reports
To process payments and manage your account and credit balance
To send transactional emails (receipts, reports, account notices)
To analyze usage patterns and improve the product
To detect and prevent fraud or abuse
To comply with legal obligations

3. Health and Financial Data Handling

The health and financial profile data you provide (age, health status, assets, family history) is used solely for computing LTC strategy recommendations. We do not sell this data to third parties. Profile data entered without an account is processed in your browser and is not stored on our servers. Profile data associated with an account is stored encrypted and can be deleted at any time by deleting your account.

4. Data Sources We Use

Our actuarial models are built on federal and publicly available datasets including SSA Period Life Tables, CMS Nursing Home Compare data, CareScout/Genworth Cost of Care Surveys, and HHS/ASPE LTSS Risk Projections. We do not collect personal data from these sources. All modeling is performed against aggregate statistical distributions.

5. Cookies and Tracking

We use essential cookies necessary for the Site to function. With your consent, we also use analytics cookies to understand how visitors use the Site.

6. Third-Party Services

Cloudflare -- CDN, DDoS protection, Workers API hosting, and D1 database
Stripe -- Payment processing (PCI-DSS compliant)
Vercel -- Hosts and delivers our web application

7. Data Retention

Account data: retained for the life of your account plus 2 years
Strategy reports: retained for the life of your account
Payment records: retained as required by law (typically 7 years)
Anonymous profile data (no account): not stored beyond the browser session

8. Your Rights

Depending on your location, you may have the right to:

Access the personal data we hold about you
Correct inaccurate data
Request deletion of your data
Object to processing or withdraw consent
Data portability

To exercise any of these rights, email us at privacy@smarttechinvest.com. We will respond within 30 days.

9. California Privacy Rights (CCPA / CPRA)

We do not sell or share personal information with third parties for their direct marketing purposes. To submit a CCPA request, email privacy@smarttechinvest.com with "CCPA Request" in the subject line.

10. Data Security

We implement industry-standard technical and organizational measures to protect your data, including TLS encryption in transit, encrypted storage at rest, and access controls.

11. Children's Privacy

The Site is not directed to children under 13. We do not knowingly collect personal information from children.

12. Changes to This Policy

We may update this policy periodically. We will post the revised policy with an updated "Last updated" date. For material changes, we will provide additional notice.

13. Contact Us

Smart Technology Investments LLC
Email: privacy@smarttechinvest.com
Website: celuvra.com