Privacy Policy
Effective Date: August 1, 2026 | Last Updated: August 4, 2026
This Privacy Policy describes how Minari Holdings LLC ("Company," "we," "us," or "our") collects, uses, stores, and protects your information when you use the CustomsPro AI desktop application and related services (collectively, the "Service"). We are committed to protecting your privacy and handling your data transparently.
1. Information We Collect
1.1 Information You Provide Directly
- License Activation Data: License key, machine hardware ID (HWID) derived from your motherboard UUID for license validation. This is a one-way hash — we cannot reverse it to identify your specific hardware.
- Commercial Documents: Invoices, packing lists, commercial documents, and other trade-related files you upload to the Service for HTS classification.
- Payment Information: When you purchase a subscription, our payment processor (Paddle) collects your name, email address, billing address, and payment card details. We do not receive or store your full credit card number — Paddle handles all payment processing.
- Support Communications: If you contact us for support, we collect your name, email address, and the content of your inquiry.
1.2 Information Collected Automatically
- License Validation: Each time the application starts, it sends your license key and HWID hash to our license server to validate your subscription. This check runs locally without transmitting any document data.
- Error Reports: If the application crashes, it may generate a local error log. These logs are stored on your computer and are not automatically transmitted to us. You may choose to share them when contacting support.
- AI API Usage: When the Service calls Google's Gemini API for HTS classification, your uploaded documents are transmitted to Google's servers. Google's processing of this data is governed by the Google Cloud Data Processing Terms. We do not store your documents on Google's servers beyond the duration of the classification request.
1.3 Information We Do NOT Collect
- We do not collect keystroke data, browsing history, or other applications running on your computer.
- We do not use cookies, tracking pixels, or analytics scripts in the desktop application.
- We do not sell, rent, or share your personal information with third parties for their own marketing purposes.
- We do not retain copies of your uploaded commercial documents after classification is complete, except as stored locally on your own computer within the application's encrypted database.
2. How We Use Your Information
We use the information we collect solely for the following purposes:
- To provide the Service: Processing your uploaded documents to generate HTS classifications, PGA risk assessments, and Section 301 exclusion analyses.
- To manage your subscription: Validating your license, processing payments, and enforcing usage limits based on your subscription tier.
- To communicate with you: Sending subscription confirmations, renewal reminders, service updates, and responding to your support inquiries.
- To improve the Service: Analyzing aggregated, anonymized classification accuracy metrics (not individual user data) to improve our AI models and HTS matching algorithms.
- To comply with legal obligations: Responding to lawful requests from government authorities, enforcing our Terms of Service, and protecting our legal rights.
3. Data Storage and Security
3.1 Local Storage
All commercial documents you upload, along with their classification results and audit trail records, are stored locally on your computer within an AES-256 encrypted SQLite database. The encryption key is derived from a password stored in your local configuration. We have no access to this local database.
3.2 Cloud Processing
During classification, your documents are temporarily transmitted to Google's Gemini API servers. We instruct Google not to use your data to train their AI models (per Google's API terms for paid accounts). Google's data centers employ industry-standard security measures including encryption at rest and in transit.
3.3 License Server
License validation data (license key, HWID hash, subscription status) is transmitted over HTTPS and stored on servers operated by our license management provider (Lemon Squeezy / Paddle). This data is encrypted at rest.
3.4 Security Measures
We implement commercially reasonable technical and organizational measures to protect your information, including: TLS 1.3 encryption for all network communications, AES-256 encryption for local databases, and access controls limiting internal access to support personnel only. However, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security.
4. Data Retention
- Local Data: Classification records and audit trails remain on your computer until you delete them or uninstall the application. You can delete individual records or all data at any time through the application interface.
- License Data: We retain your license information (key, HWID hash, subscription tier, activation date) for the duration of your subscription plus 30 days after cancellation for accounting purposes.
- Support Tickets: Support communications are retained for 2 years from the date of last activity.
- Payment Records: Transaction records are retained for 7 years as required by applicable tax and financial regulations.
5. Your Rights and Choices
Depending on your jurisdiction (including under the GDPR if you are in the EEA/UK, or under the CCPA if you are a California resident), you may have the following rights:
- Access: Request a copy of the personal data we hold about you.
- Correction: Request that we correct inaccurate or incomplete personal data.
- Deletion: Request that we delete your personal data, subject to legal retention obligations.
- Portability: Request a copy of your data in a structured, machine-readable format.
- Objection: Object to our processing of your personal data in certain circumstances.
- Non-Discrimination: We will not discriminate against you for exercising any of these rights.
To exercise any of these rights, contact us at privacy@customspro1ai.com. We will respond to your request within 30 days. We may need to verify your identity before processing your request.
6. International Data Transfers
The Service is operated from the United States. Your documents are processed through Google's Gemini API, which may involve data transfers to Google's servers in the United States. Google maintains certifications under the EU-U.S. Data Privacy Framework, UK Extension, and Swiss-U.S. Data Privacy Framework. By using the Service, you consent to the transfer of your information to the United States and other jurisdictions where our service providers operate.
7. Third-Party Services
Our Service integrates with the following third-party services:
We encourage you to review the privacy policies of these third-party services. We are not responsible for their data handling practices.
8. Children's Privacy
The Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have inadvertently collected personal data from a child under 18, we will promptly delete it.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. When we make material changes, we will notify you via the email address associated with your account or through the Service at least 14 days before the changes take effect. The "Last Updated" date at the top of this policy indicates when it was last revised.
10. Contact Us
If you have questions, concerns, or would like to exercise your data rights, please contact us at:
Minari Holdings LLC
Data Protection Officer
Email: privacy@customspro1ai.com
Website: https://customspro1ai.com
If you are in the EEA or UK and believe we have not adequately addressed your concerns, you have the right to file a complaint with your local data protection supervisory authority.