What we collect and why
We collect only what is needed by the bodies before which we carry out the procedures, and what is needed to run your account:
| Data | Requested at | Given to |
|---|---|---|
| Your email and country | Registration, before payment | Not given to anyone. Used to contact you, to send your login codes, and to check your country's eligibility |
| Passport (data page) | The consent screen, and reused in Stages 1 and 5 | Our identity-verification provider, the formation parties (Stage 1), Wise (Stage 5) |
| Live face photo (selfie) — and, only in the stricter check (Agreement, Clause 15), a short video of your face | The consent screen | Our identity-verification provider only |
| Payment card details | Payment | You enter them directly with our payment provider. We do not see or store them |
| Your phone number | Stage 1 | Not given to anyone. Used to contact you |
| Your full name and address | Stage 1 | The formation parties (Stage 1), then each later party, to the extent its form requires |
| Date of birth and nationality | Stage 5 | Wise |
| Company name, business activity and capital | Stage 1 | The formation parties (Stage 1), then each later party, to the extent its form requires |
| BE-13 form data and your signature on it | Stage 1 | The BEA, through an eFile account we create in your name and hand over to you |
| Domain registration data | Stage 2 | Our domain provider. The data is hidden in the WHOIS record (the public register of domain owners) unless you ask otherwise |
| Your business description, your logo, and what you choose to publish | Stage 3 | Published on your company's website, as you choose |
| Your signature on Form SS-4 and the form's data | Stage 4 | The IRS |
| Proof of address (a lease or an alternative document), your business description, the countries you deal with, your role in the company, your expected transaction volume, whether you have an online store | Stage 5 | Wise |
| Verification with Wise | Stage 5 | A "Waiting for you" step in which we show you exactly what to do |
| Your messages to support | When you contact us | Us, and our machine-translation service |
The lease shows your landlord's name and signature. We use them only for this step, and they are deleted together with your data.
Legal basis for processing your data
We process your data to perform the Agreement with you. We process your passport image and your face photo based on the explicit consent you give on the consent screen.
Who receives your data
- Your data is received only by those who need it for their step: the State of Wyoming, the registered agent, the IRS, the BEA, Wise, our domain and email providers, our office and phone provider, our fax provider, our payment provider, our identity-verification provider, and — only if you open a payment dispute — your card issuer (through our payment provider).
- The site also runs on technical services that process data on our behalf: hosting, email delivery (login codes and notifications), a security check on the registration and password-reset forms that confirms they are sent by a person and not by an automated program (it sees your IP address and technical details of your browser, not what you type in the form), and machine translation (support messages).
- We disclose only the part of your data that the law, or an order from a competent official authority, requires us to disclose. We tell you when we do this, unless the law prevents us.
- We do not sell your data, we do not share it with anyone other than those listed above, and we do not use it for advertising.
Automated checks and human decisions
When you submit your documents, the system checks them first: that all fields are complete and that every document is present in a readable format. The decision to approve or reject is always made by a person. Your messages to support may be machine-translated, and they are used only to reply to you.
Referral links
If you reach the site through a referral link published by one of our partners (a content creator, for example), we keep the referral ID for 90 days. The referral counts if your Stage 1 is approved within those 90 days, and the link owner earns their commission at that Approval. We pay the commission, not you. We do not give the link owner your name, your email or your documents. All the link owner sees is the number of completed orders that came from their link.
Cookies and analytics tools
- On the public page, we use a website analytics tool and an advertising pixel from an advertising platform, to understand how visitors reach us and to measure our ads. [Tool names and cookie durations to be set at build.]
- The referral ID (above) is stored on your device for 90 days.
Accounts we create in your name
We create the company email and the subscriptions in your name, and we use them during the service. At Handover, all of them are handed over to you with their login details: the company email password is changed, the Handover file explains how to change the passwords of the rest, and we permanently remove our access to them.
Identity verification and your face photo
- On the consent screen, we verify your identity through our identity-verification provider, which specializes in identity verification. You photograph the data page of your passport and take a live photo of your face. If you reach the stricter check (Agreement, Clause 15), you also record a short video of your face. The provider compares the images and tells us the result. We receive the result and the data read from the passport, and we use them in the Stages that need them.
- Your face photo, and your face video if you record one, have one purpose only: to prove that the person who accepted the Agreement is the passport holder. They are not given to any other party and are not used for anything else.
- The provider keeps the images and data it captures under its own privacy policy, published on its website (see "Retention and deletion").
Retention and deletion
- We keep your data and documents from your registration until Handover, and then for 150 days after it.
- Handover is the day the Handover email is sent, and the 150 days are counted from that day. Before deletion, a complete package of all your documents will already have reached you as part of the Handover.
- 150 days after Handover, we automatically delete all your documents, your personal data and your Stage data. We also delete the Agreement, the record of your acceptance of it (Clause 16 of the Agreement), your Handover Acknowledgment, your identity-verification result, the payment and refund record, and our correspondence with you. We keep these for this period so that we have proof of the contract if a payment dispute (chargeback) is opened with your card issuer. After deletion, we have no copy left to send you. The package you received is your copy.
- After deletion, the access log remains (see "Access log"), and so does the blocklist for anyone whose account has been blocked (below). We keep nothing else.
- If you have paid and the service has not started yet, your account and data remain for as long as your right to a refund exists.
- If you registered but did not pay, did not verify your identity, or your country was not accepted in the eligibility check, your data is deleted 150 days after your registration, unless you pay before then.
- If the service ended because the work stayed with you for 150 consecutive days without a response (Clause 9 of the Agreement), all your data and documents stay with us for 150 days from the date the service ended, and then they are all deleted. The access log remains.
- If the service was terminated and your account blocked (Clause 10 of the Agreement), all your data and documents stay with us for 150 days from the date of termination, and then they are all deleted, except your name, passport number and email. These stay on our blocklist and are never deleted. The access log remains.
- If you received a refund before Stage 1 was approved, all your data and documents stay with us for 150 days from the refund, and then they are all deleted. The access log remains.
- Our deletion covers only what we hold. What we have given in your name to other parties (the State of Wyoming, the IRS, the BEA, Wise, service providers, our payment provider and our identity-verification provider) stays with them under their own rules. Your Wise Business account and your subscriptions with those providers became yours at Handover, and you manage them from then on.
Access log
Every access to any of your documents is recorded: the document name, who opened it (you, us, or the system), when, from which IP address, and what they did. This log is never edited or deleted. Your name stays in it after your data is deleted. It does not contain the documents themselves.
Security
- You sign in to your account with a password and a code sent to your email each time. Your password is not stored as text. It is stored as a digital fingerprint (hash) from which the password cannot be recovered, so no one can read it, not even us.
- The code is valid for 2 minutes and can be used only once. You can request a new code after 2 minutes, up to 2 times.
- The Handover file is protected by a password that is not sent in the same email. The password is shown to you inside your account after you sign in.
Messages we send you
- Login codes
- Approval or rejection of your documents, with the reason
- A "Waiting for you" step
- Completion of a Stage
- A stated duration nearing its end
- Handover
- A daily reminder while you have a Stage whose documents you have not submitted, a rejected Stage, or a "Waiting for you" step
We do not send marketing messages to your email.
Your rights
At any time during the service, you can use your account to see what you have uploaded, correct any information before its Stage is approved, and request a full copy of your documents. For any request or question about your data, email us at support@setupswift.com from your registered email, and we will reply within 5 Working Days. We do not delete your data before its scheduled date (150 days), even if you ask us to, because it is our proof of the contract if a payment dispute is opened. Changing information after it has been submitted to the relevant party is outside the service (Clause 11 of the Agreement).
Service provider
Grayson Supply Co LLC, State of Wyoming, United States, under the trade name SetupSwift.