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Botdoc and California Privacy Law

Effective July 1, 2026.Last updated: June 7, 2023

BOTDOC AND CALIFORNIA PRIVACY LAW

CCPA / CPRA Compliance Statement

At Botdoc, trust is our most important value. This statement describes how ShortSave, Inc., a Colorado corporation doing business as Botdoc (“Botdoc,” “we,” “us,” or “our”) approaches compliance with the California Consumer Privacy Act (Cal. Civ. Code §1798.100 et seq.), as amended by the California Privacy Rights Act (CPRA), and the regulations adopted by the California Privacy Protection Agency (CPPA), including the 2025/2026 CPPA regulations effective January 1, 2026.

This statement supplements our Privacy Policy at https://botdoc.io/privacy-policy/. Defined terms used here have the meanings given in our Privacy Policy and Terms of Service.

1. What Botdoc Does

Botdoc is a secure digital transport platform that enables organizations to send, receive, and transmit sensitive files and data through encrypted workflows. We operate as a SaaS and API-based solution. We process Personal Information strictly on behalf of our customers and do not act as a data broker or resell Personal Information.

2. Our Role: Service Provider

With respect to customers doing business in California, Botdoc acts as a “service provider” as defined under the CCPA/CPRA (Cal. Civ. Code §1798.140(ag)). As a service provider, Botdoc:

  • Processes Personal Information only on behalf of the customer and pursuant to the customer’s documented instructions;
  • Does not sell or share Personal Information received from or on behalf of customers;
  • Does not retain, use, or disclose Personal Information outside the direct business relationship with the customer or for any commercial purpose other than providing the Services;
  • Does not combine Personal Information received from one customer with Personal Information received from other customers or collected from Botdoc’s own interactions;
  • Will notify the customer within five (5) business days if Botdoc determines it can no longer meet its obligations as a service provider;
  • Grants customers the right to audit Botdoc’s compliance with applicable data protection requirements;
  • Processes Personal Information only to the minimum extent necessary to complete the secure transmission, and cannot access, read, or view the contents of data transmitted through the Services due to end-to-end encryption. Botdoc therefore processes Personal Information strictly as a conduit for transmission, not as a data repository or analytics platform; and
  • Flows down equivalent service provider obligations to sub-service providers (subprocessors).

The customer’s Terms of Service and Data Processing Addendum (DPA) at https://botdoc.io/data-processing-addendum/ set out the contractual basis for Botdoc’s role as a service provider and meet the written contract requirements under CCPA/CPRA. Because Botdoc operates as a secure digital transportation platform and cannot access transmitted content, Botdoc’s processing of Personal Information is limited to what is strictly necessary to complete the transmission, consistent with the CCPA/CPRA minimum necessary standard.

3. We Do Not Sell, But We Do Share for Cross-Context Behavioral Advertising

Botdoc does not sell Personal Information for monetary or other valuable consideration as those terms are defined under CCPA/CPRA. However, Botdoc does use third-party advertising and analytics services (including Google Ads) that may constitute “sharing” of Personal Information for cross-context behavioral advertising as those terms are defined under CCPA/CPRA. The categories of Personal Information that may be shared for this purpose are online identifiers (cookie IDs and similar), internet or other electronic network activity information (browsing history on botdoc.io), and inferences drawn from that activity.

Botdoc does not share Personal Information that constitutes Customer Data transmitted through the Botdoc Services for any advertising purpose; advertising-related sharing is limited to website-visitor data collected on botdoc.io.

3.1 Global Privacy Control (GPC)

Botdoc honors the Global Privacy Control (GPC) signal as a valid opt-out request under CCPA/CPRA regulations (11 CCR §7025). When Botdoc detects a GPC signal from a consumer browser, Botdoc will treat that signal as an opt-out of the sharing described in Section 3 with respect to that browser session. Where Botdoc can reasonably associate a GPC signal with an authenticated Botdoc account, the opt-out will apply on a forward-going basis to that account.

4. Sensitive Personal Information (SPI)

To the extent Botdoc processes Sensitive Personal Information (as defined under CCPA/CPRA §1798.140(ae)), Botdoc handles such information only for the purposes set forth in §1798.121(a) and Reg §7027. Sensitive Personal Information may include, depending on the transmission Customer initiates through the Services:

  1. Social Security Number, driver’s license, state ID card number, passport number;
  2. account log-in, financial account, debit or credit card number with required access code, password, or credentials;
  3. precise geolocation;
  4. racial or ethnic origin, religious or philosophical beliefs, union membership;
  5. contents of mail, email, or text messages (unless Botdoc is the intended recipient);
  6. genetic data;
  7. biometric information used for identification;
  8. personal information concerning health, sex life, or sexual orientation.

Because Botdoc operates through end-to-end encryption and cannot access or view the contents of transmitted data, Botdoc cannot independently determine whether any particular transmitted content constitutes Sensitive Personal Information. The customer as controller is responsible for determining what Sensitive Personal Information, if any, is transmitted through the Services.

As a service provider, Botdoc:

  • Uses Sensitive Personal Information only for the purposes specified by the customer and permitted under the CCPA/CPRA service provider exception;
  • Does not use Sensitive Personal Information to infer characteristics about consumers beyond what is necessary to provide the Services;
  • Does not disclose Sensitive Personal Information to third parties except subprocessors acting on Botdoc’s behalf, or as required by law; and
  • Complies with consumer requests to limit the use and disclosure of Sensitive Personal Information that Botdoc controls directly (Customer Account Data).

Botdoc does not use or disclose Sensitive Personal Information for cross-context behavioral advertising. The advertising-related sharing described in Section 3 is limited to online identifiers, internet or other electronic network activity information, and inferences drawn from that activity, and does not include Sensitive Personal Information.

Because Botdoc acts as a service provider for customer-transmitted content, consumers wishing to exercise Sensitive Personal Information rights with respect to documents or data transmitted through the Services should contact the Botdoc customer (controller) who initiated the transmission.

5. California Consumer Rights

California residents have the following rights under the CCPA/CPRA. Where Botdoc acts as a service provider, the majority of these rights should be exercised directly with the Botdoc customer (controller). For Personal Information Botdoc controls directly (Customer Account Data), requests may be submitted to support@botdoc.io.

RightDescription
Know / AccessRight to know what Personal Information is collected, used, disclosed, or sold, and to request a copy.
DeleteRight to request deletion of Personal Information collected, subject to exceptions.
CorrectRight to request correction of inaccurate Personal Information (added by CPRA, effective Jan 1, 2023).
Data PortabilityRight to receive Personal Information in a portable, machine-readable format.
Right to Opt-Out of SharingBotdoc shares certain online identifiers and activity data for cross-context behavioral advertising as described in Section 3. California residents may opt out via the “Do Not Sell or Share My Personal Information” link in the botdoc.io footer, by sending a Global Privacy Control (GPC) signal, or by emailing support@botdoc.io. The opt-out applies to website-visitor sharing only; Botdoc does not share Customer Data transmitted through the Services for any advertising purpose.
Limit SPI UseRight to limit use and disclosure of Sensitive Personal Information to necessary purposes (added by CPRA).
Non-DiscriminationRight not to receive discriminatory treatment for exercising CCPA/CPRA rights.
Opt-In (Minors)Consumers under 16 have the right to affirmatively opt in before their Personal Information is sold or shared. Botdoc’s Services are not directed to minors under 16, and Botdoc does not knowingly collect Personal Information from minors under 16 for the website-visitor sharing described in Section 3. If Botdoc learns that it has collected Personal Information from a minor under 16 without the required opt-in (or, for minors under 13, parental consent), Botdoc will cease sharing that Personal Information for cross-context behavioral advertising and delete it consistent with applicable law.
Automated Decision-Making Technology (ADMT)Right to Opt-Out (effective January 1, 2027 per CPPA regulations). Botdoc does not currently use ADMT for significant decisions about consumers and will publish updated procedures before the January 1, 2027 effective date if its practices change.

6. How to Submit a Request

To submit a consumer rights request relating to Personal Information Botdoc controls directly (Customer Account Data):

  • Email: support@botdoc.io (include “CCPA Request” in the subject line)
  • Mail: ShortSave, Inc., a Colorado corporation doing business as Botdoc, Attn: Compliance Team, 1909 Woodmoor Drive, Monument, Colorado 80132

Response timeline: Botdoc will acknowledge receipt within 10 business days and respond within 45 calendar days of receiving a verifiable request. If additional time is needed, Botdoc may extend the response period by an additional 45 days (90 days total) with notice to the requestor.

Verification: Botdoc will verify the identity of the requestor before processing a deletion, access, or correction request. Verification may require confirmation of the email address and account information on file.

Authorized agents: A consumer may designate an authorized agent to submit a request on their behalf. Botdoc may require the consumer to verify their identity directly and confirm the authorized agent’s authority.

Service provider note: For Personal Information transmitted through the Services on behalf of a Botdoc customer (controller), consumers should contact that Botdoc customer directly to exercise their rights. Botdoc, as service provider, will cooperate with the customer’s response to verified requests.

7. Data Retention

Botdoc retains Personal Information only as long as necessary for the purposes described in our Privacy Policy, or as required by applicable law. Our retention practices for key categories:

  • Customer Content (transmitted files and documents): Deleted from Botdoc’s environment upon completion of the secure transport and expiration of the applicable retention period set in the Botdoc dashboard or Order Form. Botdoc does not retain Customer Content after the applicable period.
  • Customer Account Data: Retained for the duration of the customer relationship, plus a reasonable period thereafter for legal and business purposes.
  • Transaction and audit logs: Retained for the period required by applicable legal and compliance obligations, including SOC 2 audit requirements.
  • Marketing and contact data: Retained until opt-out or request for deletion.

8. No AI/ML Training on Customer Data

Botdoc does not use Personal Information, including Customer Content, to train, develop, fine-tune, or improve any artificial intelligence or machine learning model for the benefit of any party other than the Customer. Botdoc may use aggregated, anonymized, de-identified usage statistics for product improvement purposes, provided such data cannot be used to identify any individual.

This commitment is binding and reflected in Botdoc’s Corporate Terms of Service and Data Processing Addendum.

9. Subprocessors and Third-Party Service Providers

Botdoc shares Personal Information only with service providers and sub-service providers under written contracts that restrict their use of Personal Information to providing services to Botdoc. We do not allow subprocessors to use Personal Information for their own independent purposes.

Categories of third parties with whom Botdoc shares Personal Information: cloud infrastructure providers, payment processors (PCI DSS certified), analytics providers, customer support tools, and advertising and website-analytics providers.

Botdoc uses Google Ads and Google Analytics as service providers for website-visitor advertising and analytics. These are listed at https://botdoc.io/botdoc-subprocessors/ along with all other Botdoc subprocessors.

A current list of Botdoc’s subprocessors is available at https://botdoc.io/botdoc-subprocessors/.

10. 2025/2026 CPPA Regulations — Botdoc’s Position

The CPPA finalized significant new regulations effective January 1, 2026, covering cybersecurity audits, risk assessments, and automated decision-making technology (ADMT). Botdoc’s position:

  • Cybersecurity Audits: Botdoc undergoes an annual SOC 2 Type II audit conducted by an independent third-party auditor. This audit addresses cybersecurity controls consistent with CPPA cybersecurity audit requirements. Botdoc will monitor whether it meets the thresholds for mandatory CPPA cybersecurity audit certification and will comply with applicable deadlines.
  • Risk Assessments: Botdoc conducts risk assessments of its data processing activities and will comply with applicable CPPA risk assessment requirements, including any required submissions, on the schedule established by the CPPA regulations. Botdoc’s use of Google Ads remarketing on botdoc.io constitutes a “high-risk processing activity” under CPPA risk-assessment regulations and is the subject of an annual risk assessment. The risk assessment documents the categories of Personal Information shared, the purposes of the sharing, the safeguards (opt-out mechanisms, GPC honoring, Sensitive PI restrictions), and the residual risks identified.
  • Automated Decision-Making Technology (ADMT): Botdoc does not use ADMT to make significant decisions affecting consumers, as defined in the CPPA regulations (employment eligibility, credit approval, healthcare, housing). Botdoc does not process consumer Personal Information to train ADMT systems that render significant decisions. The ADMT opt-out right (effective January 1, 2027) is preserved but not currently applicable to Botdoc’s practices, and Botdoc will publish updated procedures before that effective date if its practices change.

11. California Shine the Light

California residents may request information about Personal Information that Botdoc may have shared with third parties for those third parties’ direct marketing purposes during the preceding calendar year. Because Botdoc does not share Personal Information with third parties for the third parties’ direct marketing purposes, there is no information to disclose under Cal. Civ. Code §1798.83. Requests for confirmation may be sent to support@botdoc.io.

12. Twelve-Month Look-Back

This Statement describes Botdoc’s privacy practices during the twelve (12) months preceding the “Last updated” date above. For practices during earlier periods, Botdoc maintains an archive of prior versions of this Statement available on request to support@botdoc.io.

13. Non-Discrimination

Botdoc will not discriminate against California consumers for exercising their CCPA/CPRA rights, including by denying goods or services, charging different prices, providing a different level of quality, or suggesting that the consumer will receive a different price or quality.

14. Changes to This Statement

Botdoc may update this statement from time to time to reflect changes in applicable law, CPPA regulations, or Botdoc’s practices. Material changes will be communicated consistent with Botdoc’s Privacy Policy. The current version is always available at https://botdoc.io/ccpa/.

15. Contact Us

For questions about this statement or to submit a CCPA/CPRA rights request:

Botdoc Compliance Team ShortSave, Inc., a Colorado corporation doing business as Botdoc 1909 Woodmoor Drive, Monument, Colorado 80132 Email: support@botdoc.io (subject: “CCPA Request”)

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