Privacy Policy

Effective March 29, 2026 · Last updated April 18, 2026

1. Who We Are

Makaivelli LLC (“Company,” “we,” “us”) operates the Singulariti™ platform. We are a private software enterprise. We are NOT a federal agency and are NOT affiliated with the U.S. Department of Veterans Affairs.

2. What Data We Collect

Information You Provide

·Account registration (name, email, role)
·Veteran claim files (C-files, STRs, medical records, decision letters)
·Uploaded evidence documents (PDFs, images, text files)
·Journal entries and lay statements
·Payment information (processed by Stripe — we do not store card numbers)

Information Collected Automatically

·IP address and browser type
·Usage analytics (pages visited, features used, scan counts)
·Device information (for MFA and security)
·Log data (request IDs, timestamps, error logs)

Information We Do NOT Collect

·Social Security Numbers (SSNs are redacted during processing)
·Biometric data (unless you opt into ID.me verification)
·Location data beyond IP-based country detection

3. How We Use Your Data

Purpose	Legal Basis
Process your C-file scans	Performance of contract
Generate analysis reports	Performance of contract
Train and improve AI models	Legitimate interest (anonymized/synthetic data only)
Detect and prevent fraud	Legitimate interest
Send service notifications	Performance of contract
Comply with legal obligations	Legal obligation

CRITICAL: We NEVER use your actual veteran data to train AI models. All model training uses synthetic data generated from statistical patterns. Your C-file content stays in your account and is never mixed with other users' data.

4. How We Protect Your Data

Encryption

·In Transit: TLS 1.3 for all connections
·At Rest: AEAD envelope encryption (AES-256-GCM)
·Key Management: KEK/DEK architecture — master keys rotated quarterly
·Evidence Files: Individually encrypted with unique DEKs per file

Access Control

·Role-Based Access Control (RBAC): Veteran, VSO, Attorney, Admin
·Attribute-Based Access Control (ABAC) via OPA policy engine
·Multi-Factor Authentication (MFA) required for all accounts
·JWT tokens with 60-minute expiration

Audit Trail

·Every data access logged with actor, action, resource, timestamp
·Audit logs immutable and retained for 7 years
·Human Approval Gate logs all output reviews

5. Data Retention

Data Type	Retention Period
Account information	Duration of account + 90 days
C-file scan results	3 years (or as legally required)
Uploaded evidence	Until deleted by user (max 5 years)
Audit logs	7 years
Payment records	As required by tax law
AI model training data	Indefinite (synthetic only)

6. Data Sharing

We share your data ONLY with:

·Stripe — Payment processing (PCI DSS compliant)
·Google Cloud — Gemini AI API (data in transit only, not stored by Google)
·Anthropic — Claude AI API (data in transit only, not stored by Anthropic)
·Law enforcement — Only with valid legal process (subpoena, court order)

We NEVER sell your data. We NEVER share your data with advertisers. We NEVER share your data with the VA or any federal agency unless legally compelled.

7. Your Rights

You have the right to:

·Access your data at any time
·Export your data in machine-readable format (JSON)
·Delete your account and all associated data
·Correct inaccurate information
·Restrict processing of your data
·Object to specific uses of your data
·Withdraw consent at any time

To exercise these rights, contact: privacy@makaivelli.com

8. Veterans-Specific Protections

We comply with:

·38 U.S.C. § 5701 — Confidentiality of VA records
·38 CFR Part 1, Subpart B — Restrictions on disclosure of VA records
·HIPAA — Health Insurance Portability and Accountability Act
·Privacy Act of 1974 — Federal records protections

9. Children's Privacy

Singulariti is not intended for use by individuals under 18. We do not knowingly collect data from minors.

10. Changes to This Policy

We will notify you of material changes via email and in-app notification with 30 days notice.

11. Contact

Makaivelli LLC — Privacy Office
privacy@makaivelli.com