1. Information We Collect
We collect the following types of information when you use Submission Management:
- Account Information: Name, email address, organization name, and role when your account is created by an administrator.
- Filing Data: XML and EIS filing documents you upload, including associated metadata such as CIK numbers, form types, and accession numbers.
- EDGAR® Credentials: Filer tokens, user tokens, and CCC codes that you provide for filing submissions. These are encrypted at rest using AES-256.
- Usage Data: Activity logs including login events, file uploads, submissions, and administrative actions, recorded for security and compliance purposes.
- Contact Inquiries: Name, email, company name, and message content submitted through our contact form.
2. How We Use Your Information
We use your information to:
- Provide, operate, and maintain the Submission Management platform
- Process and submit filings to the SEC® EDGAR® system on your behalf
- Validate filing documents against XSD schemas
- Manage CIK delegation status and requests
- Send email notifications about filing status, account activity, and system updates
- Maintain audit trails for compliance and security
- Respond to contact inquiries and provide customer support
3. Data Security
We implement comprehensive security measures to protect your data:
- Encryption at Rest: EDGAR® tokens, CCC codes, and other sensitive credentials are encrypted using AES-256 before database storage.
- Encryption in Transit: All data transmitted between your browser, Submission Management servers, and EDGAR® is protected via HTTPS/TLS.
- Two-Factor Authentication: TOTP authenticator app or email-based verification with trusted device management.
- Role-Based Access Control: Granular permissions ensure users can only access features appropriate to their role.
- Data Separation: Each organization's data is logically separated with enforced access boundaries, ensuring users can only access their own organization's data.
4. Data Retention
We retain your data for as long as your account is active or as needed to provide the Service. Filing records and activity logs are retained for compliance purposes. Upon account termination, we will retain your data for a reasonable period to allow for export, after which it will be securely deleted.
5. Third-Party Services
Submission Management interacts with the following third-party services in the course of providing the Service:
- SEC EDGAR® System: Filing submissions, status checks, and delegation management are performed through EDGAR®'s APIs.
- Email Service Provider: Transactional emails (notifications, invitations, 2FA codes) are sent through our email service provider.
We do not sell, rent, or share your personal information with third parties for marketing purposes.
6. EDGAR® Data Handling
Filing documents uploaded to Submission Management are transmitted to the SEC® EDGAR® system as directed by you. We do not modify filing content. EDGAR® response data (accession numbers, filing status, acceptance notifications) is stored to provide status tracking and audit trail functionality. Submission Management does not independently disseminate or publish your filing data.
7. Your Rights
You have the right to:
- Access the personal information we hold about you
- Request correction of inaccurate information
- Request deletion of your account and associated data
- Export your filing data
- Opt out of non-essential email communications
To exercise these rights, contact your organization's administrator or reach out to us through the contact form.
8. Children's Privacy
Submission Management is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children.
9. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated revision date. We will make reasonable efforts to notify users of material changes via email or in-app notification.
10. Contact Us
If you have questions about this Privacy Policy or our data practices, please contact us through the contact form on our website.