1. Who We Are

Null Agency LLC is a New Mexico limited liability company. We build privacy-first software tools. This Privacy Policy covers all of our products and websites: nullagency.io, GhostMetrics, PhantomEtch, Titan Index, and Faceoff.

For any privacy-related questions, contact us at mike@nullagency.io.

2. What We Collect (Product by Product)

Different products collect different things. Here's the full picture:

Product	What We Collect	What We Don't Collect
GhostMetrics	Anonymous, aggregated pageview data (page URL, referrer, country, browser type, screen size). Magic-link email for dashboard authentication.	Cookies, IP addresses (not stored), personal identifiers, cross-site tracking
PhantomEtch	Nothing. Zero. Your PDFs never leave your browser.	Files, document content, usage data tied to individuals
Titan Index	Anonymous pageview analytics (via GhostMetrics). Email if you subscribe.	Cookies, personal identifiers, financial data
Faceoff	Anonymous pageview analytics (via GhostMetrics).	API keys (stored encrypted in your browser only), prompts, model responses, personal identifiers
nullagency.io	Anonymous pageview analytics (via GhostMetrics). Email if you subscribe.	Cookies, personal identifiers

3. Cookies

We do not use cookies. None of our products set cookies. We do not use tracking pixels, fingerprinting, or any other cross-site tracking technology. This is by design, not by accident.

Because we don't use cookies, you will never see a cookie consent banner on any Null Agency product.

4. Analytics (GhostMetrics)

We use our own analytics product, GhostMetrics, across our websites. GhostMetrics is built to be privacy-first:

• No cookies are set
• No personally identifiable information is collected
• IP addresses are not stored or logged
• No cross-site or cross-device tracking
• No data is shared with third parties
• Data collected: page URL, referrer domain, country (derived at request time, not stored with IP), browser type, screen size, and timestamp

GhostMetrics is fully compliant with GDPR, CCPA, and PECR without requiring consent banners, because it doesn't collect personal data.

5. Email Collection

If you voluntarily subscribe to updates via our email forms (on nullagency.io or Titan Index), we collect your email address. Here's how we handle it:

• We use your email only to send you updates about Null Agency and its products
• We do not sell, rent, or share your email with anyone
• We do not send spam or promotional emails for third parties
• You can unsubscribe at any time by clicking the unsubscribe link in any email or by emailing mike@nullagency.io
• Upon unsubscribe, your email is deleted from our systems

6. Authentication (GhostMetrics)

GhostMetrics dashboard access uses magic-link email authentication. When you request access, we send a one-time login link to your email address. We store your email address solely for the purpose of authenticating you to your dashboard. We do not use this email for marketing unless you separately opt in.

7. Client-Side Data (PhantomEtch & Faceoff)

PhantomEtch

PhantomEtch processes PDFs entirely within your browser. Your documents are never uploaded to our servers, never transmitted over the network, and never accessible to us. We have zero access to your files. When you close the tab, the data is gone.

Faceoff

If you choose to enter API keys in Faceoff, those keys are encrypted and stored exclusively in your browser's local storage. They are never sent to Null Agency servers. Your prompts and model responses are sent directly from your browser to the respective AI providers. We never see, log, or store your prompts, responses, or API keys.

You can clear your stored API keys at any time through the Faceoff interface or by clearing your browser's local storage.

8. Data We Do Not Collect

To be explicit, we do not collect:

• Names, physical addresses, or phone numbers
• Payment or financial information
• IP addresses (not stored or logged)
• Device identifiers or fingerprints
• Location data beyond country-level (derived at request time, not stored)
• Browsing history or cross-site behavior
• Your documents, files, or content
• Your API keys, prompts, or AI model responses

9. Data Sharing and Selling

We do not sell your data. We do not rent your data. We do not share your data with third parties for their marketing purposes.

We may disclose information only if required by law (such as a valid subpoena or court order), and even then, we can only disclose what we actually have — which is very little.

10. Data Retention

• Analytics data: Aggregated analytics data is retained for the lifetime of a GhostMetrics site. Since it contains no personal data, there is nothing to delete on a per-user basis.
• Email addresses: Retained until you unsubscribe, at which point they are deleted.
• GhostMetrics auth emails: Retained for as long as the account is active.
• Client-side data: Stored in your browser. We have no control over it. Clear it through your browser settings.

11. Your Rights (GDPR & Beyond)

If you're in the European Economic Area (EEA), United Kingdom, or another jurisdiction with data protection laws, you have the following rights:

• Access: You can ask what data we hold about you. (Spoiler: almost nothing.)
• Rectification: You can ask us to correct inaccurate data.
• Erasure: You can ask us to delete your data. For email subscribers, just unsubscribe. For GhostMetrics dashboard users, email us.
• Portability: You can request a copy of your data in a machine-readable format.
• Objection: You can object to our processing of your data.
• Restriction: You can ask us to restrict processing of your data.

To exercise any of these rights, contact mike@nullagency.io. We will respond within 30 days.

Legal Basis for Processing (GDPR)

Where we process personal data, our legal bases are:

• Consent: When you provide your email to subscribe to updates
• Legitimate interest: Anonymous analytics to understand product usage (no personal data involved)
• Contract performance: Magic-link authentication to provide GhostMetrics dashboard access

12. California Privacy Rights (CCPA)

If you're a California resident, you have the right to:

• Know what personal information we collect (see Section 2 — it's not much)
• Request deletion of your personal information
• Opt out of the sale of your personal information (we don't sell it, so there's nothing to opt out of)
• Non-discrimination for exercising your privacy rights

13. Children's Privacy

Our Services are not directed at children under 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will delete it promptly.

14. Security

We take reasonable measures to protect the limited data we do collect. However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we minimize risk by minimizing what we collect in the first place.

15. International Data Transfers

Our Services are operated from the United States. If you access them from outside the United States, your information may be transferred to, stored, and processed in the United States. By using our Services, you consent to this transfer. Given the minimal and non-personal nature of the data we collect, the privacy risk of such transfers is negligible.

16. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we'll update the "Last updated" date at the top of this page. If we make significant changes that affect your rights, we'll make reasonable efforts to notify you (for example, via a notice on our website or by email if you're a subscriber).

17. Contact

Questions, concerns, or requests about your privacy? We're here:

Null Agency LLC
Email: mike@nullagency.io
Web: nullagency.io