Privacy Policy

1. Introduction & Overview

This Privacy Policy explains how SimpleRAS collects, uses, processes, stores, and protects personal and compliance data when you visit our website (simpleras.com), utilize our cloud applications, or interact with our software services (collectively, the "Service").

SimpleRAS provides practice management, statutory deadline tracking, and compliance reporting tools designed specifically for Texas Registered Accessibility Specialists ("RAS"), accessibility consultants, and architectural firms operating under the Texas Architectural Barriers Act (Texas Occupations Code Chapter 469) and Title 16 Texas Administrative Code (16 TAC) Chapter 68.

2. Our Role: Data Controller vs. Data Processor

Depending on the context of the data provided, the SimpleRAS protected series operates in two distinct capacities:

• Data Controller: The SimpleRAS protected series acts as a Data Controller for subscriber account data, registration details, billing contact information, and website analytics. Mustard Seed Labs LLC does not act as a Data Controller.
• Data Processor / Service Provider: When a subscriber inputs, uploads, or generates project inspection records, owner/architect contact transmittals, site photographs, plan review findings, or Record of Transactions (ROT) entries into SimpleRAS, the subscriber acts as the Data Controller, and the SimpleRAS protected series processes such data strictly on the subscriber's behalf to deliver the Service. Mustard Seed Labs LLC does not act as a Data Processor or process any data on behalf of subscribers.

3. Categories of Information Collected

We collect and process the following categories of information:

A. Subscriber & Account Information

• Contact Identification: Full name, firm/company name, professional email address, phone number, and physical office address.
• State Credentials: State of Texas Registered Accessibility Specialist (TDLR RAS) license numbers, firm affiliations, and authorized staff credentials.
• Authentication Data: Usernames, encrypted password hashes, and session authentication tokens.

B. Compliance, Project & Inspection Data (Customer Data)

• Project Identification: Texas Automated Barriers System (TABS / EABPR) project numbers, project titles, physical construction site addresses, and construction valuations.
• Stakeholder Contact Details: Building owner entities, designated owner agents, architects of record, design professionals, and general contractor representatives inputted by the specialist.
• Technical Findings & Inspection Data: TAS 2012 code citations, plan review notes, punch list items, field measurements, annotated field photographs, and statutory transmittal letters.
• Record of Transactions (ROT): Timestamped logs of statutory events, sequence numbers (1.0 through 7.1), delivery receipts, and transmittal histories under 16 TAC §68.76.

C. Billing & Payment Information

Payment transactions are processed securely through our third-party payment processor, Stripe, Inc. The SimpleRAS Series does not store raw credit card numbers, CVVs, or full payment card data on our servers. We receive only transaction identifiers, card expiration dates, last-four digits, and subscription status tokens.

D. Automated Technical & Device Telemetry

• Log Data: IP addresses, browser user-agent strings, device operating systems, screen resolutions, error logs, and performance metrics.
• Cookies & Local Storage: Essential session storage keys (such as dark/light theme preferences and authentication state) necessary to operate the application. We do not sell tracking cookies or use third-party advertising network trackers.

4. How Information Is Used

We process information strictly for legitimate operational and compliance purposes:

• To provision, maintain, and secure your SimpleRAS workspace.
• To retrieve and normalize official project records from the TDLR TABS database upon user request.
• To calculate statutory 16 TAC Chapter 68 turnaround clocks (30-day plan reviews, 1-year inspection windows, 90-day corrective action windows).
• To generate architectural-grade PDF inspection reports, plan review notices, and official state forms (AB042, AB043, Form 005, Form 247N).
• To transmit official deliverables and cover letters to building owners and architects via verified email transmittals.
• To maintain an immutable, audit-ready Record of Transactions (ROT) log for TDLR state reviews.
• To manage subscriptions, process invoices, and provide customer support.

5. Infrastructure & Subprocessors

The SimpleRAS Series engages enterprise-tier infrastructure and technology providers to ensure high availability and security. All subprocessor agreements are maintained exclusively by the series:

6. Total Parent Entity Insulation & Recourse Boundaries

Pursuant to Texas law, all privacy covenants, data processing agreements, security commitments, and regulatory liabilities arising under this Policy are the sole and exclusive responsibility of Mustard Seed Labs LLC – SimpleRAS Series.

Under no circumstances shall any user, data subject, regulatory agency, or third party have recourse against the general assets, officers, members, or other series of Mustard Seed Labs LLC for any alleged breach, data incident, regulatory enforcement action, or claim arising from the operation of SimpleRAS.

7. Data Security & Encryption Standards

We implement enterprise-grade technical, operational, and organizational security controls:

• Encryption in Transit: All web and API traffic is encrypted using modern Transport Layer Security (TLS 1.3 / HTTPS).
• Encryption at Rest: Customer database records, uploaded field photos, and generated PDF deliverables are encrypted using AES-256 standards on Google Cloud storage infrastructure.
• Access Control: Administrative access to production databases is restricted to authorized engineering personnel using multi-factor authentication (MFA) and least-privilege role boundaries.
• Data Backups: Redundant multi-region database backups are performed daily to prevent data loss.

8. Statutory Record Retention for Texas RAS

Under 16 TAC §68.76 and TDLR rules, Registered Accessibility Specialists are subject to mandatory record retention obligations (e.g., maintaining complete project files, verification receipts, and Record of Transactions logs for a minimum statutory period, typically three years from project completion).

The SimpleRAS Series retains project and transaction records in active workspaces for the duration of the customer's subscription. Upon subscription termination or upon explicit request, customers can export their complete compliance archive (including ROT PDFs, reports, and raw data). Data deletion requests will be processed in accordance with legal and regulatory record-retention requirements.

9. Data Sharing & Disclosures

We do not sell, rent, or monetize your personal data or your clients' project details. We disclose information only under the following limited circumstances:

• With Authorized Subprocessors: As necessary for cloud hosting, email delivery, and billing as set forth in Section 5.
• Legal & Regulatory Compliance: If required by applicable law, court order, or official state regulatory subpoena (such as in connection with an active TDLR administrative proceeding or state audit).
• Business Transfers: In the event of a merger, reorganization, financing, or sale of assets involving the SimpleRAS protected series, customer data will transfer under equivalent confidentiality protections. Mustard Seed Labs LLC is shielded from any liability associated with such transfers.

10. Your Data Rights & Choices

You have the right to:

• Access, review, and update your personal account information via your workspace settings.
• Export your complete project database, inspection reports, and Record of Transactions in standard formats (PDF, JSON).
• Request deletion of your account and associated data (subject to statutory audit retention obligations).
• Opt out of non-essential operational communications (statutory transmittals and security notices remain required).

11. Contact & Legal Notices

For privacy inquiries, data export requests, or formal notices, please contact: