Privacy policy.

Last updated: September 30, 2026

This Privacy Notice for Panolayer, Inc. (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• visit our website at https://www.panolayer.com, or any website of ours that links to this Privacy Notice;
• use Panolayer, an agentic engineering platform that helps developers build complex software without breaking what already works; or
• engage with us in other related ways, including any marketing or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

1. What information do we collect?

Personal information you disclose to us

In short: we collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us.

The personal information we collect may include:

• names;
• email addresses;
• API keys / provider credentials;
• billing addresses.

Sensitive information. We do not process sensitive information.

Payment data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with it. All payment data is handled and stored by Stripe. Panolayer does not receive or store your full card number. Stripe's checkout handles payment collection directly, and Panolayer only receives limited billing metadata back (customer ID, plan, billing period, and payment status).

Social login data. We may provide you with the option to register using your existing GitHub or Google account. If you choose to register this way, we will collect certain profile information about you from that provider — see How do we handle your social logins?.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. We also collect information through cookies and similar technologies.

The information we collect includes:

• Log and usage data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, recorded in log files. Depending on how you interact with us, this may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as timestamps, pages and files viewed, searches, and which features you use), device event information (such as system activity and error reports), and hardware settings.
• Device data. Information about the computer, phone, tablet, or other device you use to access the Services, which may include your IP address, device and application identification numbers, browser type, hardware model, internet service provider, operating system, and system configuration information.
• Location data. Information about your device's location. We use approximate, IP-derived location (not precise GPS geolocation) for abuse and fraud prevention on the website. If you disable location settings on your device, some Services features may be affected.
• Product and agent-usage telemetry. Information about how you use the app's features and AI-agent workflows, collected to understand product usage and reliability. Examples include which features or workflows you start (e.g., an agent loop, a swarm run, code verification, autocomplete), whether a run succeeded or failed, how long it took, and usage/cost metrics tied to your plan (such as requests made or limits reached). This data is linked to your account so it can be attributed to you across the website and desktop app.

Google API. Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Information collected from other sources

In short: we may collect limited data from identity and payment providers you choose to connect.

In order to authenticate you and process payments, we may obtain information about you from other sources, such as identity providers (Clerk) and payment processors (Stripe), rather than directly from a form on our own site. If you register or sign in using your GitHub or Google account, we receive certain profile information about you from that platform, such as your name and email address. You may have the right to withdraw your consent to processing your personal information — see Withdrawing your consent. Any personal information we collect from your social login depends on that provider's own settings; their use of your information is not governed by this Privacy Notice.

2. How do we process your information?

In short: we process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior consent.

We process your personal information for the following purposes:

• To facilitate account creation and authentication and otherwise manage user accounts. (Retention: for as long as your account remains active, plus 90 days after closure to allow account recovery and resolve related requests.)
• To deliver and facilitate delivery of services to the user. (Retention: for as long as your account remains active. Local project data, indexes, and tokens stay on your device and are not separately retained on our servers.)
• To respond to user inquiries and offer support. (Retention: for as long as needed to resolve the inquiry and maintain a support history, typically up to 24 months.)
• To send administrative information to you (product/service changes, changes to our terms and policies, and similar information). (Retention: for as long as your account remains active, to enable necessary service communications.)
• To fulfill and manage your orders, payments, and subscription changes made through the Services. (Retention: for as long as the subscription is active, and for 7 years afterward as required by applicable tax and accounting laws.)
• To request feedback, and to contact you about your use of our Services. (Retention: for as long as needed to review and act on the feedback, typically up to 24 months.)
• To send you marketing and promotional communications, if in accordance with your marketing preferences. You can opt out at any time — see What are your privacy rights?. (Retention: n/a.)
• To protect our Services, including fraud monitoring and prevention. (Retention: up to 12 months from the date of the event, or longer where needed to investigate a specific security incident.)
• To identify usage trends, so we can better understand how our Services are used and improve them. (Retention: up to 24 months from the date of the event.)
• To save or protect an individual's vital interest, such as to prevent harm.
• To operate AI-agent and model-gateway features you configure. When you run an agent, autocomplete, or another model-backed feature, relevant prompts, code context, or repository metadata are routed through our gateway to the model or search providers you've selected, in order to return a result to you.

3. What legal bases do we rely on to process your information?

In short: we only process your personal information when we have a valid legal reason to do so — such as your consent, to comply with laws, to provide you with the Services under a contract, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, we rely on the following legal bases:

• Consent. We may process your information if you have given us permission for a specific purpose. You can withdraw your consent at any time — see Withdrawing your consent.
• Performance of a contract. To fulfill our contractual obligations to you, including providing our Services.
• Legitimate interests, where those interests do not outweigh your rights and freedoms — for example, to: send information about special offers and discounts; analyze how our Services are used so we can improve them; diagnose problems and prevent fraudulent activity; and understand how users use our products so we can improve user experience.
• Legal obligations, such as cooperating with a law enforcement body or regulatory agency, or exercising or defending our legal rights.
• Vital interests, such as situations involving a potential threat to the safety of any person.

If you are located in Canada, we may process your information with your express or implied consent, which you can withdraw at any time, or — in limited, legally defined circumstances — without consent (for example: investigating fraud, a business transaction, assessing an insurance claim, identifying an injured or deceased person, responding to a subpoena or court order, or where the information is already publicly available).

4. When and with whom do we share your personal information?

In short: we may share information in specific situations, and with specific categories of third parties.

Vendors, consultants, and other third-party service providers. We may share your data with third parties who perform services for us or on our behalf and require access to do that work. We have contracts in place with these providers that limit their use of your data to the purposes we instruct.

The categories of third parties we may share personal information with are:

• AI platforms (see Do we offer artificial intelligence-based products?)
• Cloud computing services
• Communication & collaboration tools
• Data analytics services
• Government entities
• Payment processors
• User account registration & authentication services

We also may need to share your personal information in the following situations:

• Business transfers, in connection with a merger, sale of company assets, financing, or acquisition of all or a portion of our business.
• Marketplace plugin publishers, if you choose to install and run a third-party coding agent — see Marketplace plugin publishers are independent third parties, not Panolayer.

5. Do we use cookies and other tracking technologies?

In short: we may use cookies and similar technologies to maintain security, keep you signed in, remember your preferences, and measure product usage. We do not use these technologies for advertising.

We use cookies and similar technologies (such as local storage) to keep you signed in, remember your locale and theme preference, and help maintain the security of our Services. We also use analytics tooling that sets its own identifier to measure feature usage across the website and desktop app, tied to your signed-in account. We do not use advertising or retargeting cookies, and we do not share cookie data with ad networks.

6. Do we offer artificial intelligence-based products?

In short: we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

Use of AI technologies. We provide certain AI-backed features through third-party AI service providers that you configure, which may include Anthropic and OpenAI, or another OpenAI-compatible endpoint of your choosing — or, if you do not configure your own provider, Panolayer's own managed model service. Your input, output, and related personal information will be shared with and processed by the provider you've selected to enable your use of that feature. You must not use these features in a way that violates the terms or policies of any AI service provider.

Our AI products are designed for the following functions: AI automation; AI development; natural language processing; AI search; machine learning models; AI applications; AI document generation (living documents generated from your codebase architecture); and AI insights (the verification engine and architecture-level code review).

How we process your data using AI. All personal information processed using our AI features is handled in line with this Privacy Notice and our agreements with the relevant providers.

How to opt out. Panolayer's AI processing is opt-in by action — nothing runs an AI model over your code unless you deliberately trigger it. You can also:

• log in to your account settings and update your configuration (for example, disabling autocomplete, or removing a configured model provider);
• contact us using the contact information provided below; or
• simply not run an AI-powered feature — agent loops, swarm runs, verification, and autocomplete are only triggered by your explicit action, and there is no background or automatic processing of your code or prompts through an AI model.

7. How do we handle your social logins?

In short: if you choose to register or log in using GitHub or Google, we may have access to certain information about you.

Our Services allow you to register and log in using your GitHub or Google account. Where you choose to do this, we receive certain profile information about you from that provider — often your name, email address, and profile picture, as well as other information you choose to make public on that platform. We use this information only for the purposes described in this Privacy Notice. We do not control, and are not responsible for, other uses of your personal information by GitHub or Google; review their own privacy notices to understand how they collect, use, and share your information.

8. Is your information transferred internationally?

In short: we may transfer, store, and process your information in countries other than your own.

Our servers, and those of our service providers, are located in the United States. Regardless of your location, your information may be transferred to, stored by, and processed in the United States and other countries where our third-party providers operate (see When and with whom do we share your personal information?).

If you are a resident of the European Economic Area (EEA), United Kingdom (UK), or Switzerland, these countries may not have data protection laws as comprehensive as those in your country. We take measures to protect your personal information in accordance with this Privacy Notice and applicable law, including by relying on the European Commission's Standard Contractual Clauses for transfers of personal information to our third-party providers. These clauses require recipients to protect personal information originating from the EEA or UK in accordance with European data protection law. Further details can be provided upon request.

9. How long do we keep your information?

In short: we keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer period is required by law.

We will only keep your personal information for as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). See How do we process your information? for our retention periods by purpose. When we no longer have an ongoing legitimate need to process your information, we will delete or anonymize it, or, where that isn't possible (for example, because it's in a backup archive), we will securely isolate it from further processing until deletion is possible.

10. How do we keep your information safe?

In short: we aim to protect your personal information through a system of organizational and technical security measures.

We have implemented reasonable technical and organizational security measures appropriate to a developer tool that handles source code and credentials, including:

• TLS for website and API traffic;
• local storage of desktop session tokens in the platform keychain when available;
• scoped, short-lived desktop sessions;
• policy and audit controls on Guardian-mediated model calls;
• sandboxing for Marketplace container agents, with declared permissions.

No method of transmission or storage is completely secure, so we cannot guarantee that unauthorized third parties will never be able to defeat our security. You are responsible for access to devices that have the app installed and for the repositories you open.

11. Do we collect information from minors?

In short: we do not knowingly collect data from or market to children under 18 (or the equivalent age specified by law in your jurisdiction).

We do not knowingly collect, solicit, or sell personal information from children under 18 (or the equivalent age specified by law in your jurisdiction). By using the Services, you represent that you meet this age requirement, or that you are the parent or guardian of a minor who does and consent to their use of the Services. If we learn we've collected information from someone under this age, we will deactivate the account and delete the data. If you become aware of any such data, contact us at [email protected].

12. What are your privacy rights?

In short: depending on your state of residence in the US, or if you are in the EEA, UK, Switzerland, or Canada, you have rights that give you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (the EEA, UK, Switzerland, and Canada), you have the right to: (i) request access to and a copy of your personal information; (ii) request rectification or erasure; (iii) restrict processing; (iv) request data portability, where applicable; and (v) not be subject to solely automated decision-making that produces legal or similarly significant effects — if such a decision is made, we will inform you, explain the main factors, and offer a way to request human review. You may also have the right to object to certain processing. Make such a request using the contact details in How can you contact us about this notice?. We will consider and act on any request in accordance with applicable law.

If you are in the UK and unhappy with how we've handled your personal information, you can complain directly to us; we will acknowledge your complaint within 30 days, investigate without unjustifiable delay, and keep you informed of the outcome. If you're not satisfied with our response, you can refer your complaint to the Information Commissioner's Office (ICO): ico.org.uk/make-a-complaint, helpline 0303 123 1113, or by post to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

If you are in the EEA or UK, you also have the right to complain to your Member State data protection authority or the UK data protection authority. If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, you have the right to withdraw it at any time by contacting us (see How can you contact us about this notice?). This will not affect the lawfulness of processing before withdrawal, or processing based on a lawful ground other than consent.

Opting out of marketing and promotional communications

You can unsubscribe from marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us. You will be removed from marketing lists, though we may still send you service-related messages necessary for the administration of your account.

Account information

If you would like to review or change the information in your account, or terminate your account, you can log in to your account settings. Upon a request to terminate your account, we will deactivate or delete your account and information from our active databases, though we may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, or comply with legal requirements.

Cookies and similar technologies

Most web browsers accept cookies by default. You can usually set your browser to remove or reject cookies; doing so may affect certain features of our Services.

If you have questions or comments about your privacy rights, email us at [email protected].

13. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting. No uniform technology standard for recognizing and implementing DNT signals has been finalized, so we do not currently respond to DNT browser signals or any other automatic mechanism communicating your choice not to be tracked online. If a standard is adopted that we must follow, we will update this Privacy Notice.

California law requires us to disclose how we respond to browser DNT signals: because there is not yet an industry or legal standard for honoring them, we do not respond to them at this time.

14. Do United States residents have specific privacy rights?

In short: if you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and details about the personal information we hold about you, correct inaccuracies, obtain a copy, or delete it. You may also have the right to withdraw consent. These rights may be limited in some circumstances by applicable law.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. It is illustrative, not a comprehensive inventory — see What information do we collect? for full detail.

We will use and retain the collected personal information as needed for the Services, or for:

• Category A — as long as the user has an account with us, except where retained longer as required by applicable tax and accounting laws for billing records.
• Category B — as long as the user has an account with us, except where retained longer as required by applicable tax and accounting laws for billing records.
• Category D — as long as the user has an account with us, except where retained longer as required by applicable tax and accounting laws for billing and subscription records.
• Category F — up to 24 months from the date of the event.
• Category G — up to 12 months for abuse-prevention logs; up to 24 months for analytics-derived location data.

Will your information be shared with anyone else?

We may disclose your personal information to our service providers under a written contract — see When and with whom do we share your personal information?. We may also use your personal information for our own internal purposes, such as technological development; this is not considered “selling” your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months: Category A (Identifiers), Category D (Commercial information), Category F (Internet or other electronic network activity information), and Category G (Geolocation data).

Your rights

You have rights under certain US state data protection laws, though these rights are not absolute. They include the right to: know whether we are processing your personal data; access it; correct inaccuracies; request its deletion; obtain a copy of what you've shared with us; non-discrimination for exercising your rights; and opt out of the processing of your personal data for targeted advertising (or sharing, as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. Depending on your state, you may also have the right to obtain a list of the categories or specific third parties to which we've disclosed personal data, to review and correct automated profiling, or to limit use of sensitive personal data.

How to exercise your rights

To exercise these rights, contact us by visiting your account settings, by emailing [email protected], by visiting our contact page, or by using the contact details in How can you contact us about this notice?.

Under certain state laws, you can designate an authorized agent to make a request on your behalf; we may deny a request from an agent who does not submit proof of valid authorization.

Request verification

Upon receiving your request, we will need to verify your identity. We will only use personal information provided in your request for that purpose, or, if needed, request additional information for identity verification or fraud-prevention purposes. A request submitted through an authorized agent may require additional verification, including written and signed permission from you.

Appeals

If we decline to act on your request, you may appeal by emailing [email protected]. We will inform you in writing of the outcome, including our reasoning. If your appeal is denied, you may complain to your state attorney general.

California “Shine the Light” law

California Civil Code Section 1798.83 permits California residents to request, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes, and the names and addresses of those third parties, in the preceding calendar year. To make such a request, contact us using the details in How can you contact us about this notice?.

15. Do other regions have specific privacy rights?

In short: you may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. This Privacy Notice satisfies the notice requirements of both Acts. If you do not wish to provide personal information necessary to fulfill its purpose, it may affect our ability to offer you our products, respond to your requests, manage your account, or confirm your identity.

You have the right to request access to or correction of your personal information at any time by contacting us — see How can you review, update, or delete the data we collect from you?. If you believe we are unlawfully processing your personal information, you can complain about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner, or a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

You have the right to request access to or correction of your personal information at any time by contacting us — see How can you review, update, or delete the data we collect from you?. If you are unsatisfied with how we address a complaint, contact The Information Regulator (South Africa): general enquiries at [email protected], or complaints (POPIA/PAIA form 5) at [email protected] and [email protected].

16. We do not use Customer Content to train Panolayer's foundation models.

When you open a repository or run an agent, the app processes your source code, diffs, prompts, and verification results on your machine, and — only for the specific model-backed feature you invoke — with the model or search provider you've configured. We do not build a marketing or training database from your code.

17. Marketplace plugin publishers are independent third parties, not Panolayer.

If you install and run a third-party coding agent from the Marketplace, the relevant prompts or code context you send to that agent go directly to its publisher, under that publisher's own terms — not Panolayer's — and only because you chose to install and run it.

18. Local-first processing, human-in-the-loop.

Indexing, architecture mapping, and much of the verification engine run entirely on your device. Agents propose changes; you review and approve them — the product is designed so a human stays in control of what actually gets committed to your code.

19. Do we make updates to this notice?

In short: yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this Privacy Notice. If we make material changes, we may notify you by prominently posting a notice of the changes or by directly notifying you. We encourage you to review this Privacy Notice periodically.

20. How can you contact us about this notice?

If you have questions or comments about this notice, email us at [email protected], or contact us by post at:

Panolayer, Inc. [Mailing address to be added] United States

21. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or US state of residence, you may have the right to request access to the personal information we collect from you, details about how we've processed it, correct inaccuracies, or delete it. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit your account settings.

This Privacy Policy was created using Termly's Privacy Policy Generator.