SKILL TRACER - PRIVACY POLICY
Version 2 (placeholders filled). Companion to the Skill Tracer EULA & Terms of Use. For internal review, then external counsel. Not legal advice. See "Skill Tracer - Reviewer Notes & Open Items" for assumptions and open decisions. Should be reconciled with the existing company-wide "Metano Privacy Policy."
1.INTRODUCTION
1.1 This Privacy Policy explains how Metano Inc., a Delaware corporation with a principal place of business at 1051 Craig Dr, San Jose, CA 95129, USA ("Metano," "we," "us"), collects, uses, shares, and protects information in connection with Skill Tracer, the AI-skill scanning service at https://labs.metano.ai/scanner and related interfaces and APIs (the "Service"). It should be read together with the Skill Tracer EULA & Terms of Use ("Terms").
1.2 Capitalized terms not defined here have the meaning given in the Terms (for example, "Content," "Results," "Public Submission").
1.3 IMPORTANT: The public Service is public by design. Content you submit to the public Service, and its Results, are shared publicly. Please read Section 5 before uploading anything.
1.4 The Service is designed to be usable anonymously and to minimize personal data. Even so, some data we handle (for example, IP address and information contained in uploaded Content) may constitute personal data under laws such as the EU GDPR, the India Digital Personal Data Protection Act (DPDP), and the California Consumer Privacy Act (CCPA). This policy is written to address those laws.
2.INFORMATION WE COLLECT
2.1 Information you provide: if you create an account or contact us, details such as name, email, and any information you choose to add.
2.2 Content you submit: the skills, files, URLs, and related material you upload for analysis. Content such as executables, packages, and documents may itself contain personal information relating to you or to others.
2.3 Information collected automatically: IP address, user-agent and device information, request logs, and interaction/usage data.
2.4 Cookies and similar technologies: used to operate, secure, and measure the Service (see Section 9).
3.HOW WE USE INFORMATION
3.1 To provide, operate, maintain, and secure the Service, including generating and displaying Results and threat intelligence.
3.2 To develop and improve Service features and quality.
3.3 To communicate with you about the Service, including administrative and security notices.
3.4 To prevent fraud, abuse, and security threats, and to enforce the Terms.
3.5 To comply with legal obligations.
3.6 WE DO NOT USE CONTENT YOU UPLOAD TO TRAIN, FINE-TUNE, OR OTHERWISE DEVELOP MACHINE-LEARNING OR AI MODELS (see Terms Section 7).
4.HOW WE SHARE INFORMATION
4.1 Public Submissions: Content and Results from Public Submissions are shared publicly and made available to the Community and any third party, including via a public URL and download. We may also display limited submitter metadata (for example, a ciphered submitter identifier and coarse location such as city and country). [Reviewer: confirm what submitter metadata, if any, is shown.]
4.2 Service providers: we share information with vendors who help us host, operate, secure, and measure the Service (for example, our cloud host), under appropriate contractual restrictions.
4.3 Legal and safety: we may disclose information where required by law, regulation, legal process, or to protect the rights, safety, or security of Metano, users, or the public.
4.4 Corporate transactions: information may be transferred in connection with a merger, acquisition, financing, or sale of assets.
4.5 We do not sell personal information.
5.PUBLIC SUBMISSIONS: WHAT THIS MEANS FOR YOUR DATA
5.1 When you make a Public Submission, your Content and its Results become visible to and downloadable by an unlimited number of people. Public Submissions are not confidential.
5.2 Do not upload confidential, commercially sensitive, or personal data to the public Service. If you do not want something to be public, do not submit it to the public Service; use the Private Service instead (Section 11).
5.3 If your Content contains personal data of third parties, you must have a lawful basis and any required consent before uploading it. You are solely responsible for third-party claims arising from such uploads.
5.4 Because Public Submissions are public and may be copied and retained by third parties, we cannot reliably identify personal data within them, recall them, or guarantee their deletion once shared. Requests relating to personal data contained in Public Submissions may not be technically satisfiable.
6.RETENTION
6.1 We retain information only for as long as necessary for the purposes for which it was collected, or as required to operate the Service, comply with legal obligations, resolve disputes, and prevent fraud, abuse, and security threats.
6.2 Public Submissions (Content and Results) are retained indefinitely and remain publicly available as part of the Service corpus.
6.3 Operational logs (for example, request and IP logs) are retained for [90] days unless a longer period is required. [Reviewer: confirm log retention period.]
7.YOUR RIGHTS
7.1 Subject to applicable law (including GDPR, India DPDP, and CCPA), you may have rights to access, correct, delete, restrict, or object to the processing of your personal information, and to data portability, and rights against certain automated decision-making.
7.2 To exercise these rights, contact us at legal@metano.ai. We may need to verify your identity.
7.3 The rights in this section are subject to the limitations in Section 5 for personal data contained in Public Submissions.
7.4 EU/UK users may lodge a complaint with their supervisory authority. India (DPDP) users may contact our Grievance Officer / Data Protection Officer (Section 15). California (CCPA) users have the rights to know, delete, correct, and opt out of sale/sharing; we do not sell personal information.
8.LEGAL BASES FOR PROCESSING (where applicable)
8.1 Where GDPR or similar laws apply, we process personal information on the bases of: performance of a contract (providing the Service), our legitimate interests (securing and improving the Service, preventing abuse, and sharing threat intelligence with the community), your consent (where required, for example certain cookies), and compliance with legal obligations.
9.COOKIES AND SIMILAR TECHNOLOGIES
9.1 We use cookies and similar technologies to keep you signed in, remember preferences, secure the Service, and measure usage. You can control cookies through your browser settings; some features may not function without them. [Reviewer: confirm whether a consent banner is required for EU/UK traffic.]
10.SECURITY
10.1 We take reasonable technical and organizational measures to protect personal information. No method of transmission or storage is fully secure, and we cannot guarantee absolute security. Public Submissions are, by design, not protected as confidential.
11.PRIVATE / ENTERPRISE SERVICE
11.1 A private, non-public version of Skill Tracer is available under a separate written agreement for customers who do not want their submissions shared publicly. Data handling for the Private Service is governed by that agreement, not by this public Privacy Policy. To request it, contact info@metano.ai.
12.HOSTING AND INTERNATIONAL DATA TRANSFERS
12.1 The Service is hosted on Google Cloud Platform in the United States. If you access the Service from outside the United States, your information will be processed in the United States and potentially other countries.
12.2 We do not currently offer a data-residency guarantee for the public Service. Where required for transfers of personal data from the EU/UK or India, we rely on appropriate safeguards. [Reviewer: confirm transfer mechanism, for example Standard Contractual Clauses; note data-residency options for the Private Service.]
13.CHILDREN
13.1 The Service is not directed to children and is intended for users aged 18 and over. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us personal information, contact us and we will take appropriate steps. [Reviewer: confirm age threshold across GDPR (16), CCPA (13), and DPDP (18); 18 chosen as the strictest.]
14.CHANGES TO THIS POLICY
14.1 We may update this Privacy Policy from time to time. Changes are effective when posted or as otherwise stated. Material changes will be communicated as required by law.
15.CONTACT
15.1 Data Protection Officer / Grievance Officer: Ratnesh Pandey, contactable at legal@metano.ai.
15.2 General privacy questions and rights requests: legal@metano.ai, or by post to Metano Inc., 1051 Craig Dr, San Jose, CA 95129, USA.
Effective date: [date this policy is posted]. Skill Tracer publicly launched on 26 June 2026.