개인정보처리방침

Your privacy is important to us. This Privacy Policy explains how MITRITY collects, uses, shares, and protects personal data when you visit our website, use our Service, or interact with us.

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1. Data Controller

The data controller for the personal data described in this policy is:

MITRITY MITRITY AB Registration number: 559564-7305 VAT number: SE559564730501 Registered office: Stockholm, Sweden

Data Protection Officer (DPO): Email: dpo@mitrity.com

If you have any questions or concerns about how we process your personal data, please contact our DPO.

2. What Data We Collect

We collect and process the following categories of personal data:

2.1 Account Data

Data you provide when creating an account or managing your subscription:

• Full name
• Email address
• Organization name and details
• Job title or role
• Phone number (optional)
• Billing address
• Payment information (processed by Stripe; MITRITY does not store full payment card details)
• Authentication credentials (password hashes, MFA settings)
• Account preferences and settings

2.2 Agent Action Data

Data transmitted by Customer's AI agents through the Edge Node to the Service:

• Action metadata (action type, target resource, timestamps, duration)
• Action parameters (configuration values, command parameters)
• Agent identifiers (agent ID, agent type, mission scope)
• Action outcomes (success, failure, blocked)
• Behavioral patterns (action sequences, frequency patterns)

Important: Agent action payloads may contain personal data of Customer's end users or employees. The processing of such personal data is governed by the Data Processing Agreement (DPA), where Customer is the data controller and MITRITY is the data processor.

2.3 Usage Data

Data generated automatically through your use of the Service:

• Features used, pages visited within the Service, and click patterns
• Session duration and frequency
• Device information (browser type, operating system, screen resolution)
• IP address
• Geographic location (city/country level, derived from IP address)
• Performance data (page load times, errors encountered)

2.4 Communication Data

Data from your interactions with us:

• Support tickets and correspondence
• Feedback and survey responses
• Marketing preferences and consent records

2.5 Website Visitor Data

Data collected when you visit mitrity.com:

• IP address
• Browser type and version
• Pages visited and referring URL
• Cookies and similar technologies (see our Cookie Policy)

2.6 Academy Data

If you take courses in MITRITY Academy, we process your course progress, exam answers and results, and the certificates you earn. Each certificate has a public verification page, reached through a link with a random code that is printed on the certificate. Anyone with the link can see the course, the issue date and the certificate ID. Your name appears on that page only if you choose to show it, and you can change that choice at any time. The verification page is not listed in search engines.

3. Legal Basis for Processing

We process personal data based on the following legal grounds under GDPR Article 6:

4. How We Use Data

4.1 Service Delivery

• Providing, operating, and maintaining the Platform
• Processing and validating agent actions through Edge Nodes and the Control Plane
• Generating governance dashboards, reports, and alerts
• Managing user authentication and access control
• Processing subscriptions and billing

4.2 Service Improvement

• Analyzing usage patterns to improve features and user experience
• Identifying and fixing bugs, errors, and performance issues
• Developing new features based on aggregated usage insights

4.3 Machine Learning and Analytics

• Training and improving ML models that detect anomalous agent behavior
• All training data is anonymized and aggregated before use
• Individual customers or data subjects are not identifiable in training data
• ML models are designed to improve governance accuracy for all customers

4.4 Security

• Monitoring for unauthorized access, fraud, and abuse
• Enforcing the Acceptable Use Policy
• Investigating security incidents
• Maintaining audit logs

4.5 Communications

• Sending transactional emails (account confirmation, password reset, billing receipts, alerts)
• Sending service notifications (maintenance, incidents, product updates)
• Sending marketing communications (only with your consent)

4.6 Legal and Compliance

• Complying with legal obligations (tax reporting, regulatory requirements)
• Establishing, exercising, or defending legal claims
• Responding to lawful requests from public authorities

5. Data Sharing

We share personal data only in the following circumstances:

5.1 Sub-Processors

We use the following third-party sub-processors to deliver the Service:

A current list of sub-processors is maintained in the Data Processing Agreement.

5.2 Legal Requirements

We may disclose personal data if required by law, regulation, legal process, or governmental request. We will notify you of such disclosure unless prohibited by law.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of MITRITY's assets, personal data may be transferred to the acquiring entity. We will notify affected individuals and provide an opportunity to opt out where feasible.

5.4 With Your Consent

We may share personal data with third parties when you have given us explicit consent to do so.

5.5 What We Do Not Do

• We do not sell personal data.
• We do not share personal data with advertisers.
• We do not use personal data for profiling that produces legal effects on individuals.

6. International Data Transfers

6.1 EU-Based Infrastructure

The Service infrastructure is hosted in the European Union (Google Cloud europe-north1, Finland). The majority of personal data processing occurs within the EU.

6.2 Transfers Outside the EU

Where personal data is transferred to sub-processors located outside the EU/EEA (e.g., Stripe and SendGrid have operations in the United States), we ensure appropriate safeguards are in place, including:

(a) EU-US Data Privacy Framework — Where the sub-processor is certified under the EU-US Data Privacy Framework;

(b) Standard Contractual Clauses (SCCs) — EU Commission-approved standard contractual clauses; and/or

(c) Adequacy decisions — Where the European Commission has determined that the destination country ensures an adequate level of data protection.

6.3 Transfer Impact Assessments

We conduct transfer impact assessments for each sub-processor to evaluate the legal framework and data protection practices in the destination country and implement supplementary measures where necessary.

7. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy:

After the retention period expires, personal data is deleted or anonymized in accordance with our data deletion procedures.

8. Data Subject Rights

Under GDPR, you have the following rights regarding your personal data:

8.1 Right of Access (Article 15)

You have the right to obtain confirmation of whether we process your personal data and to access a copy of that data, along with information about how it is processed.

8.2 Right to Rectification (Article 16)

You have the right to have inaccurate personal data corrected and incomplete data completed.

8.3 Right to Erasure (Article 17)

You have the right to request deletion of your personal data where:

• The data is no longer necessary for the purpose it was collected;
• You withdraw consent and there is no other legal basis for processing;
• You object to processing and there are no overriding legitimate grounds; or
• The data has been unlawfully processed.

This right is subject to exceptions, including where retention is required by law.

8.4 Right to Restriction of Processing (Article 18)

You have the right to restrict the processing of your personal data in certain circumstances, such as while we verify the accuracy of your data or assess an objection.

8.5 Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller, where processing is based on consent or contract performance and carried out by automated means.

8.6 Right to Object (Article 21)

You have the right to object to processing based on legitimate interest. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests. You have an absolute right to object to processing for direct marketing at any time.

8.7 Right Not to Be Subject to Automated Decision-Making (Article 22)

We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.

8.8 Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

8.9 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer:

Email: dpo@mitrity.com

We will respond to your request within 30 days, as required by GDPR. If the request is complex, we may extend this by an additional 60 days with notice.

We may need to verify your identity before processing your request. There is no fee for exercising your rights, unless requests are manifestly unfounded or excessive.

8.10 Right to Lodge a Complaint

If you are not satisfied with how we handle your request, you have the right to lodge a complaint with a supervisory authority. In Sweden, the supervisory authority is:

Integritetsskyddsmyndigheten (IMY) Swedish Authority for Privacy Protection Box 8114 104 20 Stockholm, Sweden Website: https://www.imy.se Email: imy@imy.se

You may also lodge a complaint with the supervisory authority in your country of residence.

9. Data Security

We implement appropriate technical and organizational measures to protect personal data, including:

• Encryption: TLS 1.3 for data in transit; AES-256 for data at rest
• Access controls: Role-based access control, mandatory multi-factor authentication
• Tenant isolation: Database-level isolation between customers
• Infrastructure security: Google Cloud Platform security features, Cloud Armor WAF, private networking
• Monitoring: Continuous security monitoring, intrusion detection, and audit logging
• Personnel: Background checks, confidentiality agreements, security training for all employees
• Incident response: Documented incident response plan with 72-hour breach notification

10. Children's Privacy

The Service is not directed to individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete that data promptly.

If you believe we have inadvertently collected personal data from a child under 16, please contact us at dpo@mitrity.com.

11. Cookies and Similar Technologies

We use cookies and similar technologies on our website and within the Service. For detailed information about the cookies we use, their purposes, and how to manage them, please see our Cookie Policy.

12. Third-Party Links

Our website and Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing them with personal data.

13. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. When we make material changes, we will:

(a) Update the "Last updated" date at the top of this policy;

(b) Notify you via email or through a prominent notice in the Service at least 30 days before the changes take effect; and

(c) Where required by law, seek your consent to the changes.

We encourage you to review this policy periodically.

14. Contact Information

For questions, concerns, or requests related to this Privacy Policy or our data processing practices:

Data Protection Officer MITRITY AB Email: dpo@mitrity.com

General inquiries Email: hello@mitrity.com Website: https://mitrity.com