Privacy Policy

1. Who we are and our role

Tracecanon is operated by Nimavera Inc. (in formation). For data-protection questions, contact privacy@tracecanon.com or our data-protection contact at privacy@tracecanon.com.

Account and billing data. For the personal data of the users who sign in, administer organizations, and are billed, we act as the controller (in California terms, the “business”).

Customer Content. For the recordings, documents, transcripts, embeddings, and findings that a customer organization uploads and processes, that organization is the controller and we act as its processor, processing on its documented instructions. The terms of that processing are set out in our Data Processing Addendum. If you are an individual whose voice or data appears in Customer Content, please direct data-subject requests to the organization that uploaded it; we will support them as their processor.

2. Data we process

Account data — name, work email, hashed password, MFA enrolment, organization and team membership, role, interface language, and account/login timestamps.

Organization and billing data — organization name, plan and entitlements, seat and usage counters, Stripe customer and subscription identifiers, and invoices. Payment-card details are handled by Stripe and never reach our servers.

Customer Content — the audio, video, and documents you upload, and the derived transcripts, speaker labels, embeddings, cited answers, inconsistency findings, chronologies, and exports. This may contain personal data and special-category data about third parties; you control what you upload.

Sharing links — secure, expiring share tokens you create to give a recipient scoped, time-limited access to a specific export or matter view.

Operational and audit data — an ordered, append-only, hash-chained metadata trail covering evidence handling, processing and model activity, access, reviews, corrections, exports, sharing, security, billing, and account changes, plus server logs (request path, status, timing), job metadata, and error diagnostics. The audit trail does not store evidence content, transcript text, excerpts, prompts, questions, answers, credentials, or model responses.

Cookies / local storage — a small number of strictly necessary items described in the Cookie Policy.

3. How we use data and our legal bases

• To provide the Service — accounts, uploads, transcription, search, analysis, exports, and sharing — is performance of our contract with the customer (and, for Customer Content, processing on the customer’s instructions).
• To take payment and manage subscriptions via Stripe — contractual necessity.
• To secure the Service and prevent abuse — tenant isolation checks, rate limits, quotas, and the audit trail — is our legitimate interest (and yours) in a safe, reliable service.
• To provide support and send service messages — contractual necessity / legitimate interest.
• To comply with legal obligations — for example, tax and accounting records — is a legal obligation.

We do not sell personal data, we do not use it for advertising or cross-product profiling, and we do not use Customer Content to train AI models.

4. Sub-processors

We use a small set of vetted service providers to run Tracecanon — hosting, object storage, transcription and language-model providers, email, payments, and error monitoring. Each is bound by a data-processing agreement and processes data only to provide its service to us. The current list, with each provider’s role, data categories, and location, is maintained on the Sub-processors page.

For every matter, OpenRouter receives the complete normalized audio for transcription, transcript segments and document chunks for semantic indexing, claim extraction, and chronology, relevant visual evidence pages with local OCR text for image interpretation, and the relevant excerpts, structured claim pairs, and query needed for cited answers or comparison. These jobs are sent in bounded requests rather than placing the complete matter into a single language-model prompt. Every request is restricted to an approved provider allow-list with model training and data collection denied and explicit zero-data-retention routing.

5. Tenant isolation and internal monitoring

Customer Content is isolated per organization: every record carries an organization key and matter access is authorized on every read, so your content is never made accessible to other Tracecanon customers or to other Nimavera products. Internal operational monitoring receives processing and cost metadata (for example, job counts, durations, and error rates) — never Customer Content — to keep the Service healthy.

6. Retention

Customer Content — source media and derived data — is retained according to the retention policy of your plan and matter, and is deleted after that period, subject to any legal hold you apply. Share-link tokens expire automatically. Account and organization data is kept while the account is active. Audit records and security logs are retained for a limited period appropriate to their security and accountability purpose. Billing records are kept as long as tax and accounting law requires (typically 6–10 years). On termination, Customer Content is deleted or returned as described in the Data Processing Addendum.

7. Your rights

Subject to applicable law, you may exercise the following rights over personal data for which we are the controller (chiefly account and billing data):

• Access a copy of your personal data;
• Rectify inaccurate data (much of it is editable in Settings);
• Erase your data, subject to our legal retention obligations;
• Port your data in a structured, machine-readable format;
• Object to or restrict processing based on legitimate interests;
• Withdraw consent where processing relies on it;
• Lodge a complaint with your data-protection supervisory authority.

Contact privacy@tracecanon.com. Where personal data appears in Customer Content, the customer organization is the controller; direct your request to that organization and we will assist it as processor.

8. International transfers

Nimavera Inc. (in formation) is based in the United States, and some sub-processors are located in the United States or other countries. Where personal data is transferred out of the EEA, the United Kingdom, or Switzerland, we rely on appropriate safeguards — the European Commission’s Standard Contractual Clauses, the UK Addendum, and, where a provider is certified, the EU-U.S. Data Privacy Framework — together with technical and organizational measures. Where your plan requires it, matters can be configured to keep processing within a specific region.

9. Security

We protect data with private object storage and short-lived signed URLs, encryption of secrets and of data in transit, MFA-ready authentication with server-side session revocation, per-organization access checks on every read, isolated validation of untrusted uploads, prompt-injection defenses that treat retrieved content as data, and an append-only hash-chained audit trail. See the full Security overview. No system is perfectly secure; report concerns to security@tracecanon.com.

10. Data-breach notification

If we become aware of a personal-data breach affecting data we process, we will notify the affected customer organization without undue delay and, where we are the controller and it is likely to result in a risk to individuals, the relevant supervisory authority and affected individuals as required by law. As processor, we will assist the controller in meeting its own breach-notification obligations.

11. Children

Tracecanon is a professional tool intended for use by adults in a business context. It is not directed to children, and we do not knowingly collect personal data directly from children through account sign-up. Recordings uploaded as Customer Content may, depending on the matter, contain data about minors; the customer organization is the controller of that content and is responsible for its lawful basis and safeguards.

12. Changes to this policy

We may update this Privacy Policy. Material changes — such as a new category of data or a new sub-processor — will be notified by email or in-app. The “Last updated” date reflects the current revision.

13. Contact

Privacy enquiries and requests: privacy@tracecanon.com or privacy@tracecanon.com. A postal address for service of notice is available on request via those addresses.