Privacy Policy
Last updated: October 2026
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.
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:
| Data Category | Legal Basis | Details |
|---|---|---|
| Account Data | Contract performance (Art. 6(1)(b)) | Necessary to create and manage your account and provide the Service |
| Agent Action Data | Contract performance (Art. 6(1)(b)) | Necessary to deliver the core governance and monitoring functionality |
| Billing and payment | Contract performance (Art. 6(1)(b)) | Necessary to process subscriptions and payments |
| Academy data | Contract performance (Art. 6(1)(b)) | Necessary to provide the courses and certificates you sign up for; your name is shown on a certificate's verification page only with your consent (Art. 6(1)(a)) |
| Academy activity for sales follow-up | Legitimate interest (Art. 6(1)(f)) | To find organizations that may benefit from the MITRITY platform and contact them about it. We look at an organization's Academy activity — work email domain, team size, course progress and whether a checkout was started — never exam answers. You can object at any time (Section 8.6); marketing emails are sent only with your consent |
| Usage Data (analytics) | Legitimate interest (Art. 6(1)(f)) | To understand usage patterns, improve the Service, and ensure security. Our interest in improving our service is balanced against minimal privacy impact (data is pseudonymized/aggregated) |
| Security monitoring | Legitimate interest (Art. 6(1)(f)) | To detect and prevent fraud, abuse, and security incidents |
| Marketing communications | Consent (Art. 6(1)(a)) | Only with your explicit opt-in consent; you may withdraw consent at any time |
| ML model training | Legitimate interest (Art. 6(1)(f)) | To improve governance accuracy using anonymized and aggregated data only |
| Legal compliance | Legal obligation (Art. 6(1)(c)) | When required by applicable law (e.g., tax records, regulatory requests) |
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)
- Contacting organizations whose Academy activity suggests the platform could help them (you can object at any time)
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:
| Sub-Processor | Purpose | Data Processed | Location |
|---|---|---|---|
| Google Cloud Platform | Infrastructure hosting, compute, storage, database | All Service data | EU |
| Stripe, Inc. | Payment processing | Billing data, payment details | EU/US (with appropriate safeguards) |
| Twilio SendGrid | Transactional email delivery | Email addresses, email content | EU/US (with appropriate safeguards) |
| Google Analytics 4 | Website analytics | Website visitor data (anonymized IP) | EU settings enabled |
| Google reCAPTCHA Enterprise | Bot protection on forms | IP address, browser characteristics, interaction patterns | EU (via GCP) |
| LinkedIn Ireland UC | LinkedIn Insight Tag — ad campaign attribution on public marketing pages (loaded only with explicit Marketing consent) | IP address, browser characteristics, page URL, LinkedIn member ID where applicable | EU/US (Standard Contractual Clauses; EU-US DPF) |
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 Google Cloud regions within the European Union. 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:
| Data Category | Retention Period | Rationale |
|---|---|---|
| Account Data | Duration of the account + 30 days post-deletion | Service delivery; 30-day grace period for account recovery |
| Agent Action Data | As defined in the Subscription Plan (default: 7 days for Starter, 30 days for Professional, 90 days or as agreed for Enterprise) | Service delivery; customer-configurable |
| Academy data (progress, results, certificates) | Duration of the account; deleted with it | Certificates stay verifiable while the account exists |
| Billing records | 7 years after the transaction | Swedish accounting law (Bokforingslagen) and tax regulations |
| Contract records (the quote, who accepted it — name, title, email, time, IP address and browser — and invoices) | 7 years after the contract ends | Swedish accounting law and evidence of the agreement |
| Usage Data | 26 months | Analytics and service improvement |
| Support correspondence | 3 years after resolution | Quality assurance and dispute resolution |
| Sales follow-up records | While the conversation is active, and at most 24 months after the last contact | Following up on interest in the platform |
| Marketing consent records | Duration of consent + 3 years | Demonstrating lawful consent |
| Security logs | 12 months | Security monitoring and incident investigation |
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