Effective: 2026-10-12, as published at https://ergoda.com/privacy/
Version: 1
Every version: ergoda.com/legal/#versions, each at its own URL.
This policy covers personal data we process as a controller: data from the website, and the account and billing data of the people who use our service. Personal data in what your deployment sends us (derived metrics, and any tool catalogue you submit) is processed by us as a processor under the Data Processing Agreement, not under this policy.
1. Who is responsible
Maffen Oy, business ID 3633966-3, Kahlojantie 18a, 21420 Lieto, Finland.
Contact for anything in this policy: legal@ergoda.com.
We have not appointed a Data Protection Officer, as we are not required to.
2. What we collect, why, and on what legal basis
| Data | Why | Legal basis | Kept for |
|---|---|---|---|
| Email address you sign up with | To create the account, issue the API key, and reach you about the service | Contract (Art. 6(1)(b)) | Life of the account + 12 months |
| Name and verified email address from dashboard sign-in, the sites you may open and your role on each | To sign you in, decide what you may open and change, and record who made each decision: an approval, a key, a membership change is stored under the name and address that signed in | Contract (Art. 6(1)(b)); legitimate interest (Art. 6(1)(f)) in an auditable record of who approved a route | Life of the account + 12 months; a signed-in session ends after at most 8 hours |
| Your organization's name, and your answers to the optional questions when you open it: how you heard of Ergoda, what your agent does, what you want from Ergoda, and your monthly model spend as a range. Each answer is one choice from a fixed list | To show the name to your team, and to learn who uses the service and what to build next | Contract (Art. 6(1)(b)) for the name; legitimate interest (Art. 6(1)(f)) in understanding our users for the answers, which you may skip | Life of the account + 12 months |
| Company name, VAT number, billing address | To invoice you and account for VAT | Contract; legal obligation (Art. 6(1)(b), (c)) | 6 years from the end of the accounting period, as Finnish bookkeeping law requires |
| Payment records — amount, date, last four digits, processor reference | To take payment and reconcile it | Contract; legal obligation | 6 years, as above |
| Usage counts — governed requests, timestamps, site identifier | To meter and bill you, and to operate the service | Contract | Life of the account + 12 months |
| Support email you send us | To answer you | Contract; legitimate interest (Art. 6(1)(f)) in running support | 24 months |
| Server logs — IP address, request path, timestamp, user agent | Security, abuse prevention, debugging | Legitimate interest (Art. 6(1)(f)) in keeping the service up and secure | 30 days |
| Emails you consent to receive about launches and findings | To send them | Consent (Art. 6(1)(a)) | Until you unsubscribe |
We collect no other personal data. We do not use personal data for profiling or advertising, we make no automated decisions with legal or similarly significant effects, and we do not sell personal data.
3. Website and cookies
The public website consists of static files. It uses no analytics, cookies, third-party assets, trackers or fingerprinting. Where we measure site usage, we do so server-side, in aggregate and without identifiers.
The dashboard sets only strictly necessary cookies: one that keeps you signed
in; one that lasts for the ten minutes a sign-in takes and is cleared when it
completes; and one on ergoda.com that records only that someone is signed in,
so the website's menu can offer the dashboard instead of signup. None of them
identifies you to anyone but us, and none is used for any other purpose.
4. No model training
We do not use your data, including account data, usage data and anything your deployment sends us, to train or fine-tune any model. We do not sell it, and we do not share it for anyone else's marketing.
Cross-customer statistics ("priors") are derived from derived metrics only: counts, rates, hashes and scores. They contain no prompt or response content and no per-customer identifier, they are aggregated over a published minimum number of contributing customers, and you can opt out of them at no price penalty. The policy is set out in the Terms §11 and the DPA §11.
5. Recipients and service providers
We disclose personal data to service providers that help us run the service and our business. They process the data for the purposes described here, under our instructions where they act as our processors. The categories below describe who receives data and why; we do not maintain a provider-by-provider list in this policy.
| Category | For | Where |
|---|---|---|
| Payment, invoicing and tax-service providers | Card payments, invoices, tax calculations, payment records and invoice or receipt emails | EEA and United States |
| Cloud hosting, application and database providers | Running the API, dashboard and website, and storing account, usage and billing data | United States (US East) |
| Account-email delivery providers | Sending welcome, key recovery, billing and service notices | United States |
| Identity and sign-in providers | Dashboard sign-in using your name and verified email address | United States |
| Error-monitoring providers | Error reports from our code, without request contents | United States |
| DNS and email-routing providers | DNS for ergoda.com; receiving messages sent to support@ergoda.com and legal@ergoda.com and forwarding them to our inbox | United States |
| Business email, file-hosting and bookkeeping providers | Our business inbox and files, including forwarded support and legal messages, and our bookkeeping records | EEA and United States |
We send account email (welcome, key recovery, card and hold notices, and service notices) through Resend. Invoices and receipts are sent by Stripe. Alerts about your routes go to a webhook you configure.
Model providers are not our processors: we send them neither your account data nor your traffic. Comparison calls made by the Software run in your own infrastructure with your keys, as described in DPA §6.
The sub-processors for data we process on a customer's behalf are listed in
Annex III of the DPA, and at
https://ergoda.com/legal/subprocessors.
6. International transfers
Our infrastructure is in the United States: the database is in US East, and the application and the database's point-in-time history are in the United States. Personal data we process is therefore transferred outside the EEA.
For these transfers we rely on the EU Standard Contractual Clauses and, where
applicable, the recipient's certification under the EU–US Data Privacy
Framework. Copies of the clauses are available on request at
legal@ergoda.com.
7. Your rights
Under the GDPR you have the right to access, rectify and erase your personal data, to restrict or object to our processing of it, and to data portability. Where we rely on consent, you may withdraw it at any time; withdrawal does not affect processing carried out before it.
To exercise these rights, email legal@ergoda.com. We respond within 30 days,
free of charge. We will ask you to confirm that you control the account email
address.
You may also lodge a complaint with the Finnish Data Protection Ombudsman (Tietosuojavaltuutetun toimisto, PO Box 800, FI-00531 Helsinki, tietosuoja.fi) or with the supervisory authority where you live or work.
8. Security
Your software authenticates with an API key, which we store only as a hash. People sign in to the dashboard through WorkOS with a verified email address; we never see or store a password. Data is encrypted in transit and at rest. Access is limited to personnel who need it. Billing and metering records are append-only, so charges can be reconstructed independently of our payment processor's records.
In the event of a personal data breach, we notify the supervisory authority within 72 hours where required, and notify affected customers without undue delay.
9. Children
The service is sold to organisations. It is not directed at children and we do not knowingly collect their data.
10. Changes
We publish any change here with a new effective date and email account holders about material changes at least 30 days before they take effect. Every version remains available at its own URL, listed at ergoda.com/legal/#versions.