Privacy Policy

We execute a written Art. 28 GDPR processing agreement with every processor before processing begins. Your own DPA with us is available in your account under Settings → Data protection & processing agreement. The list of sub-processors is kept current in this Privacy Policy and updated when any change occurs.

5a. Data flow for BYO-AI features

For transparency, here's exactly what reaches an AI provider when:

• Executive summary for IT Assessments: findings list (description + priority + effort) + customer industry / size (when set). No customer address, no contact data, no logos.
• Quote drafter from IT Assessment: findings list + service catalog of the workspace. No customer personal data, no price overrides.
• Lead outreach drafter: lead email + the three weakest IT Assessment categories. No full answer list, no score, no IP.
• Quote reply drafter: last ~10 messages in the quote thread.
• Service-report drafter / status structurer / milestone generator: only the fields visible in the editor at submission time.

For cloud providers like Anthropic or OpenAI their DPA terms apply. For self-hosted endpoints (Ollama on your own server), nothing leaves your network. You can disable AI features any time by setting the provider to "—" in Settings → AI.

5b. AI Assistant (Bob)

Workspace data may be sent to Anthropic's API when you use the in-product AI Assistant ("Bob"). See § 5 of the Terms and the DPA for details on what's transmitted, retention, and your rights. You can disable Bob in Settings → AI Assistant.

6. Third-country transfers

Where data is transferred to the USA or another third country (Stripe support, Apple App Store), the transfer is based on:

• the European Commission's adequacy decision for the EU-US Data Privacy Framework (Art. 45 GDPR), if the recipient is certified under DPF, or
• the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR), supplemented by risk-mitigating measures (encryption, pseudonymisation).

Copies of the relevant agreements are available on request.

7. Storage periods

• Account data: for the duration of the contract. 30 days after termination / account closure for dispute resolution, then irreversible deletion.
• Invoicing data: 10 years (§§ 147 AO, 257 HGB). Longer only if required by specific law.
• Server logs: rotated after 14 days.
• IT Assessment / project content: until you delete it or close the account (see above). Finalised IT Assessments remain as an immutable record in your account until the tenant itself is removed.
• Support emails: case closure plus six months.

8. Your rights as a data subject

The GDPR grants you the following rights:

• Right of access to data held about you (Article 15)
• Right to rectification of inaccurate or incomplete data (Article 16)
• Right to erasure (“right to be forgotten”, Article 17)
• Right to restriction of processing (Article 18)
• Right to data portability in a structured, machine-readable format (Article 20) — exposed via Settings → Data export (ZIP of JSON + CSV)
• Right to object to processing based on legitimate interest (Article 21)
• Right to withdraw consent for the future (Article 7(3))

To exercise these rights, contact privacy@mspercury.com. If your identity is in doubt we may request additional evidence.

Right to lodge a complaint with the supervisory authority (Article 77 GDPR):

9. Cookies & tracking

By default we only set strictly necessary cookies whose use does not require consent under § 25 (2) (2) TDDDG:

• mspercury_session — authentication (HttpOnly, Secure, SameSite=Lax; 30-day expiry)
• mspercury_locale — UI language preference (1 year)
• mspercury_consent — your cookie-banner decision, granted/denied (1 year)
• mspercury_flash — short-lived action confirmation (30 seconds)

Optional: Google Analytics 4 — landing page only, opt-in

On our public landing page ("/") only, we additionally load Google Analytics 4 after your explicit opt-in via the cookie banner (provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; measurement ID G-XH207QDBRV). It tells us which content earns its place. The authenticated app (dashboard, IT Assessments, quotes) does not load gtag.js — there is no tracking inside the app.

We use Google Consent Mode v2 with ad_storage=denied, ad_user_data=denied, ad_personalization=denied — no data is sent to Google for advertising or personalization purposes. IP anonymization is on. A transfer to the United States cannot be ruled out, but is covered by Standard Contractual Clauses and the EU–US Data Privacy Framework (adequacy decision of 10 July 2023). Legal basis: Art. 6 (1) (a) GDPR and TDDDG § 25 (1).

You can withdraw your consent any time on /legal/cookies with a single click. Fonts (Geist) remain self-hosted; there is no request to Google Fonts or any other CDN. Apart from Google Analytics we do not use any other tracker (no Meta Pixel, no Plausible, no Matomo).

10. PWA & iOS app

MSPercury is installable as a Progressive Web App (PWA). Installing to the home screen registers a service worker that caches static resources (HTML, CSS, JS, images) locally so the app can still launch when offline. Form data and IT Assessment content are not cached offline — all edits require an active connection to our servers.

The iOS app is a Capacitor wrapper around the same web application and transmits no data to Apple, third parties, or the operating system beyond what a plain web app would. Downloads from the App Store are subject to Apple's own privacy terms.

11. Version of this policy

Effective: May 20, 2026. We may update this policy as processing changes or law / case law requires. The current version is always at mspercury.com/legal/privacy.