Controller
CipherRun Inc.
Processes data submitted via /app, /api/v1, waitlist forms, and Stripe checkout.
Sub-processors
Stripe · Postmark · Render · Neon · Cloudflare
Full disclosure list and policy links in §4.
Data-subject requests
Response within 30 days; 60 for complex (Art. 12(3) GDPR).

1. What this policy covers

CipherRun is the data controller for personal information submitted through the customer dashboard at /app, the public-facing API at /api/v1, the waitlist and early-access forms on the marketing site, and the Stripe checkout hosted at /pricing. It covers data we collect, why we collect it, who we share it with, how long we keep it, and the rights you have over it.

2. Data we collect

We collect six explicit categories of data:

CategoryWhatWhere it lives
Account Email, Stripe customer ID, API key prefix (cr_ws_…), workspace name, role (admin/editor/viewer), tier assignment customers, workspaces, workspace_users
Billing Card last-4 + brand only (Stripe holds the PAN; CipherRun never sees it), subscription status, current period end, invoice history subscriptions + Stripe dashboard mirror
Workflow runs YAML inputs submitted, step outputs captured during execution (verdict, score, extracted IOCs). Raw credentials stored in integrations.config are encrypted — never written to run logs. workflow_runs, execution_logs
Operational events IP address, user-agent, and referrer of inbound requests; kept for security log retention only, deleted by §5. analytics_events + inferred from outreach_messages / outreach_replies
Email Outbound transactional email (magic-link tokens, early-access nurture, weekly practitioner digest). Inbound replies captured by the Postmark webhook to routes/postmark-webhooks.js are stored in outreach_replies. Postmark (US datacenter) + practitioner_leads, digest_log, outreach_messages, outreach_replies
Support tickets Anything you send to legal@, security@, support@, or privacy@. Includes the message content, metadata (sender, timestamp), and any files you attach. Encrypted archive, 2-year retention (see §5)

3. Why we process it

4. Sub-processors

The following vendors process data on CipherRun's behalf. This is the GDPR sub-processor disclosure required by Art. 28, plus the card-network disclosure required for PCI DSS Level 1 merchants using Stripe.

VendorPurposeRegionCompliance
Stripe Payments Europe Ltd.Card processing, invoice generation, webhook deliveryUS / EUPCI DSS Level 1; DPA on file
Postmark (ActiveCampaign LLC)Transactional email (magic links, nurture, digest)USDPA executed
Render Inc.Application hostingUSDPA executed
Neon (Databricks Inc.)PostgreSQL hostingUSDPA executed
Cloudflare R2File / object storage (used by workflow attachment steps via the Polsia platform proxy)Global edgeDPA executed

We notify subscribers on the email list in §3 at least 30 days before adding a new sub-processor. The list above is the canonical version.

5. Retention windows

Concrete numbers — the schedule governs both production and any backups held longer by the platform.

Data classWindowAfter expiry
Account + billing (customers, subscriptions)Life of account + 7 yearsHard deleted; tax-record copy retained for IRS / HMRC audit
Workflow run logs (workflow_runs, execution_logs)90 days hot, then aggregate-only countersPer-step verdicts and step outputs deleted; counters (run count, score distribution) kept
Auth tokens (auth_tokens)15-minute TTL; consumed on verifyNever persisted after consumption — burned at first use
Magic-link tokensSingle use; expired after 15 minutesBurned and deleted
Workspace invite tokens (workspace_invites)7-day TTLHard deleted; pending roles rolled back
Analytics events (analytics_events)12 months; then aggregatedRaw event payloads deleted; rollup tables kept
Security disclosure inbox2 yearsHard deleted unless part of an active case (then retained to case close)

6. Your rights

Under the GDPR (and mirrored rights under the UK GDPR, CCPA, and similar regimes) you have the right to:

Email privacy@cipherrun.io (or legal@cipherrun.io as fallback). We respond within 30 days, or 60 days for complex requests where Art. 12(3) GDPR allows the extension. Where we cannot fulfill a request, we explain the legal basis.

7. Cookies and analytics

CipherRun uses only localStorage on the customer surface — the cr_onboarding onboarding-checklist state, the cr_theme light/dark mode toggle, and the 30-day JWT session cookie used by middleware/require-auth.js. The Meta Pixel (ID 1735807277592543) runs on marketing surfaces (landing.ejs, pricing.ejs, the waitlist modal at views/partials/waitlist-modal.ejs) and does not load on /app, /login, /admin/*, or any API endpoint. We do not run any third-party retargeting pixels on authenticated product surfaces.

8. International transfers

CipherRun Inc. is headquartered in the United States. For data subjects in the European Economic Area, the United Kingdom, or Switzerland, transfers to the US rely on Standard Contractual Clauses (SCCs) executed with Stripe and Postmark, and on adequacy decisions where available. The current set of executed SCCs is available on request from privacy@cipherrun.io.

9. Security measures

Encryption in transit is enforced end-to-end (TLS 1.2+). Credentials stored in integrations.config (your Jira and ServiceNow tokens) are encrypted at rest. Access control is gated by the admin/editor/viewer RBAC chain in middleware/require-workspace.js. CipherRun is actively working toward a SOC 2 Type II audit; our responsible-disclosure policy at /security is the same commitment we make to auditors. Security disclosures go to security@cipherrun.io per that page; nothing in this privacy policy replaces the disclosure scope and safe-harbor at /security.

10. Children

CipherRun is a business service. It is not intended for children under 16, and we do not knowingly collect personal data from anyone under 16. If we become aware that we have, we will delete the record and notify the guardian that submitted it.

11. Changes to this policy

Material changes get the same notice regime as Terms §11 — at least 14 days of email notice plus a Postmark blast, with an updated effective date at the top of this page. Non-material changes are posted silently.

12. Contact

Our Data Protection Officer is reachable at privacy@cipherrun.io. Postal correspondence: CipherRun Inc., [registered address — will be filled before the SOC 2 Type II audit cycle closes]. You also have the right to lodge a complaint with your local data-protection supervisory authority; nothing in this section limits that right.

Post-termination data handling is governed by the retention windows in §5; account closure itself is described in /legal/terms §7.