Privacy Policy

This Privacy Policy explains how Nimavera Inc. (in formation) ("Trusvo", "we", "us") handles personal data in connection with the Trusvo service. It should be read with our Terms of Service, Subprocessors list, and — for personal data we process on your behalf — our Data Processing Addendum.

1. Our two roles: controller and processor

Trusvo plays two distinct data-protection roles, and the difference determines your rights and our obligations:

• Controller. For your account, billing, security, and product-usage data, we decide the purposes and means, so we act as a controller.
• Processor. For the Customer Content you upload so the Service can build your Evidence Graph and draft answers, we act as a processor on your behalf — you are the controller of any personal data inside that content, and we process it only on your instructions. Those processing terms live in the DPA.

This policy focuses on the personal data for which we are the controller; the DPA governs the rest.

2. Information we collect

Account information

Name, work email, company name, password (stored only as a salted hash, never in plaintext), two-factor-authentication settings and recovery codes (stored hashed/encrypted), and any profile or company image you add.

Customer Content you upload

Repository files, configuration, infrastructure manifests, policies, architecture docs, and questionnaires you provide or connect. Values that look like secrets — API keys, credentials, tokens, private keys — are detected and redacted before storage and before any content is sent to a model. In config-only mode, application source code is excluded from ingestion entirely. Customer Content is processed under the DPA, not this policy.

Usage, technical, and audit data

Access timestamps, IP address, request metadata, and audit-log entries for privileged and security-relevant actions, used to operate, secure, rate-limit, and support the Service. Trust Room analytics use a day-rotating visitor hash and store no raw IP or user-agent for that purpose.

Buyer / visitor data

When a buyer interacts with a Trust Room you publish (name, work email, questions asked, NDA acceptance, access grants), that data is Customer Content you control; we process it on your behalf so the Trust Room and buyer flow work.

Payment data

Handled by Stripe. We store a customer identifier and subscription status — never your full card number.

Communications

Emails and support correspondence you send us.

3. How and why we use data, and our legal bases

Where you are in the EEA or UK, the GDPR/UK GDPR legal basis is shown in parentheses:

• Provide the Service — authenticate you, parse uploads, build the Evidence Graph, draft answers, run buyer and agent flows, publish Trust Rooms (performance of a contract).
• Secure the Service — authentication, two-factor, rate-limiting, abuse prevention, SSRF and injection defenses, audit logging (legitimate interests in keeping a security product secure).
• Billing and fraud prevention — process subscriptions and prevent payment fraud (contract / legal obligation).
• Support and service communications — respond to you and send security and service notices (contract / legitimate interests).
• Product updates and, where relevant, marketing — only with your consent where consent is required, and always with an opt-out.
• Comply with law — respond to lawful requests and keep required records (legal obligation).

4. How we share data

We share personal data only with the subprocessors that help us run the Service (see Subprocessors), when required by law or valid legal process, or in connection with a merger, acquisition, or asset sale (with notice, and the successor bound by this policy). We do not sell personal data, and we do not use it for third-party advertising. Uploaded source files are never publicly accessible; a Trust Room exposes only what you explicitly publish.

5. International transfers

We and our subprocessors may process data in the United States and other countries. Where personal data is transferred out of the EEA or UK, the transfer relies on an appropriate safeguard — typically the EU Standard Contractual Clauses (and the UK Addendum) or an adequacy decision — a copy of which is available on request.

6. Data retention

We keep controller data for as long as your account is active. When you delete your account, we delete your Customer Content and account data within 30 days, except where a longer period is required by law or for legitimate records such as invoices and fraud-prevention logs. Backups are purged on a rolling schedule. Trust Room visitor records are retained under your control until you delete them or your account.

7. Security

We use TLS in transit and encryption at rest; hashed credentials; secret redaction before storage and before any model call; strict tenant isolation; least-privilege access; SSRF guards on outbound fetches; and audit logging. Our Security overview describes these in more detail. No system is perfectly secure, but security is the problem we exist to help with, and we hold our own practices to the standard we help you prove.

8. Your rights

Depending on where you live, you may have rights to access, correct, delete, port, or restrict processing of your personal data, and to object to processing or withdraw consent. EEA/UK residents may lodge a complaint with a supervisory authority; California residents have rights under the CCPA/CPRA, including to know, delete, correct, and opt out of "sales" or "sharing" (we do not sell or share personal data for cross-context advertising). For personal data we process as a processor on your behalf, we will refer a data-subject request to you, the controller, and assist you in responding. To exercise a right, contact privacy@trusvo.com; we will respond within the time the law requires and will not discriminate against you for exercising a right.

9. Breach notification

If we become aware of a personal-data breach affecting your data, we will notify you without undue delay and, where we act as processor, in line with the timelines in the DPA, with the information you need to meet your own notification obligations. We will describe what happened, the likely impact, and the steps taken.

10. Self-hosted deployments

If you run Trusvo in your own infrastructure, your Customer Content stays in your environment and no Trusvo-operated subprocessor hosts it; you become the controller and processor for that deployment, and Sections 2–7 above apply only to any account or telemetry data you choose to send us.

11. Children

The Service is for organizations and is not directed to children under 16. We do not knowingly collect their personal data.

12. Changes

We will post updates here and, for material changes, notify you in-app or by email. The version and effective date are shown at the top.

13. Contact

Privacy questions or requests: privacy@trusvo.com. Nimavera Inc. (in formation), United States. If we appoint a data protection officer or an EEA/UK representative, their contact details will be published here.

Pre-launch template texts describing how Trusvo actually works. Not legal advice — have counsel review before relying on them.