Privacy Policy

1. Data Controller

Cornilius Inc. is the data controller (or business, under US state privacy laws) for personal data processed through this service. Cornilius Inc. is a Delaware C-Corporation, United States. The registered office is stated in the Terms of Service.

2. What Data We Collect

• Account data: email address, company name, billing contact
• Usage data: MCP call logs, playbook execution records
• Memory data: analytical summaries and definitions stored at tenant request
• Technical data: IP address, user agent (for security)
• Setup data: project names, stack metadata, and configuration notes when you purchase Paid Setup

3. US privacy laws — service provider role

For US customers, we process personal information as a service provider / data processor on your behalf where applicable under US state privacy laws, including the Delaware Personal Data Privacy Act and similar state statutes. We process business contact details, account identifiers, and query/metadata logs strictly to provide the Service — not to sell personal information or use it for unrelated advertising. You instruct us on what to store in Cornilius; you remain responsible for lawful collection of data you send through your agent.

4. Legal basis (GDPR Article 6)

Where GDPR applies, we process personal data on these bases: (a) performance of contract — to deliver the Service and Paid Setup; (b) legitimate interests — security monitoring, abuse prevention, and service improvement that does not override your rights; (c) consent — where explicitly obtained (for example optional analytics cookies); (d) legal obligation — where required to comply with law.

5. Retention

Account and billing data is retained for the duration of the contract plus 90 days, unless a longer period is required by law. Memory, playbook, and tenant configuration data is deleted on account termination or earlier on verified request, subject to backup rotation (up to 35 days — 7-day continuous-backup point-in-time restore plus nightly immutable snapshots kept roughly 30 days before deletion). Security and audit logs may be kept longer where necessary for fraud prevention and legal compliance.

6. International transfers

Primary infrastructure is hosted in Azure West Europe (Netherlands). For EEA/UK customers, transfers outside the EEA use appropriate safeguards (for example Standard Contractual Clauses) where required. MCP calls to your coding agent may route data to model providers (for example Anthropic or OpenAI) under their terms and locations — you choose and control those connections.

7. Your rights (GDPR and US state laws)

• Right of access
• Right to rectification / correction
• Right to erasure / deletion
• Right to restriction of processing
• Right to data portability (where applicable)
• Right to object to certain processing
• Right to opt out of sale or sharing (we do not sell personal information)

To exercise any right, contact legal@cornilius.ai. We will respond within 30 days (or as required by applicable law). You may lodge a complaint with your local data protection authority. Postal legal notices: see the Terms of Service.

8. Cookies

We use strictly necessary cookies for session management and authentication. Optional analytics cookies are set only with your consent via the cookie banner. You can withdraw consent at any time through banner settings or browser controls.

9. Contact

For privacy inquiries or to exercise your rights, contact legal@cornilius.ai. For postal legal notices, see the Terms of Service.

10. Paid Setup Service and customer systems

If you purchase our Paid Tailored Setup Service, we may process limited personal and business data you provide for discovery and configuration — including account identifiers, project names, and metadata about your analytics stack. Where you grant us access to third-party tools (for example Mixpanel, Google Analytics, or a data warehouse), we use that access only to perform the agreed setup scope and only for the duration of the engagement unless you agree otherwise in writing.

We do not copy your raw event-level production data into Cornilius unless you explicitly ask us to store summaries or definitions as part of onboarding. Credentials you share for setup should be scoped, revocable, and removed when setup completes.

Residual risk: connecting your agent to Cornilius and to third-party AI providers means some information may leave your environment. We use commercially reasonable safeguards; we cannot eliminate all risk of unauthorized access, misconfiguration, or disclosure by a model provider. See Terms Section 6.

We do not use your Customer Data to train foundation AI models. See Terms Section 5(d).

A list of subprocessors is available on request.

Connecting your agent also sends data you choose to that agent's model provider (for example Anthropic, OpenAI) under their privacy terms — those providers are yours, not Cornilius subprocessors, unless we call them ourselves.