Privacy Policy

1. Who is responsible for your data

Monoceros s. r. o. operates the ModoPersona service and is the controller of account, subscription, website, support, security, and service usage data described in this policy. ModoPersona is the name of the service, not a separate legal entity. The controller's details are:

Contact the privacy team at privacy@modopersona.com.

ModoPersona provides each account holder with a private manager workspace. For direct-report content entered or connected for work, the account holder, their employer, or another applicable customer normally decides the workplace purpose and acts as controller; Monoceros s. r. o. acts as processor/service provider. Creating an account does not create an organization-wide workspace. If information about you is stored by a manager, contact that manager or employer, or contact us and we will help route the request.

2. Data we collect

Account and commercial data

Name, email address, authentication details, locale, account timestamps, trial and subscription status, Paddle customer or subscription identifiers, and support communications. Paddle receives and handles payment-method and transaction details; we do not store complete card details.

Private manager-workspace content

Names, roles, work email addresses, reporting relationships, written and spoken recaps, recordings and transcripts, meeting context, commitments, goals, strengths, preferences, blockers, risks, achievements, evidence, notes, suggested questions, and the history of confirmations and corrections. Content may reveal sensitive information depending on what a user chooses to provide; ModoPersona does not require that information and users should avoid entering it unless lawful and necessary.

Connected-service data

If you connect a service, we receive authorization tokens and selected account, workspace, calendar, attendee, meeting, sales-account, opportunity, project, task, assignee, stage, status, next-step, and due-date information from Google, Microsoft, Jira, Linear, Asana, HubSpot, Pipedrive, or Attio. We limit imports to the features and permissions shown during the account holder's connection.

Technical and usage data

IP address, browser and device information, session and security events, request and error logs, feature interactions, performance information, and cookie preferences. Optional PostHog analytics is collected only after consent. Session replay is limited to public pages, masks form inputs, excludes request bodies and headers, and is disabled throughout employee workspaces. We do not send voice transcripts or employee facts as analytics properties.

AI processing data

Relevant portions of recaps, transcripts, and employee context are sent to the configured AI provider to transcribe audio, extract structured facts, create embeddings, prepare briefings, and answer evidence-based questions. We also record operational data such as the model used, token counts, duration, estimated cost, and success or failure.

3. Why we process data and our legal bases

• Provide the service and perform our contract: create and secure accounts, process recaps, maintain profiles, generate preparation material, synchronize authorized integrations, provide exports, support users, and administer subscriptions.
• Legitimate interests: protect the service, prevent fraud and trial abuse, diagnose errors, measure reliability and cost, improve workflows, and communicate about the service. We balance these interests against the rights of affected people.
• Consent: run optional analytics and, where applicable, process information or recordings that require consent. Consent can be withdrawn at any time without affecting earlier lawful processing.
• Legal obligations: keep required tax and transaction records, respond to lawful requests, and establish, exercise, or defend legal claims.
• Customer instructions: process private manager-workspace content on behalf of the applicable customer/controller under its documented instructions and lawful basis.

4. AI assistance and managerial decisions

ModoPersona organizes evidence and suggests preparation prompts; it does not make employment decisions on behalf of customers. Users must review AI output and its supporting evidence. We do not use solely automated decision-making that produces legal or similarly significant effects about employees or account holders.

The standard service is not intended to make, guide, recommend, or materially influence hiring, promotion, compensation, performance evaluation, discipline, termination, scheduling, or another consequential employment decision.

Records imported from a connected sales CRM or work-item service are business context for a manager's conversation. They may support a neutral question but are never converted into employee facts and never enter sentiment, severity, conversational signals, attention priority, comparison, quota or performance evaluation, or an employment decision.

Manager-authored notes may support tentative conversational context such as a recurring blocker, possible frustration, workload concern, or change in energy or ownership. We link that context to its source and do not treat it as a certain internal, medical, or psychological state. We do not infer emotion from facial expressions, gestures, voice characteristics, biometrics, connected-system activity, or productivity telemetry. We also do not infer health, disability, burnout, personality, aptitude, or protected characteristics.

5. Who receives data

We disclose only the data needed to the following recipients:

• infrastructure, database, storage, hosting, and email providers, including Amazon Web Services and, depending on deployment, Vercel and Neon;
• OpenAI, the configured AI provider;
• Sentry for privacy-limited error monitoring and operational telemetry;
• PostHog for optional product analytics after consent;
• Paddle, which acts as merchant of record and authorized reseller for paid purchases and handles checkout, payment, tax, invoicing, refunds, and subscription administration under its own Privacy Policy;
• Google, Microsoft, Atlassian Jira, Linear, Asana, HubSpot, Pipedrive, or Attio when you choose to connect or disconnect those services;
• professional advisers, auditors, acquirers, and public authorities where reasonably necessary and legally permitted; and
• other recipients when you direct us to disclose data or give consent.

Service providers are required to protect personal data and may process it only for the contracted purpose. Paddle acts as an independent controller for the purchase and payment data it processes as merchant of record under its own privacy notice.

6. International transfers

ModoPersona and its providers may process data outside your country or the European Economic Area. Where required, we use a recognized transfer mechanism such as an adequacy decision, the European Commission's Standard Contractual Clauses, and supplementary safeguards. You may contact us for information about the safeguard relevant to your data.

7. Retention

• Account and confirmed manager-workspace content is kept while the account is active and removed from active systems after account deletion, unless limited retention is legally required.
• Raw recordings, transcripts, and pending AI extractions follow the user's selected retention period: 30 days, 90 days, one year, or until account deletion.
• Connected-service credentials are kept until the connection is revoked, expires, or the account is deleted. Cached integration content may remain until account deletion or an applicable retention process removes it.
• The cookie preference lasts one year. Optional analytics follows the configured PostHog project retention settings.
• Security, support, billing, tax, and legal records are kept only as long as necessary for their purpose and applicable law. Encrypted backups expire on a limited operational cycle.

Users can manage raw voice retention, export data, and delete an account from the authenticated privacy controls.

8. Security

We use technical and organizational measures designed to protect data, including access controls, tenant isolation, encryption in transit, restricted credentials, retention controls, and operational monitoring. No online service can guarantee absolute security. Contact us promptly if you believe an account or data may have been compromised.

9. Your choices and rights

Depending on where you live and our role, you may have rights to access, correct, delete, restrict, object to processing, or receive a portable copy of personal data; withdraw consent; and complain to a data protection authority. Legitimate-interest processing can be challenged based on your circumstances. These rights may have lawful exceptions.

Account holders can use the privacy controls in the service or email privacy@modopersona.com. We may need to verify your identity. If a customer controls the requested workplace data, we may refer the request to that customer. EEA residents may complain to the authority where they live, work, or where an alleged infringement occurred; the European Data Protection Board lists national authorities.

California and other US state rights

Where an applicable US state privacy law applies, you may also have rights to know the categories, sources, purposes, and recipients of personal information; access, correct, delete, or obtain a portable copy; opt out of sale, sharing, targeted advertising, or qualifying profiling; limit qualifying sensitive-personal-information use; appeal a denial; and exercise rights without unlawful discrimination.

ModoPersona does not sell workspace personal information, share it for cross-context behavioural advertising, or use it for targeted advertising. Email privacy@modopersona.com to exercise a right or use an authorized agent. We will verify the request proportionately. When an employer or other customer controls direct-report data, we route the request to that controller and assist its response.

10. Cookies

We use essential cookies for authentication, security, and remembering privacy choices. Optional analytics stays off until accepted. See the Cookie Policy and use Cookie settings to change your choice at any time.

11. Children

ModoPersona is a workplace service for adults and is not directed to children. You must be at least 18 to hold an account. Do not submit children's personal data unless it is lawful, necessary for an authorized workplace purpose, and subject to appropriate safeguards.

12. Changes to this policy

We may update this policy as the service, providers, or law changes. We will post the new version here and update the date above. We will provide additional notice through the service or by email when a change materially affects how we use personal data.

13. Contact

Send privacy questions or rights requests to privacy@modopersona.com. Send suspected security issues to security@modopersona.com and product or account questions to support@modopersona.com.