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1. Introduction2. Data Controller3. Scope of this policy4. Personal data we collect5. Cookies and tracking6. How we use personal data7. Legal bases for processing8. Data sharing and sub-processors9. International data transfers10. Data retention11. Data security12. Data subject rights13. Complaints14. Automated decision-making15. Changes to this policy16. Contact

Privacy Policy

Last updated: April 28, 2026

1Introduction

This Privacy Policy explains how COVENANCE.AI S.R.L. ("Covenance", "we", "us") collects, uses, and protects personal data when you visit or use the Seer AI website (the "Website") and the Seer AI oversight platform (collectively, "Seer AI" or the "Service").

We are committed to complying with Regulation (EU) 2016/679 (GDPR) and applicable EU data-protection laws.

2Data Controller

COVENANCE.AI S.R.L.

Via di Affogalasino 34, 00148 Rome, Italy

VAT number: IT18129351005

Email: privacy@covenance.ai

Covenance acts as:

  • Data Controller for visitors to the Website, leads, and prospective customers
  • Data Processor when operating the Seer AI platform on behalf of its customers (under a Data Processing Agreement)

3Scope of this policy

This Policy applies to:

  • Visitors of the Seer AI marketing website
  • Users requesting product information, demos, or trials
  • End users of the Seer AI browser extension, network proxy, SDK, or dashboard
  • Customers and authorized employees using the Service
Note: This policy does not apply to third-party AI tools (such as ChatGPT, Claude, Gemini, Copilot) that the Service observes; those tools have their own privacy policies governed by their providers.

4Personal data we collect

4.1 Website usage data

Automatically collected when you visit the Website:

IP address
Device and browser type
Operating system
Pages visited, timestamps, referrer URLs

Purpose: security, basic analytics, website improvement.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR).

4.2 Contact and demo-request data

When you submit a demo request or otherwise contact us, we collect:

Email address
Name (if provided)
Company name (if provided)
Role or title (if provided)
Message content

Purpose: respond to your request, schedule demos, follow up on sales discussions.

Legal basis: pre-contractual measures (Art. 6(1)(b)) or your consent (Art. 6(1)(a)).

4.3 Service telemetry (when Seer AI is deployed in your organization)

When the Seer AI browser extension, network proxy, or SDK is deployed by a customer, the Service may process:

Prompts submitted to AI tools
AI tool outputs reviewed by Seer AI
Risk classifications and policy match results
Audit metadata (timestamps, tool used, workspace, anonymized user identifier)
Important: when Seer AI processes this data on behalf of an organization, Covenance acts strictly as a data processor under the customer's instructions. The customer is the data controller and decides what is logged, retained, and shared. Wherever technically feasible, prompt and output review is performed on-device and is not transmitted to Covenance servers.

Legal basis: contract performance (Art. 6(1)(b)).

Processor obligations: Art. 28 GDPR.

5Cookies and tracking

The Website uses:

  • Strictly necessary cookies (security, session management) that do not require consent
  • Privacy-respecting analytics only where lawful and disclosed in our Cookie Policy

See our Cookie Policy for the full list of cookies used. We do not use advertising or cross-site tracking cookies.

6How we use personal data

We use personal data to:

  • Operate, secure, and improve the Website and the Service
  • Respond to demo requests and other inquiries
  • Provide the Seer AI oversight platform under our customer agreements
  • Generate audit-ready evidence for our customers' compliance programs
  • Meet our own legal and regulatory obligations
We do not sell personal data. We do not use the prompts, outputs, or content reviewed by the Service to train any third-party AI model.

7Legal bases for processing

Depending on the context, processing is based on:

Consent

Art. 6(1)(a)

Contract or pre-contractual measures

Art. 6(1)(b)

Legal obligation

Art. 6(1)(c)

Legitimate interests

Art. 6(1)(f), balanced against your rights

8Data sharing and sub-processors

We may share data with trusted providers acting as processors, including:

  • Cloud hosting and infrastructure providers
  • Email delivery providers (for demo-request notifications)
  • Analytics and monitoring services
  • Security, logging, and incident-response providers

All sub-processors are bound by GDPR-compliant agreements. A current list of sub-processors is available on request to privacy@covenance.ai.

9International data transfers

Where personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards, including:

  • EU Standard Contractual Clauses (SCCs)
  • Adequacy decisions of the European Commission, where applicable
  • Supplementary technical measures (encryption in transit and at rest, access controls)

10Data retention

We retain personal data:

  • Only for as long as necessary for the purposes stated in this policy
  • In accordance with legal, contractual, and regulatory requirements

Customer telemetry processed by the Service is retained according to the customer's contract and configuration, and is deleted or returned upon termination unless retention is legally required.

11Data security

We implement appropriate technical and organizational measures to protect personal data, including:

Access controls and least-privilege principles
Encryption in transit (TLS) and at rest
On-device processing where feasible
Secure cloud infrastructure and segregated environments
Logging, monitoring, and intrusion detection
Confidentiality obligations for personnel and contractors

12Data subject rights

Under GDPR, you have the right to:

Access your personal data
Rectification of inaccurate data
Erasure (“right to be forgotten”)
Restriction of processing
Data portability
Object to processing
Withdraw consent at any time

Requests can be sent to privacy@covenance.ai.

We respond within statutory deadlines.

13Complaints

If you believe your rights have been violated, you may lodge a complaint with the supervisory authority in your EU Member State of residence, work, or alleged infringement.

For Italy, the competent authority is the Garante per la protezione dei dati personali (garanteprivacy.it).

14Automated decision-making

We do not perform automated decision-making producing legal or similarly significant effects on individuals within the meaning of Art. 22 GDPR.

The Seer AI Service classifies prompts and outputs for risk-management purposes. Where a customer chooses to act on such classifications (for example, blocking an action), the customer is responsible for that decision and is required to provide human review where required by law.

15Changes to this policy

We may update this Privacy Policy from time to time. The latest version will always be published on this page with an updated date.

16Contact

For privacy-related questions or requests:

Emailprivacy@covenance.ai
Company

COVENANCE.AI S.R.L.

Via di Affogalasino 34, 00148 Rome, Italy

VAT number: IT18129351005

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