Privacy Policy
Agent Ledger ("we", "us", or "our") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share information when you use our website and API (collectively, the "Service").
This policy is written in accordance with the General Data Protection Regulation (GDPR) and other applicable European data protection law.
1. Who we are (controller)
Agent Ledger is the data controller for personal data processed through the Service.
📧 Contact: hello@agentledgerhq.com
2. What data we collect and why
| Category | Data collected | Purpose | Legal basis |
|---|---|---|---|
| Account data | Name, email address | Account creation, authentication, support | Contract (Art. 6(1)(b) GDPR) |
| API usage data | API key usage timestamps, endpoint calls, rate limit consumption | Service delivery, billing, security | Contract (Art. 6(1)(b) GDPR) |
| Customer data | Agent descriptions, decision summaries, scan answers you submit via API | Delivering the compliance service | Contract (Art. 6(1)(b) GDPR) |
| Billing data | Name, email, billing country (handled by Lemon Squeezy) | Payment processing | Contract (Art. 6(1)(b) GDPR) |
| Technical data | IP addresses, browser/client info (request logs, max 30 days) | Security, abuse prevention | Legitimate interests (Art. 6(1)(f) GDPR) |
| Communication | Email content when you contact support | Customer support | Contract / legitimate interests |
3. Data we do NOT collect
- We do not collect sensitive personal data (health, biometric, political, religious data) from your end users
- We do not use cookies for tracking or advertising
- We do not sell your data to third parties
- We do not use your Customer Data to train AI models
4. How we store your data
Your data is stored in Cloudflare D1 (SQLite-based database distributed on Cloudflare's global edge network, with primary storage in the EU). API keys are stored as SHA-256 hashes only — we cannot recover your raw key after generation.
Decision audit logs use tamper-evident hashing (SHA-256 audit hash per entry) to ensure integrity for compliance purposes.
5. Data retention
- Account data: retained for the duration of your account + 90 days after closure
- Decision logs and agent data: retained for the duration of your account; you can delete them at any time via the API
- Request logs: maximum 30 days
- Billing records: 7 years (legal obligation under EU accounting law)
6. Third parties
We share data with the following processors:
- Cloudflare, Inc. — infrastructure and edge network (EU data centre used). Privacy: cloudflare.com/privacypolicy
- Paddle — payment processing. Privacy: paddle.com/legal/privacy
- Resend, Inc. — transactional email (welcome emails and system notifications). Privacy: resend.com/privacy
We do not share your data with any other third parties unless required by law.
7. International transfers
Cloudflare operates globally but we configure storage in EU regions. Resend and Lemon Squeezy are US-based companies. Where personal data is transferred outside the EEA, we rely on Standard Contractual Clauses (SCCs) as the transfer mechanism.
8. Your rights (GDPR)
As a data subject under the GDPR, you have the following rights:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate personal data
- Erasure ("right to be forgotten"): Request deletion of your personal data
- Restriction: Request we restrict processing of your data
- Portability: Receive your data in a structured, machine-readable format
- Objection: Object to processing based on legitimate interests
- Withdraw consent: Where processing is based on consent, withdraw it at any time
To exercise any of these rights, email us at hello@agentledgerhq.com. We will respond within 30 days.
You also have the right to lodge a complaint with your national data protection authority. In the Netherlands: Autoriteit Persoonsgegevens.
9. Security
We take appropriate technical and organisational measures to protect your data, including:
- All data in transit encrypted with TLS 1.3
- API keys stored as SHA-256 hashes only
- Audit logs protected with cryptographic hashes
- Access to production systems limited to authorised personnel
10. Cookies
Our website does not use tracking cookies or advertising cookies. We may use a session cookie for login state only, which is strictly necessary and does not require consent under the ePrivacy Directive.
11. Changes to this policy
We may update this Privacy Policy from time to time. We will notify registered users by email at least 14 days before material changes take effect. The current version is always available at agentledgerhq.com/privacy.html.
12. Contact
For privacy questions or data subject requests:
📧 hello@agentledgerhq.com