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Privacy Policy

Engram Memory LLC — Last Updated: March 29, 2026

1. Overview

This Privacy Policy (“Policy”) describes how Engram Memory LLC (“Company,” “we,” “us,” or “our”) collects, uses, processes, stores, and discloses information in connection with our cloud-based services (the “Services”).

This Policy applies to all users, customers, and authorized personnel (“Users,” “you,” or “your”) who access or use the Services.

To the extent we process personal data on behalf of a customer acting as a controller, we act as a data processor. In all other cases, we act as a data controller.

2. Definitions

  • “Personal Data” means any information relating to an identified or identifiable natural person.
  • “Customer Data” means any data submitted to the Services by or on behalf of a customer.
  • “Processing” means any operation performed on data (e.g., collection, storage, use, disclosure).
  • “Subprocessor” means any third party engaged to process data on behalf of the Company.

3. Categories of Data Collected

3.1 Account Data

  • Name
  • Email address
  • Organization name

3.2 Customer Data

We process Customer Data solely on behalf of our customers and in accordance with their instructions. This may include documents, files, structured/unstructured content, knowledge bases, embeddings, and metadata.

3.3 Technical and Log Data

  • IP address and device identifiers
  • Authentication events
  • API usage logs
  • Error and performance data

4. Legal Bases for Processing

Where applicable under law, we rely on:

  • Contractual necessity (to provide Services)
  • Legitimate interests (security, analytics, improvement)
  • Legal obligations
  • Consent (for optional features and integrations)

5. Data Processing and Instructions

5.1 Role of the Parties

Customer = Data Controller. Engram Memory LLC = Data Processor. We process Personal Data only in accordance with customer instructions, as necessary to provide the Services, and as required by applicable law.

5.2 Customer Responsibilities

You represent and warrant that you have all necessary rights to provide Customer Data, your use of the Services complies with applicable laws, and you have provided required notices and obtained necessary consents.

6. Subprocessors

We may engage Subprocessors to support delivery of the Services, including infrastructure providers, security and CDN providers, and AI model providers (when enabled). All Subprocessors are bound by written agreements with data protection obligations no less protective than this Policy. A current list of Subprocessors will be made available upon request.

7. AI and Automated Processing

If you enable AI features, data may be processed by third-party AI providers. Processing occurs strictly at your direction. We do not use Customer Data to train models unless explicitly stated. You acknowledge that AI outputs may be inaccurate or incomplete and you are responsible for reviewing outputs before reliance.

8. Security Measures

We implement industry-standard security controls, including:

  • Encryption in transit (TLS 1.2+)
  • Access controls and authentication safeguards
  • Logical separation of customer environments where applicable
  • Continuous monitoring and logging

Despite these measures, no system is completely secure. Use of the Services is at your own risk.

9. Data Breach Notification

In the event of a confirmed data breach affecting Personal Data, we will notify affected customers without undue delay, provide relevant details reasonably necessary for compliance, and take commercially reasonable steps to mitigate impact.

10. Data Retention and Deletion

We retain data only as long as necessary to provide the Services, comply with legal obligations, and resolve disputes. Upon termination, Customer Data will be deleted within a commercially reasonable timeframe. Backup copies may persist temporarily per standard retention cycles.

11. International Data Transfers

Data may be processed in the United States and other jurisdictions. Where required, we implement safeguards such as Standard Contractual Clauses (SCCs) or equivalent lawful transfer mechanisms.

12. Confidentiality

We treat Customer Data as confidential and will not access it except as necessary to provide Services or disclose it except as permitted under this Policy. Personnel are bound by confidentiality obligations.

13. User Rights

Subject to applicable law, data subjects may access, correct, or delete Personal Data, restrict or object to processing, and request portability. Where we act as a processor, requests should be directed to the customer (controller).

14. Indemnification

You agree to indemnify and hold harmless Engram Memory LLC from any claims arising out of your violation of applicable laws, your misuse of the Services, or your failure to obtain required consents.

15. Limitation of Liability

To the maximum extent permitted by law, the Services are provided “as is” and “as available.” We disclaim all implied warranties, including merchantability and fitness for a particular purpose. In no event shall Engram Memory LLC be liable for indirect, incidental, consequential, or punitive damages. Our total aggregate liability shall not exceed the amounts paid by the customer in the 12 months preceding the claim.

16. Compliance Framework Alignment

We design our practices to align with GDPR, CCPA/CPRA, and SOC 2 principles (security, availability, confidentiality). Formal certifications may be pursued separately.

17. Audit Rights (Enterprise Provision)

For enterprise customers, we may provide reasonable documentation demonstrating compliance. Audits may be permitted under mutually agreed terms. Customers must avoid disruption to operations and protect confidentiality.

18. Policy Updates

We may update this Policy from time to time. Material changes will be communicated via email or in-product notice. Continued use constitutes acceptance.

19. Contact Information

For all privacy, legal, or data protection inquiries:

Engram Memory LLC
Email: [email protected]