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itogai·Legal·Privacy Policy

Data and privacy

Privacy Policy

Effective October 15, 2026Last modified October 15, 2026Version PP-2026-10-15 v5.1

Effective Date: October 15, 2026 for any Account created on or after that date. For an Account existing on that date, this version takes effect thirty (30) days after itogai gives notice under the Customer Terms of Service, and the version in effect before this one governs until then. Last Modified: October 15, 2026 Document Version: PP-2026-10-15 v5.1

This Privacy Policy describes how Itogai LLC, a Florida limited liability company with its principal office in Lake Worth, Florida, United States of America (“itogai,” “we,” “us,” or “our”), collects, uses, shares, retains and protects Personal Data, and sets out the rights of the individuals whose Personal Data we process.

What this Policy covers

This Policy applies to the itogai relationship intelligence platform (the “Subscription Service”) wherever and however it is accessed, including through any itogai website, application, client, extension or interface, present or future. It also applies to the itogai marketing website, to the Trustbound™ Revenue Program and other Professional Services, and to our relationships with prospective customers, partners, podcast guests, event attendees and the public.

This Policy defines its scope by what itogai does, never by where itogai does it. A new itogai surface is covered by this Policy from the day it exists, without an amendment. What each surface runs on, and what device capabilities it may request, is recorded in the Product Surface Register, which is published, versioned and incorporated into this Policy by reference.

This Policy describes every capability of the Subscription Service as designed, whether or not a particular capability is enabled for a particular account at a particular time. Whether a capability is available to an account is shown in the Subscription Service and is not restated here.

Questions: privacy@itogai.com.

Table of Contents

  1. Who we are and the roles we hold
  2. The Personal Data we collect
  3. Where data comes from
  4. How content is handled: the three levels
  5. Why we use Personal Data
  6. Akai and automated processing
  7. Google API Limited Use disclosure
  8. How we share Personal Data
  9. Sub-processors and the registers
  10. International transfers
  11. Retention and deletion
  12. Security
  13. Your privacy rights
  14. Cookies and similar technologies
  15. Children’s privacy
  16. Region-specific disclosures
  17. How this Policy changes
  18. How to contact us

1. Who we are and the roles we hold

1.1 What itogai does. itogai is a relationship intelligence platform. It helps the people who use it understand and take care of their professional relationships, through the TrustGraph™ scoring algorithm, TrustRings™ network organization, the TrustReach™ action layer, and Akai, itogai’s relationship intelligence co-pilot.

1.2 The roles we hold.

  • For information about our customers, our website visitors, our event attendees, our podcast audience and other prospective customers, itogai acts as a controller under the GDPR, UK GDPR, Swiss FADP and LGPD, and as a business under the CCPA where the CCPA applies to it.
  • For Customer Data that a customer imports, or that we receive from a Data Source the customer has authorized, itogai generally acts as a processor, as an operador under the LGPD and, for Personal Information subject to the CCPA, as a service provider under it. That processing is governed by the Customer Terms of Service and the Data Processing Agreement that forms part of them.
  • Where a customer uses a Group to collaborate with colleagues, the organization that holds the Group is the controller of the Group record. Section 8.4 sets out what a Group does and does not make visible.

2. The Personal Data we collect

2.1 Account Data. Name, email address, employer, role, time zone, language preference, and the authentication tokens issued when you sign in or connect a Data Source. itogai never sees, stores or asks for the password of an account you connect.

2.2 Billing Data. Billing entity name, billing contact, billing address, the country in which the customer’s legal entity is registered where that is relevant to pricing eligibility, and tax identifiers. Payment instrument details are collected directly by our payment processor and are never transmitted through or stored by itogai.

2.3 Usage Data. How the Subscription Service is used: screens viewed, features used, Spark consumption, timing of activity, referring pages and comparable telemetry.

2.4 Device and Log Data. IP address, browser or client type and version, operating system, language, and access logs. Where you enable notifications on a surface that offers them, this also includes a push subscription identifier issued by the notification provider. The Product Surface Register records which surfaces offer notifications.

2.5 Communications. The content of messages you send us, survey responses and in-product feedback.

2.6 Customer Data, meaning data you connect, upload, import or read on screen. What a customer brings into an account through one of the five ways in Section 3.1, and what itogai derives from it:

  • contact records: name, email address, phone number, professional information (such as title, employer, work history and education), a professional web address, and a birthday where the customer records one. No contact record holds a location;
  • relationship metadata derived from communication and calendar activity, meaning envelope fields such as sender, recipient, timestamp and subject, including those of a message the customer sends from itogai through their own account;
  • professional information about a contact in an import the customer started, or about the one person the customer names to reach, that itogai completes as Section 3.3 describes;
  • conversation metadata from a conversation file the customer imports or a conversation the customer saves from their screen: who took part, when, how often, in which conversation and in which direction, and the names and phone numbers shown for the people in it;
  • structured relationship signals derived from a source the customer has consented to at Level 2, as described in Section 4; and
  • enrichment data added through a data provider at the customer’s request, such as a title, an employer, a work email address, a work or mobile phone number and a professional web address.

2.6a Audio a person records. Where a person chooses to record a voice input, itogai receives that audio recording and sends it to the transcription provider named in the AI Provider Register. itogai does not retain the recording after transcription. No itogai surface records audio at any other time.

2.6b The enrichment store and the shared copy. Where a customer requests enrichment of a contact, or the completion of Section 3.3 fills a card in an import the customer started, itogai retains the result against that contact record in that account’s own copy so the same lookup is not repeated. Where the provider’s written agreement permits a shared copy, the fields obtained from that provider are also kept once in the shared copy, which Section 5.8a describes. Section 11.1 states how long, and Section 13.6 sets out how a person who is not a user asks for removal from both.

2.6c Feedback between users. Where a user rates an introduction or a counterpart, itogai holds the rating, any comment, and the standing it derives from them, and shows that standing to the two people concerned. A comment a User marks as for itogai only is read by itogai and shown to nobody else.

2.7 Data about people who are not users. When a customer imports a contact, connects a Data Source, or imports or saves from their screen a conversation, itogai receives Personal Data about people who do not themselves use the Subscription Service, and the completion and enrichment of Section 3.3 add professional information about them from the sources it names, at the customer’s request or as part of an import the customer started. A conversation includes other people, and it may incidentally contain sensitive content the customer did not set out to share. itogai reads a conversation only at the level the customer has consented to for that source (Section 4), derives relationship signals, never stores the text, and never derives or keeps a signal that reveals an excluded category under Section 2.8. We process this data on the customer’s behalf, the customer is responsible for having a lawful basis to bring it in, and Section 13.6 sets out what those individuals may ask of us directly, including removal.

2.7a Consent records. When you consent to a source, or turn content signals on or off for it, itogai records the date, the consent text you were shown in your language, your locale, the content signals setting at that moment and, for integrity only and never shown to anyone, a hash of your IP address and browser identifier. If the text ever changes, you are shown it again for that source with a line saying what changed.

2.8 What itogai does not collect. itogai does not knowingly collect, and asks customers not to submit: protected health information; payment card data beyond what the payment processor collects directly; government-issued identifiers; biometric data used to identify a person; precise geolocation or a device’s location; or information about anyone under the age of eighteen (18).

No itogai surface requests a device’s location at any precision, or its address book. Microphone access is requested only at the moment a person chooses to record a voice input, and photo library and camera access only at the moment a person chooses to set a profile photo, and only on the surfaces the Product Surface Register records. The itogai companion acts only on the person’s click, reads a page only on a site the person has consented to and whose terms permit it, and keeps no message text. From its toolbar, on the person’s click, it reads the address and title of the tab the person is on, and nothing else from that tab, to save them with the person’s note. It never reads, keeps or sends a site’s cookies or a sign-in session. What each surface may request, and what it requests as built, is stated in the Product Surface Register. A capability that appears in the register as “may request” but not as “requests” is not in use, and itogai treats any divergence between the register and a surface as both a breach of the register as incorporated and a defect to be corrected in the surface.

2.9 How itogai handles this data internally. Inside itogai, every category above is classified, and each classification carries its own handling, retention, access, deletion and permitted-recipient rules. No classification holds anything this Policy does not disclose. The classification exists so that the commitments in this Policy can be checked against the systems that hold the data, and the security page at itogai.app/legal/security describes the program that does the checking.

3. Where data comes from

itogai receives Personal Data directly from you, automatically through your use of the Subscription Service, from the Data Sources a customer authorizes, from data providers at a customer’s request or as part of an import the customer started, and from available public sources at a customer’s request.

3.1 The five ways data enters an account. Every Data Source enters through one of five ways, each initiated and turned on by the customer and none on by default: connected accounts (an email, calendar, contacts or record system connected through the provider’s own sign-in and revocable there or in itogai); archive and file imports (a copy of the customer’s own data that the customer requests from a service through that service’s own download feature and uploads, a spreadsheet the customer maps, a contacts file, a file selected in a cloud drive, or an AI conversation export); conversation exports (a conversation file the customer exports and uploads, produced in compliance with the source service’s terms, that holds only the conversation itself and never another service’s credentials, keys or backups); on-screen reading (a conversation the customer has open on a site they have consented to and whose terms permit it, which the customer saves to their account with the itogai companion on their own click, only that conversation and only the part the customer has displayed on screen, never in the background and never while the customer is signed out of itogai); and manual entry (what the customer types or saves by hand, including the address and title of a page saved with a note from the companion’s toolbar, which is the only path to Level 3).

3.2 Which sources itogai supports. The page Supported sources and import methods at itogai.app/legal/data-sources describes, by category, the sources itogai supports and the way each enters an account. It is informational, and it is not incorporated into this Policy: this Policy speaks by the way data enters and by category, so that a source can be added without changing what we promise. Free-text fields in a connected record system are not read: itogai reads the structured fields and leaves the free text alone.

3.3 Professional information itogai completes. To complete your contacts, itogai uses professional information from available public sources and from the data providers listed in our Sub-processors register. When a customer imports contacts, itogai completes their cards this way, within a monthly number of profile completions the Service Schedule states. When a customer names a person they want to reach, itogai completes that person’s profile the same way and keeps it only in that customer’s account. Where a customer requests enrichment of a contact, a data provider returns business contact details such as a title, an employer, a work email address, a work or mobile phone number or a professional web address. A completed card can hold a name, professional information (such as title, employer, work history and education) and a professional web address. itogai never keeps a location. A customer can turn the completion off and delete what it wrote at any time. This information can be incomplete or out of date, and itogai doesn’t guarantee its accuracy.

This Policy does not apply to a third party’s own site or service. The Subscription Service links to and integrates with systems itogai does not control, including every Data Source you connect and our payment processor. itogai is not responsible for the privacy practices, content or security of any of them, and their own policies govern what they do with your data.

Connecting a source is always an act by the customer. itogai requests only the permissions necessary to provide the Subscription Service, and the authorization screen presented by the source describes exactly what is being granted. Permission to send email or to write calendar events is requested only the first time a customer sends or schedules from itogai, never when an account is connected. Any authorization may be revoked at any time, either inside the Subscription Service or in the settings of the source itself. Section 11.3 sets out what happens to data already derived when a source is disconnected.

4. How content is handled: the three levels

Every source itogai reads is handled at one of three levels. The level is set per source, stated here by category, and shown in the product for each source you have brought in.

Level What happens
Level 1. Metadata only itogai reads and retains envelope metadata only: sender, recipient, timestamp, subject and comparable fields. Body content is never read and never stored. This is the default for every source.
Level 2. Derived signal Content is read in memory for the limited purpose of extracting relationship signal, and then discarded. Only the derived signal persists. Raw text is never written to itogai’s database
Level 3. Retained content Raw text persists. This applies only to what a person saves by hand. No automated path writes to this level

By category. A connected mailbox and calendar are Level 1, and the structured fields of a connected record system are read as contact, company, deal and activity records while its free text is not read (Section 3.2). A spreadsheet, a contacts file, a data export and a document selected as a contact source are read once to extract the contact fields they hold, and no text from them is retained; for a file a person selects as a contact source, a model provider in the AI Provider Register may do the extraction, as that register states. A conversation file, an AI conversation export and an on-screen conversation are Level 1 unless content signals are on for that source, when they are Level 2. Manual entry is Level 3.

Two rules bind these levels permanently.

  1. Email message bodies never rise above Level 1. This is absolute. No consent, no setting, no product update and no future source moves them.
  2. A level is raised only by the customer’s own consent, for that specific source. A level is never raised by default, by a product update, or by adding a new source.

Email is read through the narrowest permission each provider offers for message metadata, so the provider itself does not return a message body, and calendar events are read without their descriptions.

Text you send or schedule from itogai. When you send a message from itogai through your own connected account, its text exists only until your provider confirms the send, and a description you write in itogai for an event only until your calendar confirms it. What stays is who, when, the subject or title and the provider’s identifiers, at Level 1.

Content signals, the Level 2 setting. Content signals are a per-source setting, off by default. We ask you at the moment you connect, upload or read a source, with a concrete example of what the setting adds (with content signals on, itogai can tell that you and a contact talked about an introduction last month and remind you to follow up; without it, itogai only knows you talked). With the setting on, the text of that source is read once, in memory, to derive relationship signals, and discarded. You can turn it off in settings at any time: that deletes every signal derived from content for that source and keeps everything derived from who, when and how often. Turning it on affects future imports only, because raw files no longer exist. Email is never a source this setting can apply to.

Why itogai states the level rather than a slogan. The phrase “we never read your messages” would be inaccurate, so itogai does not use it. At Level 1 there is nothing to read, because only the envelope is requested. At Level 2, content is read in memory and discarded, and only a derived signal remains. Naming the level is the only description that stays true across every source.

5. Why we use Personal Data

Legal bases under the GDPR, UK GDPR and LGPD are noted in parentheses.

5.1 To provide the Subscription Service. To operate accounts; to compute TrustGraph scores, TrustRings organization and TrustReach recommendations; to deliver Professional Services; and to carry out the actions a user initiates, including sending, from the user’s own account, a message the user reviewed and clicked send on, and scheduling an event the user chose. (Performance of a contract; legitimate interests; consent where required.)

5.2 To bill and manage payments. Including verifying eligibility for any pricing adjustment a customer requests, and administering refunds. (Performance of a contract; legal obligation.)

5.3 To communicate with you. To answer support requests; to send transactional messages about your account, security and billing; and, where you have opted in, to send product and marketing messages you can unsubscribe from at any time. (Performance of a contract; legitimate interests; consent for marketing where required.)

5.4 To send notifications you have enabled. Where you enable notifications on a surface that supports them, we use a push delivery provider to deliver them. A notification may contain the name of a person in your network, because that is what makes it useful. Notifications are turned off by declining the permission or by changing the setting on the surface, and doing so stops delivery. (Consent; performance of a contract.)

5.5 To improve and develop the Subscription Service. To understand how it is used, to find and fix problems, and to improve the TrustGraph scoring algorithm. This uses aggregated and de-identified data only, and nothing pooled across customers trains, tunes or calibrates the scoring model. itogai does not use identifiable Customer Personal Data to improve the Subscription Service or the scoring model, except that the scoring uses an account’s own data within that account, as part of providing the Subscription Service to it; what the scoring learns from that data is never used for another account, and it is deleted with the account’s data. (For itogai’s own Account, Usage and Device Data, legitimate interests. Customer Personal Data is processed only on the customer’s instructions under the Data Processing Agreement.)

5.6 Security and abuse prevention. (Legitimate interests; legal obligation.)

5.7 To comply with law and enforce our rights. (Legal obligation; legitimate interests.)

5.8 What we never do with Customer Data. We do not use Customer Data, including anything received from a restricted Google API scope, for advertising, and we do not use it to train generalized artificial intelligence or machine learning models. Section 6.4 states how that commitment is made and verified with each model provider. We never sell the Personal Data of the people in a customer’s network, and never share it with anyone for their own purposes; we never combine one customer’s contact data with another customer’s to build a profile of a person; and no path exists in the Subscription Service that serves one customer’s contact data to another customer except network sharing that the customer whose contacts it shows switched on (Section 8.4a) or a Group both belong to. The shared copy of Section 5.8a is not one customer’s contact data: it holds only professional fields obtained from data providers, never anything a customer brought in, saw in their own account or typed. These are commitments built into the product, not settings, and Section 7.2 of the Data Processing Agreement states them contractually.

5.8a The shared copy. Where a data provider’s written agreement permits a shared copy, itogai keeps the fields it obtained from that provider about a person once, in that shared copy. itogai is the controller of the shared copy. It holds only fields obtained from a data provider: no user or import identifier, no count of the accounts that hold the person, and nothing a customer brought in, saw in their own account or typed. It is used for an account only for a person already in that account’s contacts, on that account’s own request or as part of an import that account started, and the action is charged as the Service Schedule states, and what it supplies is copied into that account’s own copy. An account that holds the person can see that the shared copy holds fields for them before it pays, and nothing else. A shared row that no account holds anymore is deleted within thirty (30) days, and a removal request under Section 13.6 deletes it at once. itogai relies on its legitimate interests in running the Subscription Service efficiently and in limiting how often a person’s professional information is requested from data providers, on the basis of the written assessment Section 5.9 describes. The shared copy is never sold, never shared with anyone for their own purposes, and never used to build a profile of a person across accounts.

5.9 The people in our users’ networks. Most of the Personal Data itogai holds about a person who is not a user is held on a customer’s behalf, and the customer is the controller with the lawful basis Section 2.7 describes. For the limited processing itogai carries out in its own name about those people (operating the features that necessarily concern them, deriving relationship signals and TrustGraph scores for the user’s own judgment, answering their requests, keeping the never-sell and no-cross-customer rules, keeping the shared copy of Section 5.8a, and carrying the lines in introduction emails that point to the notice described below), itogai relies on its legitimate interests and those of its users in taking care of relationships they already have, on the basis of a written assessment that balances those interests against the rights of the people concerned and that is available to a supervisory authority on request. That processing involves an estimate of relationship strength, which is profiling in the sense the GDPR uses the word: it is shown only to the user whose network the person is in and, at that user’s direction, to tools that user connects, it is never shown to the person scored, it produces no decision about the person, and it is never used for employment, credit, insurance, housing or any decision with legal or similarly significant effect (Section 6.3). itogai does not tell each person at the moment a user brings them in, for the reasons recorded per source type in an assessment kept under Article 14(5)(b) of the GDPR; instead, the page Notice to people in our users’ networks at itogai.app/legal/network-notice carries everything Article 14 requires, in plain terms, every introduction email a user sends through itogai from their own account carries one line, “Sent via itogai”, that links that page, an introduction email itogai sends from its own address carries a line saying how the sender came to use itogai and how to ask itogai for removal, and Section 13.6 gives every person the removal path and every right without an account. A person may object to this processing at any time, and itogai honors the objection.

6. Akai and automated processing

6.1 What Akai is. Akai is itogai’s relationship intelligence co-pilot. It drafts messages for your review, surfaces possible warm introduction paths, prepares context briefs, and answers questions you ask about your own network.

6.2 What Akai does not do. Akai does not send anything. Every outbound message it drafts is delivered only after a person has reviewed it and clicked send, and it goes out from that person’s own connected account, as them; the one exception is an introduction email their own account can’t send, which they can choose to send from intros@itogai.com, in itogai’s own name (Section 18). There is no automatic send, no scheduled send on your behalf, and no configuration that creates one. This is a design commitment, not a default setting, and it applies to every surface.

6.3 Scores are support for your judgment. A TrustGraph score is a probabilistic estimate produced from the signals available to it. It is not an assessment of a person’s character, creditworthiness, employability or eligibility for anything. itogai does not make, and does not enable, a decision that produces a legal or similarly significant effect on a person by automated means. Section 13.2 records your related right.

6.4 The model providers. Akai runs on third-party model providers. itogai engages a model provider only where that provider commits that our Customer Data will not be used to train the provider’s general-purpose models, and a provider that will not commit is not engaged. What each engaged provider has committed to, and the date we last verified it, is stated per provider in the AI Provider Register, because it rests on a separate instrument with each one and those instruments differ.

6.4a Where you run Akai on your own key. On the plans the Service Schedule states, you may run Akai on your own key with a provider in the AI Provider Register. Prompt content then leaves under your own agreement with that provider, and the training position that register records for itogai’s account does not apply to that traffic. Section 3a of the register states this in full.

6.5 What is never sent to a model provider, and what transits. Email message bodies are never sent. Where you have turned content signals on for an imported or on-screen conversation, its text may transit one model provider named in the AI Provider Register once, at import, to derive relationship signals; the text of a spreadsheet, contacts file or document you select as a contact source may transit one provider once, to extract contact fields only, and is not retained; no provider uses it to train its models, no provider keeps it beyond the period its verified terms set for abuse monitoring (today, up to thirty (30) days, or fifty-five (55) days for Google, and longer for content a provider’s own systems flag for a policy violation) unless itogai holds a zero-data-retention agreement with that provider, in which case nothing is kept, the request carries no account identifier, and the AI Provider Register says so in one line. Anything held at Level 1 is never available to be sent, because it is never read or stored in the first place.

6.6 Every generated text says so. Every Akai output carries a marker that identifies it as generated, on every surface, together with the statement that a score is support for your own judgment. itogai keeps that marker in every release. Where the law of a place where the Subscription Service is offered requires generated text to be identified as such, this is how itogai meets it.

6.7 How itogai governs its AI features. Only providers named in the AI Provider Register can receive prompt content, through a list fixed in configuration; every request runs inside a limit on the amount of text it may carry; content from a source, a file or a page is handled as data and never as an instruction; a model’s output is treated as untrusted until a person reviews it; itogai checks the behavior of every Akai feature before each release that touches it; and a message sent without a person’s click, or an output that exposes the scoring model’s mechanics, is treated as a security incident. The AI tools itogai’s own team uses to build the Subscription Service work under the same rules: they never hold a production secret and never publish a change on their own.

7. Google API Limited Use disclosure

itogai’s use and transfer of information received from Google APIs to any other application adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

  1. We use Google user data only to provide or improve user-facing features that are visible and prominent in the Subscription Service.
  2. We do not transfer Google user data to others except as necessary to provide or improve those user-facing features; to comply with applicable law; or as part of a merger, acquisition or sale of assets, in each case after obtaining the user’s explicit consent or as otherwise permitted by Google.
  3. We do not use Google user data for advertising of any kind, including retargeting, personalized advertising and interest-based advertising.
  4. We do not allow humans to read Google user data, except with the user’s affirmative agreement for specific messages; when necessary for security purposes such as investigating abuse; when necessary to comply with applicable law; or where the data is aggregated and used for internal operations in accordance with applicable privacy policies.
  5. We do not use data obtained through Google Workspace APIs to develop, improve or train generalized or non-personalized artificial intelligence or machine learning models, and we do not transfer such data to a third party for that purpose.
  6. Nothing received from Google APIs, raw or derived, feeds the scoring model or any other model beyond providing the features of the account it belongs to.

What itogai receives from Google, and why. Message metadata from Gmail (sender, recipients, date and subject), under Gmail’s metadata-only permission, to understand who you’re in touch with and how often; events on calendars you own (time, title and attendees, without descriptions), to understand who you meet; the contacts you hold (name, email address, phone number, employer and role); and, only when you first choose to, permission to send an email you reviewed and clicked send on and to create an event you scheduled, used for nothing else.

Gmail’s restricted scope is held at Level 1 under Section 4, and email message bodies are never read or stored. itogai’s compliance with the Google API Services User Data Policy is the subject of its App Defense Alliance CASA verification at Assurance Level 1 (formerly Tier 2).

8. How we share Personal Data

We do not sell Personal Data, and we do not share Personal Data for cross-context behavioral advertising.

8.1 With sub-processors. Third parties that process Personal Data on our behalf, under written agreements limiting them to the services they provide to us. They are listed in the Sub-processors register, described in Section 9.

8.2 With other users. An account belongs to one person and is never shared between people, as Section 2.2 of the Customer Terms of Service states. What another user can see of your Customer Data is limited to what you contribute to a Group (Section 8.4) or share through network sharing (Section 8.4a).

8.3 With third parties you authorize. Where you direct itogai to send data to a system you have connected with your own credentials, itogai transmits it at your direction. Those destinations are listed in the Sub-processors register under customer-directed recipients. Data already delivered to one of them is governed by your own agreement with that provider, and itogai cannot retrieve or delete it.

8.4 Inside a Group. Where a customer’s organization holds a Group, a member contributes a contact to it only by choosing to, member by member. An organization may make contribution a condition of membership in a Group it holds, and a member who joins on that condition has made that choice; where it does, or where a member opts in, the Group pools derived, aggregate signals at Group level, scoped to that Group, and a member’s individual relationship data stays with the member who observed it. What a Group makes visible to other members is business-card depth: a contact’s name, employer, role and the fact that a colleague knows them. It does not expose relationship scores, communication metadata, message content, or the strength or history of any colleague’s relationship, and there is no setting that widens it. A member can see at all times whether their contacts are contributed, and can stop contributing going forward at any time. The organization holding the Group is the controller of the Group record.

8.4a Sharing your network. You may switch on network sharing: one setting for your whole account, off by default, which asks you to confirm before it turns on. With it on, other itogai users who have you as a contact can see you as a bridger and ask you for an introduction to someone you know; they see, for a person you know, a name, employer and role and the fact that you know them, at business-card depth, and nothing else. Anyone further along a route than the people you know appears to them by role at most, as Section 8.4b says. With it off, nobody can. Switching it off takes effect at once: what others could see through it leaves their view on their next read, and nothing derived from it survives against their accounts.

8.4b On a path. Where the Subscription Service shows you a route to a person you do not know, the people between you who are not your own contacts appear by role only, never by name, and nothing about them is retained on your account.

8.5 Where a facilitated introduction involves a fee. Where the Subscription Service is used to request an introduction and the person making it has set a fee, the requesting person pays it in Sparks or in cash through itogai’s payment processor, which settles a cash fee to the person making the introduction; itogai does not hold or control funds. The fee is agreed between the two people concerned, and itogai takes no share of it beyond the platform fee stated in the Service Schedule. Whether the person making the introduction tells the person being introduced that a fee is involved is that person’s decision. If you were introduced to someone through itogai and you ask us whether a fee was involved, we answer honestly, once we have confirmed you were a party to that introduction. A person who affirmatively states that no fee was involved when one was is in breach of the Acceptable Use Policy. The Bridger Terms set out the full arrangement.

8.6 For legal reasons. Where we believe in good faith that disclosure is necessary to comply with law, legal process or a governmental request; to enforce our agreements; to protect the security or integrity of the Subscription Service; or to protect the rights, property or safety of itogai, our customers or others.

8.7 In a business transaction. In connection with a merger, acquisition, financing, reorganization, bankruptcy or sale of assets, Personal Data may transfer to the acquiring entity, subject to the protections in this Policy or to notice of any change to them.

8.8 With your consent. For any other purpose, with your consent.

9. Sub-processors and the registers

9.1 The register model. itogai does not maintain vendor lists inside its contracts. It maintains registers: published, versioned documents, each carrying the same notice rule. Three are incorporated into this Policy by reference: the Sub-processors register, the AI Provider Register and the Product Surface Register. The fourth, the page Supported sources and import methods, is informational and is not incorporated, as Section 3.2 states.

Register Holds
Sub-processors Every third party that processes Personal Data on itogai’s behalf, with the categories of data each receives and where it processes them
Supported sources and import methods (informational, not incorporated) The sources a customer may bring in, described by category and by the way data enters an account
AI Providers Every model provider, with the training commitment verified and dated for that provider
Product Surfaces Every surface the Subscription Service is delivered on, with the device capabilities each may request and requests

Adding a vendor, source, provider or surface updates the applicable register. No amendment to this Policy is required, which is what allows itogai to ship an integration without a contract cycle. The converse holds as well: a third party that receives Personal Data and does not appear in the applicable register is a defect, and it is a defect whether or not anyone has noticed.

9.2 The categories of recipient, stated here. The register carries the names. This Policy carries the envelope, which does not change when a name does:

  • infrastructure, hosting, database and identity providers that run the Subscription Service;
  • a payment processor;
  • model providers that perform inference for Akai and related features, including looking up professional information from available public sources at a customer’s request;
  • data providers that return business contact details or professional information about a contact submitted for enrichment or completed as part of an import the customer started;
  • mailbox and calendar aggregation providers;
  • communication providers that deliver email and push notifications;
  • analytics and error monitoring providers;
  • abuse prevention providers;
  • a customer relationship system of record, a meeting-notes tool and a product feedback board itogai uses to run its own business;
  • internal collaboration and support routing providers; and
  • a marketing website host.

9.3 Two disclosures stated plainly. Our error monitoring provider records a session replay of activity on the authenticated platform, with all text masked and all media blocked before transmission, rather than error reports alone. Our two product analytics providers receive the user’s email address itself as the identifier distinguishing one user from another, which is a direct identifier rather than a pseudonymous one. itogai runs no other telemetry on the authenticated platform, and the platform serves its own typefaces and static assets from its own origin.

9.4 Notice of a change. One definition governs every itogai register and every legal document wherever a change affects personal data. Where a document turns on something else, it states its own trigger, and the same thirty (30) days’ notice applies:

A change is material when it expands the categories of personal data processed, expands the purposes of processing, expands the categories of recipients, or reduces a right the customer holds.

A material change carries at least thirty (30) days’ advance notice, by email to the registered account owner and by publication, with a route to object and a termination remedy where the objection cannot be resolved. Everything else is routine, published immediately with the version incremented, except that adding or replacing a sub-processor always carries the advance notice above.

10. International transfers

itogai is based in the United States. Personal Data we process may be transferred to and processed in the United States and in other countries where itogai or a sub-processor operates. Those countries may have data protection laws that differ from those where you live.

10.1 From the EEA, the United Kingdom and Switzerland. Where we transfer Personal Data to a country not recognized as providing an adequate level of protection, we rely on the European Commission’s Standard Contractual Clauses (Module Two where the customer is a controller, and Module Three where the customer is itself a processor), the United Kingdom International Data Transfer Addendum, and the Swiss transfer mechanism approved by the Federal Data Protection and Information Commissioner.

10.1a The Data Privacy Framework. itogai intends to self-certify to the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework (together, the DPF), administered by the United States Department of Commerce. Until the Department of Commerce lists Itogai LLC on the Data Privacy Framework List, transfers from the EEA, the United Kingdom and Switzerland rest on the instruments in Section 10.1, and itogai makes no claim of DPF participation. From the day itogai is listed, which itogai will state in this Section with the date, the following applies to Personal Data itogai receives from the EEA, the United Kingdom and Switzerland in reliance on the DPF, and nothing else in this Policy changes:

  • Itogai LLC complies with the DPF Principles for that data. Where this Policy and the Principles conflict, the Principles govern. The DPF program and the List are at dataprivacyframework.gov.
  • The types of Personal Data and the purposes are those in Sections 2 and 5; itogai’s role as controller or processor for each is as Section 16.1 states.
  • Choice. Where itogai would disclose Personal Data to a third party acting as a controller, or use it for a purpose materially different from the one it was collected for, it offers the person a choice first; for sensitive data, affirmative express consent.
  • Access. A person may access the Personal Data itogai holds about them and correct, amend or delete it where inaccurate or processed in violation of the Principles, through Section 13.
  • Onward transfers. itogai remains responsible under the Principles for Personal Data it transfers to a third party acting on its behalf, where that third party processes it in a manner inconsistent with the Principles, unless itogai proves it is not responsible for the event giving rise to the damage.
  • Recourse. A person with an inquiry or complaint about itogai’s handling of DPF data should first write to privacy@itogai.com, and itogai responds within forty-five (45) days. itogai will refer unresolved complaints to JAMS, an independent dispute resolution provider based in the United States, at no cost to the person; the JAMS DPF program is at jamsadr.com/dpf-dispute-resolution. A person may also contact their national data protection authority, the Information Commissioner’s Office or the Swiss Federal Data Protection and Information Commissioner. Where a complaint remains unresolved after these steps, the person may invoke binding arbitration under Annex I of the DPF Principles.
  • Enforcement. itogai is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
  • Public authorities. itogai may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; Section 6.7 of the Data Processing Agreement states how itogai handles such a request.
  • Human resources data. itogai does not receive human resources data from the EEA, the United Kingdom or Switzerland under the DPF.

The Standard Contractual Clauses and the UK Addendum in Section 10.1 remain in place for every transfer the DPF does not cover and take over in full for any transfer the DPF ceases to cover, so that no transfer is ever without an instrument.

10.2 From Brazil. Transfers rely on the bases in Article 33 of the Lei Geral de Proteção de Dados, including standard contractual clauses, necessity for the performance of a contract with the data subject, and consent where applicable.

10.3 Colombia, Mexico, Peru and Chile. Where a customer in Colombia brings Personal Data into the Subscription Service, itogai receives it as an encargado under a contract that meets Article 25 of Decreto 1377 de 2013, which is Section 6.8 of the Data Processing Agreement. Where a customer in Mexico does so, itogai assumes the obligations of an encargado under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares and its Reglamento (Data Processing Agreement 6.9). Where a customer in Peru does so, itogai assumes the obligations of an encargado de tratamiento under Ley 29733 and its Reglamento (Data Processing Agreement 6.10). Where a customer in Chile does so, itogai assumes, from the day Ley 21.719 enters into force, the obligations of a mandatario under that law (Data Processing Agreement 6.11). itogai holds no database in, and has no establishment or registration in, any of these countries. Section 10.4 states where itogai’s personnel work from.

10.3a Elsewhere. We use other transfer mechanisms permitted under local law.

10.4 Where processing happens. The Sub-processors register states the processing location of each sub-processor. itogai’s own application hosting runs in the United States. Where a sub-processor operates in more than one region, its entry in the register says so. itogai’s own contractors access its production systems from the United States and from Colombia, under written terms that bind them to process Personal Data only on itogai’s instructions and to store none of it locally; no Personal Data is stored in Colombia.

11. Retention and deletion

We keep Personal Data only as long as necessary to provide the Subscription Service and to meet the purposes in this Policy, including legal, accounting and reporting obligations.

11.1 The general rule. Account Data and Billing Data are kept for the life of the customer relationship and a reasonable period after it. Customer Data is kept for the life of the relationship, subject to the windows below. Usage Data is kept for twenty-four (24) months. Device and Log Data are kept for twelve (12) months. An enrichment result, and what the completion of Section 3.3 wrote, is kept against the contact record it describes and is deleted with that record. A shared row of Section 5.8a is deleted within thirty (30) days once no account holds the person. The text of a message you send from itogai through your own account is deleted once your provider confirms the send, and a description you write for an event once your calendar confirms it. An audio recording is deleted on completion of transcription and is not retained, and a security or access log implicated in an investigation is kept until that investigation closes. Where a longer period is necessary to defend a legal claim or to meet a legal obligation, Section 11.6 applies and the data is kept for no longer than that purpose requires.

11.2 Export, and export on termination. You can export your Customer Data at any time while your account is active, from inside the Subscription Service, in a structured, machine-readable format.

For thirty (30) days after an account terminates, that export remains available. Where a terminated account can no longer sign in, the account owner may request the export by writing to support@itogai.com from the address on the account, and itogai delivers it within ten (10) business days of a verified request made inside the thirty day window. When the window closes itogai deletes the data, subject to Section 11.5.

This is a right the customer holds, and shortening or removing it is a material change under Section 9.4.

11.3 Disconnecting a Data Source. itogai stops reading from a disconnected source immediately. Metadata and structured signals already derived during the period of authorized access remain part of the customer’s TrustGraph record until the customer deletes them or the account terminates. Raw content processed at Level 2 is not written to itogai’s database or to any log at any point. Cached metadata not yet incorporated into the structured record is deleted within seven (7) days of disconnection.

11.3a Raw files you upload, and what is derived from them. A raw file you upload is deleted as soon as it has been processed, and within twenty-four (24) hours where processing fails or you do not finish the steps. Records derived from a source can be deleted per import (which removes the records attributable only to that import), per source (turning content signals off deletes what was derived from content), and with the account: everything derived from a source is deleted within thirty (30) days of account deletion, subject to Section 11.5 and 11.6. No category of data derived from a source is kept for longer, and where Section 11.6 ever applies to such data, this Policy will name the reason beside it.

11.4 Deletion, and how to ask for it.

You can delete your account from inside the Subscription Service, on every surface that offers account settings, including any itogai application. You do not have to contact anyone, and you do not have to use a different device or surface than the one you signed up on. You can also write to privacy@itogai.com from the address on the account.

itogai publishes a deletion request page at itogai.app/support that anyone can reach without signing in, so that a person who can no longer access their account can still ask.

On a verified deletion request, itogai deletes the Personal Data, or irreversibly anonymizes it so that it can no longer be attributed to you or to any identifiable person, within thirty (30) days, subject to Section 11.5 and to any legal obligation to retain.

Stated plainly, because the distinction matters: where a record must persist for the integrity of the surrounding data, itogai strips it of every identifier rather than removing the row, and the result cannot be re-linked to a person by itogai, and itogai holds no key or auxiliary dataset that would permit re-linking. Where no such constraint applies, the data is deleted. Either way, after thirty days itogai no longer holds Personal Data about you from that account in its production systems, subject to Sections 11.1, 11.5 and 11.6.

11.5 Backups. Backups are retained for ninety (90) days for disaster recovery and are then overwritten on a rolling schedule. A deletion or anonymization carried out under Section 11.4 propagates through the backup cycle within that period.

11.6 Legal holds. We may retain Personal Data longer where necessary to comply with law, resolve disputes, enforce our agreements or defend legal claims.

12. Security

12.1 Technical controls. Industry-standard encryption in transit, currently TLS 1.2 or higher, and at rest, currently AES-256. Role-based access control, multi-factor authentication for itogai personnel, audit logging, network segmentation, and logical tenant isolation enforced at the database layer. Specific algorithms and protocols may be updated where the update does not reduce the overall level of security.

12.2 Operational controls. Least-privilege access for itogai personnel, periodic access review, revocation on offboarding, vendor security review, and an incident response procedure.

12.3 Internal access to customer data. itogai operates an internal console for running the service. Access through it is role-restricted, logged, and limited to the purposes stated in this Policy. itogai personnel do not read customer content outside those purposes.

12.4 CASA verification. itogai holds App Defense Alliance CASA verification at Assurance Level 1 (formerly Tier 2), renewed annually by a new Letter of Validation, an independent assessment of the security controls supporting its Google API integrations and the Level 1 handling described in Section 4. The verification covers those integrations and the controls behind them. It is not an assessment of the Subscription Service as a whole, and it is not a substitute for SOC 2 or ISO/IEC 27001, neither of which itogai holds. The dates of the current Letter of Validation are on the security page at itogai.app/legal/security.

12.5 What itogai does not claim. itogai is not certified under SOC 2 Type II or ISO/IEC 27001, and does not describe either as in progress or under way. itogai is 100% bootstrapped. Its security program is calibrated to the categories of data it processes and the risks they carry. itogai does not describe its encryption as end to end, because encryption at rest and in transit is a different thing.

12.6 If there is a breach. Where a security incident affects Personal Data for which itogai is the controller, itogai notifies the affected individuals without undue delay where applicable law requires it or where the incident is likely to result in a high risk to their rights, and notifies the relevant supervisory authority within the period the applicable law sets, which under the GDPR is seventy-two (72) hours of becoming aware of it. The notice describes what happened, what data was involved, what itogai has done, and what you can do. Where you are in Florida, itogai notifies you as expeditiously as practicable and no later than thirty (30) days after determining that a breach of security affecting your personal information has occurred, under section 501.171 of the Florida Statutes, and notifies the Florida Department of Legal Affairs within the same period where five hundred (500) or more individuals in Florida are affected. Where itogai holds Personal Data as a customer’s processor or third-party agent, it notifies that customer without undue delay and, where feasible, within seventy-two (72) hours, and in every case within ten (10) days, as Section 3.7 of the Data Processing Agreement states, so that the customer can meet its own duties to you. Where the law of the place you are in sets a different period, itogai meets that one too; its incident plan carries every clock that applies to it.

12.7 Reporting a security issue to us. Write to legal@itogai.com. We acknowledge receipt and work in good faith to investigate and remediate. The Acceptable Use Policy Section 5 sets out the full coordinated disclosure route.

12.8 No method is perfect. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12.9 Our security program, in one place. The controls in Sections 12.1 to 12.3 are part of one written program with one control set, named policies, owner roles, review dates and evidence, covering everything itogai runs. The security page at itogai.app/legal/security describes it in plain words and carries the one table of what itogai holds today (its CASA Letter of Validation, and the fact that it holds no SOC 2 report and no ISO/IEC 27001 certificate); a report or a certificate is added to that table with its date and nowhere else. The policies are available to a customer or an auditor under a confidentiality agreement on request to legal@itogai.com.

13. Your privacy rights

To exercise any right, write to privacy@itogai.com.

13.1 Rights everyone has. You may ask for access to the Personal Data we hold about you, ask us to correct it, ask us to delete it, and ask us to stop sending you marketing messages.

13.2 GDPR and UK GDPR. Rights of access, rectification, erasure, restriction, portability and objection. You also have the right not to be subject to a decision based solely on automated processing producing legal or similarly significant effects. itogai does not make such decisions, and Section 6.3 explains what a TrustGraph score is and is not. We respond to verifiable requests within thirty (30) days, extendable where the law permits.

13.3 LGPD. Rights to confirmation of processing, access, correction, anonymization, blocking, deletion, portability, information about sharing, and revocation of consent. We respond within fifteen (15) days, extendable where the law permits.

13.4 California: the CCPA and CPRA. The CCPA applies to a business that crosses one of its thresholds; itogai has not crossed one today, and this Section becomes operative on the day it does, without any other change. itogai honors the rights below for every California resident regardless. California residents have the right to know, to delete, to correct, to opt out of sale or sharing, to limit the use of sensitive personal information, and to non-discrimination for exercising any of them, and itogai honors each of those requests.

itogai has not sold, and has not shared for cross-context behavioral advertising, the Personal Information of any California resident in the preceding twelve (12) months. itogai does not use or disclose Sensitive Personal Information for any purpose that would trigger a right to limit. We respond to a verifiable consumer request within forty-five (45) days, with one further forty-five (45) day extension where reasonably necessary.

13.5 Other US state privacy laws. Residents of states with comprehensive consumer privacy laws hold comparable rights subject to each state’s definitions and exceptions.

13.6 If you are not a user. If a customer has provided Personal Data about you to itogai, for example by importing a contact record, or by importing or saving from their screen a conversation you took part in, write to privacy@itogai.com. This is the removal path for anyone who appears in a source a customer brought in. You do not need an account, and we answer within thirty (30) days, or the shorter period the law that applies to you sets, extendable only where that law allows.

For most of that data itogai is the processor and the customer is the controller, which means the decision is theirs rather than ours. Here is exactly what we do:

  1. We acknowledge your request within five (5) business days, and we do not decide its substance, because that decision belongs to the customer as controller.
  2. We tell you which customer holds your data, so you have somewhere to go, unless telling you would breach a legal obligation we owe.
  3. We forward your request to that customer straight away, and we remove every enrichment result about you, in every account, together with the shared copy of Section 5.8a and everything the completion of Section 3.3 wrote about you, at once, which is ours to decide and does not wait on the customer.
  4. If they have not answered within thirty (30) days, we suppress your record ourselves, so it is no longer processed for relationship signals, and we tell you and them that we have done so.

Where itogai is the controller of the data rather than the processor, we decide the request ourselves and Sections 13.1 to 13.5 apply to you directly. The page Notice to people in our users’ networks at itogai.app/legal/network-notice explains, in plain terms and without any legal citation, what itogai is likely to hold about you, why, where it came from, who receives it, how long it is kept, and how to exercise every right without an account. Once you have been removed at your request, itogai keeps a suppression record so that a later import from the same user’s sources does not bring you back.

13.7 Verification. We verify identity before responding, which may mean confirming the email address on an account or asking for further identifying information. Information provided for verification is used for nothing else.

14. Cookies and similar technologies

itogai and its providers use cookies, local storage, session storage, pixels and comparable technologies (together, “Cookies”). The Cookie Policy is the full statement and is incorporated into this Policy by reference.

14.1 The categories in use.

Category Purpose
Strictly necessary Authentication, session integrity, request routing, security. These cannot be switched off without breaking the Subscription Service
Functional Remembering preferences such as language, time zone and the last view you were in
Analytics and performance Understanding how the Subscription Service and the marketing website are used, and finding and fixing problems. On the marketing website, analytics cookies are set only after a visitor agrees. Where the law requires consent, we rely on consent
Marketing Not in use. The marketing website sets no marketing cookies, and itogai places no advertising tracker inside the authenticated Subscription Service

14.2 Your choices. Most browsers allow you to block or delete Cookies. itogai responds to Global Privacy Control signals to the extent applicable law requires. itogai does not respond to Do Not Track headers, because no industry standard for them was adopted. Where consent is the basis for a category, the Cookie Policy states how to give and withdraw it, and withdrawing consent does not affect the lawfulness of processing before withdrawal.

15. Children’s privacy

The Subscription Service is a business product and is not directed to children. itogai does not knowingly collect Personal Data from anyone under the age of eighteen (18), or under such higher age as the law where that person lives sets. Where local law sets a lower floor, including thirteen (13) under COPPA in the United States, sixteen (16) at the highest under Article 8 of the GDPR, and twelve (12) under the LGPD in Brazil, itogai applies eighteen rather than the lower figure, and the Customer Terms of Service prohibit a customer from submitting information about anyone below it. If you are under eighteen, you may not register for or use the Subscription Service, and Section 2.2 of the Customer Terms of Service states that requirement.

If we learn that we have collected Personal Data from a child without the consent the law requires, we will take reasonable steps to delete it. A parent or guardian who believes a child has provided Personal Data to itogai should write to privacy@itogai.com.

16. Region-specific disclosures

These supplement the rest of this Policy and do not replace it.

16.1 EEA, United Kingdom and Switzerland. itogai may act as a controller, for example over Account Data, Billing Data, Usage Data and Communications, or as a processor, for example over Customer Data a customer imports or that we read from a source they authorized. Where itogai acts as a processor, the Data Processing Agreement governs. Any individual may lodge a complaint with a competent supervisory authority. European Union and EEA authorities are listed at edpb.europa.eu; in the United Kingdom, the Information Commissioner’s Office is at ico.org.uk; in Switzerland, the Federal Data Protection and Information Commissioner is at edoeb.admin.ch. Representatives under Article 27. itogai’s processing is subject to the GDPR and the UK GDPR under Article 3(2) of each, because it offers the Subscription Service to people in the EEA and the United Kingdom and because the relationship signals it derives relate to people there who appear in its users’ networks. itogai is putting in place a representative in the European Union and a representative in the United Kingdom under Article 27, and will state the name and address of each in this Section from the day the appointment takes effect; the appointment changes nothing else in this Policy. Until that day, people in the EEA and the United Kingdom reach itogai directly at privacy@itogai.com. itogai has no establishment, office or entity in the EEA or the United Kingdom, and a representative is a contact point and not an establishment. At any time, an individual in the EEA, the United Kingdom or Switzerland may reach itogai directly at privacy@itogai.com, and itogai answers on the same timeframes as it answers anyone else.

16.2 Brazil. The rights in Section 13.3 apply. itogai’s privacy contact for LGPD purposes, being the encarregado, is reachable at privacy@itogai.com. A data subject may also file a complaint with the Autoridade Nacional de Proteção de Dados at gov.br/anpd.

16.3 California. In addition to Section 13.4, the categories of Personal Information itogai collects are those in Section 2, collected from the sources in Section 3, for the purposes in Section 5, and disclosed for a business purpose to the categories of recipient in Section 9.2. Retention periods are in Section 11. itogai does not use or disclose Sensitive Personal Information for any purpose beyond those CCPA Section 1798.121 permits.

Shine the Light. Under California Civil Code Section 1798.83, a California resident may request information about disclosures of Personal Information to third parties for those third parties’ own direct marketing purposes. itogai makes no such disclosures. To submit a Shine the Light request, write to privacy@itogai.com with that subject line.

16.4 Nevada. A Nevada resident may submit a verified request directing itogai not to make any sale of any covered information, as Nevada Revised Statutes Section 603A.340 defines it. itogai does not sell covered information. Submit a request to privacy@itogai.com.

16.5 Appeals. Where a United States state privacy law requires a designated appeals process, and itogai declines a request you made, you may appeal by replying to our decision or by writing to privacy@itogai.com with the subject line “Privacy Rights Appeal.” We respond within the period that state’s law sets, and where we decline the appeal we tell you how to contact that state’s attorney general.

16.6 Latin America outside Brazil. itogai serves people across Latin America, from the United States. Where a local data protection law gives you rights, you may exercise every one of them by writing to privacy@itogai.com, and itogai answers on the timeframes that law sets or, where it sets none, within thirty (30) days. In particular:

  • Colombia. Ley 1581 de 2012 and Decreto 1377 de 2013. Your rights of access, update, rectification, deletion and revocation of authorization, and the right to file a complaint with the Superintendencia de Industria y Comercio at sic.gov.co. itogai holds no database in Colombia and is not registered there; where a Colombian customer brings your data in, itogai receives it as an encargado under a contract that meets Article 25 of Decreto 1377 (Section 10.3).
  • Mexico. The Ley Federal de Protección de Datos Personales en Posesión de los Particulares published on March 20, 2025 and its Reglamento. Your ARCO rights (access, rectification, cancellation and opposition) and the right to file a complaint with the Secretaría Anticorrupción y Buen Gobierno. Where a Mexican customer brings your data in, itogai acts as its encargado and assumes the obligations that law places on one (Section 10.3).
  • Peru. Ley 29733 and its Reglamento, Decreto Supremo 016-2024-JUS. Your rights of information, access, rectification, cancellation and opposition, and the right to file a complaint with the Autoridad Nacional de Protección de Datos Personales. itogai is putting in place a representative for Peru under Article VII of that Reglamento and will state the representative’s details here from the day the appointment takes effect. Where a Peruvian customer brings your data in, itogai assumes the obligations of an encargado de tratamiento (Section 10.3).
  • Chile. Ley 19.628 today and, from December 1, 2026, Ley 21.719, which creates the Agencia de Protección de Datos Personales. Your rights of access, rectification, deletion, opposition and portability under whichever law is in force, exercised through privacy@itogai.com. Where a Chilean customer brings your data in, itogai assumes the obligations of a mandatario from the day Ley 21.719 enters into force (Section 10.3).
  • Argentina. Ley 25.326. Your rights of access, rectification, update and deletion, and the right to file a complaint with the Agencia de Acceso a la Información Pública. itogai has registered no database in Argentina.

16.7 Where itogai is, and how it applies each law. Itogai LLC is a Florida limited liability company. It has no subsidiary, branch, office, establishment or registration in any other country, and it does not create one to satisfy a privacy law. Each privacy law applies to itogai by that law’s own test, which itogai reviews at every revision of this Policy; where a law reaches itogai, this Policy and the Data Processing Agreement carry what it requires. A representative, an encarregado or a privacy contact named in this Policy is a contact point and never an establishment.

17. How this Policy changes

17.1 The rule. The definition in Section 9.4 governs. A material change carries at least thirty (30) days’ advance notice, by publication and by email to the registered account owner. Where the law requires renewed consent, we obtain it before the change takes effect. A routine change is published immediately with the Last Modified date and Document Version updated.

17.2 Versions. Each version carries a Document Version identifier and an Effective Date. On written request to privacy@itogai.com we will provide the version in effect on a specified date.

17.3 Google API continuity. Any change affecting itogai’s compliance with the Google API Services User Data Policy, including the Limited Use requirements in Section 7, or affecting the Level 1 handling of restricted Google scopes, follows the material change procedure and is made available for review during any App Defense Alliance CASA re-verification.

17.4 The standing obligation. Every statement in this Policy is true on the day it publishes and stays true afterwards. When the product changes, this Policy changes with it, in the same release or before it. A policy that describes a product that no longer exists is not out of date. It is inaccurate, and itogai treats it as a defect of the same severity as a broken service.

18. How to contact us

For Write to
Privacy questions, data subject requests, rights requests, removal requests, appeals, Shine the Light, Nevada, and the LGPD encarregado privacy@itogai.com
Legal notices, sub-processor objections, security reports, questions about the security program and requests for the policies under a confidentiality agreement legal@itogai.com
Account issues, outages and data export requests support@itogai.com
Billing and pricing eligibility billing@itogai.com

Mail itogai sends you comes from no-reply@itogai.com for transactional messages and notifications@itogai.com for product notifications. An introduction email a user sends through itogai goes out from that user’s own email account, with one line, “Sent via itogai”, that links our notice for people in users’ networks; intros@itogai.com sends one only when the user’s own account can’t send it and the user chooses to send it from there. None of the three itogai addresses is monitored, and a reply to any of them does not reach a person. To reach a person about an introduction, write to support@itogai.com.

itogai will never ask you for a password, a payment card or a one-time code by email. Anything that does is not from itogai. Report it to legal@itogai.com.

Postal address: Itogai LLC Attn: Privacy 4821 Jumping Way Lake Worth, Florida 33467 United States of America

Changelog

Amended October 15, 2026, version PP-2026-10-15 v5.1. This is a material change: it adds the shared copy, and it takes effect for an Account existing on October 15, 2026 thirty (30) days after itogai’s notice.

  • New Section 3.3 states the professional information itogai completes from available public sources and from data providers, what a completed card can hold, that no location is ever kept, and that the information can be incomplete or out of date. Section 3 carries the sentence that says where that information comes from.
  • Section 2.6 lists the contact record fields as designed, with no location for any contact.
  • New Section 5.8a describes the shared copy of fields bought from data providers, of which itogai is the controller, what it never holds, whom it serves, and its deletion within thirty days once no account holds the person. Sections 2.6b, 2.9, 11.1 and 13.6 follow it, and a removal request now reaches every copy at once.
  • Section 4 states that email is read through each provider’s metadata-only permission, and that the text of a message sent from itogai is deleted once the provider confirms the send. Section 3 states that permission to send and to write calendar events is asked for only at first use.
  • Section 5.5 states that nothing pooled across customers trains the scoring model and that scoring adapts only inside one account. Section 7 lists what itogai receives from Google and why, and adds that nothing received from Google feeds a model beyond the features of the account it belongs to.
  • Section 8.4a describes network sharing as it works: one setting, off by default, and switching it off takes effect at once. Section 5.8 follows it.
  • Section 9.1 says which registers are incorporated (three) and that the sources page is informational, so Section 9.1 and Section 3.2 no longer differ. Section 9.2 widens the enrichment category to data providers.
  • Sections 5.9 and 18 describe introduction emails as they now go out: from the user’s own account with one “Sent via itogai” line, and from intros@itogai.com only when the user’s own account can’t send. Sections 5.1 and 6.2 state that a message a user sends goes out from their own account, with that one exception.
  • Section 2.8 states what the itogai companion reads: a page only on a site the person has consented to and only on the person’s click, and, from its toolbar, the address and title of the tab the person is on, which Section 3.1 counts as manual entry; it never reads a site’s cookies or a sign-in session.

What changed from PP v2.0, May 11, 2026, and why.

  • The two-architecture description was replaced by three explicit content levels, set per source and stated by category in Section 4. Email bodies are held at Level 1 permanently.
  • The sub-processor table left this Policy for the Sub-processors register, and this Policy now states the categories of recipient instead.
  • Section 11.4 says what actually happens on deletion: itogai deletes or irreversibly anonymizes, and says which happens when.
  • Section 12.6 adds breach notification to individuals where itogai is the controller. The prior version had none.
  • Retention periods are now stated for Usage, Device and Log Data, which the prior version left open.
  • Section 13.6 sets out a four-step procedure for a person who is not a customer, including a thirty-day suppression fallback where the customer does not answer.
  • Two disclosures were added that the prior version omitted: session replay, and the use of an email address as the analytics identifier.
  • Section 3.1 defines the five ways data enters an account, and Section 3.2 points to the informational page Supported sources and import methods in place of a contractual register, with the rule that free-text fields in a record system are not read carried into Section 3.2. Section 2.6 names the category, data you connect, upload, import or read on screen, and adds conversation metadata. Section 2.7 states that a conversation includes other people and may incidentally contain sensitive content, and how itogai treats it; Section 2.7a describes consent records. Section 4 describes the content signals setting. Section 6.5 states the one case in which consented content transits a model provider. Section 11.3a states the deletion of raw uploads and of derived records. Section 12.4 names the CASA level itogai holds as the App Defense Alliance now names it, Assurance Level 1, formerly Tier 2. Section 13.6 states that it is the removal path for anyone who appears in an imported or on-screen conversation.

Amended September 21, 2026, before first publication. Section 8.5 no longer restricts what an introduction fee may be based on, because the Bridger Terms now permit a fee that depends on a future event the two parties define. What itogai does with the payment, and the fact that itogai takes no share of the fee, are unchanged.

  • The age floor is eighteen (18), raised from sixteen. itogai applies eighteen wherever a lower figure would otherwise apply, because eighteen is the age of majority in most jurisdictions itogai serves.

Also amended September 21, 2026, before first publication.

  • The scope statement says this Policy describes the Subscription Service as designed, whether or not a capability is enabled for a given account.
  • Section 9.2 adds an eleventh category of recipient, mailbox and calendar aggregation providers, which the Sub-processors register already carried.
  • Section 8.4 states that a member can see and stop their own contribution to a Group.
  • Section 18 names the third send-only address, intros@itogai.com, matching the Legal Hub.
  • Section 2.8 follows the register’s column names, may request and requests.
  • Section 2.6 names every field a contact record may carry, and new Section 2.6c covers feedback between users.
  • New Section 6.4a states what changes when a user runs Akai on their own provider key.
  • New Sections 8.4a and 8.4b describe sharing a network with another user at business-card depth on both people’s agreement, and how a person on a path who is not your contact appears.
  • Section 9.2 adds integration platforms and a context service to the categories of recipient, and names the tools itogai uses to run its own business.

Also amended September 21, 2026, before first publication, on the security, privacy and AI governance layer.

  • New Section 2.9 maps every category of Personal Data to one of itogai’s eight internal data classes and states that no class holds anything this Policy does not disclose.
  • Section 5.8 states, as a commitment built into the product, that itogai never sells or shares the Personal Data of the people in a customer’s network and never combines one customer’s contact data with another’s. New Section 5.9 states the legitimate interest itogai relies on for its own limited processing about people who are not users, the written assessment behind it, the profiling transparency, the public notice page and the right to object.
  • New Sections 6.6 and 6.7 state that every generated text carries a marker saying so, and how itogai governs its AI features and the AI tools its own team uses.
  • New Section 10.1a, the Data Privacy Framework, written once: itogai intends to self-certify, makes no claim of participation until listed, and the Section becomes operative on the listing date with no further change. New Section 10.3 states the Colombia, Mexico, Peru and Chile positions, and Section 10.4 discloses that itogai’s contractors access production systems from the United States and Colombia.
  • Section 12.6 adds the Florida clock (individuals within thirty days; the Department of Legal Affairs at five hundred or more Floridians) and the ten-day outer limit for notifying a customer. New Section 12.9 points to the security page and the one table of what itogai holds.
  • Section 13.4 is rewritten to activate. It states that the CCPA does not apply to itogai today, names the thresholds, and becomes operative on the day one is crossed without any other change; Section 16.3 follows it.
  • Section 13.6 points to the new page Notice to people in our users’ networks and states the suppression record kept after a removal.
  • Section 16.1 rewrites the Article 27 position: itogai’s processing is subject to Article 3(2) on both limbs, representatives in the EU and the UK are being put in place and will be named from the day each appointment takes effect, and the Article 27(2)(a) ground relied on until then is recorded.
  • Section 16.6 names the Latin American laws with their authorities (Colombia, Mexico under the 2025 law, Peru with the representative line, Chile with the December 1, 2026 date, Argentina), and new Section 16.7 states where itogai is and that it creates no entity anywhere to satisfy a privacy law.

A copy of the prior version is available on written request to legal@itogai.com.

Document version: PP-2026-10-15 v5.1. Published at itogai.app/legal/privacy-policy.

© 2026 Itogai LLC. All rights reserved. itogai, the itogai logo, Trustbound, TrustGraph, TrustRings, TrustReach, and Akai are trademarks of Itogai LLC.

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