Privacy Policy

1. Our Commitment to Your Privacy

Agion ("we," "us," "our") is committed to protecting your privacy and handling your personal data in an open and transparent manner. This Privacy Policy explains how we collect, use, process, and safeguard your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable laws.

This policy covers website visitors, customers, job applicants, and any other individuals whose personal data we process.

2. The Data Controller

Agion Oy is the Data Controller responsible for the personal data described in this policy. This means we decide what data is collected and why. We are responsible for:

Data you provide when you visit our website (e.g., through contact forms, cookies).
Data related to the management of our customer accounts (e.g., billing and contact information).
Data collected for marketing and sales purposes.

Contact Details of the Data Controller

Company:: Agion Oy
Address:: Nummikatu 18-20, 90100 Oulu, Finland
Privacy email:: [email protected]

When you use our AI agent platform to process data you own, you are the Data Controller, and Agion acts as the Data Processor on your behalf. Our respective roles and responsibilities for this processing are governed by a Data Processing Agreement (DPA), available upon request at [email protected].

3. What Personal Data We Collect and Why

We process different categories of personal data for specific purposes, and we only do so when we have a lawful basis.

Account & Billing Data

Examples: Name, business email, phone number, billing address, payment details.
Purpose: To create and manage your account, provide our services, process payments, and communicate with you about your subscription.
Lawful basis: Performance of a contract (Art. 6(1)(b))

Platform Operational Data

Examples: System logs, IP addresses, usage metadata.
Purpose: To secure the platform, monitor performance, prevent fraudulent activity, and provide customer support.
Lawful basis: Legitimate interest (Art. 6(1)(f)) to ensure the security and stability of our service.

Website & Marketing Data

Examples: Name, email, company name (from contact forms), cookie data, IP address.
Purpose: To respond to your inquiries, provide you with marketing communications (with your consent), and analyze website traffic to improve our site.
Lawful basis: Consent (Art. 6(1)(a)) for marketing communications and analytics; legitimate interest (Art. 6(1)(f)) for responding to direct inquiries.

Customer Content Data

Examples: Any personal data contained within the missions, workflows, tools, or other content you upload to our platform.
Purpose: To perform the services you have requested as part of your contract. We only process this data based on your documented instructions.
Lawful basis: As a Data Processor, we process this on your behalf. Your lawful basis as the Controller applies.

Data Category	Examples	Purpose	Lawful Basis
Account & Billing	Name, business email, phone number, billing address, payment details.	To create and manage your account, provide our services, process payments, and communicate with you.	Performance of a contract (Art. 6(1)(b))
Platform Operational	System logs, IP addresses, usage metadata.	To secure the platform, monitor performance, prevent fraudulent activity, and provide support.	Legitimate interest (Art. 6(1)(f))
Website & Marketing	Name, email, company name, cookie data, IP address.	To respond to inquiries, provide marketing communications, and analyze website traffic.	Consent (Art. 6(1)(a)) for marketing and analytics; legitimate interest (Art. 6(1)(f)) for responding to direct inquiries.
Customer Content	Personal data in missions, workflows, tools, or content you upload.	To perform the services you have requested. We only process based on your documented instructions.	Data Processor on your behalf

4. Job Applicants and Recruitment

When you apply for a position at Agion, we process the personal data you provide in your application, such as name, contact details, CV, and any other information you choose to include, together with interview notes and assessments produced during the process. We use this data to assess your application and take steps prior to entering into an employment contract (Art. 6(1)(b)) and to manage and document the recruitment process (legitimate interest, Art. 6(1)(f)). We collect data primarily from you; references or information from other sources are collected only with your consent. Please do not include special categories of personal data in your application. We may use AI-assisted tools to support the review of applications.

If you are not selected, we retain your application data for eighteen (18) months from the end of the recruitment process, based on our legitimate interest in defending against legal claims, after which it is securely deleted. With your consent, we may retain your data longer to contact you about future openings. Application data is accessible only to those involved in the recruitment decision; if you apply through a third-party platform such as LinkedIn, that platform's own privacy policy also applies. The rights described in this policy apply equally to job applicants.

5. Data Sharing and Third Parties

Agion does not sell your personal data.

We use a limited number of third-party service providers to help us operate our website and deliver our services. We have Data Processing Agreements (DPAs) in place with these providers, as required under GDPR Article 28.

Website services

Google Analytics 4 / GA4 (Google Ireland Ltd, deployed via Google Tag Manager) — We use Google Analytics 4 to measure aggregate website traffic (pages visited, session duration, referral source). Google processes IP addresses and usage data to produce anonymised analytics reports; no personal profiles of individual visitors are created. GTM is the container that deploys the GA4 script; GTM itself does not independently process personal data. Data is processed under Google's Data Processing Amendment (GDPR-compliant). Legal basis: consent.
Leadfeeder / Dealfront (Dealfront Group GmbH) — We use Leadfeeder to identify which companies (not individuals) visit our website, based on IP address lookup against public company databases. Leadfeeder does not identify natural persons. The data processed is your company's IP address and pages visited. This service is only loaded if you accept analytics cookies. Legal basis: consent. Dealfront is headquartered in Germany (EEA); data does not leave the EEA.

Platform sub-processors

For customers using the Agion platform, we use sub-processors including cloud infrastructure providers and payment processors. A full sub-processor list is available upon request at [email protected]. We will notify customers at least 30 days before making any changes to our sub-processor list.

Cookies

We use a small number of cookies and similar technologies on this website. You can manage your preferences via the cookie banner. The cookies we use:

cc_cookie (first-party) — Set by the cookie consent banner to remember your cookie preferences. Strictly necessary. Expires after 6 months.
_ga, _ga_* (Google Analytics 4, via GTM) — Set only if you accept analytics cookies. Used to measure website traffic in aggregate. Both expire after 2 years; the session ID cookie is refreshed on each visit.
Leadfeeder / Dealfront cookies — Set only if you accept analytics cookies. Used to attribute company-level website visits. Session and persistent cookies; typical retention 30 days.

Strictly necessary cookies (consent record) are set regardless of your preference. All analytics and tracking cookies are loaded only after you grant consent.

6. International Data Transfers

The Agion control plane is hosted in Finland. The data plane, which runs your agents, can be installed on your own infrastructure in the cloud and region you choose. Where personal data is transferred outside of the European Economic Area (EEA), we ensure it is protected through an adequacy decision, such as the EU-US Data Privacy Framework for certified recipients, or through EU Standard Contractual Clauses (SCCs).

7. Data Security

We take the security of your data seriously and have implemented appropriate technical and organizational measures to protect it. These include:

Encryption: Data is encrypted both in transit (using TLS) and at rest.
Access Controls: We enforce strict role-based access controls to limit access to personal data to authorized personnel only.
Audit logs: Governed actions on the platform are recorded in an audit trail that customers can review and export.

8. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected.

Customer Account Data: Retained for the duration of your subscription and for a subsequent period as required by law (e.g., for tax and accounting purposes).
Website & Marketing Data: Email addresses and contact details collected via website forms (including waitlist and demo sign-ups) are retained until you withdraw consent or request erasure. We review marketing contacts at least annually and delete those who have not opened an email or visited our website in the preceding 12 months.
Operational Data: System logs are typically retained for a rolling period of 90 days, unless a longer period is required for security investigations.
Customer Content Data: Content you process on the platform, including the audit trail of governed actions in your missions, is processed on your behalf under our data processing agreement and retained for the duration of your subscription term. When your contract ends, we delete or return it as set out in your agreement.

9. Your Rights as a Data Subject

Under GDPR, you have the following rights regarding your personal data:

Right to Access: You can request a copy of the personal data we hold about you.
Right to Rectification: You can request that we correct any inaccurate or incomplete data.
Right to Erasure: You can request that we delete your personal data.
Right to Restrict Processing: You can request that we limit the processing of your data.
Right to Data Portability: You can request to receive your data in a machine-readable format.
Right to Object: You can object to us processing your data for our legitimate interests.
Right to Withdraw Consent: Where we process your data based on consent, you can withdraw that consent at any time — including via the cookie banner on this website for analytics cookies. Withdrawal does not affect the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us at [email protected]. We will respond within one month of receiving your request.

You also have the right to lodge a complaint with a supervisory authority in your country of residence if you believe we have not processed your personal data in accordance with GDPR.

10. Breach Notification

In the event of a personal data breach, Agion will notify the relevant supervisory authority — the Finnish Data Protection Ombudsman (tietosuoja.fi), or the authority in your country of residence — without undue delay and, where feasible, within 72 hours of becoming aware of the breach, as required by Article 33 GDPR. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay.

For customers using the Agion platform: where a breach involves personal data you control, we will notify you as the Data Controller without undue delay so that you can fulfil your own regulatory notification obligations.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this policy indicates when it was last revised. We encourage you to review this policy periodically.