Trust

What is true,
with dates.

Customer data is not sold, not shared, and not used to train models. We train and fine-tune nothing on it, and since 11 Oct 2026 every model call is limited to providers that do not train on prompts. Everything on this page comes from one file, and so do the versions your assistant reads: /trust.json and /trust.md.

The short answers

Training
Customer data is not sold, not shared, and not used to train models. We train and fine-tune nothing on it, and since 11 Oct 2026 every model call is limited to providers that do not train on prompts.
Where it is stored
Stored in Frankfurt, Germany (Neon Postgres on AWS eu-central-1), since 11 Oct 2026. Before that day it was in the US (AWS us-east-1).
Where it is processed
Processed in Frankfurt, Germany (Vercel functions, region fra1), since 11 Oct 2026; before that day in Washington, D.C. Five things happen outside Frankfurt: page delivery and the sign-in check (Vercel's network, nearest the reader), accounts (Clerk, US), payments (Stripe, worldwide), the mails we send you (Resend, US), and model calls for the built-in assistant (place not established).
Who signs
The agreement is between Pirate Skills GmbH, represented by Ben Sufiani, and the company a workspace admin names when accepting. Only a signed-in admin can accept. An assistant cannot.
When you leave
When you end the contract, export first if you want a copy; a download works even after a subscription ends. A workspace is deleted when its admin asks us, within 30 days of the request, with everything in it. Invoices are kept for as long as German tax law requires.
When a sub-provider changes
Every change to the list below is dated in the change log. A new sub-provider is announced 30 days before it starts, by mail to the address your workspace names.

As of 14 Oct 2026 · version 2026-10-14.1

Who runs it

Company
Pirate Skills GmbH, Im Mediapark 5, 50670 Cologne, Germany
Register
Amtsgericht Köln HRB 106817 · VAT ID DE278873758 · represented by Ben Sufiani
People
One person, Ben Sufiani, runs Customer Magic and is the only one with access to production data.

Sub-providers

9

Every company that handles data for us, checked against its own pages on 14 Oct 2026. Where we could not verify something it says so.

  • Neon

    Your workspace data · since 15 Jul 2026

    The database.

    Which data
    Everything in your workspace: deals, contacts, notes, history, incoming findings, settings.
    Where
    Frankfurt, Germany (AWS eu-central-1). Whether Neon's own logs and control systems stay in that region is not established.
    Company
    Databricks, Inc., US (parent of Neon, LLC)
    Transfer basis
    EU standard contractual clauses (modules 2 and 3); EU–US Data Privacy Framework by the provider's own statement; the official list could not be read on 11 Oct 2026.
    Our agreement with them
    Applies automatically with Neon's terms.
  • Vercel

    Your workspace data · since 1 Jul 2026

    Runs the application and delivers its pages.

    Which data
    Every request and response passes through it, with your IP address and browser details. It keeps server logs.
    Where
    Server code runs in Frankfurt (fra1). Pages, the sign-in check on each request and cached files are served from the network location nearest the reader, worldwide. If Frankfurt fails, Vercel reroutes to the next closest region. Where logs are kept is not established.
    Company
    Vercel Inc., US
    Transfer basis
    EU standard contractual clauses (modules 1, 2 and 3); EU–US Data Privacy Framework by the provider's own statement; the official list could not be read on 11 Oct 2026.
    Our agreement with them
    Applies automatically with Vercel's terms.
  • Model providers behind Vercel's AI gateway

    Your workspace data · since 1 Jul 2026

    Answers for the assistant built into the app: the daily brief, drafts and chat. Your own connected assistant is not part of this; that is your tool and your provider.

    Which data
    The deals, notes and workspace profile the built-in assistant is asked about, for that one call.
    Where
    The gateway picks one of the three per call. The place is not established.
    Company
    Anthropic, Amazon Web Services (Bedrock) or Google Cloud (Vertex), as sub-providers of Vercel
    Transfer basis
    Covered by Vercel's agreement and its agreements with each provider.
    Our agreement with them
    Covered by Vercel. Every call asks the gateway to use only providers that do not train on prompts (since 11 Oct 2026). Vercel keeps no prompts or answers. Zero retention at the model provider is not requested; Anthropic states it deletes within 30 days.
  • Clerk

    Accounts and billing · since 22 Jul 2026

    Sign-up, sign-in, workspaces and members, API keys.

    Which data
    Your team's names, email addresses, sign-in sessions, and which workspace each person belongs to. No deals or contacts.
    Where
    United States. Clerk offers no EU option.
    Company
    Clerk, Inc., US
    Transfer basis
    EU–US Data Privacy Framework by the provider's own statement; the official list could not be read on 11 Oct 2026; EU standard contractual clauses as the fallback.
    Our agreement with them
    Applies automatically with Clerk's terms.
  • Stripe

    Accounts and billing · since 5 Aug 2026

    Payments and invoices.

    Which data
    Your company's name, billing address, VAT ID, the paying admin's email, and payment details. We never see a card number. Nothing during the trial: no Stripe customer exists until you pay.
    Where
    Worldwide, including the United States.
    Company
    Stripe Payments Europe, Limited
    Transfer basis
    EU–US Data Privacy Framework by the provider's own statement; the official list could not be read on 11 Oct 2026; EU standard contractual clauses as the fallback.
    Our agreement with them
    Applies automatically with Stripe's terms. Stripe also uses payment data on its own responsibility to prevent fraud.
  • Resend

    Your workspace data · since 26 Aug 2026

    Sends our mails to your team: the morning mail, the Monday summary, trial and account notices.

    Which data
    The recipient's email address and name, and the mail itself — which names the deals and next steps that are due.
    Where
    United States.
    Company
    Plus Five Five, Inc., US
    Transfer basis
    EU standard contractual clauses (modules 1, 2 and 3); EU–US Data Privacy Framework by the provider's own statement; the official list could not be read on 11 Oct 2026.
    Our agreement with them
    Applies automatically with Resend's terms.
  • PostHog (EU cloud)

    Usage measurement · since 2 Sept 2026

    Shows us how the product is used.

    Which data
    Which screens and buttons a signed-in person uses, with their user and workspace id, and their device. No deal or contact content.
    Where
    Frankfurt, Germany.
    Company
    PostHog, Inc., US
    Transfer basis
    EU standard contractual clauses; EU–US Data Privacy Framework by the provider's own statement; the official list could not be read on 11 Oct 2026.
    Our agreement with them
    PostHog's agreement has to be signed separately. Whether ours is signed is not established.
  • Meta pixel

    Usage measurement · since 2 Sept 2026

    Tells us which advertisement a sign-up came from.

    Which data
    Page visits and sign-up events from your browser, only after you agree to marketing cookies. No workspace content.
    Where
    not established
    Company
    not established
    Transfer basis
    not established
    Our agreement with them
    not established
  • iubenda

    Usage measurement · since 2 Sept 2026

    The cookie choice and the hosted privacy policy.

    Which data
    Your cookie choice and the IP address it was made from.
    Where
    not established
    Company
    not established
    Transfer basis
    not established
    Our agreement with them
    not established

How long things are kept

  • Deals, contacts, notes and history on the board

    Until you delete them or the workspace is deleted.

    Your control: Edit or remove on the board; export any time.

  • A closed finding in the incoming review (name, address, company, what happened, and the background assistant's reason, which can say what it found on public web pages)

    The person's details are removed 7 days after it is closed. Only a fingerprint, the category and the outcome stay.

    Your control: Your admin sets 0 to 30 days in Settings → Trust.

  • A finding nobody decided

    Closed and emptied after 30 days.

    Your control: Fixed.

  • One person in the incoming review

    Removed at once, whole rows, when asked.

    Your control: The assistant tool `erase_person`.

  • Links in mails we send (Done, Push a week, Unsubscribe)

    Only a hash is stored. Action links expire after 7 days, unsubscribe links after a year; expired ones are deleted hourly.

    Your control: None needed.

  • The record of admin actions (who, what, when)

    Until the workspace is deleted.

    Your control: None.

  • Database backups at Neon

    How long a deleted row stays restorable from Neon's history is not established.

    Your control: None.

  • Invoices and what they are based on

    For as long as German tax law requires. Held at Stripe.

    Your control: None.

Protection

  • Every row belongs to one workspace, and every query is limited to it in the shared code path, not by a filter per screen. This is what our tests check hardest.
  • Sign-in is handled by Clerk. We hold no passwords.
  • An assistant connects by a consent screen in your browser, or with a workspace API key that reads only unless an admin grants more.
  • Connections are encrypted in transit (TLS). The database is encrypted at rest by Neon.
  • Every route that touches your data checks who is asking and is rate-limited. Tests read the source to hold that.
  • Admin actions are written down with who and when.
  • Secrets live in the hosting environment, never in the code.
  • Internal errors are logged and never returned to a caller.
  • No assistant and no background worker contacts anyone or has the final word on an incoming finding. A signed-in person does.

If something goes wrong

How fast
Without undue delay, and no later than 72 hours after we learn that your data was affected.
How
By mail to your workspace's notice address; if none is set, to every admin of the workspace.
What it says
What happened, which data, what we have done and what you should do. We send what we know and follow up.

Not offered

9
SOC 2 report
Not held.
ISO 27001 certificate
Not held.
Filled-in security questionnaires as a standing service
Not offered. Write to us and one person answers.
A negotiated or customer-paper agreement
Not offered. One agreement for every customer.
Audit or penetration-test reports
None exist.
Choosing a storage region per workspace
Not offered. Everyone is in Frankfurt.
Deleting a workspace yourself
We have no delete button of our own. On request, within 30 days.
Withdrawing an assistant's access yourself
Not built for browser-consent connections; API keys can be revoked in Settings. Write to us.
A named data protection officer
None appointed.

Change log

4
  • 14 Oct 2026The background assistant in the incoming review now looks up, on public web pages, people it cannot place who came more than once, and writes what it found as a guess in its reason. Your own assistant does the lookup; we receive only the reason, which is emptied with the person's details. Write "no web lookups" in the never-list to switch it off.
  • 11 Oct 2026This page, its change log and the draft data-processing agreement were published. Model calls now ask the gateway to use only providers that do not train on prompts.
  • 11 Oct 2026The application's server code moved from Washington, D.C. (iad1) to Frankfurt (fra1), next to the database.
  • 11 Oct 2026The database moved from the US (AWS us-east-1) to Frankfurt (AWS eu-central-1). Until that day the security page said "EU" while the data was in the US.

Data-processing agreement dpa-2026-10-11-draft

DRAFT — not in force. This text has not been reviewed by a lawyer and cannot be accepted yet. It is published so you can read what we intend to agree to.

Read itMarkdownSettings → Trust