1.Data Controller
Agento Nexus is an AI Venture Operating System operated by Habitusnet Consulting AG, a company incorporated under Swiss law.
Data Controller
Habitusnet Consulting AG
Operating as Agento Nexus
Löwenstrasse 42
CH-8001 Zürich, Switzerland
Commercial Register: Canton of Zürich
Data Protection Contact: [email protected]
This policy explains how we collect, use, store, and protect your personal data when you use our platform at agento.nexus and related services. It applies to all users regardless of location.
2.Google User Data
Agento Nexus uses Google OAuth 2.0 for authentication. This section specifically describes how we handle data received from Google APIs, in compliance with the Google API Services User Data Policy and the Google APIs Terms of Service.
Google API Services Limited Use Disclosure
Agento Nexus's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
| Google Requirement | Covered In |
|---|---|
| Data Accessed | Section 2.1 below |
| Data Usage | Section 2.2 below |
| Data Sharing | Section 2.3 below |
| Data Storage & Protection | Section 2.4 below |
| Data Retention & Deletion | Section 2.5 below |
2.1Data Accessed from Google
When you sign in with Google, we request access to the following scopes only:
- email — Your Google account email address.
- profile — Your name and profile picture.
We do not request access to Gmail, Google Drive, Google Calendar, Google Contacts, YouTube, Google Ads, or any other Google service. We only access the minimum data required for authentication.
2.2How We Use Google User Data
The Google user data we receive is used exclusively for the following purposes:
- Authentication — Your email address is used to create and authenticate your Agento Nexus account. It serves as your unique identifier on the platform.
- Account personalization — Your name and profile photo are displayed in the application interface (e.g., sidebar, navigation) to personalize your experience.
- Notifications — Your email address may be used to send you platform notifications such as executive decision summaries, account security alerts, and service updates. You can manage notification preferences in your account settings.
We do NOT use Google user data to:
- Train artificial intelligence or machine learning models
- Serve or target advertisements
- Build user profiles for sale to third parties
- Enrich data for purposes unrelated to the Agento Nexus service
2.3How Google User Data Is Shared
We do not sell, rent, or trade Google user data with any third party. Google user data is shared only in the following limited circumstances:
- Infrastructure providers — Your email and name are stored in our database hosted on Neon (PostgreSQL, Frankfurt, EU) and the application runs on Google Cloud (Zurich, CH). These providers process data on our behalf under data processing agreements.
- Email delivery — If we send you email notifications, your email address is shared with our email delivery provider (Postmark) solely for the purpose of delivering those emails.
- Legal requirements — We may disclose Google user data if required by Swiss or applicable law, or in response to valid legal process.
Google user data is never shared with LLM/AI providers. Your email and name are not included in any prompts sent to language model providers.
2.4How Google User Data Is Stored and Protected
- Storage location — Google user data (email, name, profile photo URL) is stored in our PostgreSQL database hosted by Neon in Frankfurt, Germany (EU).
- Encryption at rest — All data is encrypted at rest using AES-256 encryption provided by the database provider.
- Encryption in transit — All data transfers use TLS 1.3 encryption.
- Access controls — Google user data is protected by Row-Level Security (RLS) policies in the database, ensuring strict tenant isolation. Role-based access control (RBAC) limits which application functions can access user data.
- Session security — Authentication sessions use signed JWT tokens (httpOnly, Secure, SameSite cookies). Session tokens do not contain your Google credentials or access tokens.
We do not store your Google OAuth access token or refresh token. Authentication is session-based — once your identity is verified, the Google token is discarded.
2.5Google User Data Retention and Deletion
- Active accounts — Your Google user data (email, name, profile photo) is retained for the duration of your active account.
- Account deletion — When you delete your account or request data deletion, all Google user data is permanently removed from our database within 90 days. Audit logs containing your user ID (but not your email or name) may be retained for up to 7 years as required by Swiss commercial law (Art. 958f CO).
- Requesting deletion — You can request deletion of all your data, including Google user data, at any time by emailing [email protected]. We will process your request within 30 days.
- Revoking access — You can revoke Agento Nexus's access to your Google account at any time via your Google Account permissions page. After revoking access, you will no longer be able to sign in with Google, but your existing account data will be retained until you request deletion.
3.Data We Collect
We collect the minimum data necessary to provide our service. Here is what we collect and why:
3.1Account Data
- Email address — provided via Google OAuth during sign-in. Used to create your account, authenticate sessions, and send executive notifications.
- Name and profile photo — provided via Google OAuth. Used to personalize your dashboard.
We only request basic profile information from Google. We never access your Gmail, Google Drive, Google Calendar, or any other Google services beyond authentication.
3.2Company Data
- Company name and website URL — provided by you during onboarding.
- Business intelligence — generated by crawling your publicly accessible website (OSINT) to provide your executive team with context about your business.
3.3Usage and Interaction Data
- Decisions and initiatives — decision requests, deliberation outcomes, consensus records, and venture data you create on the platform.
- Executive interaction data — how your AI executives collaborate, including relationship learning metrics and team performance data.
- Content artifacts — documents, plans, and other content generated by your executive team.
3.4Technical Data
- IP address, browser type, device information, and access timestamps — collected automatically for security, performance monitoring, and abuse prevention.
3.5Payment Data
Payment processing is handled by Stripe. We do not store credit card numbers or full payment credentials on our servers. Stripe processes your payment data in accordance with PCI DSS Level 1 standards. We retain only a reference to your Stripe customer ID and subscription status.
4.How We Use Your Data
- To provide the AI Venture Operating System — powering executive deliberation, consensus building, initiative tracking, and venture management.
- To process executive deliberations via LLM providers — your decision queries and business context are sent to third-party AI providers to generate executive analysis and recommendations (see Section 4).
- To generate business intelligence — crawling your publicly accessible website to give your executive team relevant business context.
- To send notifications — via email and other configured channels (e.g., Telegram) about executive recommendations, decision outcomes, and account updates.
- To improve the platform — using anonymized, aggregated usage patterns to improve features and performance.
- To comply with legal obligations — including Swiss commercial law record-keeping requirements.
What we do NOT do:
- We do not sell your personal data to third parties.
- We do not use your data for advertising purposes.
- We do not share your data with data brokers.
- We do not use your business data to train our own AI models.
5.LLM Provider Data Processing (Supply Chain Transparency)
To power AI executive deliberation, your queries and business context are sent to third-party Large Language Model (LLM) providers for processing. We are transparent about this supply chain:
5.1LLM Providers
- Google (Gemini) — executive analysis and deliberation
- Groq — high-speed inference for real-time executive responses
- Inception Labs (Mercury) — specialized reasoning tasks
We do not permit LLM providers to train on your data. Data processing agreements are in place with each provider that prohibit use of your data for model training or improvement.
5.2Sub-processors
| Provider | Purpose | Location |
|---|---|---|
| Google Cloud | Application hosting | Zurich, CH (europe-west6) |
| Neon | Database (PostgreSQL) | Frankfurt, DE (EU) |
| Cloudflare | CDN, DNS, email routing, browser rendering | Global edge (origin in EU) |
| Stripe | Payment processing | EU/US |
| Postmark | Transactional email delivery | US |
| E2B | Sandbox code execution | EU |
| Google (Gemini) | LLM inference | Global |
| Groq | LLM inference | US |
| Inception Labs | LLM inference | US |
5.3Bring Your Own Key (BYOK)
If you use the BYOK feature, your API keys are encrypted using AES-256-GCM with PBKDF2-derived keys before storage and are never logged or exposed in plaintext. When BYOK is enabled, queries are sent directly to the provider using your key, and billing occurs on your own provider account.
6.Data Residency
We prioritize keeping your data in Europe. Here is where your data is stored and processed:
- Primary database — Neon PostgreSQL, Frankfurt, Germany (EU)
- Application hosting — Google Cloud Run, Zurich, Switzerland (europe-west6)
- CDN and DNS — Cloudflare global edge network (origin servers in EU)
- LLM processing — varies by provider. Google: global infrastructure. Groq: US. Inception Labs: US.
For LLM processing that occurs outside the EU/Switzerland, we rely on Standard Contractual Clauses (SCCs) and provider data processing agreements to ensure adequate data protection.
Enterprise customers can request dedicated data residency configurations, including EU-only LLM processing where available.
7.Data Retention
| Data Type | Retention Period | Basis |
|---|---|---|
| Account data | Active account + 90 days after deletion | Reactivation and data export window |
| Decisions, ventures, interactions | Active account + 90-day grace period | Contractual performance |
| Audit logs | 7 years | Swiss Code of Obligations, Art. 958f |
| Technical logs | 90 days | Security and debugging |
You can request a full data export (GDPR Article 20, data portability) or deletion (GDPR Article 17, right to erasure) at any time by contacting [email protected].
8.Your Rights
We respect your data rights regardless of where you are located. Below are your rights under applicable regulations:
8.1Under the EU General Data Protection Regulation (GDPR)
If you are located in the European Economic Area (EEA), you have the following rights:
- Right of access (Art. 15) — request a copy of the personal data we hold about you.
- Right to rectification (Art. 16) — request correction of inaccurate personal data.
- Right to erasure (Art. 17) — request deletion of your personal data, subject to legal retention obligations.
- Right to data portability (Art. 20) — receive your data in a structured, machine-readable format.
- Right to restrict processing (Art. 18) — request that we limit how we use your data.
- Right to object (Art. 21) — object to the processing of your personal data for certain purposes.
- Right to lodge a complaint — with your local data protection supervisory authority.
8.2Under the Swiss Federal Act on Data Protection (nDSG/FADP)
As a Swiss company, we comply with the revised Swiss Federal Act on Data Protection (nDSG), effective September 1, 2023. Swiss residents have equivalent rights including:
- Right to information about data processing (Art. 25 nDSG)
- Right to data portability (Art. 28 nDSG)
- Right to object to automated individual decisions (Art. 21 nDSG)
The competent supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, CH-3003 Bern.
8.3Other Jurisdictions
Regardless of your country of residence, we honor data subject requests for access, correction, deletion, and portability. Contact [email protected] and we will respond within 30 days.
9.Compliance Tiers
Data protection measures scale with your subscription:
| Feature | Free / Starter | Professional | Enterprise |
|---|---|---|---|
| Data protection | Standard | Enhanced | Custom |
| Infrastructure | Shared | Shared | Dedicated option |
| Audit logging | Basic | Enhanced | Full audit trail |
| Data export | On request | Self-service | API + scheduled |
| Data residency | EU default | EU default | Custom regions |
| SSO/SAML | — | — | Available |
| Security audits | Regular internal | Regular internal | Third-party on request |
| Compliance certs | — | — | On request |
10.Security Measures
We implement comprehensive security measures to protect your data:
- Encryption at rest — AES-256 encryption for all stored data.
- Encryption in transit — TLS 1.3 for all network communications.
- Row-level security — PostgreSQL RLS policies enforce strict tenant data isolation. Your organization's data is never accessible to other tenants.
- API key encryption — BYOK vault with AES-256-GCM and PBKDF2-derived keys.
- Access controls — Role-based access control (RBAC) with 4 roles and 23 granular permissions.
- Security reviews — Regular internal security reviews and penetration testing.
- Audit logging — All administrative actions and data access events are logged for accountability.
No system is completely secure. While we implement industry-leading measures, we cannot guarantee absolute security. We will notify affected users promptly in the event of a data breach, in accordance with GDPR Article 33/34 and Swiss FADP requirements.
12.Legal Basis for Processing
We process your personal data on the following legal bases under GDPR Article 6:
- Performance of a contract (Art. 6(1)(b)) — processing necessary to provide the Agento Nexus service under your subscription agreement.
- Legitimate interests (Art. 6(1)(f)) — security monitoring, fraud prevention, and platform improvement using anonymized data.
- Legal obligation (Art. 6(1)(c)) — compliance with Swiss commercial law record-keeping and tax obligations.
- Consent (Art. 6(1)(a)) — where applicable, for optional features such as marketing communications (you can withdraw consent at any time).
13.International Data Transfers
While our primary infrastructure is in the EU and Switzerland, some data processing occurs in the United States (LLM providers, email delivery). For these transfers, we rely on:
- EU Standard Contractual Clauses (SCCs) approved by the European Commission.
- Swiss-specific data transfer mechanisms as recognized by the FDPIC.
- Provider-specific data processing agreements with adequate safeguards.
The European Commission has recognized Switzerland as providing an adequate level of data protection. Transfers between EU member states and Switzerland do not require additional safeguards.
14.Children's Privacy
Agento Nexus is a business platform designed for professional use. It is not intended for children under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child under 16, we will delete that data promptly.
15.Changes to This Policy
We may update this privacy policy from time to time. For material changes, we will notify you via email at least 30 days before the changes take effect. Non-material changes (such as clarifications or formatting updates) may be made without notice. The "Last updated" date at the top of this page always reflects the most recent version.
Continued use of the platform after the effective date of changes constitutes acceptance of the updated policy.
16.Contact
For questions about this privacy policy, to exercise your data rights, or to report a privacy concern:
Habitusnet Consulting AG
Operating as Agento Nexus
Löwenstrasse 42
CH-8001 Zürich, Switzerland
Privacy inquiries: [email protected]
General support: [email protected]
We aim to respond to all privacy-related inquiries within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority or the Swiss Federal Data Protection and Information Commissioner (FDPIC).