Adjutant — Privacy Policy

DRAFT for review. Prepared to satisfy A2P/10DLC, GDPR/CCPA, and general privacy requirements. Confirm entity + contact and have counsel review. Placeholders in [brackets].

1. Who we are

[MoreGain Capital, LLC] operates Adjutant, a managed AI assistant. Contact: [[email protected]].

2. Information we collect

Account & billing: name, email, phone, company, payment info (via our processor — we do not store full card numbers).
Call data: audio recordings, transcripts, phone numbers, timestamps, and derived action items and decisions.
Connected accounts: data from email, calendar, CRM, and other tools you authorize, limited to granted scopes.
Usage & device: logs, metrics, and diagnostics.

3. How we use it

To provide the Service (answer/route/transcribe calls, build your memory and decision tree, run integrations, bill you), to secure and improve the Service, to support you, and to comply with law. We do not sell your personal information. We do not use your private content to train third parties' foundation models.

4. Sub-processors

Provider	Purpose
LiveKit	Telephony / call transport
OpenAI / Google (Gemini)	Real-time voice & language models
Anthropic (Claude)	Decision/reasoning engine
Composio	Managed OAuth / integrations
Stripe	Payments
Qdrant / [cloud host]	Memory vector store / infrastructure

SMS/A2P: mobile opt-in data and consent are not shared with third parties or affiliates for marketing purposes. Message content is used only to deliver the Service.

5. Retention

Call audio recordings: auto-deleted 90 days after the call by default (customer-configurable).
Transcripts & derived facts/decisions: retained to power memory and the decision tree (default ~24 months, customer-extendable).
Legal hold: deletion is suspended for data subject to a legal hold.
Account data: retained while your account is active and for a reasonable period after, then deleted.

6. Your rights & controls

You can access, export, correct, or delete your data from your account, or by contacting us. Depending on your location (e.g., GDPR/CCPA), you may have additional rights; we honor verified requests. You may revoke any connected-account access at any time. A kill-switch/export is provided so you are never locked in.

7. Security

Per-customer data isolation (row-level security), encryption in transit and at rest, per-tenant encrypted credentials, access controls, audit logging, and monitoring. No system is perfectly secure.

8. Children

The Service is for business use by adults and is not directed to children under 16.

9. Changes & contact

We will post updates here with a new "last updated" date. Questions: [[email protected]].

🪖 Adjutant · draft compliance bundle · not yet legal-reviewed