Privacy Policy

1. Data Controller

The data controller responsible for your personal data is:

Piotr Ciechowicz
Schmohlstr. 2
13086 Berlin, Germany
Email: privacy@murmurd.com

2. Data We Collect

2.1 Account Data

When you register, we collect:

• Name and email address
• Password (encrypted)
• Profile picture (optional)
• Timezone preference
• Slack user ID (if connected)

2.2 Organization Data

For organization accounts:

• Organization name
• Division and team structures
• Member roles and relationships
• Billing information

2.3 Usage Data

When you use Murmurd:

• Check-in responses
• Escalation reports
• Priority records
• Interaction timestamps

2.4 Technical Data

Automatically collected:

• IP address
• Browser type and version
• Device information
• Access logs

3. Legal Basis for Processing

We process your data under the following legal bases (Article 6 GDPR):

Data Type	Legal Basis
Account data	Contract performance
Usage data	Contract performance
AI processing	Legitimate interest
Marketing	Consent
Analytics	Legitimate interest

4. How We Use Your Data

We use your data to:

• Provide and maintain the Service
• Send check-in prompts and reminders
• Generate AI-powered summaries
• Route escalations to appropriate team members
• Process payments
• Send transactional communications
• Improve our Service
• Comply with legal obligations

5. AI Processing

5.1 AI Summaries

Your check-in responses may be processed by AI to generate weekly summaries. This processing:

• Uses only data within your organization
• Excludes items marked as confidential
• Is performed by third-party AI providers
• Does not train AI models on your data

5.2 AI Provider Options

You can choose from multiple AI providers:

• OpenAI (US-based)
• Anthropic (US-based)
• Your own API key (Bring Your Own Key)

6. Data Sharing

6.1 Within Your Organization

Your data is visible to:

• Team members (for team-visible items)
• Managers (for escalations and summaries)
• Organization admins (for all organization data)

6.2 Service Providers

We share data with:

Provider	Purpose	Location
Stripe	Payment processing	US/EU
Slack	Messaging integration	US
Mailgun	Email delivery	EU
Railway	Hosting	EU
AI Providers	Summary generation	US

6.3 Legal Requirements

We may disclose data when required by law or to protect our rights.

7. International Transfers

Some of our service providers are located outside the EU. We ensure appropriate safeguards through:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions where applicable
• Additional technical measures

8. Data Retention

We retain your data for:

Data Type	Retention Period
Account data	Duration of account + 30 days
Check-ins	2 years
Escalations	2 years
Priorities	2 years
AI Summaries	1 year
Audit logs	3 years

After termination, your data is deleted within 30 days unless legally required to retain it.

9. Your Rights

Under GDPR, you have the right to:

9.1 Access

Request a copy of your personal data.

9.2 Rectification

Correct inaccurate or incomplete data.

9.3 Erasure

Request deletion of your data (“right to be forgotten”).

9.4 Restriction

Request limitation of processing in certain circumstances.

9.5 Portability

Receive your data in a structured, machine-readable format.

9.6 Object

Object to processing based on legitimate interest.

9.7 Withdraw Consent

Withdraw consent at any time where processing is based on consent.

To exercise these rights, contact privacy@murmurd.com.

10. Cookies and Tracking

10.1 Cookie Consent

When you first visit our website, you will see a cookie consent banner. You can choose to:

• Accept All: Enable analytics cookies for a better experience
• Decline: Only essential cookies will be used

You can change your preference at any time by clearing your browser’s local storage and revisiting the site.

10.2 Essential Cookies

We use essential cookies for:

• Authentication
• Session management
• Security features
• Cookie consent preferences (stored in localStorage)

These cookies are strictly necessary and do not require consent.

10.3 Analytics Cookies (Consent Required)

If you consent, we use Google Analytics 4 to understand how our website is used. Google Analytics:

• Sets cookies including _ga, _ga_*, and _gid
• Collects anonymized IP addresses (IP anonymization is enabled)
• Tracks page views, session duration, and user interactions
• Is subject to Google’s Privacy Policy

If you decline cookies, Google Analytics is not loaded and no analytics cookies are set.

10.4 Third-Party Cookies

Our integrations (Slack, etc.) may set their own cookies subject to their privacy policies.

11. Data Security

We protect your data through:

• AES-256 encryption at rest
• TLS 1.3 encryption in transit
• Regular security audits
• Access controls and logging
• Employee security training

12. Children’s Privacy

Murmurd is not intended for users under 18. We do not knowingly collect data from children.

13. Changes to This Policy

We may update this policy periodically. We will notify you of material changes via email or in-app notice.

14. Complaints

If you believe we have violated your privacy rights, you may file a complaint with:

• Our Data Protection Officer: dpo@murmurd.com
• Your local data protection authority (in Germany: Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit)

15. Contact

For privacy-related questions:

• Email: privacy@murmurd.com
• Address: See our Impressum