Privacy Policy

Introduction

This Privacy Policy explains how Temprix, registered with the Dutch Chamber of Commerce (KvK) under number 42087766, with registered address at Kratonkade 726, 3024 EX, Rotterdam, Netherlands (“Temprix,” “we,” “us”), collects, uses, and protects personal data in connection with the Temprix service (the “Service”) and our websites, including temprix.app and related sites.

This Policy uses defined terms consistent with our Terms of Service (e.g., “Customer,” “Workspace,” “Member,” “Data Region”). Where a term is used here without definition, it has the meaning given in the Terms of Service.

This Policy describes Temprix’s practices as a data controller. Where Temprix processes data on behalf of a Customer as a data processor (for example, Workspace Member data entered by an admin), that processing is governed by our Data Processing Agreement (“DPA”), not this Policy — see Scope for how this split works.

Scope — Who This Policy Covers

Temprix acts in two distinct roles depending on whose data is at issue. This Policy addresses both scenarios required under GDPR Articles 13 and 14:

• Article 13 (data collected directly from you): applies when you create an account, sign in, contact us, or otherwise provide your own personal data to Temprix.
• Article 14 (data collected about you by others): applies when a Customer or Workspace admin adds you as a Member and enters personal data about you in a Workspace.

Temprix’s roles are:

• As Controller, for: the account holder’s own account data; usage and technical data collected for Temprix’s own purposes (including security and fraud monitoring); billing data; and prospect/lead data used for outbound marketing (How we use data).
• As Processor, for: Workspace Member data entered by a Customer about its team members (e.g., name, title, location, timezone, event/capacity data), and the Workspace’s audit log activity trail. The Customer is the controller for this data and is responsible for having a lawful basis to collect and share it with us. Our processing of it is governed exclusively by the DPA.

If you are a Member of a Workspace and have questions about how your data is handled, your organization (the Workspace’s Customer) is your primary point of contact, since they control that data. Temprix remains available as a fallback at privacy@temprix.app.

Data We Collect

How We Use Data and Our Legal Bases

For prospect/lead data specifically: we source business contact information from public professional sources (e.g., company websites, professional networking platforms). We conduct outbound marketing only in jurisdictions where business-to-business email communication is permitted without the recipient’s prior consent — for example, the United States (under CAN-SPAM) and countries in the European Economic Area whose laws include a similar business-to-business exemption, where we additionally rely on legitimate interest and restrict outreach to contacts whose employer is a legal entity (as opposed to a sole trader or partnership). We do not send outbound marketing to contacts in jurisdictions that require prior consent for this kind of communication. Every communication clearly identifies the sender, links to this Policy, and includes a working opt-out. You may object at any time via the unsubscribe link or by contacting privacy@temprix.app, and we maintain a suppression list to honor opt-outs on an ongoing basis. If you do not become a Customer, we delete or suppress your contact data within 12 months of when we first collected it or your last interaction with us, whichever is later; a record that you opted out is retained indefinitely, to ensure we do not contact you again.

Aggregated and anonymized data. We may derive aggregated or anonymized data from use of the Service that does not identify any Customer or individual (referred to as “Service Data” in our Terms of Service). We may use Service Data for purposes including product improvement, analytics, benchmarking, and the development and training of statistical and machine learning models (for example, capacity forecasting). Service Data is never used to identify any Customer or individual. Because Service Data does not identify any individual, it is not personal data and is not subject to the rights described in Your rights. Customer Data (i.e., data that does identify a Customer or individual) is not used to train machine learning models.

Data Region and Storage

At Workspace creation, the Customer selects a Data Region — currently United States or European Union. This choice determines where that Workspace’s regional data (Member records, events, capacity data) is stored and processed, and cannot be changed after creation.

Separately, a limited set of pseudonymized identifiers (for example, hashed email addresses used for cross-region invitation lookups, and non-personal workspace routing metadata) is processed in the United States regardless of the Data Region selected for a Workspace. This applies universally and is not affected by your Data Region choice. These identifiers cannot be used to identify you on their own.

Authentication is also handled by shared, global infrastructure (AWS Cognito), which is deployed in the United States. This means account credentials and authentication data (name, email, password hash, or your Google sign-in identifier) are processed in the United States for all users, regardless of your Workspace’s Data Region.

When a Workspace admin invites a new Member by email, that email address is checked against our global authentication infrastructure in the United States to determine whether it belongs to an existing Temprix user, before any resulting Workspace/Member data is created in the Workspace’s own Data Region. This lookup applies to the invited email address itself, regardless of which Data Region the inviting Workspace uses.

What this means for EU customers. If you select the EU Data Region, your Workspace’s operational data is stored and processed in the EU (eu-central-1). However, certain account-level and routing data — including authentication via AWS Cognito, cross-region invitation lookups, and pseudonymized workspace routing metadata — is still processed in the United States, as described above and in our International data transfers section.

International Data Transfers

Personal data may be transferred outside the European Economic Area (EEA) in three independent circumstances:

1. Data Region selection. If a Customer selects the United States as its Workspace’s Data Region, that Workspace’s regional data is stored and processed there.
2. Temprix’s own global infrastructure. Certain infrastructure Temprix relies on for every Workspace is deployed in the United States regardless of Data Region choice, including: authentication and account data (via AWS Cognito, described in Data region and storage); the email-address lookup performed when inviting a new Member; pseudonymized identifiers used for cross-region routing; and billing webhook metadata, which is received and processed by our billing infrastructure in the United States before regional billing state is stored in a Workspace’s selected Data Region. Authentication-related emails (e.g., email verification, password reset) are dispatched from this US infrastructure for all users, while other Service notification emails are dispatched from the Workspace’s own selected Data Region (Third-party service providers).
3. Service provider locations. Certain service providers we rely on (Third-party service providers) are established in, or process data in, the United States. Where a provider primarily processes data in the EEA (for example PostHog Cloud EU), residual processing by a US-headquartered provider may still occur and is covered by the safeguards below.

Where personal data is transferred outside the EEA, we rely on the European Commission’s Standard Contractual Clauses (SCCs) as our primary transfer mechanism. Where a provider is also certified under the EU-U.S. Data Privacy Framework (DPF), this serves as an additional safeguard.

Third-Party Service Providers

We share personal data with the following categories of service providers, in the capacity noted below. Where a provider processes data on Temprix’s behalf as controller, it acts as our vendor; where it processes Workspace/Member data on a Customer’s instructions, it acts as a sub-processor under the DPA.

• Amazon Web Services (AWS). Hosts the Service, including Workspace data in the Customer’s selected Data Region, global authentication (AWS Cognito), pseudonymized routing metadata, and transactional email delivery. AWS acts as our vendor for controller-role data and as a sub-processor for Workspace/Member data.
• Stripe. Processes payments and subscription billing. Stripe also acts as an independent controller for its own fraud-prevention purposes; see Stripe’s privacy policy for details. Temprix stores only Stripe customer and subscription identifiers — not card data. Stripe acts as our vendor and is not a sub-processor of Workspace/Member data.
• Google. Where you or a Member signs in via Google single sign-on, Google acts as an independent controller of your Google account, and we receive authentication data (such as name, email, and profile picture) from Google as controller.
• Email providers. Transactional email for the Service is delivered through AWS infrastructure, as described above.
• PostHog (PostHog Inc. / PostHog Cloud EU). Used for product analytics and related telemetry across (a) our marketing websites and documentation and (b) the Temprix Service. On marketing websites and documentation, Temprix acts as controller and PostHog acts as our vendor for that controller-role processing (for example pageviews, interaction events, and — where a visitor is signed in — an account identifier). Within the Service, where PostHog processes Personal Data in connection with providing the Service (including usage tied to accounts or Members, feature usage, product improvement, and exception or error signals where enabled), PostHog acts as a sub-processor under the DPA and is listed in DPA Annex II. Analytics data for our PostHog Cloud EU project is hosted in the European Economic Area (eu.i.posthog.com, Frankfurt). See PostHog’s privacy policy. PostHog Inc. is established in the United States; where residual non-EEA processing occurs, we rely on SCCs and, where applicable, PostHog’s participation in the EU–U.S. Data Privacy Framework, as described in International data transfers.
• Other marketing and outreach tools. Used for business communications. These tools process controller-role data only and act as our vendors; they are not sub-processors of Workspace/Member data.

The authoritative, Article 28 sub-processor list for data processed on a Customer’s behalf is maintained in DPA Annex II and in our DPA; material additions will be disclosed through the DPA’s sub-processor notification process.

Cookies and Similar Technologies

We use cookies and similar technologies (such as local storage) where they are strictly necessary to operate the Service: to keep you signed in (authentication tokens), to route your requests to the correct Data Region’s infrastructure (a routing cookie containing no personal information), and — on billing and checkout pages only — fraud-prevention cookies set by our payment processor, Stripe. We do not use cookies or similar technologies for advertising.

Article 5(3) of the ePrivacy Directive applies to storing or accessing information on your device regardless of the specific technology used. We consider the mechanisms above strictly necessary for providing the Service and processing payments, which qualifies them for the exemption from consent under that Article.

Marketing websites and documentation. Product analytics on our marketing websites and documentation is provided by PostHog in cookieless mode: PostHog does not set analytics cookies or use local or session storage for anonymous visitor tracking on those sites. When a signed-in visitor is identified, we may send an account identifier (for example a Cognito sub) to PostHog as controller-role analytics personal data for product improvement, without relying on analytics cookies. See Third-party service providers.

Temprix Service. Within the authenticated Service, product analytics via PostHog runs for product improvement and usage analytics, as disclosed above and in the DPA. Strictly necessary authentication, routing, and (on checkout) Stripe cookies continue to apply as described in this section.

Data Retention

We retain personal data for as long as your account or Workspace remains active, or as otherwise necessary to provide the Service.

• Workspace deletion: Following deletion, Customer Data is retained for 30 days to allow for reactivation or export, after which it is scheduled for permanent deletion, consistent with our Terms of Service.
• Account deletion: Following deletion of an individual account, account data is retained for 30 days to allow for recovery, after which it is scheduled for permanent deletion.
• Backups: Residual copies of deleted data may persist in encrypted backups for up to 35 additional days after deletion completes, after which they expire as part of our normal backup rotation.
• Billing data: Retained for 7 years following the relevant transaction, in line with Dutch fiscal record-keeping requirements. Stripe retains billing records according to its own retention policy.
• Audit logs: Workspace audit logs are retained for 6 months on the Free Plan and without a fixed time limit on paid Plans, unless a shorter period is required by the Customer’s instructions under the DPA.
• We may retain data in de-identified or aggregated form without a fixed time limit, provided it no longer identifies any individual.

Member deactivation and erasure. Deactivating a Member removes their active access but retains their data by default. A Workspace admin can remove or overwrite a deactivated Member’s identifying fields (e.g., name, email) directly within the product by editing the Member’s record; associated historical capacity data is retained without those identifying fields in the current Member record, to preserve the accuracy of the Workspace’s records. Removing identifying fields from a Member’s current record does not remove references to those fields that may already exist in the Workspace’s audit log activity trail, which is retained as described above. Note that in small Workspaces, it may still be possible to infer a former Member’s identity from patterns in retained event data. For erasure needs beyond what the admin interface supports — including removal from historical audit records — contact privacy@temprix.app.

Your Rights

Subject to applicable law, you have the right to:

• Access the personal data we hold about you (Article 15)
• Rectify inaccurate or incomplete data (Article 16)
• Erase your data, subject to legal retention requirements (Article 17)
• Restrict processing in certain circumstances (Article 18)
• Object to certain processing, including processing based on legitimate interest (Article 21)
• Data portability — receive your data in a machine-readable format (Article 20)
• Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal

Exercising these rights: You can request a copy of your data at any time via privacy@temprix.app. Workspaces on the Standard Plan and above also have self-service CSV data export available directly in the product. We will respond to requests without undue delay and within one month, as required by GDPR Article 12(3).

If you are a Workspace Member (rather than the account holder), your Workspace’s Customer is the controller of your data and is your primary contact for exercising these rights, since they determine how your data is collected and used within the Workspace. Temprix will support such requests as a processor and remains available directly at privacy@temprix.app where the Customer is unable to assist.

Children’s Privacy

The Service is intended for business use by adults. By using the Service, Customers represent that individuals using it on their behalf are at least 18 years old, consistent with our Terms of Service. Temprix does not knowingly collect personal data from individuals under 18, and the Service is not directed at children under 16.

Security

We use industry-standard technical and organizational measures to protect personal data, including encryption in transit and at rest, access controls, and regular security reviews. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. For more detail, see our Security overview.

Legal Disclosures

We may disclose personal data where required to comply with a legal obligation, such as a court order, subpoena, or lawful request from a tax authority, law enforcement, or other government body, or where necessary to protect the rights, property, or safety of Temprix, our Customers, or others.

Automated Decision-Making

We do not use personal data to make decisions that produce legal effects or similarly significantly affect you through automated processing alone, within the meaning of Article 22 GDPR.

Business Transfers

If Temprix is involved in a merger, acquisition, or sale of all or substantially all of its assets, personal data may be transferred to the acquiring entity as part of that transaction. We will provide notice to affected account holders and/or an in-app notice before personal data becomes subject to a different privacy policy, consistent with our practice for material changes described in Changes to this policy.

Supervisory Authority

If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. As Temprix is established in the Netherlands, our lead supervisory authority is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl). If you are in the EEA, you may lodge a complaint with the supervisory authority of your habitual residence, place of work, or the place of the alleged infringement. If you are outside the EEA, local law may provide additional remedies.

Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will notify affected account holders by email and may also display an in-app notice, at least 30 days before the change takes effect where practicable. The Last updated date at the top of this page reflects the current version. This Policy is a transparency notice describing our data practices, not a contract requiring your acceptance; your rights and our obligations are governed by applicable law regardless of continued use of the Service.

Contact

Questions about this Policy or your data can be directed to:

Email: privacy@temprix.app

Postal address: Temprix, Kratonkade 726, 3024 EX, Rotterdam, Netherlands