1. Who we are
Main Perfection, Lda. (ROOTKey), Campo Grande n.º 28, 4.º B, 1700-093 Lisboa, Portugal ("ROOTKey", "we", "us"), is responsible for the personal data described in this policy. We have not appointed a data protection officer, as the law does not require one for our activity. For any question or request about your personal data, write to security@rootkey.ai.
2. Our two roles
Controller. We decide how and why we use the data of website visitors, people who contact us or subscribe to our newsletter, job applicants, account holders and billing contacts. This policy covers that data.
Processor. When a customer connects or uploads files, documents, tables or databases to the ROOTKey platform, the customer decides what that content is used for. For that content we act on the customer's instructions, under our Terms and a data processing agreement, which is available on request at security@rootkey.ai. If your data is in content that a customer of ours processes, see section 10.
3. What we collect, why and for how long
| Purpose | Data | Legal basis | How long we keep it |
|---|---|---|---|
| Running and protecting the website | IP address, browser and device type, pages requested, security checks on forms (Cloudflare Turnstile) | Legitimate interest in operating a secure website | 12 months in technical logs |
| Website and product analytics (PostHog, Google Analytics) | Pages viewed, clicks, device, approximate location, pseudonymous identifiers | Your consent, which you can withdraw at any time | 14 months |
| Measuring our advertising (Google Ads) | Ad click identifiers and conversion events (for example, a form sent), and whether you visited the website, to show you ROOTKey ads | Your consent, which you can withdraw at any time | Up to 90 days in cookies; 14 months in reports |
| Answering contact and demo requests | Name, email, company, company size, subject and message | Steps you ask us to take before a contract, and our legitimate interest in answering business enquiries | 3 years after our last interaction |
| Newsletter | Email and the topics you choose | Your consent | Until you unsubscribe |
| Job applications | Name, email, CV or profile link and message | Steps you ask us to take before a contract | 1 year after the recruitment process ends, unless you agree to a longer period |
| Platform account | Name, email, organisation, sign-in and security data, settings and usage of the service | Performance of our contract with you | While the account is active and 30 days after it is closed |
| Billing and payments | Billing name and address, tax number, invoices and payment status. Card details are handled by Stripe; we never see or store full card numbers | Performance of the contract and our legal obligations | 10 years, as required by Portuguese tax law |
| Customer support | Your messages and the information needed to solve the issue | Performance of the contract and our legitimate interest in supporting users | 3 years after the request is closed |
We do not sell personal data, and we do not make decisions about you based solely on automated processing.
4. Integrity proofs and the public blockchain
To prove that a file has not changed, the platform calculates a SHA-256 fingerprint of it and records that fingerprint on the Polygon public blockchain. Only fingerprints and technical identifiers are recorded, never the content of a file, its name or personal data. A fingerprint cannot be turned back into the file.
Records on a public blockchain are permanent: nobody, including ROOTKey, can change or delete them. When you delete a file or close your account, we delete the link between the fingerprint and you in our own systems, so the record on the blockchain can no longer be associated with you.
5. Where the data is stored
On the SaaS version of the platform, data is stored in data centres in the European Union, with Amazon Web Services, Cloudflare and, for some services, Microsoft Azure or Google Cloud, all in EU regions. When a customer runs ROOTKey in its own private cloud or on its premises, its content stays in its infrastructure and we only access it as agreed with the customer, for example for support.
6. Who we share data with
We use the following service providers, who process personal data on our behalf, under contract and only for the purposes described here:
| Provider | What for |
|---|---|
| Amazon Web Services | Hosting of the platform (EU regions) |
| Cloudflare | Website hosting, content delivery, security and the form security check (Turnstile) |
| Microsoft Azure, Google Cloud | Hosting of some platform services (EU regions) |
| Microsoft 365 | Email and internal documents |
| HubSpot | Contact management and email, including the newsletter |
| Stripe | Payments and subscriptions |
| PostHog (EU hosting) | Product and website analytics, only with your consent |
| Google Analytics and Google Ads measurement, only with your consent |
We may also share data with public authorities when the law requires it, with our professional advisers under a duty of confidentiality, and with a buyer or successor if ROOTKey is involved in a merger or acquisition, who must keep protecting the data as described here.
7. Transfers outside the European Union
We prefer providers and regions in the European Union. Some providers, such as Google, HubSpot, Microsoft and Stripe, are based in the United States or may access data from there. In those cases the transfer relies on the EU-U.S. Data Privacy Framework when the provider is certified under it, or on the Standard Contractual Clauses approved by the European Commission, with additional safeguards where needed.
8. Security
We protect personal data with encryption in transit, access control based on need, logging of access, and integrity verification of our own records. No system is free of risk: if a personal data breach is likely to put you at risk, we will notify the supervisory authority and, where required, you, as the law sets out.
9. Your rights
You can ask us to access, correct or delete your personal data, to restrict or object to its use (including for direct marketing, at any time), to receive it in a portable format, and you can withdraw any consent you gave, without affecting what was done before. Write to security@rootkey.ai; we answer within one month, and may ask you to confirm your identity. You can unsubscribe from the newsletter through the link in every email, and change your cookie choices at any time with the Cookie settings link at the bottom of every page.
You also have the right to complain to the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (www.cnpd.pt), or to the authority of the country where you live.
10. People whose data our customers process
If your personal data is in files or systems that a customer of ours protects with ROOTKey, that customer is responsible for it. Please send your request to them; we will help them answer it.
11. Children
Our website and services are meant for professionals and are not directed to children under 16. We do not knowingly collect their personal data; if you believe we have, contact us and we will delete it.
12. Changes to this policy
We may update this policy when our services or the law change. The date at the top shows the latest version. If a change is significant, we will tell account holders by email before it takes effect.