Privacy Policy

Effective Date: 1 August 2024  |  Last Revised: 9 October 2026  |  Version 2.2

Key Points: Plain Language Summary

BAI Analytics is a privacy-first AI company. Here is what that means in practice:

  • We do not sell your personal data : ever.
  • We never use your content or data to train AI models.
  • Primary customer-content storage is regionally configured. Certain enabled features use contracted sub-processors in the locations disclosed in our live register.
  • AI processing is governed and regionally configured. EU-residency deployments use approved EU processing routes, with provider details maintained in our live sub-processor register.
  • You can request access to, correction of, or deletion of your data at any time.
  • We will give you at least 30 days notice of any material changes to this Policy.

Questions? Contact our Privacy Officer: privacy@boundary-ai.com

1. Introduction and Scope

BoundaryAI, Inc. (trading as "BAI Analytics") and its affiliated entities (collectively "BAI Analytics", "BoundaryAI", "we", "us", or "our") are committed to protecting your privacy and handling your personal data with transparency and care. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data when you use our platform, products, and services (the "Services").

This Policy applies to:

  • Customers and authorised users of the BAI Analytics platform ("Customers");
  • Visitors to our websites at boundary-ai.com and associated domains;
  • Prospective customers and partners who interact with us;
  • End users of applications built by Customers using the BAI Analytics API ("End Users").

This Policy does not apply to third-party services linked from our platform. We encourage you to review their privacy notices separately.

Enterprise and contracted customers: If you have signed a separate Data Processing Agreement (DPA), Business Associate Agreement (BAA), or Enterprise Master Services Agreement (MSA) with BAI Analytics, the terms of that agreement govern to the extent of any conflict with this Policy.

2. Data Controller and Affiliated Entities

The BAI Analytics legal entity identified in the applicable order form, subscription agreement, or invoice provides the contracted Services. BoundaryAI, Inc., a Delaware corporation, is the controller for this website and for business-contact data unless another BAI Analytics entity is identified at collection. For customer content, the customer ordinarily acts as controller and the applicable BAI Analytics contracting entity acts as processor.

Note for EU and UK customers: Your order form or subscription agreement identifies the contracting entity and any customer-specific residency commitment. Transfers outside the EEA or UK are covered by an adequacy decision, the EU Standard Contractual Clauses, the UK Addendum, or another lawful mechanism, as applicable. See Section 9 and our live sub-processor register.

Privacy Officer: All privacy enquiries and data subject requests should be directed to:

BAI Analytics Privacy Officer

Email: privacy@boundary-ai.com

Postal: Privacy Officer, BoundaryAI, Inc., 1100 Av. du Docteur-Penfield #504, Montréal, QC H3A 1A8, Canada

Response time: We acknowledge all requests within 72 hours and respond fully within 30 days.

EU and UK data subjects have the right to contact their national supervisory authority. In the UK, this is the Information Commissioner's Office (ico.org.uk). In the EU, contact the supervisory authority in your Member State of habitual residence.

3. Infrastructure, Data Residency, and AI Architecture

BAI Analytics is built primarily on Google Cloud Platform (GCP). Primary databases and object storage are configured by customer environment. Some optional product functions use other contracted sub-processors, so storage location and processing location must be read together with the applicable order form and our live sub-processor register.

3.1 Regional Isolation

We offer three deployment environments: North America, European Union, and Global. A customer's primary storage and processing environment is selected during contracting or provisioning. Region-specific deployments use processing routes compatible with the applicable residency commitment; the Global environment may use approved locations and disclosed providers as defined in the applicable agreement. Administrative account data and business communications remain subject to the transfer terms described in Section 9.

3.2 AI Model Architecture : Your Data Stays Private

How BAI Analytics AI inference works:

BAI Analytics uses controlled cloud AI services selected according to the customer environment and enabled feature:

  • Google Cloud Vertex AI is the approved platform for regional analysis and embedding workloads.
  • AssemblyAI may be used for supported EU audio workflows through its EU endpoint; Google Cloud Speech-to-Text is the regional fallback.
  • Customer inputs and outputs are used to provide the Services and are not used by BAI Analytics to train shared or general-purpose models.
  • Only providers and routes compatible with the customer's contracted environment are enabled for customer-content processing. A service that is not available in that environment does not receive or process customer content.
  • Identity services such as Clerk process account, authentication, organisation, device, and session data only; they do not receive survey responses, recordings, transcripts, or analysis content.
  • Public-source collection services such as Apify process only customer-selected publicly available information collected by that service; they do not receive private customer datasets or other customer content.
  • Feature-specific purposes and factual processing locations are maintained in the live sub-processor register.

Sub-processors: The authoritative list, including provider purpose and processing location, is maintained in our Vanta Trust Center sub-processor register.

4. Personal Data We Collect

We collect personal data in three ways: data you provide directly, data generated through your use of the Services, and data received from third parties.

4.1 Data You Provide Directly

4.2 Data Generated Through Use of the Services

4.3 Data from Third Parties

We may receive personal data from: identity verification and fraud prevention services; publicly available professional directories for B2B outreach; and integration partners where you have authorised data sharing.

4.4 Special Categories of Data

We do not require special-category personal data to provide the standard Services. Customer-provided free text, audio, transcripts, or imported records may nevertheless contain such data incidentally. Customers must have an appropriate lawful basis and safeguards, and must notify us at privacy@boundary-ai.com before intentionally processing special-category data.

5. Legal Basis for Processing (GDPR / UK GDPR)

Where EU GDPR or UK GDPR applies, we rely on the following lawful bases:

Legitimate interests: Where we rely on legitimate interests, we have conducted a balancing test confirming our interests do not override your fundamental rights. You may request a copy of our Legitimate Interests Assessment at privacy@boundary-ai.com.

6. AI Model Training : Our Commitment

Your data is not our training data.

BAI Analytics does not use your input content, output content, or any personal data to train, fine-tune, or improve AI models : ours or anyone else's.

Specifically:

  • Content of your queries, documents, prompts, and AI-generated outputs is never used for model training;
  • AI inference on Google Vertex AI runs under our private GCP organisation : Google's Cloud DPA prohibits Google from using this data for its own model training;
  • Our proprietary models are trained on curated datasets we control, not on customer data;
  • Anonymised, aggregated usage telemetry (e.g. feature adoption rates, error frequencies) that cannot be linked to any individual or organisation may be used for platform performance analysis;
  • Enterprise customers with DPAs containing explicit training prohibitions have contractual protection in addition to this policy default.

7. How We Use Personal Data

We use personal data only for the purposes described in this Policy.

8. Disclosure of Personal Data

We do not sell, rent, or trade your personal data. We may disclose personal data only in the following limited circumstances:

8.1 Sub-processors

Sub-processors that handle customer personal data are subject to contractual data-protection obligations. Because the enabled provider set can vary by product feature and customer configuration, the authoritative list is the live Vanta Trust Center register.

We provide advance notice of new sub-processors in accordance with the applicable DPA, including through the Trust Center subscription mechanism. Contractual objection rights and notice periods control where they differ from this Policy.

8.2 Corporate Transactions

In the event of a merger, acquisition, or asset sale, personal data may be transferred to the successor entity. We will give at least 30 days notice before your data becomes subject to a materially different privacy policy.

8.3 Legal Obligations

We may disclose personal data if required by law, court order, or governmental authority. We will notify affected customers of government data requests where legally permitted to do so, and publish an annual transparency report at boundary-ai.com/transparency.

9. International Data Transfers

International transfers may occur when the contracting entity, authorised personnel, or an enabled sub-processor is located outside the data subject's jurisdiction. We use the transfer mechanism appropriate to each transfer:

Important note on EU-residency deployments: Customer content is stored and processed through approved EU-compatible routes. Features that cannot meet the contracted residency requirement are not enabled for that deployment. The applicable order form and live sub-processor register document the approved scope.

You may request a copy of the applicable SCCs by contacting privacy@boundary-ai.com.

10. Data Retention

We retain personal data only as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, and resolve disputes.

On account deletion or termination, we will delete or anonymise your personal data within 30 days, subject to legal retention obligations. You will have a 30-day window after termination to export Your Content before deletion.

11. Your Privacy Rights

Depending on your location, you have rights in relation to your personal data. We are committed to honouring these promptly and without charge except in limited circumstances.

11.1 Rights Under EU GDPR / UK GDPR

11.2 California Rights (CCPA / CPRA)

California residents have the following rights under the CCPA as amended by the CPRA:

Categories of personal information collected (CCPA):

  • Identifiers (name, email, IP address, account ID);
  • Commercial information (billing and transaction records);
  • Internet or electronic network activity (usage logs, access records);
  • Professional or employment-related information (job title, company name);
  • Inferences drawn from the above to create a profile (usage patterns : never sold).

11.3 How to Exercise Your Rights

  • Email: privacy@boundary-ai.com
  • Online form: boundary-ai.com/privacy-request
  • California Do-Not-Sell/Share: boundary-ai.com/privacy-choices

We acknowledge requests within 72 hours and respond fully within 30 days. For complex requests, we may extend by 60 days with notice. We may need to verify your identity before processing : verification data will not be used for any other purpose.

11.4 Authorised Agents (California)

California residents may designate an authorised agent to submit requests on their behalf. We will require written authorisation and may verify your identity directly before processing.

12. Data Security

BAI Analytics implements technical and organisational security measures appropriate to the risk of our processing activities, in accordance with GDPR Art. 32 and industry best practice.

  • Encryption in transit using TLS 1.2 or higher for all data transmissions;
  • Encryption at rest using AES-256 for all stored personal data and content;
  • Role-based access controls, least-privilege principles, and multi-factor authentication for all administrative systems;
  • Continuous security monitoring through Vanta, providing real-time compliance and control visibility;
  • SOC 2 Type I examination completed; the report is available to eligible customers under confidentiality controls, and Type II monitoring is ongoing;
  • Regular penetration testing, vulnerability scanning, and code security review;
  • Security incident response procedures with defined notification timelines;
  • Security training, confidentiality commitments, and role-appropriate personnel screening for personnel with access to personal data;
  • Regional GCP isolation ensures that a security incident in one environment cannot affect others.

Data breach notification: In the event of a personal data breach likely to pose a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and affected individuals without undue delay.

13. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our websites and platform. We obtain your consent before placing any non-essential cookies. You can manage preferences at any time via our Cookie Preference Centre at boundary-ai.com/cookie-settings.

  • Strictly necessary cookies: Required for the operation of the Services (authentication, session management, security). These cannot be disabled.
  • Functional cookies: Remember your preferences and personalisation settings. Enabled only with your consent.
  • Analytics cookies: Help us understand how our Services are used in aggregate. Enabled only with your consent; we use anonymised/aggregated data only.
  • Marketing cookies: Used only for targeted communications where you have opted in. We do not permit third-party advertising cookies.

For full details, see our Cookies Policy at boundary-ai.com/cookies.

14. Our Role as Data Processor for Customer Data

When you use BAI Analytics to process personal data of your own end users or employees, you are the data controller for that data and we are your data processor. In that capacity:

  • We process End User data only on your documented instructions;
  • We do not use End User data for our own purposes, including AI model training;
  • We provide tools to help you respond to data subject rights requests from your End Users;
  • We will assist you in complying with GDPR, UK GDPR, CCPA, and other applicable laws;
  • We maintain records of processing activities on your behalf as required by GDPR Art. 30(2).

Enterprise customers should execute our standard DPA, available at boundary-ai.com/dpa or by contacting legal@boundary-ai.com. Public sector customers with specific regulatory requirements should contact us for tailored documentation.

15. Children's Privacy

The Services are designed for business users and professionals. We do not knowingly collect personal data from individuals under 18. If you believe we have inadvertently collected data from a minor, contact privacy@boundary-ai.com immediately and we will promptly delete that data.

16. Changes to This Policy

When we make material changes to this Policy : such as new processing activities, changes to your rights, or new data sharing : we will:

  • Notify you by email at least 30 days before changes take effect;
  • Display a prominent notice on our website and within the platform;
  • Seek your explicit agreement where renewed consent is required by applicable law.

Non-material changes (corrections, clarifications, administrative updates) may be made without advance notice and are effective upon posting. The Last Revised date at the top of this Policy always reflects the most recent update.

17. Contact Us

You may also lodge a complaint with your supervisory authority:

  • United Kingdom: Information Commissioner's Office (ico.org.uk)
  • European Union: Your national Data Protection Authority (edpb.europa.eu/about-edpb/about-edpb/members)
  • United States (California): California Privacy Protection Agency (cppa.ca.gov)
  • Canada: Office of the Privacy Commissioner of Canada (priv.gc.ca)

BAI Analytics Privacy Policy v2.2  |  Effective 1 August 2024  |  Revised 9 October 2026  |  © 2026 BoundaryAI, Inc.