Privacy Policy

1. Who we are

OgmaQ is a trade name of Ogma OS, a sole proprietorship established in the Netherlands, registered with the Dutch Chamber of Commerce (KvK) under number 42137473, registered address Burgemeester Hogguerstraat 81, 1064 CK Amsterdam, Netherlands. Ogma OS is the controller for the personal data described in this policy. Ogma OS ("OgmaQ", "we", "us") provides operational escalation support software as a service for GMP-adjacent manufacturing teams — one structured workflow to capture, triage, track and close operational escalations. Contact routes are listed in the Contact section below.

2. Role under data protection law

Pending legal review. The customer organisation is expected to act as the controller of its workspace content.

OgmaQ expects to act as a processor for customer workspace content submitted by customer users, and as a controller for its own business, account administration, security, support and contracting data. This allocation is pending legal review and will be reflected in the applicable Data Processing Agreement.

3. What data the app processes

• Account and profile data — name, work email address, and role, site and department assignments set up by your organisation's administrator. Where enterprise single sign-on is configured for a customer's deployment, this also includes the customer's corporate email domain(s), sign-in identity attributes received from the customer's identity provider, and access requests raised by users of that provider before an account is approved.
• Workspace content — the escalation records, triage notes, comments, decisions and related content that the customer's users enter into their workspace, together with the workspace configuration maintained by the customer's administrators (forms, lifecycle and similar settings), which is stored server-side for the customer's workspace. The customer controls what is entered.
• Attachments — files uploaded to escalation records are stored as file content, alongside their metadata, in Supabase-hosted object storage that is designed to be private, subject to size and file-type limits. Users who can view an escalation record can download its attachments.
• Operational logs and security records — sign-in events, audit-support trail entries and technical logs needed to run, secure and support the service, together with a server-side record of each signed-in user's cookie-consent decision and multi-factor authentication enrolment data for accounts that enable it.
• Notifications and delivery records — in-app notifications are stored server-side against your account until archived; your notification preferences (including email settings and quiet hours, stored with your browser's timezone offset) are kept server-side; and each outbound email attempt is recorded in an append-only delivery log holding the channel, a masked recipient address, the delivery outcome and rate-limit metadata.

Customer workspace content is controlled by the customer. Users should avoid entering unnecessary personal data or sensitive data into escalation records, comments, descriptions and attachments. Unless separately agreed in writing, OgmaQ is not intended for patient data, protected health information (PHI) or special-category personal data — see the Acceptable Use Policy. Requests that affect customer workspace records may need to be handled with the customer as controller.

Where the customer enables published data links, a link exposes a read-only operational data feed drawn from the customer's own workspace. Personnel columns (such as owner or reporter names) are included in a feed only when the customer explicitly enables them for that link; otherwise the feed carries no personnel names. Access to a link is logged as metadata only — the outcome, timestamp, feed format and row count — and OgmaQ does not store the raw IP address of link consumers.

4. Purposes

We process this data to provide and operate the service, authenticate users and keep accounts secure, maintain the audit-support trail that the product exists to provide, respond to support requests, send in-app and email notifications according to your organisation's and your own settings (notification emails are built to carry minimal record content), and improve the reliability and safety of the service. Where the customer enables published data links, we also process the scoped workspace data to serve the read-only operational data feed to the holders of a link URL at the customer's instruction.

5. Legal bases

The legal bases relied on for each processing activity are pending legal review. The table below sets out the expected allocation.

The final allocation will be confirmed during legal review.

6. Where data is stored and international transfers

Customer workspace data is stored in a Supabase-hosted PostgreSQL database, with attachment file content held in Supabase-hosted object storage in the same project, and the application is served through Cloudflare. See the subprocessor list for the vendors involved and their data locations.

The primary Supabase project region is EU (eu-central-1, Frankfurt). Where personal data is transferred internationally — for example to a subprocessor outside the EU — the transfer mechanisms relied on (such as the EU Standard Contractual Clauses) will be assessed and documented during legal review.

7. Retention

Customers can declare retention periods in workspace settings; these are recorded as the customer's retention policy, and the service does not currently run automated purges against them, with one exception: attachment file content is permanently deleted under an enforced workspace retention policy (by default 30 days after the owning record is archived; each workspace can adjust the period or disable the deletion). Operational records — including the audit-support trail, notification and email-delivery logs, comment history and attachment metadata — are retained by default, since removing them would undermine the traceability the service provides. See the Data Retention Policy.

8. Your rights and requests

You can raise a privacy request — access, export, correction or deletion — through the in-app privacy request workflow or by contacting the privacy contact below. Requests that affect audit-support records or another organisation's workspace are reviewed with the workspace's controller before action is taken.

For customer workspace content, OgmaQ expects to act as a processor: requests that affect a customer workspace are coordinated with that customer as the controller, and OgmaQ supports the customer in responding rather than deciding unilaterally.

Account deletion is also available self-serve in the app. Deleting an account permanently removes the sign-in identity; the associated workspace profile is then minimised rather than destroyed — the display name is replaced with a neutral reference, the email address is cleared and the account is deactivated — so that historical workflow records and the audit-support trail stay traceable. Name text captured inside historical records at the time of an action may persist after deletion; the deletion flow discloses this before you confirm.

9. Data Processing Agreement

A placeholder Data Processing Agreement scaffold is published at ogmaq.com/dpa. It is not legally final and is intended for later use as part of customer contracting, once reviewed and finalised by qualified legal counsel.

10. Subprocessors

The third-party vendors that process data on our behalf are listed at ogmaq.com/subprocessors.

11. Language and localisation

English is the primary operating language of OgmaQ. Interface localisation may be available for supported languages, and any translation applies to the application's own interface text only.

Customer-entered records remain exactly as entered — OgmaQ does not automatically translate customer-entered information. No third-party translation service currently processes customer-entered content, and no customer data is transmitted to external translation providers. Any future automatic-translation capability will be introduced as an optional feature and accompanied by updated legal documentation and privacy disclosures before release.

12. Contact

Use the route that matches your request:

• General — hello@ogmaq.com
• Privacy & data subject requests — privacy@ogmaq.com
• Security & vulnerability reports — security@ogmaq.com
• Legal, contracts & subprocessors — legal@ogmaq.com

These role-based aliases route to the OgmaQ team. hello@ogmaq.com is the general contact if you are unsure which to use.