Privacy Policy & Sovereign Data Governance

1. Sovereign Data Isolation Architecture

1.1 Isolated Tenant Infrastructure: Every enterprise deployment is isolated within a dedicated Virtual Private Cloud (VPC) container. Employee datasets, vector store embeddings, and agent reasoning traces are cryptographically partitioned to prevent cross-tenant data access.

1.2 Zero Persistent Cache: Transient data processed by temporary inference agents (`Talent Acquisition Agent`, `Payroll Agent`) is immediately scrubbed from RAM upon job completion, leaving zero unencrypted residual data on processing nodes.

2. Categories of Processed Workforce Data

To execute autonomous human capital operations under Customer authorization, HRMindMap OS processes the following categories of data:

• Identity & Personnel Records: Employee name, job title, department, email, contact details, employee ID.
• Compensation & Payroll Execution Data: Salary structure, tax withholdings, bank account routing, bonus allocations, expense receipts processed by `ExpenseAgent`.
• Talent & Performance Telemetry: Resume PDFs, interview transcripts, OKR goal progress, 360 feedback logs, and skills gap matrices.
• Agent Telemetry & Audit Logs: Timestamped execution records, API request IDs, and executive HITL approval signatures stored by `GDPRAgent`.

3. Zero Foundation LLM Training Guarantee

3.1 Complete Model Isolation: Proprietary enterprise data is never exposed to public LLM training pipelines. All zero-shot prompts and vector embeddings execute against zero-retention Enterprise API endpoints with contractual guarantees against data logging or training usage.

3.2 Customer-Specific Model Tuning: If Customer opts to fine-tune specialized agent weights (e.g. custom corporate policy Q&A), all resulting weights and embeddings remain the exclusive, encrypted property of Customer within their private tenant boundary.

4. Data Residency & Global Encryption Standards

4.1 Encryption at Rest: All stored databases, vector stores, and backup archives are encrypted using FIPS 140-2 validated AES-256 encryption with Customer-Managed Keys (CMK) via AWS KMS or Azure Key Vault.

4.2 Encryption in Transit: All data transmitted between Customer HRMS, browser clients, and HRMindMap OS nodes uses TLS 1.3 encryption with Perfect Forward Secrecy (PFS).

4.3 Regional Data Residency: Enterprise customers may select their preferred geographic data hosting region to comply with local regulations:

5. Authorized Enterprise Sub-Processors

Company engages vetted sub-processors for infrastructure, cloud hosting, and zero-retention LLM inference under strict Data Processing Agreements (DPAs):

6. Automated Compliance (`GDPRAgent` Sentry)

HRMindMap OS features a dedicated sovereign micro-agent, `GDPRAgent`, which continuously monitors data access patterns, enforces retention schedules, automatically masks sensitive PII in telemetry logs, and generates audit reports for enterprise compliance officers.

7. Data Subject Rights (GDPR / CCPA)

Employees residing in jurisdictions protected by GDPR, CCPA, or equivalent data privacy laws possess the following rights, supported via self-service portal:

• Right to Access & Portability: Export personal workforce data in structured JSON format within 72 hours.
• Right to Rectification: Instant correction of inaccurate personnel or payroll records.
• Right to Erasure (Right to be Forgotten): Automated permanent sanitization of candidate and former employee records upon authorized request.

8. Security Incident Response & DPO Contact

Company maintains a 24/7 Security Operations Center (SOC). In the event of a confirmed security incident affecting Customer data, Company will notify Customer CISO within 24 hours of verification in accordance with GDPR Article 33.

For privacy inquiries, Data Protection Impact Assessments (DPIA), or audit requests: