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Privacy Policy

Last updated: 5 October 2026 · Version 3.19

On-device by design. The foxy-audit SDK computes every cryptographic commitment on your own infrastructure, before anything is sent to us. We structurally cannot see the raw text of your AI prompts or responses, not because of a policy promise, but because our servers have no field capable of storing them. See Section 3.

Document details

Contents

  1. Introduction & Scope
  2. Definitions
  3. Our Architecture: Runtime Security Without Raw Data
  4. Information We Collect
  5. Information We Do Not Collect
  6. How We Use Information
  7. Legal Bases for Processing (EEA / UK)
  8. Sub-processors & Third Parties
  9. Data Retention & Deletion
  10. Security Measures & Blockchain Anchoring
  11. Access Controls & Authentication
  12. Cookies
  13. International Data Transfers
  14. Your Rights & Choices
  15. Security Incidents & Breach Notification
  16. Additional Disclosures
  17. Changes to This Policy
  18. Contact Us

1. Introduction & Scope

Foxy Audit is a Runtime Auditing and Security Management platform for AI systems, what Gartner's framework calls an "AI TRiSM" (Trust, Risk, and Security Management) platform. This Privacy Policy explains how Foxy Audit, an unincorporated business operated from the Islamic Republic of Pakistan by its two founders, collects, uses, and protects information in connection with the customer dashboard at app.foxyaudit.tech, the marketing site at foxyaudit.tech, the open-source foxy-audit SDK (MIT-licensed, published on PyPI), the desktop application, and the admin console (together, the "Service"). Where the desktop app's optional AI chat feature is used, prompts are sent directly from your device to the AI provider you configure (for example Anthropic, OpenAI, or a local model), using your own API key. Foxy Audit is not an intermediary for that traffic and does not receive it. Foxy Audit currently operates online without a registered physical office; this section will be updated with a registered legal entity name and address once formal SECP registration is complete.

It applies to workspace account holders, the individuals they invite to a workspace, and visitors to our sites. It does not separately govern the AI systems our customers operate: those remain the customer's own responsibility as data controller for their own end users.

A note on applicable law. Pakistan has not yet enacted a comprehensive personal data protection statute; the Personal Data Protection Bill remains in draft form before Parliament. In the interim, data-related conduct is primarily governed by the Prevention of Electronic Crimes Act, 2016 (as amended in 2025). Because we serve customers internationally, we have voluntarily built this Policy to the higher standard of the GDPR and comparable frameworks (see Sections 7 and 13-14) rather than waiting for Pakistani law to catch up, and we will update this section promptly once the Bill is enacted.

2. Definitions

3. Our Architecture: Runtime Security Without Raw Data

In short: The SDK hashes your prompts and responses on your own servers. Only the hash, never the content, reaches us.

Most AI observability and audit tools work by ingesting your prompts and responses onto their servers so they can be logged, searched, or reviewed. Foxy Audit is built the opposite way: it is designed as trust infrastructure that cannot leak what it never receives.

The foxy-audit SDK runs inside your own application, on your own infrastructure. When it observes an interaction, it computes a SHA-256 digest and a customer-keyed HMAC-SHA-256 Commitment of the prompt and response locally, in your own process, before anything is transmitted to us. Only the resulting Commitment, a policy tag, a token-count estimate, the model/agent name, and, if you enable it, client-side PII signal labels ever leave your environment. The plaintext does not.

Those Commitments are then chained on our servers into a tamper-evident audit ledger, so that you or an independent auditor can later verify that a given interaction occurred and matched a given policy outcome without our having held the underlying content at any point. This is enforced in our data model, not only described in this policy: our backend has no database field capable of storing a raw prompt or response.

4. Information We Collect

In short: Account details, hashed keys, encrypted BYOK keys, ledger hashes, usage counts, and hashed security telemetry, never your prompts.

5. Information We Do Not Collect

In short: Your prompts, your responses, your end users' data, and your BYOK key in plaintext, ever.

6. How We Use Information

7. Legal Bases for Processing (EEA / UK)

Where the General Data Protection Regulation applies, we rely on: performance of a contract, to provide the Service you have subscribed to; legitimate interests, for platform security, fraud prevention, and product improvement, balanced against your rights and freedoms; consent, for analytics cookies where required; and legal obligation, for tax, accounting, and regulatory record-keeping.

8. Sub-processors & Third Parties

In short: Seven categories of provider, each with one job: Google/OpenAI grade metadata, Alibaba Cloud grades it too and can escalate to a human, Paddle bills you, Payoneer pays us, Google handles optional sign-in, Brevo emails you, and our cloud host runs the servers. No one else touches your data.

We share a limited set of data with the following providers, strictly as necessary to deliver the Service:

We do not currently hold a SOC 2, ISO 27001, or comparable third-party attestation. Should this change, this section will be updated to reference the relevant report, together with a dedicated trust page.

9. Data Retention & Deletion

In short: Ledger data lives as long as your workspace is active. Deleting a workspace closes it at once and can be reversed for 30 days; after that an automated purge erases it permanently (see below for what survives that purge, and why).

Audit ledger. Records are retained for as long as your workspace remains active, so your compliance history stays intact and auditable. The complete ledger may be exported at any time through the Compliance Passport.

Security telemetry. Hashed IP addresses and user-agent strings are retained for 90 days by default and then purged automatically. Internal staff-action audit logs, and the records of our own staff's sign-in sessions, are retained for up to 365 days.

Sign-in security logs. Sign-in attempts, successful and failed, are recorded with the email address entered and, in place of the IP address and user agent themselves, a one-way hash of each computed with a secret key, the network the address belongs to (the /24 block for IPv4, the /48 block for IPv6) and the browser family (for example, “Chrome on Windows”). The hashes let us recognise repeated attempts from the same address without keeping the address; without the key they cannot be linked to one. These logs are retained for 30 days, after which they are deleted automatically. A failed attempt on an email address that has no account here is recorded the same way, so for that period this log can hold an email address belonging to someone who is not a Foxy Audit customer: a mistyped address, or one used in a credential-stuffing attempt against the Service. Thirty days is the shortest period over which we can still recognise a pattern of such attempts.

Session records. Each time you sign in to the dashboard we create a session record holding the IP address and user agent of that device, in plain form, so that you can see your active devices and revoke any of them. A session ends when it expires (12 hours, or 30 days if you chose to stay signed in) or when you sign out, revoke that device, or sign out everywhere. The record is deleted automatically 7 days after the session ends. A session that is still active is never deleted on this schedule, whatever its age: the period counts from the end of the session, not from its start.

Known devices. To tell you when your account is signed into from a device we have not seen before, we keep a fingerprint of each device that signs in successfully: a one-way hash, computed with a secret key, of the browser’s user-agent family and the network it connected from (the /24 block for IPv4, the /48 block for IPv6). It holds neither the IP address nor the user agent itself, and it cannot be turned back into either. Each fingerprint is deleted automatically 12 months after that device was last used to sign in.

Cancellation and deletion are different actions. Cancelling a subscription ends billing at the end of the period already paid for and leaves the workspace open: an administrator can still sign in and generate the Compliance Passport described in Section 2. Deleting a workspace is the separate action described next, and it closes access.

Workspace deletion. Deleting a workspace from the dashboard immediately blocks further sign-in and API access for that workspace, and places its records in a restricted, inaccessible state. This action can be reversed by contacting us within 30 days if deletion was made in error. Once those 30 days have passed, an automated process permanently erases the workspace in one operation: every record kept under the workspace (the audit ledger, its users and their settings, encrypted provider keys, usage records, its sign-in and session records, and the request-level security telemetry attributed to it) and then the workspace itself. What survives that purge, and why: invoices and payment records, which we retain as financial records under a legal obligation for their own period; the record that an evaluation offer was redeemed for an email address (a one-way hash of the address, not the address), kept so the same offer cannot be claimed again by deleting and re-creating a workspace; the entries in our own staff-action log that name the workspace, which are not workspace data and expire on the 365-day schedule above; any marketing form submission you made before the workspace existed, which is pre-sales data held under Section 4, not workspace data, and keeps only a reference to a workspace that no longer exists; and cookie-consent records, which are not tied to a workspace at all. Backups are not edited: the nightly dumps and daily disk snapshots described in Section 8 are each kept for 14 days and roll off on their own schedule, so a purged workspace is out of every backup 14 days after the purge.

10. Security Measures & Blockchain Anchoring

In short: TLS everywhere, hashed secrets, encrypted BYOK keys, database-enforced tenant isolation, and optional public blockchain anchoring for independent proof.

11. Access Controls & Authentication

Multi-factor authentication. Available on an opt-in basis per account, using an emailed one-time passcode (six digits, single use, five-minute validity, stored only as a SHA-256 hash). Authenticator-app (TOTP) based MFA is not currently supported.

Enterprise single sign-on. Available on an opt-in basis per organization, using OpenID Connect (OIDC). SAML is not currently supported. An identity-provider connection is scoped to a verified email domain, and new users from that domain are provisioned into the correct organization only, on a just-in-time basis.

Administrative access. Our internal administrative console uses a session-signing secret distinct from that of the customer dashboard, supports an optional IP allow-list, and requires step-up authentication for sensitive actions. Every administrative action is recorded in a staff audit trail that is tamper-evident, independently verifiable: an entry that is edited, removed from the middle, or re-ordered breaks the chain, and because the chain's head is published to a public blockchain, so does an entry removed from the end. Entries recorded before the chain existed are not covered by it.

12. Cookies

We use a small number of first-party cookies to maintain sign-in state and basic security on the dashboard (including a staff session cookie and a CSRF-protection cookie): full detail, including exact retention periods, is in our Cookie Policy, not repeated here to avoid the two documents drifting out of sync. Our marketing site displays a geography-aware consent banner (opt-in in the EEA/UK, opt-out in jurisdictions such as the United States) prior to setting any optional first-party analytics cookie. We do not use third-party advertising or cross-site tracking cookies. See our Cookie Policy for full details.

13. International Data Transfers

In short: Your workspace data is hosted in Qatar, and daily snapshots of that server's disk are stored in the European Union. Interaction metadata also reaches sub-processors in the United States, and in Singapore where a workspace selects the Qwen judge. Neither Qatar nor Singapore is the subject of an EU adequacy decision, and for the United States we cannot yet evidence a safeguard for every sub-processor: all three destinations are set out below.

Based on the sub-processors listed in Section 8 and the region in which our own infrastructure runs: your workspace data is hosted and processed in Qatar (Google Cloud region me-central1, Doha). Interaction metadata is additionally processed in the United States by our judge providers (Google, OpenAI) and by Paddle, Payoneer, and Google Identity for the purposes described in Section 8, in Singapore by Alibaba Cloud's Model Studio where a workspace selects the Qwen judge, and in the European Union by Brevo for transactional email. Daily snapshots of our server's disk are also stored in the European Union multi-region (see Section 8), so a complete copy of the hosted data is held there as well as in Qatar. We do not process personal data in Pakistan: our founders operate the business from there (Section 1), but no customer data is currently hosted or processed on Pakistani servers.

Transfers to the United States. The safeguard Article 46 GDPR requires for a transfer from the EEA, UK, or Switzerland to the United States is the EU Standard Contractual Clauses, together with the UK International Data Transfer Addendum for UK transfers and Swiss Federal Act on Data Protection safeguards for Swiss transfers. We cannot evidence that safeguard for every US sub-processor. Rather than state it as settled, here is where each one stands, and we update this list as agreements are executed:

Transfers to Singapore. Where a workspace selects the Qwen judge, interaction metadata (and, where the judge asks for it, the aggregate prior-review counts described in Section 8) is processed by Alibaba Cloud's Model Studio in Singapore. Singapore is not the subject of a European Commission adequacy decision, so this is a transfer to a third country without adequacy and it too requires a safeguard under Article 46 GDPR. No Article 46 instrument has been executed for this destination. We have entered into no Standard Contractual Clauses and no other Article 46 mechanism with Alibaba Cloud; intending to obtain one is not the same as having one, so we name none here until one exists and we will publish the date it took effect when it does.

Transfers to Qatar. Qatar is not the subject of a European Commission adequacy decision. A transfer of personal data from the EEA, UK, or Switzerland to our hosting region in Qatar is therefore a transfer to a third country without adequacy, and it requires a safeguard under Article 46 GDPR. That safeguard is not yet in place. We are putting one in place with counsel, together with the transfer impact assessment that supports it, and we will name it here, with the date it took effect, rather than describe a mechanism before it exists. If you are an EEA, UK, or Swiss customer and need a named Article 46 safeguard for any of these destinations before sending personal data, write to privacy@foxyaudit.tech and we will tell you exactly where we are.

14. Your Rights & Choices

Rights by region

We do not limit these rights to any one region: the list below names the frameworks we specifically align with; if your home jurisdiction is not listed, the general commitment in the final paragraph of this section still applies to you in full.

Our general commitment

Regardless of where you are located, on a verified request we will provide access to, correct, delete, or export your personal data, consistent with the architecture described in Section 3 (which structurally limits what we hold in the first place). We will respond to a verified request within 30 days (the standard period under GDPR Article 12; where a shorter period applies under other law, including certain U.S. state statutes, we will meet that shorter period). Such requests may be directed to us at privacy@foxyaudit.tech or as set out in Section 18.

15. Security Incidents & Breach Notification

In the event of a security incident that we determine is reasonably likely to result in unauthorized access to, or disclosure of, personal data we hold, we will notify affected workspace administrators without undue delay and in accordance with applicable law, together with a description of the nature of the incident and the steps being taken in response.

This section addresses incidents affecting Foxy Audit's own systems. It is distinct from the in-product policy-breach alerts your organization may configure to notify your own team when a logged AI interaction violates your organization's policy (see your Workspace notification preferences).

16. Additional Disclosures

Children. The Service is intended for business use by adults and organizations; we do not knowingly collect personal data from anyone under 16. If you believe a minor has provided us data, contact us and we will delete it.

Open source. The foxy-audit SDK is published under the MIT License. Reviewing its source (including the hashing and PII-detection logic described in Section 3) is the fastest way to independently verify the data-minimization claims in this Policy, rather than taking our word for them. The source ships with every release as the sdist (source distribution) on PyPI (pypi.org/project/foxy-audit, under “Download files”), so the review needs no access to any repository, and what you download is exactly the code that pip install runs.

17. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. Material changes will be communicated to account holders by email or in-app notice prior to taking effect, and the effective date above will move to the date they take effect. Every revision, material or not, carries a new version number and last-updated date above.

18. Contact Us

Questions regarding this Policy, or requests concerning personal data, may be directed to privacy@foxyaudit.tech.

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