Privacy Statement

1. Introduction

Wholegrain is a consulting-focused AI automation solution designed to enhance efficiency and scalability by completing work such as autonomous interviews and analysis for consulting projects. Wholegrain allows consulting professionals to extend their capabilities through AI agents, making the consulting process scalable and repeatable.

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes Wholegrain's policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

2. Data Protection Officer

Wholegrain is headquartered in Australia. Wholegrain has appointed an internal data protection officer for you to contact if you have any questions or concerns about Wholegrain's personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to Wholegrain's data protection officer. Wholegrain's data protection officer's name and contact information are as follows:

3. How We Collect and Use (Process) Your Personal Information

Wholegrain collects personal information about its website visitors and customers. This information generally includes:

• Email address (exclusively for identification and authorisation purposes)
• Mobile phone number (exclusively for identification and authorisation purposes)
• Agent Configuration (how you want the Wholegrain Agents to operate)
• Transcripts (inputs and outputs from conversations with Wholegrain Agents)
• Files (files you upload to Wholegrain to be researched by Wholegrain Agents)

We use this information to provide customers with services. We do not sell personal information to anyone and only share it with third parties subprocessors who are facilitating the delivery of our services.

Use of the Wholegrain Website, as is true of most other websites, Wholegrain's website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system, and other usage information about the use of Wholegrain's website, including a history of the pages you view and services you use. We use this information to help us design our site to better suit our users' needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

Wholegrain has a legitimate interest in understanding how members, customers, and potential customers use its website. This assists Wholegrain with providing more relevant products and services, with communicating value to our partners, and with providing appropriate staffing to meet member and customer needs.

4. Encryption Technology

Agent Configuration, Transcripts and Files are encrypted at rest using an AES encryption key that is unique to the owner of the Agent.

5. Training on Your Data

Wholegrain and its third-party subprocessors NEVER use your data for training purposes.

6. Cookies and Tracking Technologies

Cookies are used to identify your previous authentication to our services and identifies that assist in providing services.

7. Sharing Information with Third Parties

The personal information Wholegrain collects from you is stored in one or more databases hosted by third parties located in Australia. These third parties do not use or have access to your personal information for any purpose other than providing cloud services to us.

A list of our third-party subprocessors can be found here:

• Anthropic
• DigitalOcean
• Google
• OpenAI

We do not otherwise reveal your personal data to non-Wholegrain persons or businesses for their independent use unless: (1) you request or authorize it; (2) the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property, or safety, or the rights, property, or safety of our employees or others; (3) the information is provided to our agents, vendors, or service providers who perform functions on our behalf; (4) to address emergencies; or (5) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.

The Wholegrain website connects with third-party services such as Facebook, LinkedIn, Twitter, and others. If you choose to share information from the Wholegrain website through these services, you should review the privacy policy of that service. If you are a member of a third-party service, the aforementioned connections may allow that service to connect your visit to our site to your personal data.

8. Transferring Personal Data to Australia

Wholegrain has its headquarters in Australia. Information we collect about you will be processed in Australia. By using Wholegrain's services, you acknowledge that your personal information will be processed in Australia. Wholegrain endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Wholegrain and the practices described in this Privacy Statement. Wholegrain also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate. Since it was founded, Wholegrain has received zero government requests for information.

For more information or if you have any questions, please contact us at support@wholegrain.app.

9. Data Storage and Retention

Your personal data is stored by Wholegrain on its servers, and on the servers of the cloud-based database management services Wholegrain engages, located in Australia. Wholegrain retains service data for the duration of the customer's business relationship with Wholegrain and for a period of time thereafter, to analyze the data for Wholegrain's own operations, and for historical and archiving purposes associated with Wholegrain's services. Wholegrain retains prospect data until such time as it no longer has business value and is purged from Wholegrain systems. All personal data that Wholegrain controls may be deleted upon verified request from Data Subjects or their authorized agents.

For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at support@wholegrain.app.

10. Questions, Concerns, or Complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at: