Privacy policy
Last updated: 30 May 2026
This policy covers the plaingraph private beta. It explains, in plain English, what personal data we handle and why. We keep it under active review and will update it as the beta develops; if we make a material change we will let beta users know.
Telliskivi 60a/5, B-building, 10412 Tallinn, Estonia
Estonian registry code 3335330
Data-protection contact: [email protected]
General contact: [email protected]
1. Who we are
plaingraph OÜ is the controller for personal data processed through the plaingraph service. The company is established in Estonia, and because the service handles UK registry data and may be used by people in the UK and the EU, UK and EU data-protection law (the UK GDPR and the EU GDPR) apply to this processing. Where the law requires it, we will appoint a representative; we will name it here once appointed.
2. Personal data we process
The service is built from public corporate-registry and sanctions data. This includes personal data published in UK Companies House records — for example company officers and persons with significant control — and names appearing on the UK Sanctions List and the OFAC Specially Designated Nationals list. We also process the basic account data of our beta users (such as name, email, and API-key activity) so we can run the service.
3. Why we are allowed to use it (lawful basis)
For the registry and sanctions data, our lawful basis is our legitimate interest (and the legitimate interests of our users) in providing accurate company-intelligence and sanctions-screening data built from public records — balanced against the rights of the people in that data. Because sanctions data can be a special category of data, we also rely on the substantial-public-interest basis for that processing. For beta-user account data, our basis is performing our agreement with you and our legitimate interest in running and securing the service. We can share our balancing assessment on request.
4. The questions you send us
The questions a user or agent sends to the service (what you screen) can be more sensitive than the public registry itself. We use them only to answer your request, to keep the service secure, and to fix faults. We do not mine your query data to build the product, we do not use it to profile the people you look up for our own purposes, and we do not sell it. Our analytics and error-monitoring tools never receive the contents of what you screen (see section 5).
5. Website analytics and error monitoring
We use PostHog (EU region) for product analytics on the marketing site and the signed-in dashboard. It is only loaded after you consent, runs no autocapture or session recording, and never receives the contents of what you screen. We rely on your consent for this analytics; you can withdraw it at any time from the cookie settings. Separately, we use Sentry (EU region) for error monitoring: it sets no cookies and receives only technical error data, with request bodies, query strings, headers and cookies stripped before any error is sent, so it never receives what you screen; we rely on legitimate interests for this. Both are processors acting on our instructions, are kept separate from billing records and security audit logs, and are listed in section 8.
6. Your rights and the takedown / suppression route
Individuals have rights under applicable data-protection law, including access, rectification, objection, and erasure where it applies. Because some data derives from the public register, certain rights interact with statutory publication rules, so we cannot always remove data that the public register still publishes — but we will explain our reasons and point you to the source. To request suppression or removal of personal data surfaced by plaingraph, or to exercise any right, contact [email protected]. We aim to respond within one month, in line with data-protection law.
7. How long we keep it
We keep data only as long as we need it. Registry and sanctions data is refreshed from source and carries an as-of timestamp. The questions you send us are kept for a short period to run and secure the service and then deleted or aggregated; security and audit logs are kept longer where we need them to protect the service or meet a legal obligation. Beta-user account data is kept while your account is active and for a reasonable period afterwards. We will confirm exact retention periods as the beta matures.
8. Sub-processors and international transfers
We use a small number of trusted providers ("sub-processors") to run the service. Each one only handles data to provide its part of the service, on our instructions and under data-protection terms. The sub-processors we use for the private beta are:
| Sub-processor | What it does | Region |
|---|---|---|
| Cloudflare | Hosting and edge network — the website, the API and dashboard, caching, queues, and object storage | Global edge network |
| Neon | Managed database for accounts, API-key metadata, usage, and audit records | EU (Frankfurt) |
| WorkOS | Sign-in and account identity for the dashboard | United States |
| PostHog | Product analytics — only after you consent (see section 5) | EU |
| Sentry | Error monitoring — technical error data only, no PII (see section 5) | EU |
The private beta is free, so we do not take payment and no payment-processor receives your data during the beta. Most data stays in the UK or EEA. Where a sub-processor is outside the UK/EEA — currently WorkOS in the United States — we rely on an appropriate transfer safeguard, such as the European Commission's Standard Contractual Clauses together with the UK International Data Transfer Addendum. We keep this list current as the beta develops; for the latest version, or a copy of the safeguards, email [email protected].
9. Complaints and supervisory authorities
If you think we have mishandled your personal data, please contact us first so we can put it right. You also have the right to complain to a data-protection authority: the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) where we are established, the UK Information Commissioner's Office (ICO) for UK matters, or the authority in your own EU country. We will confirm any data-protection-fee or registration details that apply to us here.
10. Contact
Privacy questions: [email protected].
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