This Privacy Policy ("Policy") governs the collection, use, storage, and disclosure of personal information and confidential data by Engram, Inc. ("Engram," "we," "us," or "our") in connection with the Engram cognitive telemetry platform ("Platform"). By accessing or using the Platform, you consent to the practices described in this Policy.
2.1 Account Information. We collect information you provide during registration: name, email address, professional role, firm type, industry specialization, and session preferences.
2.2 Session Data. When you use the Platform, we capture and process audio recordings, screen captures, and transcripts of expert analysis sessions. This data may contain Confidential Information Memoranda (CIMs), proprietary financial analyses, non-public financial data, and other material non-public information ("MNPI").
2.3 Derived Data. We generate structured cognitive event data from your sessions, including timestamped event boundaries, confidence scores, behavioral metadata, and reasoning traces ("Derived Data").
2.4 Usage Metadata. We collect platform interaction metadata including pages visited, features used, session timestamps, and IP addresses. We do not employ third-party behavioral tracking or advertising cookies.
Engram handles confidential financial data subject to regulatory requirements including, but not limited to, the Gramm-Leach-Bliley Act (GLBA) and SEC Regulation S-P. We implement administrative, technical, and physical safeguards designed to protect data confidentiality and integrity:
5.1 We do not sell personal information.
5.2 Derived Data (structured cognitive event traces) may be licensed to third parties for AI model training, solely in accordance with the licensing terms agreed upon during your onboarding and subject to per-customer royalty obligations.
5.3 We will not share raw session recordings, audio, or unprocessed transcripts with any third party without your explicit, prior written consent.
5.4 We may disclose information where required by law, regulation, subpoena, or court order, or where necessary to protect the rights, safety, or property of Engram, our users, or the public.
Account information is retained for the duration of your active account plus 12 months following termination. Session data and Derived Data are retained in accordance with the applicable data licensing agreement. Upon expiration of all applicable retention periods, data will be securely deleted or anonymized.
Subject to applicable law, you have the right to:
To exercise any of these rights, contact us at legal@engram.ai. We will respond within 30 days of receipt.
Your data may be processed in the United States regardless of your location. By using the Platform, you consent to the transfer of your information to the United States, where data protection laws may differ from those in your jurisdiction.
The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors.
We may update this Policy from time to time. Material changes will be communicated via email to the address associated with your account or through a prominent notice on the Platform at least 30 days prior to taking effect. Continued use of the Platform after the effective date constitutes acceptance of the revised Policy.
For questions regarding this Privacy Policy or our data practices, contact:
Engram, Inc.
legal@engram.ai
New York, NY