Legal

PRIVACY
POLICY

Last updated: July 2, 2026

1. Who We Are

RGX Systems provides Automated AI Data Leakage Protection — a compliance and workspace infrastructure layer — to approved Partners (Value-Added Resellers and MSPs). Partners build their own products and services on top of our infrastructure and are solely responsible for their relationships with their own clients.

This policy covers data RGX Systems collects about its Partners. It does not govern the data Partners process on behalf of their own clients — Partners are independently responsible for their data practices and compliance obligations toward their end users.

2. Data We Collect

Partner Account Information

• Company name, contact name, and business email address provided at application
• Billing information processed securely by Stripe (we never store card details)
• Workspace configuration: plan tier, base fee, seat fee, and notes
• Workspace Security Token metadata: token prefix, creation date, last-used timestamp, and status (active/revoked) — we never store the plaintext token

Usage Data

Every request authenticated against your workspace is logged for billing and operational purposes:

• Endpoint called and HTTP method
• Timestamp and response status code
• Payload size in bytes and message count
• Processing units consumed and estimated processing cost (when pipeline processing is enabled)
• Processing time in milliseconds
• Source IP address of the API caller
• Metadata fields you pass in the request body (channel, reference IDs, etc.)

We do not log the content of your payloads — message text, contact names, and other payload data are processed in memory and not persisted to our database unless you explicitly pass them as metadata fields.

Application Data

• Information submitted in your Partner access application (business description, client base, pricing plan, etc.)
• Communications with our team relating to your account

3. How We Use Your Data

• To provision and manage your workspace and Workspace Security Token
• To calculate monthly billing: your negotiated base fee plus your negotiated per-active-seat rate, as set forth in your Order Form
• To generate usage summaries and billing reports accessible via the /usage endpoint
• To authenticate API requests by verifying your key hash
• To detect misuse, abuse, or security incidents on your node
• To send transactional emails: provisioning confirmations, key rotation notices, and invoices
• To diagnose technical issues and maintain infrastructure reliability

We do not sell your data. We do not use payload data for model training or third-party profiling. Your business data is yours.

4. PHI Handling and HIPAA Compliance

How PHI Is Processed

When a Partner submits a request to /api/v1/process with config.industry: "healthcare":

• The input is received over TLS 1.3 and held in process memory only
• Our Compliance Engine runs entirely in RAM, identifying and replacing HIPAA identifiers (SSNs, DOBs, MRNs, Insurance IDs, NPIs, phone numbers, email addresses, and street addresses) with sequentially numbered tokens such as {{REDACTED_PHI_1}}
• Person names are tokenized separately, as [NAME_1], [NAME_2], etc. — this step runs for every industry, including real_estate, which has no PHI/PII pattern ruleset of its own (see our Terms of Service for the full industry list)
• The scrubbed (de-identified) text is what gets sent to the LLM provider — the LLM never sees raw PHI or a raw name
• The original PHI string goes out of scope and is garbage-collected — no write occurs. Name tokens are the one bounded exception: a temporary, in-memory mapping is kept only long enough to translate a name token back to the real name in the response we return to you (never to the LLM provider), purged after 30 minutes of inactivity or immediately once the response is sent for a single-turn request
• Our usage log records only: byte counts, token counts, processing time, redaction pattern types, and redaction count — no PHI values, and no names

Business Associate Agreement (BAA)

RGX Systems will execute a Business Associate Agreement with any Partner whose clients operate in the healthcare sector. Render Services, Inc. (our infrastructure provider) has executed a HIPAA BAA with RGX Systems, establishing the required chain of agreements. To request a BAA, contact legal@rgxsystems.com or visit /baa.

PII Scrubbing — Professional Services, Finance, and Legal

When config.industry is set to "professional_services" or "finance", our Compliance Engine additionally redacts EINs, SSNs, account numbers, routing numbers, and payment card numbers before any LLM call, replacing them with {{REDACTED_FIN_N}} tokens; "legal" redacts privilege markers and case identifiers as {{REDACTED_LEG_N}}. Same zero-persistence guarantee applies, and person names are tokenized as described above regardless of which of these applies.

Technical Reference

For a full technical description of data movement through each processing stage, see the RGX Data Flow Diagram.

5. Non-Training Data Policy

RGX Systems does not use Partner payload data to train machine learning models. Specifically:

• Input text submitted to /api/v1/process or /api/v1/ingest is not stored in a form that could be used for model training
• We do not share payload data with any third party for training purposes
• Our LLM providers (Anthropic, OpenAI) operate under data processing agreements that explicitly prohibit use of API-submitted data for model training
• Usage metadata (token counts, request counts, etc.) that we do retain contains no message content and cannot be used to reconstruct submitted inputs

6. Pipeline Processing

When you call the /process endpoint with gateway routing enabled (by providing config.industry and config.routing_profile), input data is scrubbed of PHI/PII and person names before it is forwarded to our LLM provider under a data processing agreement that prohibits use of submitted data for model training.

If you use passthrough: true to run your own AI model instead of ours, we do not forward your data to any LLM ourselves — but the same scrubbing still applies before we hand the text back to you: PHI/PII patterns for your configured industry are replaced with numbered tokens, and person names are separately tokenized. This is so that no party's model, ours or yours, ever receives a raw name or a raw regulated identifier. In this mode, RGX Systems never reverses a name token back to the original value — the temporary, in-memory mapping used to keep the same name consistent across a conversation is purged automatically (30 minutes of inactivity, or immediately for a single-turn request) and is never written to disk, logs, or our database. See Section 4 for the equivalent detail on PHI/PII tokens.

7. Data Storage and Security

• All data is stored on secured cloud infrastructure (Render, PostgreSQL)
• Workspace Security Tokens are SHA-256 hashed before storage — we cannot retrieve your plaintext token
• Sensitive configuration data is encrypted at rest using AES-256-GCM
• All data is transmitted over TLS 1.3
• Access to production systems is restricted to authorised RGX Systems personnel only
• Usage event logs are retained for billing and audit purposes for 12 months, then purged

9. Subprocessors and Data Sharing

We share data only with the following trusted subprocessors necessary to operate our infrastructure. Each subprocessor operates under a data processing agreement with RGX Systems:

• Anthropic, PBC — LLM provider. Receives only scrubbed/de-identified text (no raw PHI/PII). Prohibited from using submitted data for model training. HIPAA-compliant data processing agreement in place.
• OpenAI, LLC — Secondary LLM provider (ultra-low-latency routing profile). Same restrictions as Anthropic — no raw PHI, no model training on submitted data.
• Render Services, Inc. — Cloud infrastructure and PostgreSQL database hosting. SOC 2 Type II certified. HIPAA BAA executed with RGX Systems.
• Stripe, Inc. — Payment processing for monthly invoicing. We never store card details; Stripe is PCI-DSS Level 1 certified.

We do not share your data with any other third parties, advertisers, or data brokers. Our full subprocessor list is available on request at security@rgxsystems.com.

10. Data Retention

• PHI: Zero retention. Raw PHI is never written to storage (scrubbed in-memory before any persistence).
• Partner account data is retained for the duration of your active workspace access
• API usage event logs (no PHI) are retained for 12 months for billing and audit purposes, then purged
• Monthly billing aggregates are retained for 7 years as required by applicable financial regulations
• Upon termination or node revocation, account data is deleted within 30 days upon written request

11. Seat-Metering Audit Rights

What Is Metered

The Seat Metering Ledger (GET /api/v1/usage, GET /api/v1/billing/summary) records the following per tenant workspace:

• seat_id — the unique identifier for each active user seat within a tenant
• first_seen — UTC timestamp of first authenticated request for the seat this billing period
• last_seen — UTC timestamp of most recent authenticated request
• request_count — total API requests from this seat during the billing period
• active — boolean; true if the seat had at least one authenticated request this calendar month

Partner Audit API Access

Partners may query their seat ledger at any time:

• GET /api/v1/usage?month=YYYY-MM — full seat-level breakdown for any historical month (up to 12 months)
• GET /api/v1/billing/summary — current month totals: active_seats, base_fee, seat_fee, estimated_total
• GET /api/v1/clients/:ref/usage — per-tenant seat activity for a specific workspace

All billing responses are returned as structured JSON and may be downloaded by Partners for independent verification. Responses include a billing_period, seat_count, per_seat_rate, and a line_items array with one entry per active seat.

Dispute Resolution

If you believe your seat count is incorrect, contact billing@rgxsystems.com within 14 days of invoice with the disputed month and your independently counted seat list. RGX Systems will respond within 5 business days with a line-item billing export. If the export confirms a metering error, a credit will be applied to the following invoice. RGX Systems will not charge a disputed seat without providing log-level evidence of authenticated activity.

12. Your Rights

As a Partner, you have the right to:

• Access the data we hold about your workspace and usage history via the /usage endpoint or by contacting us
• Request correction of inaccurate account information
• Request deletion of your account data (subject to billing retention requirements)
• Request a copy of your data in a portable format
• Withdraw consent and terminate your Partner access at any time
• Exercise seat-metering audit rights as described in Section 11

To exercise any of these rights, contact us at privacy@rgxsystems.com.

13. Cookies

Our public website uses minimal cookies necessary for session management. The API does not use cookies — all authentication is via the Workspace Security Token in the X-Api-Key header. We do not use tracking cookies or third-party advertising cookies.

14. Business-to-Business Service

RGX Systems is a strictly business-to-business infrastructure service. We do not knowingly collect or process data from individuals under 18, and we do not provide consumer-facing products or services.

15. Changes to This Policy

We may update this policy from time to time. We will notify Partners of material changes via email. Continued use of the infrastructure after changes constitutes acceptance of the updated policy.

16. Contact

For privacy-related questions or requests, contact us at:

Email: privacy@rgxsystems.com
Website: rgxsystems.com