Privacy policy

Last updated: April 2026

The most important thing to know

Incleon offers two products with different data architectures, and where your data lives depends on which one you use:

• Incleon Vantage (board-level key-person risk view, formerly the Succession Management System) runs in your cloud infrastructure. Your succession planning data stays in your environment. Incleon does not host, access, or store your employee data.
• Incleon Trueground (institutional-knowledge layer for AI agents) is a managed cloud service hosted by Incleon on Google Cloud. The transcripts, decision frameworks, entity relationships, and rules you create in Trueground are stored in infrastructure we operate on your behalf, with strict tenant isolation.

This notice explains what we collect, how we use it, and the differences between the two products.

1. Our approach to privacy

Incleon builds infrastructure for managing the continuity gap — the operational risk that emerges when senior people leave and AI agents act on stale institutional knowledge. Both of our products handle information that is sensitive by nature: who holds critical knowledge in your organization, how decisions are actually made, and where your exposure concentrates.

We've designed each product around the data architecture that fits its use case. Vantage is deployed in your environment because succession data is among the most sensitive HR data an enterprise holds. Trueground is delivered as a managed service because the institutional-knowledge layer benefits from continuous improvement, AI processing, and integration with your operational systems — capabilities that are practical to deliver as software-as-a-service.

This Privacy Notice explains what information we collect across both products, how we use it, and your rights regarding it.

2. What we collect

Vantage (deployed in your environment)

What we don't collect:

• Your succession planning data
• Employee names, roles, or assessments
• Any content you create in the platform
• Organizational charts or talent data

Your business data stays entirely in your environment.

Trueground (hosted by Incleon)

Customer content we host on your behalf:

• Transcripts and source materials you upload for knowledge extraction
• Decision frameworks, rules, and entity relationships you create in the platform
• Knowledge artifacts and exports generated from your work (DMN XML, prompt libraries, Cypher exports)
• Operational signals from systems you connect (CRM events, policy changes, drift indicators)

This content is stored in encrypted, tenant-isolated databases on Google Cloud (Canada region by default). Each customer's data is segregated by tenant identifier at every layer — application, database, message bus, and graph store. You retain ownership of all content you upload or create.

AI processing: Trueground uses large language models to extract patterns from transcripts. By default, we use enterprise LLM providers (Anthropic, OpenAI) under data processing agreements that prohibit training on your content. You can configure Trueground to use a self-hosted model instead. We will tell you which providers your tenant is configured to use, and we will notify you before changing them.

Both products — information we collect about your use of our service

3. How we use your information

We use the information we collect to:

• Provide our service — Process payments, deliver updates, provide support, operate the Trueground platform
• Improve our product — Understand how features are used, fix bugs, plan enhancements
• Communicate with you — Send service updates, respond to inquiries, share relevant information
• Ensure security — Monitor for suspicious activity, protect against fraud, investigate incidents
• Meet legal obligations — Comply with applicable laws and regulations

What we do not do: We do not use your customer content (in Trueground) or your usage data to train general-purpose AI models. We do not sell your information. We do not share it for third-party marketing.

4. Who has access

We limit access to your information:

• Incleon staff — Only team members who need access to do their jobs (support, billing, product, site reliability for Trueground). Access to Trueground customer content is logged and limited to break-glass scenarios such as incident response, and only with customer-administrator authorization unless we are required by law to act otherwise.
• Service providers — Payment processors, email services, analytics tools, identity providers (WorkOS), cloud infrastructure (Google Cloud), and LLM providers for Trueground — all bound by confidentiality and data-processing agreements.
• Legal requirements — We may disclose information if required by law, court order, or to protect rights and safety. Where legally permissible, we will notify the affected customer before disclosure.

We do not sell your information. We do not share it for third-party marketing.

5. Data controller and processor roles

This is important for GDPR, PIPEDA, and similar privacy regulations:

• Vantage employee data: You (the customer organization) are the data controller. You determine what data to collect, how to use it, and how long to keep it. Because Vantage runs in your environment, Incleon is not a data processor for this data — we are a software provider only.
• Trueground customer content: You are the data controller for the content you upload and create in Trueground. Incleon is a data processor, acting on your documented instructions. A Data Processing Addendum is available to enterprise customers and forms part of the master subscription agreement on request.
• Account and usage data (both products): Incleon is the data controller for information we collect about your organization's use of our service.

6. Your rights

Depending on your jurisdiction, you may have rights regarding information we hold about you:

• Access — Request a copy of your information
• Correction — Ask us to correct inaccurate information
• Deletion — Request deletion of your information
• Portability — Receive your information in a portable format
• Objection — Object to certain processing activities

To exercise these rights, contact us at privacy@incleon.com.

For employee data in Vantage: Since that data is in your environment, contact your organization's HR or IT team directly.

For content in Trueground: Customer administrators can export, modify, or delete content directly through the application. On subscription termination, customer content is deleted from production systems within 30 days and from backups within 90 days, unless you request earlier deletion or longer retention is required by law.

7. Data security

We protect the information we collect through:

• Encryption in transit (TLS) and at rest
• Identity-based access controls and multi-factor authentication for staff
• Tenant isolation enforced at application, database, and infrastructure layers (Trueground)
• Regular security assessments, vulnerability scanning, and dependency monitoring
• Audit logging of administrative and break-glass access to customer environments
• Employee training and confidentiality agreements
• Incident response procedures with customer notification commitments

Your responsibility for Vantage: Security of your Vantage deployment is your responsibility. We provide documentation, hardening guides, and best practices to help you maintain a secure configuration.

Shared responsibility for Trueground: We secure the platform; you control user access, role assignments, and what content you upload. We recommend reviewing our hosted security overview and configuring single sign-on through your identity provider.

8. Data retention

• Account information: Retained while your subscription is active, plus a reasonable period after for legal and business purposes.
• Usage analytics: Aggregated and anonymized data may be retained indefinitely for product improvement.
• Support records: Retained for 3 years after resolution for quality and training purposes.
• Trueground customer content: Retained for the life of your subscription. On termination, deleted from production within 30 days and from backups within 90 days, unless a longer retention period is required by law or expressly agreed.
• Vantage employee data: You determine retention in your environment. When you end your subscription, your data remains with you — we have nothing to delete.

9. International transfers

Incleon is based in Canada, which has been recognized by the European Commission as providing adequate data protection. If you're outside Canada, information we collect may be transferred to and processed in Canada.

Trueground hosting region: By default, Trueground customer content is hosted in Google Cloud's Canada region. EU-based customers can request hosting in an EU region; this is available on enterprise plans. LLM processing for AI extraction may involve transfer to providers operating in the United States under standard contractual clauses; you can opt for a self-hosted model to avoid this transfer.

Vantage: Your employee data stays in whatever region you choose to deploy your infrastructure.

10. Children's privacy

Incleon products are business applications not intended for use by children under 16. We do not knowingly collect information from children.

11. Changes to this notice

We may update this Privacy Notice from time to time. We'll post changes on this page and update the "Last updated" date. For significant changes — such as new categories of data collection, new sub-processors, or changes to data location — we'll provide notice via email to account contacts at least 30 days before they take effect.

12. Contact us

Incleon Holdings Inc.

• Privacy inquiries: privacy@incleon.com
• General: info@incleon.com
• Web: www.incleon.com