Privacy Policy

Last Updated: 2026-06-18

1. Introduction

This Privacy Policy explains how Provisionr, LLC (“Provisionr,” “we,” “us,” or “our”) collects, uses, stores, shares, and protects information when you visit our websites (provisionr.io, docs.provisionr.io, <REGION>.provisionr.io, community.provisionr.io), use our cloud-hosted platform (<WORKSPACE_ID>.provisionr.app), interact with our CLI or API, participate in our community channels, or otherwise engage with our services (collectively, the “Service”).

Provisionr is a policy-based user provisioning platform. We automate group membership management across identity providers and SaaS applications on behalf of our Customers. This means we process two fundamentally different kinds of information: data about the people and organizations that sign up for and administer the Service, and data that our Customers push through the Service about their workforce and organizational structure. These two kinds of data carry different legal roles, different retention rules, and different rights. This policy addresses both and explains precisely how we treat each.

If you are an employee or member of an organization that uses Provisionr, your employer or organization is the data controller for the workforce identity data processed through the Service. Questions about how your organization uses Provisionr should be directed to your organization’s IT or identity team. If your organization is unresponsive and you believe your data is being processed improperly, you may contact us directly at privacy@provisionr.io.

2. Data Categories and Legal Roles

We classify all information we process into four categories. Where a category contains personal data, the controller and processor roles are stated explicitly. Understanding these categories is essential to understanding your rights and our obligations.

2.1 Administrative Data

What it includes: Business contact and account information relating to you and your authorized users, including names, business email addresses, job titles, billing and payment details, commercial and sales records, and the contents of support, sales, and account correspondence.

Our role: Provisionr processes Administrative Data as a controller for the purposes of account administration, billing, sales, customer support, and meeting our legal obligations.

Important distinction: Where a support request you submit contains Platform Data (defined below), that content is governed as Platform Data and not Administrative Data.

2.2 Platform Data

What it includes: The identity and governance data that you manage through the Service, including user and group records, access policies, entitlement and assignment data, audit reports, and audit logs, together with all other personal data that the Service processes on your behalf.

Specific data elements depend on the integrations you configure, but typically include user profile attributes (name, email address, department, job title, job level, location, manager, employment status, and custom attributes you define), group membership data (Google Workspace Groups, Okta Groups, GitLab Groups and Projects, Slack User Groups), organizational structure data (team hierarchies, reporting relationships, attribute dimensions), and policy configuration data (rulesets, conditions, sync manifests, and the mapping between user attributes and group memberships). Your administrator has full control to enable or disable the processing and storage of attributes to allow you to exempt protected data as needed.

Your role: You are the controller of Platform Data. Provisionr is the processor. We process Platform Data only on your documented instructions, which include these Terms, your configuration and use of the Service, and your establishment and configuration of integrations with third-party systems, except where we are required to process by applicable law. We do not access Platform Data other than as necessary to provide, maintain, secure, and ensure the reliability of the Service, to respond to a support request you submit, or as required by law.

2.3 Infrastructure Data

What it includes: Data generated by Provisionr in the course of operating, securing, monitoring, and improving the Service, including access logs, error logs, system and application telemetry, health checks, and diagnostic and bug-report data. Infrastructure Data may incidentally contain limited identifiers such as IP addresses, request metadata, and timestamps.

Our role: Provisionr processes Infrastructure Data as a controller. We do not use Infrastructure Data to reconstruct or derive the substantive contents of Platform Data.

2.4 Analytics Data

What it includes: Usage data derived from your use of the Service that Provisionr has aggregated and de-identified so that it can no longer reasonably be used to identify, or be attributed to, an individual authorized user or an individual Customer.

Our role: Provisionr processes Analytics Data as a controller for the purpose of measuring, maintaining, and improving the Service. We do not attempt to re-identify Analytics Data and maintain technical and organizational measures designed to prevent re-identification.

3. Information We Collect

3.1 Account and Registration Information

When you create a Provisionr Workspace (<WORKSPACE_ID>.provisionr.app) through our regional HQ website (<REGION>.provisionr.io), we collect the information necessary to set up and administer your account. This includes your name, email address, organization name, and authentication credentials (via Sign in with Google or SSO through Google or Okta). If you subscribe to a paid plan, billing and payment details are collected through Chargebee-hosted checkout pages and processed by Stripe. Cardholder data is entered directly into Chargebee-hosted pages; Provisionr stores only plan metadata and your organization name, never payment methods, mailing addresses, or phone numbers.

This information constitutes Administrative Data and is processed by Provisionr as a controller.

3.2 Workforce Identity Data

When you connect your identity providers and SaaS applications to the Service, the platform ingests and caches workforce identity data from those sources. The specific data elements are described in Section 2.2 (Platform Data). This data is processed by Provisionr as a processor on your behalf.

Cached, encrypted copies of data from your connected systems are stored at rest within the Provisionr platform in your selected hosting region for policy management and evaluation. The third-party systems you connect through integrations (Google Workspace, Okta, GitLab, Slack) are your own connected systems and are not Provisionr subprocessors.

3.3 Service Usage and Operational Data

We collect information about how you and your authorized users interact with the Service to maintain operations, diagnose issues, and improve the platform:

Audit logs recording provisioning actions (group membership additions and removals), policy evaluations, sync events, and administrative actions such as policy creation, modification, and deletion. Audit logs are retained for 3 years. For Enterprise Customer-Managed deployments, log retention is controlled by the Customer, as described in Section 5.7.
CLI and API usage data including command invocations, API endpoints called, request timestamps, and error codes.
Sync operation records including sync start and completion times, the number of users and groups evaluated, and any errors or warnings generated during synchronization.

Audit logs constitute Platform Data and are retained as Platform Data Logs. Operational telemetry (error logs, performance data, health checks) and access and debug logs constitute Infrastructure Data and are retained as Infrastructure Logs. Retention periods for each are described in Section 5.6.

3.4 Website Visitor Data

When you visit our marketing websites (<REGION>.provisionr.io), we use Plausible Analytics, a privacy-focused analytics service hosted in the European Union (Estonia). Plausible does not use cookies, does not collect personal data, does not track individuals across sites, and does not build visitor profiles. All Plausible analytics data is aggregated and anonymous.

Browsing our marketing pages sets no cookies on your device. A session cookie is placed only when you use the Provisionr application. It stores a temporary session identifier, is strictly necessary for the application to function, and protects against cross-site request forgery. It does not track you across other websites, and we do not use it for advertising.

We use this session identifier within the application and, as part of our access logs, to operate, secure, and troubleshoot our services. These access logs are Infrastructure Data, described in Section 2.3, and may include the session identifier alongside request metadata and timestamps.

We also keep an aggregate count of how often each quote builder option is selected, so we can gauge interest in our products and improve them. This count is not tied to your session or to your identity, and it constitutes Analytics Data, described in Section 2.4.

If you choose to accept a quote, we will ask you to authenticate using Sign in with Google. Accepting a quote begins your service relationship with us. At that point we collect your business contact information from your Google account and link it to your quote, so we can administer your account and bill you for the services you have requested. From that point onward, this information is handled as Administrative Data, described in Section 2.1 and Section 3.1.

No other personal data from website visits is transmitted to Provisionr or to any third party.

Our documentation site (docs.provisionr.io) is hosted by Mintlify. Website visitor data on the documentation site is governed by Mintlify’s privacy practices. Mintlify does not process Customer Data.

3.5 Community and Communication Data

When you participate in our Slack community (community.provisionr.io), submit support requests, or communicate with us via email or phone, we collect the content of those communications, your contact information, and any attachments or files you share. Support ticketing is handled through Front; VoIP telephony and voicemail are handled through Quo. Community interactions hosted on Slack are also subject to Slack’s privacy policy.

This information constitutes Administrative Data, except where support requests contain Platform Data, which is governed as Platform Data.

3.6 Information We Do Not Collect

Provisionr does not collect or process the following:

Passwords or authentication secrets from your connected identity providers. We use OAuth tokens and API keys with scoped permissions to access connected platforms.
The content of emails, files, documents, messages, or communications within your connected platforms. We access only the user profile attributes, group memberships, and organizational structure data necessary to evaluate policies and provision group memberships.
Personal information from individuals under the age of 18 (see Section 12).
Biometric data, health information, or financial account information of workforce members (beyond what may incidentally appear in job title or department fields controlled by you).

4. How We Use Information

4.1 Providing and Operating the Service

We use Administrative Data and Platform Data to authenticate users and manage Workspace access; ingest and cache workforce identity data from your connected identity providers and SaaS applications; evaluate policy rules and conditions against user attributes to determine group membership eligibility; execute provisioning and deprovisioning actions across connected integrations; generate and maintain audit logs; process billing and manage subscriptions; and provide customer support.

4.2 Maintaining and Improving the Service

We use Infrastructure Data and Analytics Data in aggregate to identify and resolve bugs, optimize sync performance, plan infrastructure capacity, and improve the reliability of the platform. We do not use Platform Data to develop features for other customers or for any purpose beyond operating the Service for the Customer who provided it.

4.3 Security and Fraud Prevention

We use Infrastructure Data (IP addresses, authentication logs, API access patterns) to detect and prevent unauthorized access, abuse, and fraud. This includes monitoring for suspicious login activity, API rate limit violations, and unauthorized attempts to access Workspaces.

4.4 Communications

We use your Administrative Data to send transactional communications related to the operation of your Workspace, including sync failure alerts, security notifications, billing confirmations, and service announcements. We may also send product updates and feature announcements. You may opt out of non-transactional communications at any time, but transactional communications necessary for the operation of your account cannot be opted out of while your account is active.

4.5 Legal Compliance

We may use information as necessary to comply with applicable laws, regulations, or valid legal process, subject to the legal process requirements described in Section 9 of this policy and Section 17 of our Terms of Service.

5. How We Store and Protect Information

5.1 Infrastructure and Data Isolation

The Provisionr platform is hosted on Google Cloud Platform. Each Workspace is provisioned with a per-tenant database and a per-tenant, column-level encryption key, so your data is not commingled with another Customer’s data at the database level. On the Essentials tier, the database runs on a shared instance with shared compute, IAM, key management, and network resources. The Enterprise Provisionr-Managed tier provides additional infrastructure isolation. The Enterprise Customer-Managed deployments are hosted in the Customer’s own AWS account or GCP project that Provisionr does not have access to. Infrastructure specifications for each tier are described in the Documentation and on the Pricing page.

5.2 Data Residency

Provisionr stores Platform Data for Provisionr Cloud tiers (Essentials and Enterprise Provisionr-Managed) in the hosting region you select. At launch, the United States is the only available region. We plan to support additional regulated regions: EU, Canada, Australia, Mexico, Japan, Brazil, and India. Primary hosting is on Google Cloud Platform with regional failover where available. Cross-cloud disaster-recovery backups use AWS as an offline recovery tier and are available as an opt-out at all tiers. Where a subprocessor cannot serve your selected region, we default to United States facilities for the US region and European Union facilities for all other regions. The subprocessor list in Section 6.3 identifies each subprocessor’s data location so you can assess any cross-border transfer.

For Enterprise Customer-Managed deployments, Platform Data resides in the Customer’s own AWS account or GCP project in the respective region the Customer selects, and the Customer controls its own residency.

5.3 Encryption

Platform Data is encrypted in transit using TLS 1.2 or higher for all connections to the Service, including web access, CLI, and API. Platform Data is encrypted at rest using column-level encryption keys managed through Google Cloud KMS, with each Workspace receiving its own encryption key. Disaster-recovery backups on AWS are encrypted at rest using AWS-managed encryption.

5.4 Access Controls

Access to Platform Data within Provisionr’s infrastructure is restricted to authorized personnel who require access to perform their job functions (such as infrastructure maintenance and customer support). Access is controlled through role-based access controls, multi-factor authentication, and audit logging of all administrative access to production systems.

5.5 Integration Credentials

OAuth tokens, API keys, and other credentials used to connect the Service to your identity providers and SaaS applications are stored encrypted using Google Cloud Secret Manager and are accessible only to the sync processes operating within your Workspace. Provisionr personnel do not have access to plaintext integration credentials except in the course of diagnosing a support issue with your explicit authorization.

5.6 Retention

We retain Platform Data for the duration of your active subscription. Upon termination of your account, we delete all Platform Data within 30 days, unless a longer retention period is required by law, requested by you in writing, or specified in a separate agreement. Disaster-recovery backups age out of rotation on their ordinary cycle.

Personal data relating to a deprovisioned user, contractor, or other authorized user within your Workspace is retained for 90 days unless you specify a different period, after which the record is transformed into a de-identified ghost user record that preserves audit integrity without retaining the individual’s personal data.

Platform Data Logs, such as audit logs, are retained for 3 years. Infrastructure Logs, such as access, error, and debug logs, are retained for 90 days. For Enterprise Customer-Managed deployments, log retention is controlled by the Customer, as described in Section 5.7.

You may request earlier deletion of your data by contacting support@provisionr.io. You may export your data at any time via the CLI, API, or CSV/JSON/YAML export functionality prior to account termination.

5.7 Customer-Managed Deployments

For Enterprise Customer-Managed deployments, all data processing and storage occurs within the Customer’s own AWS account or GCP project. Provisionr does not have access to, and is not responsible for, any data stored in Customer-Managed deployments unless the Customer explicitly grants access (for example, during a support engagement). Data security, encryption, access controls, retention, and deletion for Customer-Managed deployments are the sole responsibility of the Customer.

6.1 We Do Not Sell Your Data

Provisionr does not sell, rent, lease, or trade Platform Data, Administrative Data, or personal information to any third party. We do not share your data with third parties for their marketing or advertising purposes. We do not participate in advertising networks or retargeting programs.

6.2 We Do Not Use Your Data for AI or Model Training

Provisionr does not use Platform Data, or any other Customer Data, to train, fine-tune, or otherwise develop machine learning or artificial intelligence models, whether for our own purposes, for the benefit of other customers, or for any third party, without your prior written consent. We do not use Analytics Data to reconstruct, or to train models on, identifiable Platform Data, and we do not attempt to re-identify it. Our access analytics and anomaly detection features, including Access Intelligence, run on Provisionr’s own proprietary code and do not rely on or transmit Platform Data to any third-party AI model or service. If the Service later adds a feature that relies on a third-party AI service, we will describe how it handles your data, add the service to our subprocessor list, and provide notice under our subprocessor change process before it begins processing Platform Data. See Section 10 for the full AI and Machine Learning commitment.

6.3 Subprocessors

We use a limited number of third-party service providers (“subprocessors”) to operate the Service. Each subprocessor is contractually bound to maintain security standards consistent with our own, to process data only as necessary to provide the services we have engaged them to perform, and to impose data protection obligations that are substantially equivalent to those in our agreements.

We maintain the current list of subprocessors in this section. As of the effective date of this policy, our subprocessors include:

Subprocessor	Purpose	Data Categories Processed	Processes Platform Data	Data Region
Google LLC / Google Ireland Ltd (Google Cloud Platform)	Core hosting: Compute Engine, Cloud Run, Cloud SQL, Cloud Storage, Cloud KMS, Secret Manager, Cloud Monitoring	All four	Yes, at rest	Customer-selected GCP region
Amazon Web Services, Inc. / AWS EMEA SARL	Immutable disaster-recovery backups (S3); Marketplace transaction handling for private-offer purchases	Platform (backups), Administrative (Marketplace)	Yes, encrypted backups at rest (opt-out available)	US (Ohio) for US region; EU (Ireland) otherwise
Cloudflare, Inc.	Edge network, load balancing, DNS, reverse proxy, bot mitigation (Turnstile)	Platform (in transit), Infrastructure, visitor data	In transit only	Global edge
Chargebee Inc.	Subscription and billing management via Chargebee-hosted checkout	Administrative	No	US (Virginia), EU (Frankfurt), or AU (Sydney) via AWS
Stripe, Inc. / Stripe Payments Europe, Ltd.	Payment processing (administered through Chargebee)	Administrative (payment data)	No	US or EU
Functional Software, Inc. (dba Sentry)	Application error monitoring and bug reports	Infrastructure	Incidental, via error payloads (with PII scrubbing)	US (Iowa) or EU (Frankfurt)
Mailgun Technologies, Inc. (a Sinch company)	Transactional and service email delivery	Administrative	No	US or EU per region
FrontApp, Inc.	Support ticketing and email correspondence	Administrative	Incidental, via ticket content	US or EEA via AWS
OpenPhone Technologies, Inc. (dba Quo)	VoIP telephony and voicemail transcription	Administrative	No	US
Laravel Holdings Inc. (Laravel Nightwatch)	Application performance monitoring	Infrastructure	No	US

Vendors disclosed for transparency (do not process Customer Data):

Vendor	Purpose	Data Involved
Plausible Insights OÜ	Marketing website analytics	Website visitor data only (cookieless, aggregated, EU-hosted)
Mintlify, Inc.	Hosting of public, unauthenticated documentation	Website visitor data only
Slack Technologies, LLC	Opt-in community for engineering and support discussion	Voluntary participant data only

These vendors are not processors of Customer Data. The Slack community is distinct from the Customer-controlled Slack integration described in Section 6.4.

6.4 Customer-Controlled Integrations

The core function of the Service is to read user attribute data from your connected identity providers and write group membership changes to your connected SaaS platforms. The third-party systems you connect (Google Workspace, Okta, GitLab, Slack) are your own connected systems. Provisionr acts solely as a processor of the data made available through these connections, for the sole purpose of providing the Service. These third-party platforms are not Provisionr subprocessors. Provisionr does not share your data with any connected platform beyond executing the membership changes specified by your policies.

6.5 Professional Services and Support

If you engage Provisionr for Professional Services or request hands-on support that requires access to your Workspace data, Provisionr personnel may access Platform Data to the extent necessary to deliver the requested services. Such access is limited in scope and duration to what is required for the engagement.

6.6 Legal Requirements

We may disclose information when required by Valid Legal Process (as defined in our Terms of Service), subject to the standards described in Section 9 of this policy and Section 17 of our Terms of Service.

6.7 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, data may be transferred to the acquiring entity. We will provide notice to affected Customers before any such transfer and will require the acquiring entity to honor the commitments made in this Privacy Policy.

7. Subprocessor Changes and Notification

We maintain the current list of subprocessors in Section 6.3 of this policy, identifying each subprocessor, the processing it performs, and its location. The “Last Updated” date at the top of this policy reflects the most recent change to that list.

Before a new subprocessor begins processing Platform Data, we give at least 30 days’ advance notice by email to the account contacts associated with your Workspace.

You may object to a new subprocessor within the notice period on reasonable data protection grounds by notifying us at support@provisionr.io. We will work in good faith to resolve the objection. If the objection cannot be resolved and we proceed with the subprocessor, you may terminate the affected Service and receive a pro-rata refund of prepaid fees for the unused portion of the then-current term.

Where we must replace or engage a subprocessor on an expedited basis to address a security, legal, or availability event, we may do so before the notice period elapses and will notify you by email as soon as reasonably practicable, together with the reason for the expedited change.

This notification process applies to subprocessors that process Platform Data for Provisionr Cloud tiers. It does not apply to the third-party systems you connect through integrations (which are your own systems) or to Enterprise Customer-Managed deployments (where Platform Data resides in your own AWS account or GCP project and you select your own infrastructure providers).

8. Cookies and Tracking Technologies

8.1 Marketing Websites

Our marketing pages (provisionr.io) set no cookies of any kind. They are served without a session, so no session or cross-site request forgery cookie is issued while you browse them. For analytics we use Plausible Analytics, a cookieless, privacy-focused service hosted in the European Union. Plausible does not set cookies, does not collect personal data, does not track individuals across sites, and does not build visitor profiles. We do not use third-party advertising cookies, cross-site tracking pixels, behavioral profiling technologies, or retargeting on any of our websites.

Signing in moves you into the Provisionr application, which does use essential cookies; see Section 8.2.

8.2 Application and Documentation

The Provisionr application (<REGION>.provisionr.io and <WORKSPACE_ID>.provisionr.app) uses essential cookies required for authentication and session management (such as maintaining your login state). These cookies are necessary for the Service to function and cannot be disabled while using the application. Our documentation site (docs.provisionr.io) is hosted by Mintlify; site cookies on that domain are governed by Mintlify’s privacy practices.

8.3 Bot Mitigation

Cloudflare Turnstile is used for bot mitigation on certain pages. Turnstile may set functional cookies as part of its challenge process. These cookies are not used for advertising or tracking.

8.4 Managing Cookies

You may control cookies through your browser settings. Disabling essential cookies may prevent you from accessing authenticated areas of the Service. For more information on managing cookies, refer to your browser’s help documentation.

9. Law Enforcement and Government Requests

Provisionr’s approach to law enforcement and government requests is governed by the principles of minimal disclosure, valid legal process, and customer transparency.

We will not disclose Platform Data or Administrative Data to any government agency or law enforcement body unless compelled by a valid and binding legal instrument, meaning a court order, search warrant, or lawfully issued subpoena that meets applicable jurisdictional requirements (“Valid Legal Process”). Informal requests, voluntary disclosure programs, and non-binding government inquiries do not result in disclosure of your data.

When we receive Valid Legal Process, we limit our response to the minimum data specifically identified in the instrument. We will challenge requests that are overly broad, vague, or legally deficient where it is reasonable and practical to do so.

We will notify the affected Customer prior to any disclosure unless notification is explicitly prohibited by the legal instrument or by applicable law, or unless we reasonably believe notification would create a risk of serious physical harm.

In extraordinary circumstances involving an imminent threat of death or serious physical injury, we may disclose data to law enforcement without Valid Legal Process, but only to the extent reasonably necessary to address the imminent threat. We will notify the affected Customer as soon as legally and practically possible following any such emergency disclosure.

We may publish aggregate statistics regarding the number and types of government requests received, to the extent permitted by law, without disclosing Customer-identifying information.

10. Artificial Intelligence and Machine Learning

This section provides the detailed statement of our AI and machine learning commitments.

No model training on Customer Data. We do not use Platform Data, or any other Customer Data, to train, fine-tune, or otherwise develop machine learning or artificial intelligence models, whether for our own purposes, for the benefit of other customers, or for any third party, without your prior written consent.

Analytics Data. We may use Analytics Data (which is aggregated and de-identified as described in Section 2.4) to measure, maintain, and improve the Service. We do not use Analytics Data to reconstruct, or to train models on, identifiable Platform Data, and we do not attempt to re-identify it.

Subprocessors and third-party AI. We do not transmit Platform Data to any third-party artificial intelligence service except where that service is a listed subprocessor engaged to provide the Service and is contractually bound not to use the data to train or improve its own models. We will add any such subprocessor to our subprocessor list and provide notice under the process described in Section 7 before it begins processing Platform Data.

Automated provisioning is Customer-directed. The Service executes provisioning and deprovisioning decisions according to the policies, attributes, and conditions that you define and control. We do not perform independent automated profiling of data subjects and do not make solely automated decisions that produce legal or similarly significant effects on data subjects of our own initiative. As the controller of Platform Data, you are responsible for the lawfulness of the policies you configure, including any safeguards required for automated decision-making under applicable data protection law.

Proprietary analytics. Our access analytics and anomaly detection features, including Access Intelligence, run on Provisionr’s own proprietary code. They do not rely on, and do not transmit Platform Data to, any third-party artificial intelligence model or service.

Future AI features. If the Service later adds a feature that relies on a third-party AI service, we will describe how it handles Customer Data in this section, add the service to our subprocessor list, and provide notice under the subprocessor change process before it begins processing Platform Data.

11. Your Rights and Choices

11.1 Customer Rights (Workspace Administrators)

As a Provisionr Customer, you have the right to:

Access all Platform Data and Administrative Data in your Workspace at any time through the CLI, API, or export functionality.
Correct any data within your Workspace by modifying your policies, attributes, or integration configurations.
Delete your data by deactivating policies, removing integrations, or requesting full Workspace deletion by contacting support@provisionr.io.
Export your data in CSV, JSON, or YAML format at any time.
Restrict processing by deactivating policies or disconnecting integrations to stop specific sync operations.
Object to processing: if you believe data is being processed incorrectly, contact support@provisionr.io and we will investigate promptly.
Object to subprocessors: you may object to new subprocessors within the notice period as described in Section 7.

11.2 Workforce Member Rights (Employees of Customers)

If you are an employee or member of an organization that uses Provisionr, your workforce identity data is processed by Provisionr as a processor on behalf of your organization. Your organization is the data controller and determines what data is shared with the Service and how it is used.

To exercise your data protection rights (access, correction, deletion, portability, or objection to processing), please contact your organization’s IT, HR, or identity team directly. We will cooperate with our Customers to fulfill verified data subject requests in a timely manner.

If your organization is unresponsive and you believe your data is being processed improperly, you may contact us at privacy@provisionr.io. We will work to resolve the issue in coordination with your organization. If we receive a data subject request directly from you relating to Platform Data, we will refer you to your organization and will not respond on the substance except on your organization’s instruction.

11.3 California Residents (CCPA/CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act and the California Privacy Rights Act, including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the sale or sharing of personal information.

As stated in Section 6.1, Provisionr does not sell or share personal information. With respect to Platform Data, Provisionr acts as a service provider, processes it only for the business purposes set out in these Terms, and does not sell or share it or retain, use, or disclose it outside the direct business relationship or for any purpose other than providing the Service.

To exercise your CCPA/CPRA rights, contact privacy@provisionr.io.

If you are located in the EEA, UK, or Switzerland, you may have additional rights under the General Data Protection Regulation or equivalent legislation, including the right to access, rectification, erasure, data portability, restriction of processing, objection to processing, and the right not to be subject to solely automated decision-making.

Our legal basis for processing personal data depends on the data category and context:

Administrative Data: Performance of a contract (for account holders), legitimate interests (for service improvement and security), and compliance with legal obligations.
Platform Data: Processing on your documented instructions as a processor (Article 28).
Infrastructure Data: Legitimate interests (security, reliability, and service improvement).
Analytics Data: Legitimate interests (service measurement and improvement), processed only in aggregated and de-identified form.

For Platform Data, you are the controller and Provisionr is the processor. Our data processing terms (see Section 13) are drafted to satisfy the requirements of Article 28 GDPR. Customers subject to GDPR may enter into a Data Processing Agreement (DPA) by contacting support@provisionr.io. Where Platform Data is transferred to a country without an adequacy decision, the transfer is governed by Standard Contractual Clauses or, for transfers subject to UK law, the UK International Data Transfer Addendum.

You have the right to lodge a complaint with your supervisory authority if you believe your rights have been violated.

To exercise your rights, contact privacy@provisionr.io. We will respond within 30 days, or within the timeframe required by applicable law.

12. Children’s Privacy

The Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe that a child has provided personal information to us, please contact us at privacy@provisionr.io.

Platform Data processed through the Service may incidentally include information about individuals under 18 if such individuals are members of your organization (for example, interns). You are responsible for ensuring that your use of the Service complies with applicable child protection and data privacy laws.

13. Data Processing Terms

These terms apply where Provisionr processes Platform Data on your behalf. They are designed to satisfy the requirements of Article 28 GDPR and function as a Data Processing section within this agreement. They may also be executed as a standalone Data Processing Addendum upon request.

13.1 Roles and scope. With respect to Platform Data, you are the controller and Provisionr is the processor. With respect to Administrative Data, Infrastructure Data, and Analytics Data, Provisionr acts as a controller, and those activities are governed by the remainder of this Privacy Policy. Capitalized data terms have the meanings given in these Terms, and “Controller,” “Processor,” “Process,” “Personal Data,” “Data Subject,” and “Personal Data Breach” have the meanings given in applicable data protection law.

13.2 Details of the processing. The subject matter is the provision of the Service. The duration is the term of the agreement plus the deletion period in Section 13.10. The nature and purpose is the identity governance and administration functionality of the Service. The types of personal data are the identity, group, entitlement, policy, and audit records that you manage through the Service, including data made available through your connected integrations. The categories of data subjects are your employees, contractors, and other authorized users whose records you administer.

13.3 Processing on documented instructions. Provisionr processes Platform Data only on your documented instructions, which include this Privacy Policy, the Terms of Service, your configuration and ordinary use of the Service, and your establishment and configuration of integrations with third-party systems, unless required to process by a law to which Provisionr is subject, in which case Provisionr informs you of that requirement before processing where the law permits. Provisionr promptly informs you if, in its opinion, an instruction infringes applicable data protection law.

13.4 Confidentiality. Provisionr ensures that persons authorized to process Platform Data are bound by an appropriate obligation of confidentiality and process Platform Data only as instructed.

13.5 Security. Taking account of the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing, Provisionr implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, consistent with Article 32 GDPR. These measures include per-tenant database isolation, per-tenant column-level encryption, encryption in transit (TLS 1.2+), encryption at rest (Cloud KMS), role-based access controls, multi-factor authentication for production access, and audit logging of administrative access. A current description of security measures is available to you on request.

13.6 Subprocessors. You provide general authorization for Provisionr to engage the subprocessors listed in Section 6.3 of this Privacy Policy, as updated from time to time. Third-party systems that you connect through integrations are your own systems and are not Provisionr subprocessors. Provisionr imposes data protection obligations on each subprocessor that are substantially equivalent to those in these terms and remains liable for each subprocessor’s performance. The subprocessor notification process is described in Section 7.

13.7 Assistance with data subject rights. Taking into account the nature of the processing, Provisionr assists you by appropriate technical and organizational measures, insofar as possible, to respond to requests by data subjects exercising their rights. Where the Service allows you to access, correct, export, or delete Platform Data directly, that functionality constitutes the assistance for those requests. If Provisionr receives a request directly from a data subject relating to Platform Data, it refers the data subject to you and does not respond on the substance except on your instruction.

13.8 Breach notification and impact assessments. Provisionr notifies you without undue delay after becoming aware of a personal data breach affecting Platform Data and provides the information reasonably available to it to allow you to meet your own notification obligations. Provisionr provides reasonable assistance with data protection impact assessments and prior consultations under Articles 35 and 36, taking into account the nature of the processing and the information available to Provisionr.

13.9 International transfers. Where Provisionr or a subprocessor transfers Platform Data to a country without an adequacy decision, the transfer is governed by the Standard Contractual Clauses or, for transfers subject to UK law, the UK International Data Transfer Addendum, which are incorporated by reference and completed by reference to these terms and the subprocessor list in Section 6.3.

13.10 Retention, return, and deletion. During the term, personal data relating to a deprovisioned user, contractor, or other authorized user is retained for 90 days unless you specify a different period, after which the record is transformed into a de-identified ghost user record that preserves audit integrity without retaining the individual’s personal data. On termination or expiry of the Service, Provisionr, at your choice, returns or deletes Platform Data within 30 days and deletes existing copies unless retention is required by law, with disaster-recovery backups aging out of rotation on their ordinary cycle.

13.11 Audits. Provisionr makes available to you the information reasonably necessary to demonstrate compliance with these terms and allows for and contributes to audits, including inspections, conducted by you or an auditor you mandate. Provisionr may satisfy this obligation by providing current third-party certifications and audit reports, with on-site or direct audits available where reasonably required, subject to reasonable notice, confidentiality, and frequency limits.

13.12 US state privacy laws. To the extent CCPA or CPRA applies, Provisionr acts as a service provider with respect to Platform Data, processes it only for the business purposes set out in these Terms, and does not sell or share it or retain, use, or disclose it outside the direct business relationship or for any purpose other than providing the Service.

14. International Data Transfers

At launch, the Service operates from a single hosting region located in the United States. All Platform Data, Administrative Data, and Analytics Data is processed and stored in the United States. This includes the audit and identity records you manage through the Service, your account and registration records described in Section 2.1 and Section 3.1, billing and payment records, sales records, and support correspondence. If you require that your data be processed outside the United States, you should not adopt the Service until a hosting region in your required jurisdiction is available.

We are building toward additional hosting regions, described in Section 5.2. As each region comes online, you will select your hosting region when you create your Workspace, and your Workspace will be permanently bound to it. Accessing the Service from another location does not move your data, and we do not perform in-place region transfers. Moving to a different region requires you to export your Workspace data and import it into a new Workspace that you create in the other region, which is an action only you can take.

We do not operate a global control plane. Authentication is handled independently within each region. Your Workspace ID contains a region identifier that routes you to the correct regional control plane when you authenticate. Because of this, an identity you establish under one region is separate from an identity you establish under another, and we do not link them. If you authenticate under more than one region, Provisionr treats each as a distinct identity.

Our infrastructure and support personnel operate from the United States. To operate, secure, support, and ensure the reliability of the Service, these personnel may access Platform Data stored in your selected region. Where your selected region is outside the United States, this access is an international transfer of Platform Data to the United States, even though the data remains stored in your region.

Billing and payment records are processed through Chargebee. At launch, all billing is processed in Chargebee’s United States environment. As additional regions come online, billing will be processed in a regional Chargebee environment based on your selected region: the European Union region will use Chargebee’s European Union environment, the Australia region will use Chargebee’s Australia environment, and all other regions will use Chargebee’s United States environment. Cardholder data is entered directly into Chargebee-hosted pages and processed by Stripe, as described in Section 3.1. The subprocessor list in Section 6.3 identifies the current processing location of each subprocessor.

For Customers subject to data protection laws that restrict international data transfers, such as the GDPR, transfers of Platform Data to the United States are governed by the Standard Contractual Clauses or, for transfers subject to UK law, the UK International Data Transfer Addendum, as described in Section 13.9. To request these terms as a standalone Data Processing Agreement, contact support@provisionr.io.

15. Changes to This Privacy Policy

Provisionr reserves the right to modify, amend, or replace this Privacy Policy at any time and for any reason, at its sole discretion. We may update this policy to reflect changes in our practices, our Service, applicable law, our subprocessor list, or for any other operational, legal, or regulatory reason.

For material changes (those that meaningfully alter the scope of data we collect, how we use or share it, or your rights), we will provide at least 30 days’ prior notice by email to the address associated with your Workspace or by posting a prominent notice on our website. For non-material changes (such as corrections, clarifications, formatting updates, or updates to contact information), we may update this policy without advance notice.

Your continued use of the Service after the effective date of the updated policy constitutes your acceptance of the changes. If you do not agree to the modified policy, you must stop using the Service and may terminate your subscription in accordance with the Terms of Service.

We encourage you to review this policy periodically. The “Last Updated” date at the top of this page indicates when this policy was most recently revised. Prior versions of this policy are available upon request by contacting privacy@provisionr.io.

26. Contact Information

Provisionr, LLC · 1111B S Governors Ave, Suite 97079 · Dover, DE 19904 · United States
Email: privacy [at] provisionr.io · security [at] provisionr.io · support [at] provisionr.io
Support Hours: Monday–Friday, 9:00 AM – 5:00 PM US Central (UTC-6 Winter / UTC-5 Summer)