Privacy Policy

1. Information we collect

1.1 Information you provide to us

When you create a Phronesis customer account, you provide:

• Account information: name, email address, billing contact information, organization name (where applicable)
• Payment information: processed exclusively by our payment processor Stripe, Inc. Phronesis does not store payment card numbers, bank account numbers, or credit card verification values. We retain only the Stripe customer identifier and high-level transaction metadata necessary for billing reconciliation.
• Authentication credentials: the credentials we issue to you (bearer tokens and OAuth client identifiers) and the metadata needed to validate them (issuer, audience, expiry). We do not use passwords.
• Communications: content of support requests, feedback submissions, and other voluntary communications with Phronesis

For autonomous-agent customers using the Hermes contract surface, we additionally collect:

• Delegated-authority evidence: where an agent presents an AP2 Mandate or an equivalent delegated-authority credential, we record it as evidence in the audit trail of the resulting Decision Asset (Terms §4.3). Mandate material is stored as hashes and references, not as reusable bearer material.
• Agent registration: when an autonomous agent registers to use the Service (OAuth dynamic client registration), we issue a signed client identifier derived from the registration; registration is stateless — we do not store a registration record, and we retain only a revocation entry if a client identifier is later revoked.
• Engagement inquiries: if you submit an inquiry through phronesisintel.com/deploy or the engagement_inquiry tool, we collect the decision owner, the decision described in one sentence, its materiality, the resolution horizon, the systems in play, and the contact address you provide. We use them only to evaluate and respond to your inquiry and to maintain a record of it; every inquiry is reviewed by a person before any response or engagement, and no inquiry is accepted automatically.

1.2 Information we collect automatically

When you use the Phronesis platform, we automatically collect:

• Usage telemetry: API request timestamps, endpoint paths, response codes, request payload sizes, response payload sizes
• Forecast metadata: which Decision Asset templates you request, which applied verticals (as published at phronesisintel.com/verticals) and archetypes you query, frequency of queries, total queries per billing period
• Cost-attestation records: the per-call inference cost incurred for each Decision Asset you request, kept in our billing records
• Diagnostic information: rate-limiting events, circuit-breaker triggers, error responses, support-routing signals
• Cookies: the Phronesis platform does not set authentication or tracking cookies.

1.3 Information we do NOT collect

Phronesis does NOT collect:

• Protected Health Information (PHI): Phronesis V#3 Healthcare vertical operates exclusively under HIPAA Safe Harbor enforcement code-layer rules per the Themis-Healthcare substrate. We do not process individually identifiable health information.
• Customer underlying business or financial data: Phronesis processes the Decision Asset requests you submit, but does not collect or store the underlying business datasets, financial records, or strategic plans you may use to inform your queries.
• Children's personal information: the Phronesis platform is not directed to children under 13. We do not knowingly collect personal information from children under 13.
• Sensitive personal information categories without explicit consent: Phronesis does not collect biometric identifiers, precise geolocation, racial or ethnic origin data, religious or philosophical beliefs, or genetic data.
• Personal data inside Decision Assets: Decision Assets describe market, infrastructure, and institutional events, not individuals. The Terms (§4.2) prohibit submitting queries about specifically identified individuals in violation of privacy law, and we do not design Decision Asset templates to profile natural persons.

1.4 Outreach and engagement records

We contact a limited number of businesses whose published work relates to our service, and we respond to correspondence sent to our operations mailbox. For that purpose we process business-contact information that the business or person has made publicly available or has sent to us (name, role, organization, business email address) and a record of our correspondence (dates, message content within the conversation, replies, and whether the contact asked us to stop). How replies are handled: correspondence to our operations mailbox is read and answered by an automated assistant operating under a written, versioned mandate; it may send factual replies, propose next steps, and decline. Messages that raise legal, press, regulatory, complaint, or security matters, that are unclear, or that would require a commitment are routed to a person, who replies. Every message we send identifies the sender. Our systems record, for each message received at that mailbox, that it was received and how it was classified. Service providers for this processing: Google LLC (business email) and Anthropic, PBC (the language model that drafts replies; the content of inbound correspondence and our replies is processed by Anthropic under its commercial terms, which exclude training on customer data). Purpose: to introduce our service and respond to correspondence. Lawful basis: our legitimate interest in business-to-business communication; every outreach message identifies us, gives our postal address, and offers a one-step opt-out. Retention: engagement records are kept for twenty-four (24) months from last contact, then deleted. Suppression: if you ask us to stop, we keep your address on a suppression list indefinitely, solely so we never contact you again. No automated decisions about individuals: we do not score or profile natural persons.

2. How we use your information

2.1 To provide the Phronesis platform service

• Authenticate your access to the Hermes contract surface and platform features
• Mint Decision Assets at your request where the published price list shows minting as live, and persist them to the Record
• Charge your account for subscription fees and per-call usage at agreed pricing
• Send you transactional communications about your account (billing notices, security alerts, service updates)
• Provide customer support in response to your inquiries

2.2 To improve the Phronesis platform

• Analyze de-identified, aggregated usage telemetry to understand platform performance and identify areas for improvement
• Score Decision Assets against ground-truth resolution and publish the results on the Calibration Scorecard (Market Memory)
• Improve prompt templates and archetype designs using de-identified, aggregated data, subject to Terms §7.1B and §7.2; we do not use customer-identifying information to train or improve models without separate explicit consent
• Detect and prevent fraudulent or abusive use of the platform

2.3 To comply with legal obligations

• Maintain financial records as required by federal and Colorado state tax law (typically seven years post-cancellation)
• Respond to lawful requests from regulators and law enforcement
• Enforce the Phronesis Terms of Service

3. How we share your information

3.1 Service providers (subprocessors) we share with

Phronesis does not sell, rent, or trade your personal information, and does not share it for cross-context behavioral advertising. We will update this table before adding a subprocessor that receives personal data.

3.2 Legal disclosures

We may disclose your information if required by law (subpoena, court order, regulatory request) or to protect the rights, safety, or property of Phronesis, our customers, or others. We will notify you of any legal request for your information unless prohibited by law.

3.3 Business transactions

If Phronesis or Sustainable Finance Partners, LLC undergoes a merger, acquisition, financing, sale of assets, or similar transaction, your information may be transferred to the successor entity. We will notify you in advance of any such transfer that materially affects how your information is processed.

3.4 De-identified and aggregated data

Where Phronesis uses de-identified data (Terms §7.1B, §7.2), Phronesis (i) takes reasonable measures to ensure the data cannot reasonably be linked to an identified or identifiable individual or Customer, (ii) publicly commits to maintain and use the data only in de-identified form and not to attempt re-identification, and (iii) contractually obligates any recipient to comply with the same commitments.

4. Data retention

• Active account data: retained for the duration of your active customer relationship with Phronesis
• Post-cancellation account data: retained for seven (7) years after account cancellation per accounting and tax compliance requirements; thereafter deleted or fully anonymized
• Transactional financial records: retained per applicable federal and Colorado state tax law (typically seven years)
• Decision Assets and anchors: Decision Assets and their Resolution records are retained indefinitely in the Record; their anchored cryptographic hashes are immutable and contain no personal data. Customer-identifying account data associated with the Record is deleted or anonymized on account cancellation or verified request, subject to legal retention requirements, while the Decision Assets and calibration history are preserved.
• Model-inference subprocessor: inference inputs and outputs are retained by Anthropic for up to 30 days under its standard terms (§3.1).
• Engagement inquiries: retained for twenty-four (24) months from last contact, or for the life of the resulting customer relationship if one forms.
• Outreach and engagement records: twenty-four (24) months from last contact; suppression entries retained indefinitely.
• Agent registration records: retained for the life of the registration and twelve (12) months thereafter.
• Support communications: retained for three (3) years for quality assurance and recurring-issue identification
• Diagnostic and telemetry data: retained for ninety (90) days at full granularity; aggregated for indefinite retention in anonymized form

5. Your rights

5.1 California residents (CCPA / CPRA)

If you are a California resident, you have the right to:

• Know what personal information we collect about you and how we use it
• Access the specific pieces of personal information we have about you
• Delete your personal information, subject to legal retention requirements
• Correct inaccurate personal information
• Opt-out of sale or sharing of your personal information (Phronesis does not sell or share personal information for cross-context behavioral advertising)
• Limit use of sensitive personal information (Phronesis does not collect sensitive personal information beyond what is necessary for service provision)
• Non-discrimination for exercising your CCPA/CPRA rights

5.2 Colorado residents (Colorado Privacy Act)

If you are a Colorado resident, you have the right to:

• Confirm whether Phronesis is processing your personal data
• Access your personal data
• Correct inaccurate personal data
• Delete your personal data, subject to legal retention requirements
• Data portability in a structured, commonly used, machine-readable format
• Opt-out of processing for purposes of targeted advertising, sale, or profiling in furtherance of decisions producing legal or similarly significant effects (Phronesis does not engage in any of these activities)

5.3 How to exercise your rights

Customers may also export their Decision Assets in the published portable format at any time (Terms §7.1A, §12.3). Deletion requests are honored for account and personal data; anchored hashes contain no personal data and are not alterable.

To exercise any of the rights above, contact Phronesis support at the email address in Section 11. Include:

1. The nature of your request (access, deletion, correction, etc.)
2. Sufficient information to verify your identity as the data subject
3. The specific data or processing activity your request concerns

We will respond to verified requests within forty-five (45) days as required by applicable law. We may extend this period by an additional forty-five days if reasonably necessary, with notice to you.

6. Security

Phronesis maintains technical and organizational measures appropriate to the sensitivity of the information we process:

• Encryption in transit: all communications with the Hermes contract surface and between Phronesis substrate components use industry-standard TLS encryption
• Encryption at rest: customer data is encrypted at rest in the Mnemosyne canonical persistence layer and at the production hosting layer
• Payment card data: never touches Phronesis systems; processed directly by Stripe under PCI DSS Level 1 compliance
• Credential management: to revoke or replace a credential, contact support at the address below; we can suspend a tenant's action authority immediately and block issuance of new credentials; an issued credential expires within 31 days of issuance.
• Per-tenant isolation: Phronesis substrate enforces strict per-tenant isolation; cross-tenant data access is architecturally prevented at the boundary publish layer
• Backup and disaster recovery: triple-redundancy backup of the Mnemosyne canonical ledger (operational substrate plus version-controlled snapshots plus offline archive)
• Authentication: platform access is authenticated by Authority Credential (JWT or workload credential) for all callers — human and autonomous; no password-based login surface exists, and therefore no separate two-factor layer; delegated-authority evidence is recorded where presented (Terms §4.3)

No system is perfectly secure. We will notify affected customers and applicable regulators of any data breach as required by applicable law, and for Colorado residents in any event not later than thirty (30) days after determination that a security breach occurred (C.R.S. § 6-1-716).

7. International data transfers

Phronesis operates from the United States. Customer data is stored on US-based infrastructure (production hosting in US regions; Stripe US data centers; Anthropic US-based inference). Customers located outside the United States who access the Phronesis platform consent to the transfer and processing of their information in the United States.

Phronesis does not currently offer EU-located data residency or processing. Customers subject to GDPR or other regional data protection regimes should evaluate whether US-based processing meets their compliance requirements before subscribing. If you are in the EU or UK and submit an engagement inquiry, we process it on the basis of our legitimate interest in responding to your inquiry; you may object at any time by contacting us at the address in Section 11. The same applies to outreach correspondence under Section 1.4.

8. Cookies and tracking

Phronesis uses minimal cookies:

• No third-party advertising cookies
• No cross-site tracking technologies
• No analytics services that cross-reference your activity with other websites

Phronesis does not respond to "Do Not Track" browser signals because we do not track users across websites in the first place.

9. Third-party links

The sustainablefinancepartner.com website and Phronesis platform may contain links to third-party websites or services (Stripe, Anthropic, etc.). This Privacy Policy applies only to Phronesis-operated properties. We are not responsible for the privacy practices of third-party websites or services. Please review the privacy policies of any third-party services you visit.

10. Changes to this Privacy Policy

Phronesis may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated to active customers by email at least thirty (30) days prior to the effective date of the change. We will also post the updated Privacy Policy at sustainablefinancepartner.com with an updated "Last Updated" date.

Continued use of the Phronesis platform after the effective date of an updated Privacy Policy constitutes acceptance of the updated terms.

11. Contact us

For privacy-related questions, requests, or complaints:

Sustainable Finance Partners, LLC, doing business as Phronesis
5401 S Race CT
Greenwood Village, CO 80121
United States

Email: support@phronesisintel.com

For Colorado residents: you may also contact the Colorado Attorney General's office at coag.gov.

For California residents: you may contact the California Attorney General's office at oag.ca.gov.