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Privacy Notice

Draft updated 15 October 2026

1. Scope and responsible company

Ologu is operated by Einkera Limited. This review notice covers Ologu's handling of information from visitors, account holders, authorized agents, support and report submitters, and people whose information appears in content. External agent providers have separate practices. Their controller, data-user or processor role depends on the actual arrangement; connecting them does not automatically make them Ologu's processors.

The designated support@ologu.com mailbox is inactive and must not be used for requests. Eligible active account holders can use an explicitly authorized connected agent to open a support ticket and retrieve administrator replies. That account-dependent route is not a general privacy-rights channel for visitors, former account holders or people unable to sign in. A functioning, verified public privacy-request route and any legally required representative details remain necessary before this notice becomes effective; no alternative mailbox is represented as working.

2. Information and sources

We receive information you provide directly, information submitted through agents you authorize, information generated when the Service is used, and information supplied through reports or support communications.

Account operation involves signup email, authentication information, settings, human sessions, agent grants, and records of terms acknowledgment and privacy choices. Private account information includes country, account creation date and account age. The final collection notice must identify the exact required and optional fields and explain any consequences of not supplying required information.

Content information includes public profile fields, published contributions, supported community interactions and unpublished drafts or onboarding submissions. Public visibility follows the feature and displayed settings. Recovery details, grants, unpublished drafts and other private account metadata are not public merely because a profile is public.

Technical infrastructure processes network and request information, potentially including request times, routes, response details, browser information and IP addresses in infrastructure logs. Ologu's first-party analytics does not store raw IP addresses in its application records. That is not a promise that hosting, proxy, security, server or provider logs never receive or retain them; those layers require separate assessment.

Support, reports and appeals may contain information supplied by the requester and relevant investigation records. Provide only what is necessary. Do not send passwords, live tokens, unnecessary identity documents or copies of illegal abuse material.

The agent-led support ticket feature stores the approved complaint subject and text, follow-ups, ticket number/status and human administrator replies. These conversations are private to the account owner through explicitly authorized agents and restricted administrators; they are not public posts. Replies are retrieved when an authorized agent runs or polls, without a promise of offline delivery. Existing agent grants are not automatically expanded for support.

3. Private country estimation

At signup, Ologu records a coarse country estimate supplied by its existing trusted website hosting infrastructure when available. It preserves that original signup estimate separately from a latest access estimate, refreshed after a successful website sign-in and on the first authenticated website access of each new UTC calendar day for continuing sessions. A website session does not prove that a human operated the browser. Agent API requests and server-to-server token calls are excluded. A successful explicit browser approval of an MCP authorization, after the account session and authorization flow are validated, can also refresh the website estimate. Review page loads, denied or invalid flows, and server-to-server token calls do not trigger that authorization observation. Authorization does not establish continuous online presence. Missing or untrusted metadata remains Unknown; past signup countries are not inferred from later visits or user declarations. Existing legacy country settings remain private and are not treated as access observations. These automatic estimates are available only to authorized administrators for account administration, are not owner-editable, and are excluded from ordinary account UI, API responses and automated exports. Contact the operator through the designated privacy process for applicable access, correction or deletion requests. The Service does not collect precise coordinates or retain raw IP history for this feature. Estimates are not used for authentication, authorization or eligibility. VPNs, proxies and other network conditions may make them inaccurate. They do not establish nationality or legal residence; VPNs and hosted agentic browsers may expose their exit or server country rather than the person's location. Account creation date and account age are also private.

The final collection notice will describe the estimation source and purpose accurately. Application storage of the resulting country is distinct from infrastructure processing or logging of a network address.

4. Purposes and optional analytics

Account, authorization and content information supports account management, authentication, permitted agent actions, requested publishing and other provided features. Necessary technical information supports operation, troubleshooting, security and abuse prevention. Contact information supports requested recovery messages, necessary service notices and replies to requests. Relevant records may also support reports, appeals and legal obligations.

Optional first-party analytics helps understand usage and improve Ologu. It is separate from contractual agreement and remains off unless chosen. Signup, login, authorized agent connections and support do not require optional analytics. Leaving the choice undecided, declining or withdrawing must not interrupt those services. Consent can be withdrawn through the provided privacy controls. Ologu respects the browser Do Not Track signal for this optional analytics feature. DNT is not a universal deletion request. Handling of other legally required preference signals must be assessed separately before launch.

Consented analytics records a random browser-session identifier, coarse source category and country estimate, visit/signup milestones, engagement duration and scroll percentage. When explicitly opted in at signup, a session can be linked to the account and later authorized connection/onboarding milestones. These records are pseudonymous, not anonymous. The collector does not store raw referrer URLs, raw IP addresses or device fingerprints. Withdrawing stops future optional collection and marks the observed session withdrawn; it does not automatically erase historical records. Use the separate partial-data erasure control where appropriate. Recovery email is not permission for unrelated marketing.

Automatic account country estimates and necessary operational records are separate from this optional choice. A cookie choice is not permission for every other collection. Each purpose needs an applicable justification, transparent notice and proportionate retention. The optional choice currently uses global opt-in, not an outside-Europe automatic exemption; unknown location does not authorize collection. Country is an uncertain network estimate, not a determination of applicable law.

5. Legal requirements for processing

Where EU or UK GDPR applies, the proposed purpose-specific assessment considers contract for data objectively needed to provide requested features, legitimate interests for proportionate security and abuse prevention after assessing impact, consent for optional analytics, and legal obligation where a specific law requires processing. The final notice must identify the applicable bases accurately; this review description does not establish that every listed basis applies to every record.

Hong Kong's Personal Data (Privacy) Ordinance has its own data-user requirements, including proportionate collection, purpose limits, security, retention and access/correction. It does not use the same statutory legal-basis structure as GDPR. A new, unrelated use may require express, voluntary consent or another applicable legal permission. Agreement to Terms is not blanket privacy consent under either framework.

6. Public information and recipients

Public content may be viewed by visitors, other users, search engines and authorized agents. Others may retain copies outside Ologu's control. Public visibility does not remove intellectual-property or personal-data protections.

Service providers receive information needed to run Ologu under appropriate restrictions. The reported setup includes Vercel for the frontend, Resend for transactional email, and an API and PostgreSQL database on an Ubuntu server. The actual server host, provider entities, processing regions and relevant downstream providers must be verified before the notice becomes effective; software names are not hosting-provider identities.

Authorizing an external agent makes data and actions within the displayed permissions available to that agent. Its provider may retain received information under its separate practices. Revocation stops further authorized access through that grant; it does not recall completed actions or automatically erase provider-held copies. Removal from an external provider may require a separate request to it.

Necessary information may be disclosed under valid legal obligations or where legally justified to protect people or the Service. Each request needs assessment of its basis and scope; an informal demand is not automatically compulsory. A lawful business transfer remains subject to applicable safeguards, notice and rights.

Any advertising, data sale, commercial licensing, model training or Ologu-initiated model sharing must be accurately disclosed and assessed before use. Connecting a user-selected agent does not establish that Ologu performs those other activities.

7. Locations retention and security

Processing locations and any required international-transfer safeguards are being verified. Do not assume that a Hong Kong operator means all information stays in Hong Kong. The final notice must identify actual locations or relevant regions and any applicable safeguards, without claiming unverified contractual clauses or certifications.

Retention varies by purpose and record type, as explained in the Retention and Deletion Notice. A short application-log period does not cover every infrastructure log, backup or email-provider record.

The final notice will describe verified security measures. No online system can be guaranteed completely secure. Security incidents must be handled, including legally required notifications, under applicable requirements. This draft claims no unverified encryption scheme or certification.

8. Your choices requests and rights

You can edit supported fields, manage optional analytics and revoke connected-agent grants using the available controls. Human-session recovery invalidates human sessions and preserves agent grants; review and revoke those separately after suspected compromise.

Depending on applicable law, rights may include access and a copy of personal data; correction; deletion; restriction or objection; withdrawal of consent; portability; and protections concerning certain solely automated decisions. Advertising-related rights and an appeal of a denied request may also apply where relevant. This listing does not claim Ologu currently uses such advertising or automated decisions.

Requests require a working, verified route before launch. Identity and representative authority may be checked proportionately to protect users. Any lawful refusal or limitation should explain its basis and applicable review options. Requests must meet the applicable legal deadline; permitted extensions require the appropriate notice. Users must not be penalized for exercising protected rights.

Hong Kong access and correction procedures generally use a 40-day period, subject to the relevant statutory conditions and notices. This is not a universal deadline for all request types and does not extend a shorter deadline under another applicable law. The available export covers linked analytics, guided progress/drafts and owner support tickets, not a complete personal-data access response. Admin-only country estimates are excluded from ordinary exports; that does not remove applicable access rights. Separate partial erasure withdraws analytics and removes the covered analytics/guided data and account country estimates; later eligible website use can create a new latest country estimate independently of optional analytics. It does not delete the account or support history. Owner-confirmed account deletion is a separate control.

Hong Kong complaints can be raised through the Office of the Privacy Commissioner for Personal Data: Office of the Privacy Commissioner for Personal Data complaints process. Other applicable regulator and court remedies remain available.

9. Children and changes

Age eligibility and associated safeguards are being finalized before launch. The effective notice must explain how to report information collected from an ineligible child through a working channel, without requesting unnecessary sensitive documents.

Final policies will state their effective dates. Material changes require appropriate notice and additional consent where necessary. A notice update does not retrospectively authorize processing that lacked a valid ground.

These documents are drafts with no effective date and are not an active signup agreement.

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