Privacy Policy

MigTera is building tools for creating consented, verifiable clones of how a specific person thinks. We call them harnesses. Consent and control over personal information are not side commitments for us; they are the product. This policy explains in detail what information we collect through migtera.com and our early-access program, how we use it, who we share it with, how long we keep it, and the choices and rights you have.

01Who we are

MigTera ("MigTera," "we," "us") operates the website at migtera.com and the MigTera early-access program. For the personal information described in this policy, MigTera acts as the data controller: we decide why and how it is processed. For any privacy question or request, contact us at hello@migtera.com.

02Scope of this policy

This policy covers migtera.com, our early-access waitlist, our correspondence with you, and, as described in Section 07, the commitments that govern pilot programs. It does not cover third-party websites we link to. Our early-access form is hosted by Airtable; when you use it, Airtable's own privacy practices also apply to their processing as our service provider.

03Information we collect

Information you provide

• Early-access requests. When you request access, we collect what the form asks for and anything you choose to add: typically your name, email address, company or organization, role, whether you're approaching us as an individual expert or on behalf of a team, and free-text notes about what you want to build.
• Correspondence. If you email us, we keep the message, the address you wrote from, and our reply history.
• Pilot participation. If you enter a pilot, we collect the business and contact details needed to run it. The expertise material itself (recordings, transcripts, and similar) is governed by Section 07 and a written agreement.

Information collected automatically

• Server logs. Our hosting infrastructure records standard technical data when you visit: IP address, browser type and version, device type, referring page, pages requested, and timestamps. We use this only for security, debugging, and capacity planning.

What we do not collect

We do not buy personal information from data brokers, we do not build advertising profiles, we do not use fingerprinting, and the website does not ask for or knowingly collect sensitive categories of information such as health, financial account, or government ID data. We also do not use your waitlist information to train AI models.

04Cookies and similar technologies

migtera.com does not currently use analytics or advertising cookies. Our hosting provider may set strictly necessary items required to serve the site securely (for example, load-balancing or bot-protection tokens). If we ever introduce analytics or other non-essential cookies, we will update this policy first and, where the law requires it, ask for your consent before setting them. Because we do not sell or share personal information for advertising, signals like Global Privacy Control have nothing to opt you out of on this site; we honor the spirit of them by not tracking you in the first place.

05How we use information

• Operating the waitlist: reviewing requests, prioritizing pilot candidates, and contacting you about your place in line.
• Responding to you: answering questions and handling requests sent to us.
• Progress updates: sending occasional emails about MigTera's development to people who requested access. Every such email includes an unsubscribe link, and opting out never affects your waitlist position.
• Security and reliability: detecting abuse, debugging problems, and keeping the site available.
• Legal compliance: keeping records we are required to keep and responding to lawful requests as described in Section 06.

We do not sell personal information, we do not share it with third parties for their own advertising, and we do not make automated decisions about you that have legal or similarly significant effects.

06Legal bases and sharing

Legal bases (EEA, UK, and similar jurisdictions)

• Consent: when you submit the early-access form, subscribe to updates, or agree to a pilot. You may withdraw consent at any time, without affecting processing that already happened.
• Legitimate interests: operating and securing a website, responding to people who write to us, and improving what we're building. We balance these interests against your rights.
• Contract: where processing is necessary to provide something you have asked for, such as running a pilot you've signed up for.
• Legal obligation: where retention or disclosure is required by law.

Who we share information with

• Service providers, bound by data-processing terms and acting only on our instructions: Airtable (form hosting and submission storage), our website hosting provider, and our email provider.
• Professional advisers (lawyers, accountants) where needed, under confidentiality.
• Legal requests. If we receive a subpoena or similar demand, we review it, push back on overbroad requests where we can, disclose only what we must, and notify affected people unless the law prohibits it.
• Corporate transactions. In a financing, acquisition, or similar event, information may transfer as part of the transaction; this policy would continue to apply to information collected under it, and we would notify you of any successor.

07Early access and cloning pilots

MigTera's product involves ingesting deeply personal material to build a harness of how a specific person thinks: recordings, transcripts, notes, and records of past decisions. That processing is governed by a separate written agreement with each pilot participant. This section states the commitments any such agreement will include, so they are public and checkable:

• Explicit consent before ingestion. We never ingest a person's material to build a harness of them without their prior written consent. Being cloned is opt-in, always. Consent describes, in writing, what material is ingested, who can query the harness, and where it may be deployed.
• Employers cannot consent for you. When a company sponsors a pilot around one of its people, the individual's own consent is still required. A sponsorship agreement never substitutes for it.
• The source person stays in control. Participants can review what material is included, exclude specific items, and update the scope as their thinking changes.
• Voice is separate. Voice cloning is a distinct, separately consented step. Consent to a text harness is never treated as consent to reproduce a voice, and we treat voice data with the heightened care sensitive data deserves.
• People caught in the frame. Real material often includes other people: a customer on a sales call, a colleague in a meeting. Participants must have the right to share what they submit; we minimize and, where feasible, redact third-party identifiers during ingestion; and if you appear in someone else's material and want out, we honor removal requests (see the note below).
• One person's material builds one person's harness. Material ingested for a participant is not used to build anyone else's harness and is not used to train general-purpose models.
• Answers stay traceable. Harnesses are built so answers trace back to source material, and we keep the provenance records needed to make that auditable by the participant.
• Withdrawal and deletion. If a participant withdraws, querying stops promptly and we delete their source material and the harness built from it within 30 days, except for specific records a law requires us to keep.

08Data retention

• Waitlist submissions: kept until the early-access program for which they were collected concludes, or until you ask us to delete them, whichever comes first.
• Correspondence: kept as long as needed to handle the matter, and up to 24 months afterward in case it resumes.
• Server logs: kept on a short rolling window, no longer than 90 days, unless needed for an active security investigation.
• Pilot material: kept for the term of the pilot agreement, then deleted; on withdrawal, deleted within 30 days as described in Section 07.
• Legal holds: where a law, dispute, or regulator requires retention, we keep the minimum necessary for the required period, then delete it.

09Your rights and choices

Depending on where you live, you may have the right to:

• Access the personal information we hold about you, and receive a copy in a portable format;
• Correct inaccurate information;
• Delete your information;
• Object to or restrict certain processing, including direct marketing, which we always honor;
• Withdraw consent at any time, where processing is based on consent;
• Not be discriminated against for exercising any of these rights.

We extend these rights to everyone wherever we reasonably can, regardless of jurisdiction. To exercise any of them, email hello@migtera.com. We verify requests by corresponding through the email address we hold for you, or by asking for information only you would have; we never ask for a government ID for a routine request. Authorized agents may submit requests with proof of authorization. We respond within 30 days; if a request is complex we may extend once, and we will tell you why. If we decline a request we will explain the reason, and you can ask us to reconsider.

10Regional disclosures

California

In the categories used by California law, we collect identifiers (name, email), professional information (company, role), and internet activity (server logs), directly from you or your device, for the purposes in Section 05. We do not "sell" or "share" personal information as those terms are defined in the CCPA/CPRA, and we have not done so in the preceding 12 months. California residents may exercise the rights in Section 09 without discrimination.

EEA and United Kingdom

MigTera is the controller for the processing described here. We have not yet appointed an EU or UK representative; as an early-stage company we handle all requests directly at hello@migtera.com. You have the right to lodge a complaint with your local supervisory authority, though we would welcome the chance to resolve any concern with you first.

11International transfers

We and our service providers store information in the United States and may process it in other countries. Where information originates in a jurisdiction that restricts international transfers, we rely on appropriate safeguards such as the European Commission's standard contractual clauses and the UK addendum to them, along with our processors' own certified transfer mechanisms.

12Security

We use technical and organizational measures proportionate to the sensitivity of what we hold: encryption in transit for all site and form traffic, access limited to the people who need it, multi-factor authentication on the accounts of our service providers, and security review of any new processor before we use it. Pilot material, as the most sensitive thing we will ever hold, gets stricter handling defined in each pilot agreement. No method of transmission or storage is perfectly secure; if we learn of a breach affecting your information, we will notify you and the relevant authorities as required by law, and tell you plainly what happened and what we're doing about it.

13Children

migtera.com is not directed to children under 16, and we do not knowingly collect personal information from them. If you believe a child has provided us information, contact us and we will delete it.

14Changes to this policy

We will update this policy as MigTera evolves, and in particular before any product launch that changes what we collect. We will post the revised version here with a new "Last updated" date. For material changes, we will notify people on the waitlist by email before the changes take effect, and prior versions are available on request.

15Contact

Questions, requests, or concerns: hello@migtera.com. We read everything sent to that address.