Privacy policy

Last updated: 12 October 2026

This is an English translation of the Dutch Privacybeleid. If the two versions differ, the Dutch version prevails.

This privacy policy explains how Brainforge B.V. ("Brainforge", "we" or "us") collects, uses, stores and shares personal data when you visit the ITLedger website, create an account, contact us or use the ITLedger service (together the "Service").

We process personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable Dutch and European privacy legislation.

1. Who we are

Brainforge B.V. is the controller of the personal data described in this policy when we determine why and how that data is processed.

Company: Brainforge B.V.
Registered address: Exaltolaan 36, 2841 ME Moordrecht, the Netherlands
Chamber of Commerce: 86735497
VAT number: NL864069315B01
Website: itledger.eu
Privacy contact: jorrit@brainforge.nl

When a customer uses ITLedger to store or manage information about its own employees, contractors, customers or other people, that customer usually determines why and how the information is processed. In that case the customer is the controller and Brainforge acts as processor. Requests about such customer-provided data are normally best sent to the customer concerned first.

2. Personal data we collect

Depending on how you interact with the Service, we may collect the following data:

Account and identity data, such as your name, business email address, organisation, role and authentication attributes.
Subscription and billing data, such as your plan, invoice details, payment status and limited transaction data. Payment providers process full payment card details; we do not store full card numbers.
Technical and usage data, such as IP address, browser and device type, operating system, language, pages viewed, interactions with features, timestamps, diagnostic information and security logs.
Communications, such as support questions, emails, feedback and attachments or other information you provide to us yourself.
Marketing preferences, including whether you want to receive, or no longer want to receive, product news or other communications.
Cookie and storage data, including consent choices and information collected through optional analytics after you have given consent.
Customer Content, meaning information entered into ITLedger by or on behalf of a customer. We generally process this information according to the customer's instructions.

Please do not provide personal data that is not needed for your use of the Service.

3. What we use personal data for

We may use personal data to:

provide, maintain and improve the Service;
create and manage accounts and workspaces;
authenticate users and manage access rights;
process subscriptions, payments and invoices;
respond to questions, support requests and feedback;
send important service, security and administrative messages;
monitor performance, investigate faults and understand how the Service is used;
protect the Service, our customers and others against fraud, abuse and security risks;
comply with legal, tax, accounting and regulatory obligations; and
establish, exercise or defend legal claims.

We do not sell or rent personal data and do not use personal data for third-party advertising.

4. Legal bases

Under the GDPR we base processing on one or more of the following legal bases:

Contract: the processing is necessary to provide the Service or to take steps at your request before entering into a contract.
Legitimate interest: the processing is necessary for purposes such as operating and improving the Service, preventing abuse, securing systems and communicating with business users, insofar as your rights do not override those interests.
Consent: for example before optional analytics cookies are enabled. You can withdraw your consent at any time.
Legal obligation: the processing is necessary to comply with applicable law, including tax and accounting rules.

When Brainforge acts as processor, we process personal data according to the documented instructions of the customer concerned and the agreement with that customer.

5. Cookies and analytics

We use necessary cookies and similar browser storage when this is needed to make the Service work, ensure security, remember settings and record your cookie choice.

Optional Google Analytics is disabled unless you give consent through the cookie banner. Storage for advertising and ad personalisation remains disabled. You can refuse optional analytics without losing access to the core of the Service.

More information and an explanation of how to change your choice can be found in our Cookie policy.

6. When we share personal data

We only share personal data when reasonably necessary, including with:

providers of infrastructure, hosting and databases;
providers of identity and authentication;
Mistral AI, based in France, for Richard's model processing, as sub-processor for personal data in Customer Content;
payment and billing providers;
providers of email, support and communication services;
providers of analytics services, but only when optional analytics is enabled;
professional advisers, such as lawyers, accountants and auditors;
government authorities or other parties when disclosure is required by law or necessary to protect rights, safety or security; and
a buyer, investor or successor in connection with a merger, financing, reorganisation or sale of our business or part of it, with appropriate confidentiality safeguards.

Service providers may only use personal data to provide their services to us and must secure it appropriately. A current list of sub-processors is available on request from our privacy contact.

7. International transfers

Some service providers may process personal data outside the European Economic Area. If a country is not covered by an adequacy decision, we use appropriate safeguards, such as the European Commission's standard contractual clauses, and additional measures where necessary.

8. How long we keep personal data

We do not keep personal data longer than reasonably necessary for the purposes in this policy, including legal, accounting, security and dispute requirements.

Retention periods differ by type of data. Account data, for example, is usually kept for as long as the account is active and for a reasonable period afterwards. Invoices and related records may be kept for the statutory retention period. Customer Content is kept and deleted according to the customer's agreement, configuration and instructions.

We may keep aggregated or anonymised information from which a person can no longer be identified.

9. Security

We use appropriate technical and organisational measures to protect personal data. These include access management, least-privilege access, encryption in transit, supported encryption at rest, logging, monitoring, backup procedures and secure development practices.

No system is completely secure. If you think you have found a security issue, contact us directly and do not send sensitive information until we have offered a secure method of transfer.

10. Your privacy rights

Under the GDPR and subject to applicable exceptions, you may have the right to:

access the personal data we hold about you;
have inaccurate or incomplete data corrected;
request deletion of your data;
have the processing of your data restricted;
receive certain data in a portable format;
object to processing based on legitimate interest or for direct marketing;
withdraw consent at any time, without affecting earlier lawful processing; and
lodge a complaint with a supervisory authority.

To exercise a right for data for which Brainforge is the controller, email jorrit@brainforge.nl. We may ask for information to verify your identity. We normally respond within one month, although the GDPR allows an extension for complex or numerous requests.

For personal data for which an ITLedger customer is responsible, contact that customer directly. Where necessary we support the customer in handling the request.

You can also lodge a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens.

11. Children

ITLedger is a business service and is not aimed at children. We do not knowingly collect personal data directly from children through the website.

12. Automated decisions

We do not use personal data for solely automated decisions that have legal or similarly significant effects on people.

13. External links

The Service may contain links to websites or services of others. Their own policies apply to their privacy practices; we are not responsible for those practices.

14. Changes to this policy

We may update this privacy policy when our Service, working methods or legal obligations change. We publish the revised version here and update the date above. If a change has material consequences for how we use personal data, we give additional notice where appropriate.

15. Contact

Questions or requests about this privacy policy can be sent to:

Brainforge B.V.

Exaltolaan 36, 2841 ME Moordrecht, the Netherlands

jorrit@brainforge.nl

Pseudonymisation before sending, European endpoint, zero data retention at Mistral

Richard limits the text context and removes internal fields before a model request is sent. Sensitive values are detected locally and replaced with random aliases per call. The mapping between alias and original value stays in server memory for that call. Responses are translated back locally.

By default ITLedger requires the European Mistral endpoint over HTTPS. If privacy preparation fails, nothing is sent unprotected. Requests sent to the model provider are audited. Zero Data Retention is enabled for ITLedger's Mistral organisation. This applies to supported requests without persistent storage at the provider. It is not a general commitment for all Mistral products: file storage, stateful services and Labs models, among others, fall outside this arrangement. See Mistral's explanation of zero data retention.

The setting for using data for model training is separate from zero data retention. The European endpoint determines the region of model processing; account, billing and other operational data may be processed elsewhere. See Mistral's explanation of regional processing.

Which data remains visible?

This is pseudonymisation, not anonymity. Operational data such as device details, ticket references and some team names remain visible. Images and speech fall outside the text protection. ITLedger keeps its own conversations and audit data; zero data retention at Mistral says nothing about retention by ITLedger.

Frequently asked questions

Is Richard anonymous?

No. Sensitive text values are pseudonymised, but operational context can remain recognisable.

Does text protection also apply to images and speech?

No. Images and speech fall outside this text protection.

Does ITLedger itself keep conversations?

Yes. ITLedger keeps its own conversation and audit data, separate from zero data retention at Mistral.