PRIVACY POLICY

Last updated February 2026

This Privacy Notice for CounterMeasure ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://countermeasuresec.com or any website of ours that links to this Privacy
• Notice
• Use CounterMeasure — a modular platform providing threat intelligence, detection, distributed query, agent orchestration,
• AI-assisted analysis, and infrastructure automation
• Access our API, CLI tools, or any application of ours that links to this Privacy Notice
• Engage with us in other related ways, including any support, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice. You can find more details about any of these topics by clicking the link following each key point or by using the table of contents below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more.

Do we process any sensitive personal information? Some information may be considered "special" or "sensitive" in certain jurisdictions. We process sensitive personal information only when necessary with your consent or as otherwise permitted by applicable law. Learn more.

Do we collect any information from third parties? We may collect information from public databases, OAuth providers, and other outside sources. Learn more.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. Learn more.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more.

How do we keep your information safe? We have implemented appropriate organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Learn more.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. [WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
4. INFORMATION?](#3-when-and-with-whom-do-we-share-your-personal-information)
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. [DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY
14. RIGHTS?](#12-do-united-states-residents-have-specific-privacy-rights)
15. DO WE MAKE UPDATES TO THIS NOTICE?
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
17. [HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
18. YOU?](#15-how-can-you-review-update-or-delete-the-data-we-collect-from-you)

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

*In Short: We collect personal information that you provide to us.*

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• usernames
• passwords
• contact preferences
• contact or authentication data
• job titles and organization names
• billing addresses
• API keys and access tokens

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• account login credentials
• multi-factor authentication secrets (encrypted at rest)
• security event data and threat intelligence queries submitted through the platform
• audit logs containing operational security data

Social Media Login Data. We may provide you with the option to register with us using your existing social media or OAuth provider account details (such as GitHub, Google, or Apple). If you choose to register in this way, we will collect certain profile information about you from the provider, as described in the section "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

API and CLI Usage Data. If you use our API or CLI tools (cmm, tflux-ai), we may also collect the following information:

• API request metadata (endpoints accessed, timestamps, response codes)
• CLI command invocations and flags (excluding secret values)
• Agent registration data (agent ID, capabilities, host metadata)
• Deployment target information (host identifiers, deployment type)

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

*In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.*

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. See our Cookie Policy for details.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our
• servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, API queries, and other actions you take such as which features you use), device event information (such as system activity, error reports, and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use
• to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Security Telemetry. When you use the OTLP ingest pipeline or query engine, we collect telemetry metadata (signal
• types, record counts, schema identifiers) to operate and improve the service. Raw telemetry payloads you submit are processed on your behalf and are not used for any purpose other than providing the Services.

Information collected from other sources

*In Short: We may collect limited data from public databases, OAuth providers, and other outside sources.*

In order to provide our Services and maintain account security, we may obtain information about you from other sources, such as public databases, OAuth identity providers (GitHub, Google, Apple), and security intelligence feeds. This information is used solely for the purpose of providing and securing the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

*In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.*

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your
• information so you can create and log in to your account, as well as keep your account in working order, including MFA, OAuth flows, magic links, and device trust.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with
• the requested service, including running queries, processing telemetry, executing agent tasks, and operating the AI gateway.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries
• and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products
• and services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about
• your use of our Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and
• secure, including fraud monitoring, abuse prevention, and security incident response.
• To identify usage trends. We may process information about how you use our Services to better understand how they
• are being used so we can improve them.
• To comply with our legal obligations. We may process your information to comply with our legal obligations,
• respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

*In Short: We may share information in specific situations described in this section and/or with the following third parties.*

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any
• merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Service Providers. We may share your information with third-party vendors, service providers, contractors, or
• agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. Examples include email delivery, cloud infrastructure, and analytics. We have contracts in place with our third parties, which are designed to help safeguard your personal information.
• Legal Requirements. We may disclose your information where we are legally required to do so in order to comply
• with applicable law, governmental requests, a judicial proceeding, court order, or legal process.
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to
• investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, or as evidence in litigation in which we are involved.

We do not sell your personal information to third parties.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

*In Short: We may use cookies and other tracking technologies to collect and store your information.*

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

*In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.*

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your security operations and provide you with intelligent analysis capabilities. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Our AI Products

Our AI Products are designed for the following functions:

• Threat intelligence analysis and summarization
• Detection rule generation and optimization
• Security query assistance via the MCP AI gateway
• Anomaly detection and behavioral analysis

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreements with third-party AI providers (including Anthropic, Google, and others). Security telemetry and query data you submit to AI features is processed to provide the requested analysis and is not used to train third-party AI models without your explicit consent. This ensures high security and safeguards your personal information throughout the process.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

*In Short: If you choose to register or log in to our Services using a social media or OAuth provider account, we may have access to certain information about you.*

Our Services offer you the ability to register and log in using your third-party account details (such as GitHub or Google). Where you choose to do this, we will receive certain profile information about you from your provider. The profile information we receive may vary depending on the provider concerned, but will often include your name, email address, and profile picture, as well as other information you choose to make public on such a platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

*In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.*

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Specific retention periods:

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

*In Short: We aim to protect your personal information through a system of organizational and technical security measures.*

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process, including:

• Encryption at rest: AES-256 encryption for sensitive data including OAuth tokens, MFA secrets, and vault contents
• Encryption in transit: TLS 1.2+ (TLS 1.3 preferred) for all data in transit
• Password security: Argon2id hashing for all user passwords
• Access controls: Role-based access control (RBAC) with organization-level isolation
• Audit logging: Comprehensive audit logs for all authentication and administrative actions
• Key management: Separate encryption keys per data category with support for key rotation
• Regular security audits: Periodic review of security controls and dependency vulnerabilities

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

*In Short: We do not knowingly collect data from or market to children under 18 years of age.*

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

10. WHAT ARE YOUR PRIVACY RIGHTS?

*In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.*

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
• Contact us using the contact information provided below.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. See our Cookie Policy for details.

If you have questions or comments about your privacy rights, you may email us at [email protected].

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

Global Privacy Control: We recognize and honor Global Privacy Control (GPC) signals. If you use a browser or extension that supports GPC, we will treat this as a valid request to opt out of the sale or sharing of your personal information for targeted advertising purposes under applicable state privacy laws. For more information about GPC and how to enable it, visit globalprivacycontrol.org.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

*In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.*

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months.

We only collect sensitive personal information as defined by applicable privacy laws or for the purposes allowed by law or with your consent. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section "HOW DO WE PROCESS YOUR INFORMATION?"

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal
• data, or profiling in furtherance of decisions that produce legal or similarly significant effects

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at [email protected] or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity.

13. DO WE MAKE UPDATES TO THIS NOTICE?

*In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.*

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us at:

CounterMeasure Email: [email protected] Website: https://countermeasuresec.com

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please contact us at [email protected].

We will respond to your request within 30 days. In some cases, we may need additional time (up to 60 days total) to process your request, in which case we will notify you of the extension and the reason for it.