Privacy Policy

Firebird Solutions Limited · NZBN 9429054006225 · Auckland, New Zealand

Atamaia Privacy Policy

Effective date: 9 October 2026 Last updated: 9 October 2026 Version: 2.1


The short version

  • We store what you put into Atamaia so your AI identities can remember it. That's the product.
  • We do not sell your data. We do not use it to train AI models.
  • Nothing you store is sent to any third-party AI provider. Not for storage, not for search, not for indexing. The models that make retrieval work run on hardware we operate. The only way your content reaches an outside AI service is if you connect one yourself — see section 6.
  • Your data sits inside your own tenant, isolated from every other customer.
  • Data at rest sits on a LUKS-encrypted database volume on hardware we operate. Credentials you give us — provider API keys, connector secrets, OAuth client secrets — are additionally encrypted row-by-row with AES-256-GCM under a key derived per tenant. All traffic is encrypted in transit (TLS).
  • You can export everything, at any time, through the dashboard or API.
  • We log most API requests — including your IP address — for security and performance. See section 2.3, which is more detailed than most policies because we think you should know.

The rest of this policy is the precise version. Where the two differ, the precise version governs.


1. Who this policy covers, and who we are

This policy applies to the hosted Atamaia service at atamaia.ai, including its REST API, MCP interfaces and web dashboard (the "Hosted Service"), operated by Firebird Solutions Limited, trading as Firebird Solutions.

It also applies to the atamaia.ai website and the early-access interest form. If you register interest without creating an account, we collect your email address and anything else you choose to tell us, on the basis of your consent, and use it only to contact you about early access. We keep it until you ask us to remove it or until 24 months, whichever is sooner. Ask us to remove it at any time at [email protected].

This policy does not apply to Self-Hosted Deployments. If you run the Atamaia source code on your own infrastructure, we have no access to it and no role in your data. You are the operator, and your own privacy obligations apply.

1.1 Our two roles

We handle personal information in two distinct capacities, and it matters which one applies:

We are the controller / agency We are the processor
What Your account details, billing, support correspondence, request telemetry, security logs The content you store — memories, facts, documents, tasks, messages, identity configurations
Meaning We decide why and how it is handled You decide; we act on your instructions
Your rights Exercise directly with us (section 11) You control it directly through the API and dashboard

Where you store personal information about other people in Atamaia, you are the controller of that information and we process it on your behalf. You are responsible for having a lawful basis to collect and store it, and for giving those people any notice their local law requires. If you are a business customer subject to GDPR or similar law, our Data Processing Addendum governs that relationship.


2. What we collect

2.1 Information you give us

Category Examples Why
Account information Email address, name, password hash Create and secure your account
Organisation information Tenant name, organisational units, groups, user roles Operate multi-user access control
Billing information Plan, billing address, tax details, transaction history Charge you and meet tax obligations
Support correspondence Emails and messages you send us Answer you, and keep a record

Payment card details never reach us. Payments are processed by Stripe, Inc. We receive a token, a card brand and last four digits, and transaction status — never a full card number.

2.2 Customer Content — the content you store

This is the substance of the service: memories, facts, documents, tasks, projects, messages between identities, chat sessions, AI identity configurations and preferences, standing rules, session handoffs, and the relationships between them in the memory graph.

We do not inspect, mine, analyse or profile the substance of Customer Content, other than the automated processing needed to make the service work — indexing, embedding for retrieval, graph relationship building, and enforcing quotas — all of which runs on infrastructure we operate.

How embeddings are generated. Retrieval works by converting your content into numeric vectors. Atamaia generates these using a model running on hardware we operate — currently a local inference engine on our own hardware, with an in-process open-weights model (Qwen, run on CPU) as the fallback. Your content is not sent to any third-party embedding service to do this.

This is a platform-level configuration that we control. If we ever change it to use a third-party service, that service would become a subprocessor, and we would list it at /subprocessors and give at least 30 days' notice before the change takes effect — see section 5.1.

Customer Content may contain personal information about you or about other people. What it contains is entirely your choice, subject to the limits in our Terms of Service (section 9.6 — do not store HIPAA-regulated health information, full payment card numbers, or government identity credentials).

2.3 Information we generate automatically

We write one telemetry record per HTTP request to the Hosted Service. Each record can contain:

  • the API path and HTTP method called
  • the response status code and how long the request took
  • your IP address
  • the user ID of the authenticated caller, and the API key ID where an API key was used
  • a correlation ID linking related records
  • your tenant ID
  • the timestamp
  • for errors, structured detail about the failure

Requests to /health, /openapi and /swagger are not logged this way.

These records capture that a request happened. They do not capture the content of what you stored, read or changed. The substance of a memory does not appear in a telemetry record.

We also record:

  • Usage counters — number of identities, memories and projects, for quota enforcement and billing.
  • Performance metrics — response times and error rates, to find and fix problems.
  • Agent execution events — where you run agent features, a detailed trace of each run: planning steps, tool calls, model requests and responses, failures, token counts and cost. These traces can contain the substance of Customer Content, because a tool call's arguments and a model's response are recorded in them. They sit inside your tenant and are subject to the same access controls, but see section 8.3 on how long they persist.
  • Unauthenticated traffic — automated scanners probe every public server. We keep those records deliberately as a security signal. They are not linked to any account.

2.4 Cookies

We set exactly one cookie: __Host-atamaia_oauth_bind, a browser-binding cookie used only during OAuth sign-in flows (it prevents another browser from completing a sign-in started by yours). It is strictly necessary, host-only, expires with the sign-in attempt, and requires no consent.

Authentication tokens are not stored in cookies. Your session token is kept in your browser's local storage by the dashboard. This keeps tokens out of ordinary cross-site request paths; the trade-off is that local storage is readable by any script that successfully runs on the page, which is why we run no third-party scripts or analytics at all. Authentication is thereby confined to first-party code only.

We use no analytics or advertising cookies of any kind, so there is no consent banner — there is nothing to consent to.


3. Why we use it, and our lawful basis

For customers in the EEA and UK, the lawful bases under the GDPR are:

What we do Lawful basis
Provide the Hosted Service and store your content Performance of a contract (Art. 6(1)(b))
Authenticate you and secure accounts Contract; legitimate interests in security (Art. 6(1)(f))
Enforce quotas and bill you Contract; legal obligation for tax records (Art. 6(1)(c))
Request telemetry, security logging, abuse detection Legitimate interests in operating a secure, reliable service (Art. 6(1)(f))
Service and security communications Contract; legal obligation
Marketing communications Consent (Art. 6(1)(a)) — opt-in only, withdrawable at any time
Respond to legal process Legal obligation

Where we rely on legitimate interests, we have assessed that our interest in running a secure and functional service does not override your rights, principally because telemetry excludes the substance of your content and access is restricted and logged.

Where you store special-category data (health, biometric, and similar) about other people, you must establish the Article 9 condition. We process it only on your instructions as processor.


4. What we do not do

We do not:

  • sell personal information, or share it for cross-context behavioural advertising, as those terms are defined under the California Consumer Privacy Act — we have never done so and have no plans to;
  • use Customer Content to train, fine-tune or evaluate AI models;
  • send Customer Content to third-party AI providers by default (see section 6);
  • use Customer Content for advertising or profiling;
  • allow personnel to browse Customer Content out of curiosity — access is limited to the circumstances in section 7.2 and is logged.

5. Sharing and disclosure

We share personal information only in these circumstances.

5.1 Subprocessors

Service providers who process data on our behalf under contract. The current list, what each does and where it is located, is at /subprocessors. We will give at least 30 days' notice before adding a new subprocessor that processes Customer Content; business customers under the DPA may object.

5.2 External Providers you configure

See section 6. This only happens if you set it up.

5.3 Within your tenant

Other users in your tenant see what your access controls allow them to see. See section 7.1.

5.4 Legal requirements

We may disclose information where required by valid legal process or where necessary to protect rights, safety or property. We will notify you before disclosing your information in response to legal process unless we are legally prohibited from doing so, or there is a risk to life or safety. We will challenge requests that appear overbroad or unlawful.

5.5 Business transfer

If we are involved in a merger, acquisition or sale of assets, information may transfer as part of that transaction. We will give notice before your information becomes subject to a different privacy policy, and you will be able to export and delete beforehand.


6. Third-party AI providers

Atamaia does not send your content to any third-party AI model, embedding or inference provider. Model inference performed by the platform itself — including the embedding generation described in section 2.2 — runs on infrastructure we operate.

You may choose to connect an External Provider by supplying your own credentials. If you do:

  • content you or your agents route to it leaves our infrastructure;
  • it is then handled under that provider's privacy policy and terms, not this one;
  • that provider may retain it, and may — depending on its own defaults, which you should check — use it for training;
  • the transfer may cross borders, and you are responsible for the lawfulness of that transfer.

We will show you which External Providers are configured for your tenant. We recommend you check this before storing anything sensitive.

What we record about these calls: that the call happened, its duration and its token cost, for billing and diagnostics — the usage records are held on our New Zealand infrastructure. Note that where the call is made by an agent, the agent execution trace described in §2.3 may also record the request and response content, and those traces are retained per §8.3.


7. Isolation, access control and security

7.1 Tenant isolation

Every record in Atamaia belongs to a tenant, and tenant scoping is enforced at the data layer as a global filter rather than left to individual queries. Within your tenant:

  • role-based access control governs what each user may do;
  • an organisational unit tree and group membership govern access to resources such as projects;
  • AI identities can exchange messages with each other where you enable it — that exchange stays within your tenant;
  • nothing is shared with, or visible to, another customer's tenant. There are no public, discoverable or cross-tenant surfaces.

7.2 Our access

Personnel may access Customer Content only where you ask us to for support, where strictly necessary to investigate a security incident or fault, or where required by law. Access requires a privileged permission, is limited to those who need it, and is logged.

7.3 Security measures

  • Encryption at rest: Customer Content is stored on a database volume encrypted at rest with LUKS (full-volume encryption) on hardware we operate. Credentials — AI provider API keys, connector secrets and connection strings, OAuth client secrets and PKCE verifiers — are additionally encrypted individually at the row level using AES-256-GCM with per-tenant key derivation, so they remain encrypted even to someone with direct database access. The rest of your content is not additionally field-encrypted.
  • Encryption in transit: all traffic over TLS.
  • Authentication: password hashing, JWT sessions, and scoped API keys that can be revoked individually.
  • Audit logging: consequential actions are attributed to a user and an API key.
  • Least privilege: administrative permissions are separately gated.

No system is perfectly secure. We cannot guarantee that unauthorised access will never occur.

7.4 Breach notification

If a privacy breach occurs that is likely to cause serious harm, we will:

  • notify the Office of the Privacy Commissioner (NZ) and affected individuals as soon as practicable, as required by Part 6 of the Privacy Act 2020;
  • notify the relevant EU/UK supervisory authority within 72 hours where GDPR applies, and affected individuals without undue delay where the risk is high;
  • notify business customers without undue delay, on the terms of the Data Processing Addendum section 7.3, so they can meet their own obligations;
  • notify the OAIC and affected individuals where the Australian Notifiable Data Breaches scheme applies.

8. Retention and deletion

8.1 Your content

Customer Content is retained for as long as your account is active, or until you delete it.

You can export everything at any time through the dashboard or API. We recommend exporting before deleting anything you may want back.

8.2 Deletion

During the life of your account, deletion is deliberately recoverable. Deleting an item (memory, document, task, message) removes it from every view, search index and model context you use immediately; it is retained flagged-as-deleted so that an accidental deletion — or a deletion made under transient state — can be restored. Nothing you delete by hand is permanently erased while your account remains open.

Why recoverability is the design, stated plainly. This is a memory product, and real memory does not work by deletion:

  • Information changes; it is not erased. When a fact is updated, the previous value is not destroyed — it is marked superseded, with the period it was true kept alongside it, so the chronology stays readable. You can see what was believed, when, and what replaced it.
  • Memories fade or move out of recall; they are not destroyed. A memory can be archived (out of active recall, still true) or marked no-longer-true, with the original kept. Recall itself strengthens a memory — the more something is accessed, the stronger it gets — which only works if the row survives to be recalled.
  • The irreversible act belongs to you, not to a misclick. A soft-deleted item is recoverable within the session of your account; the one moment everything genuinely ends is the one you choose: closing the account (below).

Working alongside this, every consequential action is recorded — what changed, when, and by whom (attributed to the user and credential that did it) — so the history of your data is always inspectable, not reconstructable after the fact.

When you close your account, everything is deleted. Account closure runs a complete, irreversible erasure: all Customer Content — memories, facts, documents, tasks, messages, chat sessions, agent traces, the knowledge graph, and your AI identities' memories — is deleted from our systems by cascade, including the content of your AI identities. This applies to every plan: paid accounts are purged immediately on closure; free accounts are purged within 30 days. Closure is self-service from the dashboard and requires your password confirmation: you are offered an export first, and a deletion receipt confirming what was destroyed and when is emailed to you when the erasure completes.

Backups. Deleted data is removed from live systems as above and from encrypted backups as they roll off their retention cycle — currently 30 days. Backups are age-encrypted and stored only on hardware we own.

Personal memories. Items you discard from your private memory store enter a quarantine window (default 7 days) and are then physically destroyed, row gone, unrecoverable — the one place in the product where deletion is immediate by design.

8.3 Logs, telemetry and agent traces

Request telemetry and audit records are pruned from the live tables by an automated job on the windows below. Pruned records move to encrypted archive storage on hardware we operate, where they are retained for security investigation and dispute resolution only.

Record type Retention
Request telemetry (including IP) 30 days for noise-level records, 90 days for reads and 400 days for writes in live tables, then encrypted archive
Unauthenticated / scanner traffic 30 days in live tables, then encrypted archive
Audit records (who did what) 400 days in live tables, then encrypted archive
Agent execution traces kept while the account is active; deleted at account close (section 8.2)
Billing and tax records 7 years (Tax Administration Act 1994)
Backups 30 days (backups are age-encrypted and roll off 30 days after creation)
Account records (email, name, password hash, org structure) deleted with the account at account close (section 8.2)
Support correspondence 24 months
Early-access interest form entries 24 months

8.4 Backups

Deleted content may persist in encrypted backups until they roll off on the schedule above. Backups are not used to restore individual deleted records except at your request.


9. Where your information is held

The Hosted Service operates from hardware we own and operate in Auckland, New Zealand. Your data sits on our own infrastructure — it is not held by a hyperscaler or a colocation provider.

We may move hosting as the service scales. If we do, the destination appears on the subprocessor list (see below) with 30 days' notice, and the same protections move with your data.

Subprocessors that touch data from outside New Zealand:

  • Cloudflare, Inc. — DNS and edge proxy. Sees request metadata (IP addresses, TLS state) in the course of serving traffic. Does not store Customer Content.
  • Stripe, Inc. — payment processing. Sees billing details, never the content of your memories.
  • Model providers you route to. See section 6: when a conversation or agent task uses a cloud-hosted model, the content sent to that model is processed by that provider to generate the response. The dashboard lets you pin every model to ones running on our own hardware — then no conversation content leaves it.

Cross-border disclosure. Where we disclose personal information to a party outside New Zealand, we comply with IPP 12 of the Privacy Act 2020 by ensuring the recipient is subject to comparable safeguards, through contractual terms.

EEA/UK transfers. Where we transfer personal information out of the EEA or UK, we rely on the Standard Contractual Clauses (and the UK International Data Transfer Addendum), together with supplementary technical measures including encryption in transit and at rest. Business customers can request a copy of the transfer mechanism via [email protected].


10. Automated decision-making

We do not use your personal information to make automated decisions that produce legal or similarly significant effects about you.

Quota enforcement and abuse detection are automated but are limited to service access. If your access is restricted automatically, you can contact [email protected] for human review.

Note: AI systems you configure in Atamaia may make automated decisions. That is your processing, under your control, and you are responsible for the obligations that attach to it.


11. Your rights

Rights differ by jurisdiction. Whichever applies to you, contact [email protected] — or use the API and dashboard, which give you direct access, export and deletion without needing to ask.

We respond within 20 working days (the NZ standard) and within one month where GDPR applies. We do not charge for reasonable requests. We may ask you to verify your identity.

11.1 New Zealand — Privacy Act 2020

You have the right to access the personal information we hold about you (IPP 6) and to request correction of it (IPP 7). If we refuse, we will tell you why and you may complain to the Office of the Privacy Commissioner at privacy.org.nz.

11.2 EEA and UK — GDPR

Access; rectification; erasure; restriction of processing; data portability; objection to processing based on legitimate interests; withdrawal of consent; and the right not to be subject to solely automated decision-making with legal effect. You may lodge a complaint with your national supervisory authority, or the UK Information Commissioner's Office.

We do not have an establishment in the EEA or the UK. Before we offer the Hosted Service into those markets, we will appoint the representative that Article 27 of the EU GDPR requires, and the separate one that Article 27 of the UK GDPR requires, and update this section.

11.3 California — CCPA/CPRA

Right to know what is collected, used and disclosed; right to delete; right to correct; right to opt out of sale or sharing; right to limit use of sensitive personal information; and the right not to be discriminated against for exercising these rights.

We do not sell or share personal information, and have not in the preceding 12 months. We do not use or disclose sensitive personal information for purposes beyond providing the service.

Categories collected in the last 12 months, in CCPA terms: identifiers (email, name, IP address); commercial information (subscription and transaction records); internet activity (API request telemetry); and any category you yourself place into Customer Content. Sources: you, and your use of the service. Disclosed for business purposes to the subprocessors listed at /subprocessors.

An authorised agent may make a request on your behalf with written permission.

11.4 Australia — Privacy Act 1988

Access and correction under APPs 12 and 13. Complaints to us first at [email protected], then to the Office of the Australian Information Commissioner at oaic.gov.au.

11.5 If you are not our customer

If your personal information is in another customer's Atamaia tenant, they control it. Contact them. If you cannot identify or reach them, contact us at [email protected] and we will make reasonable efforts to forward your request.


12. Children

The Hosted Service is not directed to children. You must be at least 16 to hold an account, or older where your jurisdiction requires. We do not knowingly collect personal information from children. If you believe a child has given us information, contact [email protected] and we will delete it.

If you store information about children in Customer Content, you are the controller of that information and are responsible for the additional obligations that attach to it.


13. Marketing

We will send you service and security notices — these are part of the service and cannot be opted out of while you hold an account.

Marketing emails are opt-in only. Every one has an unsubscribe link, and unsubscribing does not affect your service.


14. Changes to this policy

We may update this policy. For material changes we will give at least 30 days' notice by email and in the dashboard before they take effect, and will publish the updated version with a new effective date. Past versions are available on request.


15. Contact and complaints

Purpose Address
Privacy questions and requests [email protected]
Security reports [email protected]
General support [email protected]

Firebird Solutions Limited 34 Rainsford Road, Pukekohe, Auckland 2120, New Zealand

If you are not satisfied with our response, you may complain to:

  • New Zealand — Office of the Privacy Commissioner, privacy.org.nz
  • EEA — your national supervisory authority
  • UK — Information Commissioner's Office, ico.org.uk
  • Australia — Office of the Australian Information Commissioner, oaic.gov.au

Change log

Version Date Change
2.1 9 October 2026 Account closure is now self-service from the dashboard; deletion receipt is emailed on completion; export available through the dashboard as well as the API.
2.0 8 October 2026 Full rewrite. Added controller/processor split, lawful bases, telemetry disclosure, tenant isolation, retention schedule, jurisdiction-specific rights, breach notification.
1.0 March 2026 Initial short-form policy.