Privacy Agreement

InTune Intelligence | Effective Date: 12/15/2025

This Privacy Agreement (“Agreement”) describes how InTune Intelligence (“InTune,” “we,” “us,” or “our”) addresses privacy and data protection in connection with the services we provide (“Services”). This Agreement applies to all customers, clients, and users (“Customer,” “you,” or “your”).

1. Purpose and Scope

InTune Intelligence provides analytics, advisory, configuration, and intelligence services designed to operate entirely within the Customer’s own technology environment. This Agreement governs privacy, confidentiality, and data protection obligations related to those Services.

2. Definitions (GDPR)

For the purposes of this Agreement, the following definitions apply as set out in Regulation (EU) 2016/679 (“GDPR”):

  • “Personal Data” means any information relating to an identified or identifiable natural person.
  • “Processing” means any operation performed on Personal Data, whether or not by automated means.
  • “Controller” means the entity that determines the purposes and means of Processing.
  • “Processor” means the entity that processes Personal Data on behalf of a Controller.

3. Roles of the Parties Under GDPR

  1. The Customer is the Data Controller for all Personal Data processed within its ecosystem.
  2. The Services are designed to operate primarily within the Customer’s own systems. To the extent that InTune Intelligence processes Personal Data in the course of providing authorized support, configuration, monitoring, or security-related services, InTune Intelligence acts as a Data Processor on behalf of the Customer. Any such processing is limited in scope, subject to confidentiality obligations, and governed by the Customer’s instructions and applicable data protection laws.
  3. Where InTune Intelligence is granted limited system access, it acts solely as an authorized user or advisor, under the Customer’s instructions, and not as a Processor within the meaning of Article 28 GDPR.

4. Data Ownership

  1. All data, including Personal Data, operational data, metadata, logs, analytics outputs, and business information (“Customer Data”), remains the sole and exclusive property of the Customer.
  2. Nothing in this Agreement transfers ownership or control of Customer Data to InTune Intelligence.

5. No Data Transfer, Storage, or Hosting

  1. InTune Intelligence does not collect, receive, host, store, transmit, or retain Customer Data.
  2. All Customer Data remains entirely within systems, infrastructure, and cloud environments owned, licensed, or controlled by the Customer.
  3. InTune Intelligence does not:
    • Create external copies of Customer Data
    • Maintain backups of Customer Data
    • Transfer data outside the Customer’s environment, including outside the EU

6. Lawful Basis for Processing

  1. The Customer is solely responsible for establishing and documenting the lawful basis for Processing Personal Data under Articles 6 and 9 GDPR.
  2. InTune Intelligence does not independently determine purposes or means of Processing.

7. Access Controls and Security (Article 32 GDPR)

  1. Any access granted to InTune Intelligence is:
    • Explicitly authorized by the Customer
    • Limited to the minimum scope necessary
    • Time-bound and revocable
  2. InTune Intelligence applies appropriate technical and organizational measures, including:
    • Least-privilege access
    • Secure authentication methods
    • Confidentiality obligations for personnel
  3. Primary responsibility for data security remains with the Customer, as data resides solely in the Customer’s environment.

8. Confidentiality (Article 28(3)(b) GDPR – Analogous)

  1. InTune Intelligence ensures that all personnel with potential access to Customer systems are bound by confidentiality obligations.
  2. Confidential information will not be disclosed to third parties except:
    • With prior written authorization from the Customer, or
    • Where required by applicable law

9. Data Subject Rights

  1. The Customer is solely responsible for responding to data subject requests under GDPR, including:
    • Right of access
    • Right to rectification
    • Right to erasure
    • Right to restriction of processing
    • Right to data portability
    • Right to object
  2. InTune Intelligence does not receive or store Personal Data and therefore does not independently respond to data subject requests.

10. Data Breach Notification

  1. Since InTune Intelligence does not store or process Personal Data, it is not expected to experience a Personal Data Breach as defined under Article 4(12) GDPR.
  2. If InTune Intelligence becomes aware of a security incident related to its access credentials that could impact Customer systems, it will notify the Customer without undue delay.

11. Sub-Processors and Third Parties

  1. InTune Intelligence does not engage sub-processors for Customer Data.
  2. No Personal Data is shared with, sold to, or disclosed to third parties.

12. International Data Transfers

  1. No international transfers of Personal Data occur, as Personal Data is not transferred to InTune Intelligence.
  2. Accordingly, GDPR Chapter V transfer mechanisms (e.g., SCCs) are not applicable.

13. Audits and Compliance

  1. Upon reasonable request, InTune Intelligence will provide documentation or written assurances confirming its data-access-only model.
  2. The Customer retains full audit authority over its own systems and Processing activities.

14. Term and Termination

This Agreement remains in effect for the duration of the Services. Upon termination:

  • All system access granted to InTune Intelligence will be revoked by the Customer.
  • No Customer Data remains in the possession or control of InTune Intelligence.

15. Changes to This Agreement

Any material changes to this Privacy Agreement will be communicated in writing and will not reduce privacy protections.

16. Security Incidents and Sensitive Data

We implement reasonable administrative, technical, and organizational measures to protect client data from unauthorized access or disclosure.

As part of our services, we may store information that could be sensitive to clients, including meeting notes, confidentiality agreements, and setup or configuration instructions tailored to a client’s data, systems, or workflows.

If we become aware of a confirmed security incident involving such data, we will take appropriate steps to investigate and remediate the issue and provide notice where required by law.

If you believe your data may have been compromised or have questions about our security practices, please contact us at

17. Governing Law and Venue

This Privacy Policy is governed by and interpreted in accordance with the laws of Georgia in the United States, without regard to its conflict of law principles.

Any disputes, claims, or proceedings arising out of or relating to this Privacy Policy or our data practices shall be brought exclusively in the courts located in Atlanta, Georgia, and you consent to the personal jurisdiction of those courts.

This provision applies whether you are using our services, evaluating our services, or otherwise interacting with us prior to entering into a formal contract.

17. Contact Information

For GDPR or privacy-related inquiries: InTune Intelligence

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