Privacy & Data Protection Policy

1. Important Information and Who We Are

This privacy policy gives you information about how GetOnyx LLC (“Onyx”, “we”, “us” or “our”) a company incorporated and registered in the United States having its registered office at 15 Enterprise, Suite, 250, Aliso Viejo, CA 92656, United States, collects and uses your personal data through your use of our website, including any data you may provide when you register for the Onyx CSP Growth Engine or the Onyx Enterprise Platform (together referred to as “Platform”), connect a tenant to the Platform via API, upload contract documentation for licensing analysis or use the licensing helpdesk (together referred to as the “Services”).

The Services are not intended for children and we do not knowingly collect data relating to children. Onyx does not carry out automated decision-making or profiling that produces legal effects or similarly significant effects on individuals.

Controller and Processor Roles

Onyx’s role as a controller:

Onyx is the controller and responsible for your personal data in respect of business contact data used for account management and billing.

Onyx’s role as a processor for Partner data:

Where we process data on behalf of a partner (e.g. a Microsoft CSP) (“Partner”) to provide licensing advice to their customers, the Partner is the ‘controller’ of any personal data contained in Tenant Data, Document Data and Helpdesk & Recall Data (as defined in section 2 below) processed by Onyx on the Partner’s behalf and Onyx acts as the ‘processor’ (or sub-processor).

When acting as processor (or sub‑processor), Onyx processes such personal data only on the documented instructions of the Partner as set out in the Partner Agreement between Onyx and the Partner (“Partner Agreement”) and in this Privacy and Data Protection Policy. This Policy therefore forms part of the documented processing instructions and describes:

• the subject matter, nature and purpose of processing;
• the categories of personal data and data subjects;
• the technical and organisational security measures we apply;
• our use of authorised sub‑processors;
• our data retention and deletion commitments;
• our international transfer mechanisms; and
• how we assist Partners in fulfilling their obligations under applicable data protection laws.

2. The Types of Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified. We only collect and process personal data that is necessary to provide and improve the Services. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier and job title.
• Contact Data includes business email address and telephone numbers.
• Financial Data includes billing contact information and invoicing records. We do not collect or store payment card information.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes your login data.
• Profile Data includes your username, purchases or orders made by you, your feedback and survey responses.
• Tenant Data includes data pulled via read-only API connection from a tenant (e.g. user identifiers, subscription metadata and utilisation data) of our Partners and their customers. Such connections are read-only and can be revoked at any time by disconnecting the tenant or revoking the relevant permissions in the relevant Microsoft portal.
• Document Data includes personal data contained within uploaded contract documents, pricing or invoices provided for analysis.
• Helpdesk & Recall Data includes queries raised via the licensing helpdesk and any responses “bookmarked” by the user for indefinite storage.
• Usage Data includes information about how you interact with and use our Services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Details of Processing When Onyx Acts as Processor

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website or Platform feature in order to analyse general trends in how users are interacting with our website or Platform (as the case may be) to help improve the website/Portal and our service offering.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our services, create an account or give us feedback.
• Automated technologies or interactions. As you interact with our Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and server logs.
• API Connections. We receive tenant data directly from Microsoft environments (including the tenants of our Partners and their customers) when a user executes a “Connect Tenant” command within the Platform. These connections are read-only and can be revoked at any time by disconnecting the tenant or revoking the relevant permissions in the relevant Microsoft portal.
• Third parties. We receive data from our Partners when they raise queries on your behalf or provide us with access to their internal portals.
• Technical Data is collected from the following parties:
  • search information providers
• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
• Identity and Contact Data is collected from:
  • data brokers or aggregators, such as LinkedIn; and
  • publicly available sources

4. How We Use Your Personal Data

Legal Basis

The law requires us to have a legal basis for collecting and using your personal data. We do not use personal data for purposes unrelated to providing the Services, unless required by law or with consent. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you (or the Partner through whom you access the Platform).
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct Marketing

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing. During the registration process on our Platform when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-Party Marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting Out of Marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Cookies

We use strictly essential cookies for authentication, security and session management; these are essential for the Platform to function and cannot be switched off. If we use analytics or performance cookies, we will request your consent via a cookie banner upon your first visit. You can manage your preferences, opt-out, or withdraw consent at any time by clicking on the ‘Cookie Settings’ link in the Platform, or by adjusting your browser settings to reject cookies.

5. Disclosures of Your Personal Data

We may share your personal data where necessary with the parties set out below or the purposes set out in the table above:

• Internal Third Parties: Onyx group entities.
• External Third Parties: Cloud hosting providers (e.g. Microsoft Azure) and AI/LLM providers used to process helpdesk queries (subject to strict confidentiality). Onyx does not sell personal data to third parties, nor do we purchase personal data from data brokers, or use advertising networks that profile individuals. We only share personal data where necessary to operate, secure or improve the Services, or where required by law.
• Partners: We share data with the specific Partner through whom you accessed the Platform.
• Other Third Parties: to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers (save for Partners who are likely to have a contract in place with you) to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Onyx LLC is based in the United States. We also have employees and contractors located in both the United Kingdom and the United States, and we may operate through group companies established in either jurisdiction. This means that your personal data may be accessed or processed from these locations in the course of providing our services.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection to the UK law (such as the United States), we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. These may include:

• using the UK International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses; and/or
• entering into data transfer agreements that provide an adequate level of protection for personal data; and/or
• ensuring that the recipient is subject to binding contractual obligations to protect your personal data.

Transfers of personal data from the UK or EEA to the United States are undertaken using the UK International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses (SCCs) or any successor mechanism approved by the relevant supervisory authority.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Technical and Organisational Measures

In particular, we implement the following Technical and Organisational Measures to protect personal data:

• Encryption in transit using TLS 1.2+
• Encryption at rest using AES‑256
• Strictly read‑only API access to Tenant Data
• Role‑based access controls
• Multi‑factor authentication for administrative access
• Segregated environments for development and production
• Regular vulnerability scanning and patching
• Logging and monitoring of access to personal data
• Regular penetration testing (at least annually) by independent third parties
• Safeguards against prompt engineering and injection attacks to prevent unauthorized data exposure

These measures may be updated from time to time to maintain or enhance security. Any updates will not materially reduce the level of protection for personal data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Sub‑Processors

Onyx engages the following sub‑processors to support the provision of the Services:

Infrastructure / Hosting:

The infrastructure used to deliver the Services are located in facilities in EU and the United States and in the infrastructure sub-processors listed below. Customer accounts are usually established in one of these regions based on where the Customer is located.

Service Specific:

Onyx may update this list from time to time. Any such update will be published in this Policy.

Onyx’s Obligations When Acting as Processor

Where Onyx acts as a processor (or sub-processor) on behalf of a Partner, Onyx shall comply with the data protection obligations set out in the relevant Partner Agreement. In the absence of a signed Partner Agreement (e.g. during a trial or pre-sales engagement), Onyx commits to processing personal data in accordance with applicable data protection laws, implementing the Technical and Organisational Measures described in this section 7 and only engaging the sub-processors listed in section 7.

8. Data Retention

How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see section 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

For the licensing helpdesk, queries and responses are retained for 30 days and then deleted, unless you actively choose to “bookmark” a specific question and response using the Recall feature, in which case that Recall item will be stored until you delete it or your account is closed.

• Helpdesk Queries: Automatically deleted after 30 days (and in any event no later than 90 days).
• Recall Data: Stored indefinitely until deleted by the user or the account is closed.
• Tenant Data: Cached only for the duration of the analysis session unless otherwise agreed.
• Account Data: Retained for 6 years after the relationship ends for tax/legal purposes.

9. Your Legal Rights

You have a number of rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting Out of Marketing in section 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data.

If you are a resident of California, you may also have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

If you wish to exercise any of the rights set out above, please contact us at contact@getonyx.ai.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact Details

If you have any questions about this privacy policy, please contact us in the following ways:

• Email address: contact@getonyx.ai
• Postal address: 15 Enterprise, Suite 250, Aliso Viejo, CA 92656, USA.
• Telephone number: +1 (949) 304 8925

11. Complaints

You have the right to make a complaint to the Information Commissioner’s Office (ICO) (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us by using the above contact details or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.

12. Changes to the Privacy Policy

We keep our privacy policy under regular review. This version was last updated on 12th March 2026. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. Third Party Links

This website may include links to third-party websites, plug-ins and applications (such as Microsoft). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.