CortoTerms

Draft for review by counsel. Not yet in force.

Privacy notice

Draft · last updated 15 September 2026

  1. 1.Who we are

    Corto is an operating system for a company: it reads the public record of a business, interviews its founder, drafts a plan with the founder, and then helps the people who run the company track and do their work.

    The legal entity that provides Corto is [legal entity name to be confirmed], registered at [registered address to be confirmed], [registration number to be confirmed].

    For the data your company puts into Corto about its own people, your company decides why it is processed and we process it on its behalf. For your sign-in, your account and the sign-up itself, we decide, and this notice is ours.

  2. 2.What we collect

    • Your work email address, and the one-time codes we send to it. Sign-in is by work email only; we do not offer sign-in with a personal Google account.
    • Your company's identifiers: its GSTIN, and where needed its CIN, LLPIN or PAN; its registered name and trade name; its country and city.
    • Public records we read at sign-up using those identifiers: the GST registration and filing history, the company register (master record, directors, charges, filed accounts), and the company's public listing. These are records a regulator or the company already published; we read them, we do not create them.
    • Interview answers: what the founder, heads and employees tell Corto in written or spoken interviews, including audio when a person chooses to speak.
    • Goals and plans: the company's plan, department expectations, goals, key results and the work recorded against them.
    • X-Ray answers: an employee's answers about how the company works. Answers about feelings and perception are reported only in aggregate, are never shown against a named person to anyone including the founder, and never feed a rating or appraisal. A group's answers are shown only once at least five people in it have responded.
    • Data from systems your company connects, only when a named person in your company connects them, and only within the scope that person grants.

  3. 3.Why we use it

    • To let you sign in and to keep your account secure.
    • To produce the outside-in report about your company, the interview, the plan and the goals.
    • To run the tools your company uses in Corto, and to show each person their own work.
    • To produce the X-Ray findings for your company, in aggregate.
    • To meet our legal obligations.

  4. 4.Lawful basis and consent

    In India we process personal data under the Digital Personal Data Protection Act, 2023. Where the Act asks for consent we ask for it in plain words, for a stated purpose, and record what was shown and when.

    Consent is asked per attribute, never bundled: for example, personal details about a company's owner used to match public schemes are asked for one at a time, and refusing one does not refuse the rest.

    You may withdraw a consent at any time. Withdrawal stops the processing it covered from that moment; it does not undo processing already done lawfully.

    Where processing rests on a basis other than consent, such as the employment purposes of the company that invited you, that basis is [to be confirmed by counsel].

  5. 5.Sub-processors

    We use these providers to run Corto. Each receives only what its job needs.

    • Anthropic (connected): the AI model that drafts reports, interview follow-ups, plans and goals, reads the files you hand Corto in the chat, writes the documents you ask it for, searches the web for a question you ask it to research, and runs long work you hand it as a job in a workspace of its own (Anthropic Managed Agents), removed when the job ends.
    • Email relay (connected): sends invitations and the onboarding's emails over SMTP. Sign-in is by your own PIN, so no sign-in code is emailed. Provider [to be confirmed].
    • GST Hero (connected): reads a company's GST registration and filing record from its GSTIN.
    • FileSure (connected, test access): reads the company register — master record, directors, charges and filed accounts — by CIN or LLPIN.
    • Composio (connected): the connection layer for apps a person chooses to connect, such as their own work mailbox or company files.
    • Google (connected through Composio; planned directly): Gmail and Google Drive when a person connects them; the Google Places listing for the outside-in report (planned).
    • ElevenLabs (connected): hears spoken conversations with Corto as they are spoken and turns them into text, speaks Corto's replies, and turns meeting recordings into text.
    • Fish Audio (connected, standby): turns speech into text and text into speech for spoken conversations only where ElevenLabs is not connected.
    • DeepSeek (connected): keeps the company's memory — reads what people say and write to Corto (conversations, check-ins, messages) and records the facts in it, and sums up each day. Some of what you say is processed by DeepSeek, on servers in China. That includes a person's X-Ray conversation: what it keeps from it is kept for that person alone and is never readable by anyone else in the company. What the company sees of the X-Ray is only the aggregate described above. At sign-up it also writes the buyer's view (“See what a buyer finds”): the company's name, city, website and LinkedIn page, and what Google shows about them, are sent to DeepSeek to be researched and summed up.
    • HiSociety (planned): the organisation's usage wallet. Corto reads the balance and records usage against it.
    • Hosting, database and file storage (planned): [providers to be confirmed].

    We will update this list before a new sub-processor receives personal data.

  6. 6.Where your data is kept

    Your company's region is set from its country before anything is stored, and it is not moved afterwards. For a company in India, data is stored in India.

    Some processing happens where a sub-processor runs its service, which may be outside your country — in particular the AI model. Where that is, and the safeguards that apply, are [to be confirmed per sub-processor].

    Some of what you say is processed by DeepSeek, on servers in China.

  7. 7.How long we keep it

    We keep your company's data for as long as your company uses Corto. When your company leaves, its data is deleted on request, and deletion is confirmed in writing.

    Retention periods for each class of record, and how long deleted data remains in backups, are [to be set with counsel].

  8. 8.Export and deletion

    Your company can export everything it holds in Corto, and ask for it to be deleted, at any time. This works the same whether your company pays for Corto or not, and it is never withheld over an unpaid bill.

  9. 9.Your rights

    You may ask to see the personal data we hold about you, correct it, complete it, have it erased, and withdraw a consent you gave. You may nominate someone to exercise these rights for you.

    A person sees their own data before their manager does.

    Grievances go to [grievance officer name and contact to be confirmed]. We will acknowledge within [period to be confirmed]. If you are not satisfied, you may complain to the Data Protection Board of India.

  10. 10.Children

    Corto is for people who work at a company, on a laptop. It is not meant for anyone under 18, and we do not knowingly collect a child's data. If we learn we have, we delete it.

  11. 11.Changes to this notice

    If we change this notice we will update the date above, and tell account holders before a change that affects how their data is used takes effect.