Data Privacy Policy (Customer Data)
Periscope One, Inc. · AICON
Version 1.5 · Effective 1 August 2026
| Owner | CEO, with the CTO as custodian |
|---|---|
| Applies to | Customer data processed by Periscope One in AICON |
| Version | 1.5 |
| First issued | July 2025 |
| Status | Approved |
| Effective | 1 August 2026 |
| Review cycle | Quarterly, at the AI governance review, with annual re-approval |
1. Purpose and scope
This policy states how we handle data belonging to our customers and to their workers, in AICON. It covers all customer data whether or not AI features are involved; AI-specific commitments are in the AI Usage and Governance Policy.
It does not cover our own marketing website visitors or job applicants, which are addressed separately.
2. Our role
Periscope One is a processor acting on the instructions of the customer, who is the controller of their workers' data. We process customer data to provide the platform and for no independent purpose of our own.
3. What we process
| Category | Examples | Source |
|---|---|---|
| Worker identity and employment data | Name, email, employee identifier, job title, phone number, work location, crew membership, certifications and expiry dates | Provided by the customer, or entered by their crew leaders |
| Pre-job briefing content | Form answers, discussion topics covered, job and location details, nearest hospital, crew present | Entered by the crew |
| Briefing audio and transcripts | Recording of the spoken briefing and the text derived from it | Recorded by the crew on a mobile device |
| Job-site media | Photographs and uploaded documents | Uploaded by the crew |
| Observations | Safety observation records and their content | Entered by observers |
| Authentication and access data | Credentials, sign-in events | Generated by use of the platform |
Voice. Briefing audio contains the voices of identifiable workers. Several privacy regimes treat voice as personal data in its own right, and in some jurisdictions as biometric data. It is treated as personal data throughout this policy.
4. Purposes of processing
We process customer data only to:
- Provide the platform's functionality to the customer and their workers
- Transcribe, analyze and summarize briefings where the customer has enabled AI
- Produce reporting the customer has configured
- Support and troubleshoot the service, including reading briefing content when investigating a reported problem
- Secure the platform and investigate security events
- Meet our legal obligations
We do not process customer data to train or improve AI models, to build products for other customers, or for our own marketing or analytics about identifiable individuals. AICON operates no shared index, retrieval store or corpus that spans customers.
5. Legal basis and instructions
We process on the customer's instruction, as set out in the customer agreement and any data processing agreement. Where a customer instructs us to do something that would breach this policy or applicable law, we will decline and say why.
6. Data location
The production application, its database and its file storage are located in the United States (Microsoft Azure, principally South Central US, with supporting services in other United States regions). AI inference and AI diagnostics are performed by US-based providers listed in the AI Subprocessor List. Customer data is not transferred outside the United States in the normal operation of the service.
7. Security
Customer data is protected by:
- Encryption in transit. TLS on all connections, including to AI providers
- Encryption at rest. for the database and file storage
- Tenant isolation. customer records carry the owning portal's identifier, and every path that returns customer data is scoped to it. Scoping is applied by the platform rather than by each query, so a path cannot return another customer's data. Isolation is logical, within shared infrastructure; it is not a separate database per customer
- Administrative access control. production access is limited to named personnel and authenticated through Microsoft Entra ID
- Secret management. provider credentials are held in a managed secrets vault and read by the application's own workload identity. No credential value is held in application configuration or in source control, and commits containing credentials are blocked before they reach the repository
Full detail is in the Data Security Policy and in the control set being evidenced for SOC 2.
8. Sharing and subprocessors
We do not sell customer data and do not share it other than with the subprocessors required to deliver the service. AI-related subprocessors, what they process, and where they are located are published in the AI Subprocessor List. Each subprocessor is bound by a data processing agreement prohibiting use of customer data for its own purposes, including model training.
Customers are notified before a new subprocessor begins processing their data, with at least 30 days' notice.
9. Retention and deletion
Retention is set by the customer's contract. Where it is silent, the defaults in the Data Retention and Deletion Policy apply. Customers may request deletion of specified records or of all their data; we acknowledge within 5 business days and complete within 30 days. Detail, including what "deletion" covers and how backups are treated, is in that policy.
10. Data subject requests
Requests from individual workers (access, correction, deletion, objection) are directed to the customer, who is the controller of that relationship. Where a request reaches us directly we will forward it to the customer promptly and will assist the customer in responding. We will not action a worker's request against a customer's data without the customer's instruction, except where law requires it.
11. Incidents and notification
Suspected or confirmed unauthorized access to, disclosure of, or loss of customer data is handled under the AICON Incident Response Policy. Affected customers are notified without undue delay and no later than 72 hours after we confirm an incident affecting their data, by direct contact to their named account contact, including what we know, what is affected, what we are doing, and what they may need to do.
12. Customer responsibilities
Customers are responsible for: the accuracy and lawfulness of the worker data they provide; informing their workers about the platform's use, including the recording of briefings; managing their own users' access; and configuring the retention period they require.
13. Contact
Privacy enquiries, deletion requests and any notice required under this policy:
- Email legal@p-one.ai
- Post: Periscope One, 4225 Rollins Road, Zachary, LA 70791
Either route reaches the same team. Email is the faster of the two and is the address used for notices under our terms of service.
14. Related documents
AI Usage and Governance Policy · Data Retention and Deletion Policy · AI Subprocessor List · AICON Incident Response Policy · Data Security Policy
Version 1.5. Approved 1 August 2026.