DPO MCP Privacy Policy

1. Introduction

Quantide Growth Partners, Inc. (“QGP,” “we,” “us,” or “our”) provides the Digital Pricing Officer MCP connector (the “DPO MCP” or “Service”), a remote Model Context Protocol server that exposes QGP’s Digital Pricing Officer agent to AI clients including Anthropic’s Claude and OpenAI’s ChatGPT. This Privacy Policy describes how QGP collects, uses, discloses, and safeguards information in connection with the DPO MCP.

This Privacy Policy applies solely to the DPO MCP. It does not apply to the separate Digital Pricing Officer web application or to any other QGP product or service, each of which may be governed by its own privacy notice.

2. Data Protection Roles

For account, authentication, billing, provisioning, service operations, security, support, and usage administration, QGP determines the purposes and means of processing and acts as an independent controller or business, as those terms are used under applicable privacy laws. For customer questions, answers, and any personal information included in tool-call content, QGP processes that information only to provide the DPO MCP and only as described in this Privacy Policy, the DPO MCP Connector Terms of Service, and any applicable written customer agreement. To the extent applicable privacy law treats QGP as a processor, service provider, or contractor for such tool-call content, QGP will process that information only on the customer’s documented instructions and will not retain, use, or disclose it except as permitted by the applicable agreement and applicable law.

Use of the DPO MCP is also governed by the DPO MCP Connector Terms of Service and any applicable QGP master terms, order form, or other written customer agreement. In the event of any conflict between this Privacy Policy and those terms with respect to the DPO MCP, this Privacy Policy controls as to privacy matters.

3. Information We Collect

In connection with your use of the DPO MCP, QGP collects the following categories of information.

3.1 Account and Authentication Information
When a customer subscribes to the DPO MCP through our payment processor, we receive and store an email address (required to provision the account), an organization identifier (“customer_id”), a salted SHA-256 hash of the access token issued to the customer, the subscription tier, the monthly call limit, the token expiry, the token status, and our payment processor’s customer and subscription identifiers. We do not store the raw access token after issuance, and we do not store payment card numbers (all card data is handled by our payment processor as described in Section 5). QGP also stores a bcrypt hash of the customer’s MCP account password created when first authenticating access; the password is never stored in plaintext. Where a customer belongs to an organization, QGP also stores the organization’s join code and the seat assignment for each authorized user, up to the number of seats the organization has purchased. For customers who connect through the OAuth 2.1 authorization flow, QGP also stores rotating refresh tokens, registered OAuth client records, and short-lived authorization codes used to establish the connection. These records are also created for accounts on the no-cost free tier, which is provisioned through the same process and includes one seat and a limited monthly credit allocation. For customers who purchase downloadable skill packs, QGP also stores a purchase record identifying the pack purchased, whether the purchase is one-time or subscription, and the associated payment-processor identifiers.

3.2 Tool Call Metadata
Each time the DPO MCP processes a tool call, we generate one structured log entry containing metadata only: timestamp, tool name, customer_id, access token identifier, request path and method, HTTP status code, latency in milliseconds, outcome, usage count, workflow selected, and error information, as applicable. Tool call metadata excludes the substantive contents of customer questions and answers. Bearer tokens are never logged.

3.3 Tool Call Content (Questions and Answers)
The free-text question a customer submits through the ask_dpo tool (and the answer the Service returns) is transmitted to and processed by the DPO MCP and OpenAI. The DPO MCP does not support document or file upload. Files and documents stored in a customer’s third-party AI client are not transmitted to QGP unless the AI client includes text from those materials in a tool call. In the Service’s operating configuration, customer questions and answers are held by QGP’s DPO MCP server only in process memory during the period required to generate a response and are then discarded from that server. However, OpenAI’s developer platform may store customer questions, answers, system prompts, context provided to the agent, agent reasoning, and related processing records so that QGP can perform quality assurance and evaluate and improve the effectiveness of the DPO MCP’s responses, and not to train, fine-tune, or otherwise develop any foundation model, unless and until QGP deletes them under QGP’s OpenAI developer-platform settings or applicable OpenAI retention controls. Questions and answers are not written to disk or to any database by QGP’s DPO MCP server after the request completes.

Where a customer voluntarily includes confidential business information or personal information in the text of a question, that content is handled as described in this Section 3.3 and Section 4.3 below. Customers are responsible for complying with the applicable terms governing regulated, sensitive, personal, confidential, or third-party data submitted to the DPO MCP.

3.4 Usage Counters
We maintain a per-token monthly call counter for the purpose of enforcing the monthly call limit associated with each subscription tier and supporting billing. This counter resets on the first day of each month (UTC). For customers on an organization plan, usage is metered against a shared organization credit pool rather than a strict per-user counter; any per-user allocation is advisory only, and the organization pool is the sole enforced limit.

3.5 Technical and Network Information
The DPO MCP application logs do not capture browser type, referrer URL, or device identifiers. The underlying cloud platform (Google Cloud Run) may capture the source IP address of requests at the platform level for operational and security purposes. Additional technical information about the AI client and the device the customer uses to access the Service is captured by the third-party AI client (Anthropic or OpenAI) and is governed by that provider’s privacy policy, not this one.

3.6 Sources of Information
QGP collects information directly from customers, from the customer’s use of the DPO MCP, from the customer’s MCP Client to the extent the MCP Client transmits tool-call parameters to QGP, and from QGP’s payment processor and service providers. QGP does not intentionally collect personal information from public data brokers or third-party marketing lists for the DPO MCP.

3.7 Sensitive and Regulated Information
The DPO MCP is designed for business pricing, packaging, and monetization analysis. Customers should not submit government identifiers, financial account credentials, payment card data, protected health information, children’s data, precise geolocation, biometric data, genetic data, neural data, credentials, special-category data, or other sensitive or regulated information unless QGP has entered into a separate written agreement that expressly covers that category of information. If a customer submits such information without a separate written agreement, QGP will handle it as tool-call content under Section 3.3, but QGP does not represent that the DPO MCP is configured for regulated-data workloads.

3.8 Supplemental U.S. State Privacy Disclosure
The following table summarizes the categories of personal information QGP may collect through the DPO MCP, the sources of that information, the purposes for which QGP uses it, the categories of recipients to whom QGP may disclose it, and the applicable retention period. This disclosure is intended to provide additional transparency for U.S. state privacy law purposes and should be read together with the rest of this Privacy Policy.

Scroll the table horizontally to view all columns.

4. How We Use Information

QGP processes the information described in Section 3 for the following purposes.

4.1 Service Delivery
We process tool calls to deliver the pricing intelligence functionality of the DPO MCP, including authenticating each request, routing the question through the retrieval-augmented language-model pipeline, and returning the resulting answer to the customer’s AI client.

4.2 Billing, Provisioning, and Account Management
We process subscription and account information to provision and revoke access, to enforce monthly usage limits, to invoice through our payment processor, and to communicate with customers about their account.

4.3 Service Improvement
We may use tool call metadata (Section 3.2) and usage counters (Section 3.4) for authentication, service delivery, billing, service monitoring, capacity planning, security, fraud prevention, abuse detection, debugging, support, and enforcement of the applicable terms. We may review customer questions, answers, system prompts, context provided to the agent, agent reasoning, and related processing records stored in OpenAI’s developer platform for quality assurance, debugging, safety review, and internal improvement of the DPO MCP. We do not use the content of customer questions or answers for model training, fine-tuning, benchmarking, or cross-customer analytics. If we begin to perform aggregated or cross-customer analytics using tool call metadata or usage counters, we will update this Privacy Policy and provide advance notice as described in Section 13.

4.4 Support and Troubleshooting
We use account information and tool call metadata to diagnose and resolve service issues. Because the content of customer questions and answers is not retained (Section 3.3), such content is not available to QGP for debugging or support purposes by design.

4.5 Security, Fraud Prevention, and Enforcement
We use account information, tool call metadata, and usage counters to authenticate requests, enforce monthly limits, detect abuse, prevent unauthorized access, and otherwise protect the integrity and security of the Service.

4.6 Legal Compliance
We process information to comply with applicable laws and regulations, including tax and accounting obligations, and to respond to lawful legal process.

4.7 No Use for Model Training
Customer questions, customer answers, and any business information a customer includes in a question may be reviewed for quality assurance and internal improvement as described in Section 4.3, but are not used by QGP to train, fine-tune, or otherwise improve any foundation model, and are never incorporated into the QGP Knowledge Vault. The QGP Knowledge Vault contains only QGP’s own pricing knowledge.

4.8 Data Minimization and Purpose Limitation
QGP is designed to collect and retain only the categories of information described in this Privacy Policy for the purposes described in this Privacy Policy. Customers should limit tool-call content to information reasonably necessary for the pricing, packaging, or monetization question they ask the DPO MCP to answer. QGP will not use personal information collected through the DPO MCP for materially different purposes without updating this Privacy Policy and providing notice where required by applicable law.

4.9 Legal Bases for Processing
Where EU, UK, Swiss, or similar privacy law applies, QGP relies on the following legal bases for processing personal information: performance of a contract to provide, provision, authenticate, meter, support, and administer the DPO MCP; legitimate interests in operating, securing, monitoring, improving, debugging, and enforcing the Service, provided those interests are not overridden by applicable individual rights; compliance with legal obligations, including tax, accounting, sanctions, export-control, and lawful-process obligations; and consent where QGP expressly requests consent for a specific processing activity. Customers may withdraw consent where consent is the legal basis for processing, but withdrawal will not affect processing that occurred before withdrawal or processing conducted on another lawful basis.

5. How We Share Information; Sub-Processors

QGP does not sell personal information. QGP does not share personal information for cross-context behavioral advertising. QGP discloses information only: (a) to the limited set of sub-processors identified below, each of which processes information on QGP’s behalf under written contract and only as necessary to operate the DPO MCP; (b) to professional advisors, affiliates, successors, or transaction counterparties where reasonably necessary for business administration, legal compliance, financing, merger, acquisition, reorganization, or sale of assets; (c) as required by law, valid legal process, or governmental request; or (d) as necessary to enforce QGP’s terms or protect the rights, property, or safety of QGP, our customers, or others.

Customer inputs and outputs transmitted to OpenAI through the DPO MCP are processed under OpenAI’s applicable API terms and settings and may be stored in OpenAI’s developer platform for quality assurance and internal improvement purposes unless and until QGP deletes them under QGP’s OpenAI developer-platform settings or applicable OpenAI retention controls. QGP does not authorize OpenAI or any other QGP sub-processor to use customer inputs or outputs to train, fine-tune, or otherwise improve foundation models.

QGP may also disclose information when required to do so by law, valid legal process, or governmental request; when necessary to enforce QGP’s Terms of Service or this Privacy Policy; or when necessary to protect the rights, property, or safety of QGP, our customers, or others.

If QGP is involved in a merger, acquisition, financing, corporate reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, QGP may disclose or transfer information in connection with that transaction, subject to confidentiality protections appropriate to the transaction and applicable law. If a transaction materially changes the processing of personal information covered by this Privacy Policy, QGP will provide notice as described in Section 13.

Where QGP receives legal process seeking customer information, QGP will review the request and, where legally permitted and commercially reasonable, seek to limit the disclosure to information reasonably necessary to respond to the request. QGP may notify the affected customer where legally permitted, unless QGP determines that notice would create a security, legal, fraud-prevention, or operational risk.

QGP maintains the foregoing list of sub-processors and will notify customers in advance of any material change to the list as described in Section 13.

QGP may create or use de-identified, aggregated, or anonymized information derived from tool-call metadata, usage counters, account records, or operational logs, provided that such information does not identify a customer or individual and does not include the substantive content of customer questions or answers. QGP will not attempt to re-identify de-identified information except as permitted by applicable law to validate de-identification or investigate security issues.

6. Data Retention

QGP retains the categories of information described in Section 3 for the periods set forth in the following table.

When QGP deletes information under this Section 6, QGP deletes the information from active systems in accordance with its ordinary deletion procedures. Residual copies may remain temporarily in backups, audit logs, or security records until they are overwritten or purged in the ordinary course, unless earlier deletion is technically feasible and legally required.

QGP may retain information for longer than the periods set forth above where required by law, where necessary to establish, exercise, or defend legal claims, or where necessary to investigate or address violations of the Terms of Service. Where QGP retains information for any such longer period, such information is retained only for so long as is necessary for the relevant purpose.

7. Data Security

QGP implements technical and organizational measures designed to protect information processed in connection with the DPO MCP, including:
- Encryption of all data in transit between the customer’s AI client, the DPO MCP server, and each sub-processor, using TLS;
- Encryption of data at rest by the underlying cloud providers (Google Cloud and Supabase);
- Storage of access tokens only as salted SHA-256 hashes; the raw token is shown to the customer once at issuance and is not retrievable from QGP systems thereafter; storage of account passwords created at MCP authentication only as bcrypt hashes, never retained in plaintext;
- Storage of all secrets and credentials (API keys, database connection strings, and webhook signing keys) in Google Secret Manager, with runtime injection only; no credentials are hardcoded or persisted in container images or logs;
- Least-privilege identity and access management (IAM) for all internal access, governed by Google Cloud IAM;
- Stateless containerized services with no long-lived credentials; and
- Periodic review of security practices.

QGP’s security measures are intended to be proportionate to the limited nature of the information processed by the DPO MCP and may be updated from time to time. QGP also maintains internal access restrictions, operational logging for security and troubleshooting, vendor-management practices for key sub-processors, and incident-response procedures designed to identify, investigate, contain, and remediate security incidents affecting the DPO MCP.

Notwithstanding these measures, no method of transmission over the Internet or method of electronic storage is fully secure, and QGP cannot guarantee absolute security. If you believe the security of your information or your interaction with the DPO MCP has been compromised, please contact QGP using the information in Section 15. In the event of a personal data breach affecting customer information, QGP will notify affected customers and any applicable supervisory authorities as and when required by law.

8. Data Location and International Transfers

The DPO MCP is hosted primarily in the United States. QGP’s own production environment for the DPO MCP is operated in the United States, and the sub-processors identified in Section 5 may process information in the United States and other locations where they or their service providers operate.

If you access the Service from outside the United States, your personal information may be transferred to and processed in the United States and other jurisdictions where QGP or its sub-processors operate. The data-protection laws of those jurisdictions may differ from those of your jurisdiction of residence, and information transferred to those jurisdictions may be subject to access by courts, law enforcement authorities, or other governmental authorities under applicable law. Where required by applicable law, QGP will use appropriate transfer safeguards for international transfers of personal information.

9. Your Rights and Choices

QGP provides the following rights to all customers of the DPO MCP, regardless of jurisdiction, to the extent the rights apply to personal information QGP processes about them:
- Right of access — to obtain confirmation of whether QGP processes information about you, and to obtain a copy of such information;
- Right of correction — to request that QGP correct inaccurate or incomplete information about you;
- Right of deletion — to request that QGP delete information about you, subject to the retention periods set forth in Section 6 and any longer retention required by law;
- Right of portability — to receive a copy of your account information in a structured, commonly used, and machine-readable format.

To exercise any of the foregoing rights, please contact QGP at info@quantidegrowth.com. QGP will respond to a verified request within thirty (30) days of receipt. Where a request is complex or where QGP receives a high volume of requests, this period may be extended by an additional thirty (30) days, and QGP will notify you of any such extension within the initial 30-day period.

9.1 Communications Preferences
QGP may send service, security, legal, billing, and account notices that are necessary or useful for operating the DPO MCP. Customers may not opt out of transactional or service-related communications while they maintain an active subscription or account. If QGP sends marketing communications, recipients may opt out by following the unsubscribe instructions in the communication or by contacting QGP, but QGP may continue to send non-marketing communications.

9.2 Accuracy of Account Information
Customers are responsible for providing accurate and complete account, billing, and contact information and for keeping that information current. QGP may use the information provided by the customer for the purposes described in this Privacy Policy or as otherwise disclosed at the time of collection. QGP may take reasonable steps to maintain the accuracy of personal information it controls, but QGP may be unable to provide notices, support, access, or billing communications if customer-provided information is inaccurate or out of date.

An authorized agent may submit a request on your behalf provided that the agent furnishes written authorization signed by you. QGP may take reasonable steps to verify the identity of the requestor and the authority of any agent before responding to a request.

9.3 Additional U.S. State Privacy Rights
Depending on where you reside and whether a particular privacy law applies to QGP or to the DPO MCP, you may also have the right to: confirm whether QGP processes your personal information; obtain a portable copy of personal information you provided to QGP; opt out of the sale of personal information; opt out of sharing personal information for cross-context behavioral advertising or targeted advertising; opt out of certain profiling or automated decision-making activities; limit the use and disclosure of sensitive personal information; appeal a denial of a privacy request; and receive information about categories of personal information collected, sources, purposes, recipients, retention periods, and disclosures for business purposes. QGP does not sell personal information, does not share personal information for cross-context behavioral advertising, and does not process personal information collected through the DPO MCP for targeted advertising.

9.4 Appeals and Non-Discrimination
If QGP denies a privacy request and applicable law gives you an appeal right, you may appeal by replying to QGP’s denial notice or by contacting info@quantidegrowth.com with the subject line “Privacy Appeal.” QGP will not discriminate against you for exercising privacy rights, except where a difference in service is reasonably related to the value or availability of the information needed to provide the Service or is otherwise permitted by law.

In addition, you (or the organization on whose behalf you use the Service) may at any time disconnect the DPO MCP connector from your AI client. Upon cancellation of a subscription, QGP automatically revokes the associated access token, and residual account records are purged in accordance with Section 6.

9.5 Browser Signals, Cookies, and Tracking
The DPO MCP is accessed through third-party AI clients and does not use cookies, pixels, SDKs, or similar tracking technologies to recognize users across websites or services for advertising purposes. Because QGP does not sell personal information or share personal information for cross-context behavioral advertising through the DPO MCP, browser-based opt-out preference signals, including Global Privacy Control signals, do not change QGP’s DPO MCP data practices. Any cookies, device identifiers, analytics, telemetry, or privacy controls used by an MCP Client are governed by that provider’s terms, policies, and settings.

9.6 EU, UK, Swiss, and Similar Rights
Where EU, UK, Swiss, or similar privacy law applies, you may have additional rights to object to processing, restrict processing, withdraw consent, and lodge a complaint with a competent data-protection authority. These rights may be limited by applicable law, by QGP’s role in the processing, by the transient nature of tool-call content, and by QGP’s legal, security, billing, and contractual obligations.

10. Children’s Privacy

The DPO MCP is intended exclusively for business use by adult professionals. The Service is not directed to individuals under 18 years of age, and QGP does not knowingly collect personal information from any individual under 18. If QGP becomes aware that personal information of an individual under 18 has been collected, QGP will delete such information.

11. Third-Party AI Clients

The DPO MCP is accessed through a third-party AI client such as Anthropic’s Claude or OpenAI’s ChatGPT. Your use of any such AI client is governed by the terms, privacy policy, product settings, and data-use controls of the provider of that client, not by this Privacy Policy. Information you input into the AI client, including in the course of generating tool calls to the DPO MCP, is first handled by that provider and may be stored, logged, reviewed, or otherwise used by that provider under its own terms, policies, and settings. QGP receives only the tool-call parameters transmitted by the AI client to the DPO MCP server. QGP encourages customers to review the terms and privacy practices of any AI client through which the Service is accessed.

12. Automated Decision-Making and Profiling

The DPO MCP does not make automated decisions about individuals that produce legal or similarly significant effects. Outputs are decision-support materials for the customer’s business review and are not intended to replace human judgment. Customers are responsible for determining whether their own use of Outputs or any MCP Client involves profiling, automated decision-making, targeted advertising, employment decisions, pricing decisions about individuals, or other regulated processing, and for providing any required notices, consents, opt-outs, appeals, or human-review processes.

13. Changes to This Privacy Policy

QGP may modify this Privacy Policy from time to time and reviews its privacy practices periodically to help keep this Privacy Policy consistent with the DPO MCP’s data practices and applicable law. The “Last Updated” date at the top of this Privacy Policy indicates when the most recent changes were made. For any material change to this Privacy Policy, QGP will notify customers by email at least thirty (30) days in advance of the effective date of such change, using the email address associated with the customer’s account, unless a shorter period is needed to address security, legal, operational, or third-party platform changes. If applicable law requires a longer notice period, QGP will provide the longer period. Continued use of the Service after the effective date of any modification constitutes acceptance of the modified Privacy Policy.

14. Governing Law

This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts, without regard to its conflict-of-law principles, consistent with the governing-law and dispute-resolution provisions of the QGP Terms of Service. Disputes arising out of or relating to this Privacy Policy are subject to the same dispute-resolution provisions set forth in the QGP Terms of Service.

15. Contact Information; Privacy Questions and Complaints

For questions about this Privacy Policy, to exercise the rights described in Section 9, to report a security concern, or to raise any other privacy-related complaint or concern, please contact QGP at:

Quantide Growth Partners, Inc.
163 Highland Ave #1211
Needham, MA 02494
United States
Email: info@quantidegrowth.com