Privacy Policy
Last updated: 25 July 2026
This is a working draft, published for transparency. It reflects how the Service actually handles data today; the final wording is pending review by legal counsel and may change. Spearhead Analytics Limited is currently being incorporated in Ireland (company registration pending). Questions: privacy@ignela.com.
Spearhead Analytics Limited (in formation in Ireland — “Ignela”, “we”, “us”) operates the Ignela analytics platform (the “Service”). This policy explains what personal data we process, why, and your rights.
1. Who is the controller
- For your account and our marketing/billing (your name, email, login events, subscription), Ignela is the controller.
- For the data you connect or load into the Service (the rows your SQL returns from your connected warehouse, ingested sheets, the dashboards you build), you (or your organisation) are the controller and Ignela is the processor. We process that data only on your instructions, under the terms of a Data Processing Agreement (available to business customers on request). We do not inspect, repurpose, or sell it.
2. What we collect
| Category | Examples | Source |
|---|---|---|
| Account & identity | name, email, organisation, hashed auth factors, MFA status | you / Clerk (our auth provider) |
| Authentication events | sign-in, sign-out, password/MFA change, failed login | generated by use |
| Usage & audit logs | which dashboard you viewed, which dataset ran, exports, timestamps, actor id | generated by use |
| Billing | billing contact, plan, subscription status (no card numbers — held by Stripe) | you / Stripe |
| Connected data | whatever your SQL returns or you ingest, cached per-tenant to serve your dashboards | your connected sources |
| Technical | IP, request metadata, error traces (PII-scrubbed) | generated by use |
2a. Cookies and similar technologies
We do not use advertising or cross-site tracking cookies. The product app sets only strictly-necessary cookies:
| Cookie | Set by | Purpose | Type |
|---|---|---|---|
__session, __client (and related Clerk cookies) | Clerk | Keep you signed in; secure your session | Strictly necessary |
flynt_view_as | Ignela | Operator “view-as” support session (signed, HttpOnly) | Strictly necessary |
| OAuth nonce (short-lived) | Ignela | CSRF protection during Google Sheets connection | Strictly necessary |
Strictly-necessary cookies do not require consent under the ePrivacy rules. We also store small functional preferences (theme, sidebar/checklist state) in your browser’s local storage; these are not transmitted to us and set no cookie.
On our marketing site and docs wiki we use Vercel Web Analytics and Speed Insights, which are cookieless (no persistent identifier) and process aggregate page views and visitor IPs under our legitimate interest in understanding site traffic. See our sub-processor list for details.
3. Why we process it (legal bases)
- Contract — to provide the Service you signed up for (accounts, hosting, querying, visualising, exports).
- Legitimate interests — security, abuse prevention, audit logging, product reliability, and limited service communications.
- Legal obligation — tax/accounting records; responding to lawful requests.
- Consent — where required (e.g. optional product-update emails); you can withdraw at any time.
For connected data processed as a processor, the lawful basis is your organisation’s, as controller.
4. Sub-processors and where data lives
We use a small set of vetted sub-processors; the current list — purpose, location, and transfer safeguard — is maintained on our sub-processors page and includes our hosting provider (AWS), CDN/TLS (Cloudflare), authentication (Clerk), billing (Stripe), and transactional email (Postmark). We notify affected customers before adding or removing a sub-processor.
Data residency. Primary storage is provisioned in an EU region by default for EU customers. Some sub-processors are US-based; those transfers are covered by EU Standard Contractual Clauses. A fully EU-only deployment is available on request.
5. How long we keep it
- Account data: for the life of your account, then deleted within 30 days of closure (subject to legal retention for invoices/tax).
- Audit logs: 12 months by default (configurable per contract).
- Connected/cached data: for as long as your organisation keeps it in the Service; removed on dataset deletion or on org deletion (30-day grace, then irreversible hard delete).
6. How we protect it
- Encryption in transit (TLS) and at rest (volume encryption; client-side-encrypted backups).
- Per-tenant isolation — each organisation’s data is stored in its own isolated store, not co-mingled.
- Access controls + audit logging; role-based permissions within your org; optional field-level encryption and cell-suppression for sensitive columns.
- A documented breach-response procedure with 72-hour notification.
7. Your rights
Depending on your location (GDPR/UK GDPR and similar), you may access, correct, export, delete, restrict, or object to processing, and withdraw consent. Account holders can self-serve export and deletion in-product; for connected data, direct requests to your organisation (the controller). To exercise rights against Ignela as controller, contact privacy@ignela.com. You may also complain to your supervisory authority (in Ireland, the Data Protection Commission).
8. Children
The Service is not directed to anyone under 16; we do not knowingly collect their data.
9. Changes
We’ll post changes here and, for material changes, notify account admins by email. Continued use after the effective date constitutes acceptance.
10. Contact
Spearhead Analytics Limited (in formation, Ireland) — registered office to be confirmed on incorporation. Data protection contact: privacy@ignela.com. Data Protection Officer / EU representative: not appointed — not required (we do not carry out large-scale monitoring of individuals or process special-category data at scale).