Privacy Policy

1. Who we are

Nano EASM ("we", "us", "our") operates the Service at https://nanoeasm.com, an External Attack Surface Management platform that helps organisations discover, scan, monitor, and remediate internet-facing assets.

For the personal data covered by this policy, we are the data controller (or, under the Australian Privacy Act 1988, the APP entity) unless stated otherwise.

• Operator: BoltEdge Security, Suite 1208/530 Little Collins Street, Melbourne VIC 3000, Australia
• Contact for privacy matters: support@nanoeasm.com

We comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). For users in the United Kingdom or European Economic Area, we also comply with the UK GDPR / EU GDPR. For California residents, we observe the rights described in §9.

If we have appointed an Article 27 GDPR / UK GDPR representative, their details will be made available on request from the contact above.

2. Scope of this policy

This Privacy Policy explains how we handle:

• Personal data of account holders (people who sign up to use the Service), where we are the data controller.
• Personal data of Authorised Users within an organisation (invited team members), where we are the data controller for the account itself but the organisation owner controls organisation-level decisions.
• Visitors to nanoeasm.com and users of the unauthenticated quick-scan tools.

It does not describe how organisations using the Service handle personal data they choose to submit as Customer Data (assets, scan results, findings). For that data, the organisation is the controller and we act as their processor under the Terms of Use. If you are a data subject of an organisation's scan results and want to exercise rights over that data, contact the organisation directly.

3. The information we collect

3.1 Information you provide directly

When you create an account or use the Service, you may give us:

• Account information: name, email address, password (stored as a cryptographic hash, never in plaintext), country, optional job title and company.
• Organisation information: organisation name, slug, industry, size, website, country.
• Communications: messages you send via the contact form, support emails, or in-product feedback (including subject, body, and any attachments).
• Customer Data: domains, subdomains, IP addresses, email addresses, cloud asset URLs, asset groups, scan profiles, scan schedules, monitoring rules, and integration configurations that you submit to the Service.
• Billing information: for paid plans, your billing email and any billing address collected during checkout. Card data is collected and stored by our payment processor (Stripe), we never see, store, or process your card number directly. We retain metadata such as your Stripe customer ID, subscription status, invoice history references, and the last four digits of the payment-method brand for display purposes.

3.2 Information collected automatically

When you use the Service, we automatically collect:

• Log data: IP address, user agent, request paths, timestamps, HTTP status codes, and (for authenticated requests) the user and organisation involved. Used for security monitoring, abuse prevention, and debugging.
• Audit log entries: actions you perform inside the Service (e.g. scan started, asset added, plan changed) tied to your user ID, organisation ID, and source IP address.
• Quick-scan submissions: for users of the unauthenticated quick-scan tools, we log your IP address, user agent, the target you submitted, the request status (completed / blocked / rate-limited), and timing data. This is used for abuse prevention (rate limiting, IP blocking) and capacity planning.
• Email delivery metadata: when we send transactional email (verification, password reset, billing receipts, monitoring alerts), our email provider records delivery, bounce, and open status.

We do not use third-party analytics trackers, advertising pixels, fingerprinting libraries, or behavioural tracking.

3.3 Information from third parties

If you sign in with Google or Microsoft (OAuth), we receive your email address, name, and (where available) avatar URL from the identity provider. We do not receive your password.

We do not buy, rent, or scrape personal data from data brokers.

3.4 Customer Data and third-party personal data

The Service performs reconnaissance and security scanning against internet-facing assets that you authorise. Scan results and discovered assets may include personal data of third parties (for example, email addresses found in WHOIS records, on websites, or in breach corpora that public scanners reference).

For this category of personal data:

• You (the organisation submitting the scan) are the data controller and are responsible for ensuring you have a lawful basis to process it.
• We are the data processor, processing it on your instructions to provide the Service.
• A Data Processing Agreement (DPA) governs this relationship for customers on paid plans. Contact us to request one.

4. How we use information

We use the personal data described above to:

• Provide the Service: authenticate you, run scans you initiate, store your assets and findings, deliver alerts, send transactional email, and provide customer support.
• Bill paid plans: manage subscriptions via Stripe, send receipts, and recover failed payments.
• Secure the Service: detect and prevent abuse, fraud, and unauthorised use; investigate security incidents.
• Improve the Service: diagnose bugs, analyse aggregate usage patterns, and develop new features. We do not use Customer Data to train models or improve features that benefit other customers.
• Comply with legal obligations: respond to lawful requests from public authorities, comply with tax and accounting requirements, and enforce our Terms of Use.

5. Legal bases for processing

We process personal data under one or more of the following bases, depending on which jurisdiction's law applies to you:

• Performance of a contract: to provide the Service to you under the Terms of Use, including running scans, sending transactional email, and managing your subscription.
• Legitimate interests / reasonable use: to keep the Service secure (abuse prevention, fraud detection, audit logging), to communicate with you about your account, and to improve the Service. We have weighed these interests against your rights and freedoms.
• Legal obligation: to comply with laws that require us to retain or disclose data (e.g. tax, accounting, court orders, or notifiable data-breach reporting under the Privacy Act 1988).
• Consent: where we ask for it explicitly, for example for certain optional communications. You can withdraw consent at any time without affecting prior processing.

If you are in Australia, our processing is also conducted in accordance with the Australian Privacy Principles (APPs) in Schedule 1 of the Privacy Act 1988 (Cth). If you are in the UK or EU, the four legal bases above map to the lawful-processing grounds under Article 6 of the UK / EU GDPR.

6. Who we share information with

We share personal data only with the parties listed below, and only to the extent necessary for the listed purpose. We do not sell personal data, share it for cross-context behavioural advertising, or rent it to third parties.

6.1 Sub-processors

We rely on the following providers to operate the Service:

We require each sub-processor to provide appropriate safeguards for the data they process and we have data-protection agreements in place where required.

6.2 Legal disclosures

We may disclose personal data when required by law, court order, or binding government request, or where necessary to protect our rights, your rights, or public safety. Where legally permitted, we will attempt to notify the affected user before disclosure.

6.3 Business transfers

If we are acquired or merge with another company, personal data may be transferred to the successor entity, subject to the protections of this policy. We will notify you of any such transfer.

7. International data transfers

Our application and database are hosted on Amazon Web Services in the United States (us-east-1) region, and several of our sub-processors are also located in the US. This means personal data submitted to the Service is transferred outside Australia (where Nano EASM is incorporated) for storage and processing.

We rely on appropriate safeguards for these transfers, which may include:

• For data subject to Australian Privacy Principle 8, taking reasonable steps to ensure overseas recipients handle data consistently with the APPs.
• For UK / EU data subjects, Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum, with supplementary technical and organisational measures.
• Adequacy decisions where applicable (e.g. EU–US Data Privacy Framework, UK–US Data Bridge).

By using the Service, you acknowledge and consent to the transfer of your personal data to the United States and the other sub-processor jurisdictions listed in §6.1.

A copy of the safeguards we rely on for any specific transfer is available on request from support@nanoeasm.com.

8. How long we keep data

We keep personal data for as long as it is needed for the purposes described in this policy. Specific retention rules are set out in Data Handling & Retention. At a high level:

• Account data: retained while your account is active and for a reasonable wind-down period after deletion. If your account belongs to no other organisation, it is also deleted when your organisation is deleted automatically (see below).
• Customer Data (assets, scans, findings, reports): retained until your organisation is deleted; deleted on organisation deletion with database cascade.
• Automatic organisation deletion: an organisation is permanently deleted 90 days after its paid plan ends unless a paid plan is resumed, and an organisation on the Free plan is permanently deleted after 90 days with no member sign-in and no API or MCP key use. Owners and Admins receive warning emails 30, 7, and 1 days before deletion. Billing records held by Stripe are kept by Stripe for accounting.
• Audit logs and security logs: retained for a defined window (typically 12 months) for security and compliance.
• Quick-scan logs: retained for abuse prevention.
• Billing records: retained as required by tax and accounting law (typically 6–7 years depending on jurisdiction).
• Backups: retained on a rolling schedule and overwritten on rotation.

When data is no longer needed, we delete or anonymise it.

9. Your rights

You have the following rights in relation to your personal data, exercisable free of charge:

• Access: request a copy of the personal data we hold about you.
• Correction (or rectification), ask us to correct inaccurate or out-of-date data.
• Deletion (or erasure / "right to be forgotten"), ask us to delete your data, subject to legal retention obligations.
• Restriction: ask us to restrict processing in certain circumstances.
• Portability: receive a machine-readable export of data you provided to us.
• Object: object to processing based on legitimate interests.
• Withdraw consent: where we rely on your consent, you can withdraw it at any time without affecting prior processing.

The exact name and scope of these rights depends on the law that applies to you:

• Australia. Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you can access, correct, and complain about the handling of your personal data. If you are unsatisfied with our response to a complaint, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).
• United Kingdom / European Economic Area. Under UK GDPR / EU GDPR, you can lodge a complaint with the UK Information Commissioner's Office (ICO) or your country's supervisory authority.
• California (US). Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), you have the right to know, delete, correct, and limit use of sensitive personal information. We do not sell or share personal information for cross-context behavioural advertising.

To exercise any of these rights, email support@nanoeasm.com. We may need to verify your identity before fulfilling the request and will respond within the timeframe required by applicable law (generally 30 days under the Privacy Act 1988, one month under UK / EU GDPR, 45 days under CCPA).

If you are a data subject of an organisation's scan results, please contact that organisation directly, they are the controller of that data.

10. Children's privacy

The Service is not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe we have collected data from a minor, contact us at support@nanoeasm.com and we will delete it.

11. Security

We use industry-standard technical and organisational measures to protect personal data, including:

• TLS for all data in transit.
• Encryption for sensitive data at rest.
• Hashed (never plaintext) password storage.
• Role-based access control and least-privilege principles for internal access.
• Audit logging of administrative actions.
• Regular dependency updates and security patches.

No system is perfectly secure. If you discover a security vulnerability in the Service, please report it responsibly via support@nanoeasm.com, we appreciate coordinated disclosure.

12. Cookies and similar technologies

We use a small number of cookies and browser-storage items, all of them strictly necessary for the Service to function. We do not use analytics, advertising, or behavioural-tracking cookies.

Because all cookies/storage we use are strictly necessary, we do not display a cookie banner. If we add non-essential cookies in future (e.g. analytics), we will update this policy and provide a consent mechanism where required.

13. Changes to this policy

We may update this policy from time to time. Material changes will be notified via the Service or by email to account holders, with reasonable notice before the effective date. The "Last updated" date at the top reflects the most recent revision.

14. Contact

For privacy questions, data subject requests, or to request a copy of safeguards for international transfers:

• Email: support@nanoeasm.com
• Web: https://nanoeasm.com/#contact