OXYGENOXYGEN

Privacy Policy

Last Updated: October 8, 2026

1. About OXYGEN

OXYGEN is operated by OXYGEN GTM Inc., a Delaware corporation.Legal notice and business correspondence address: 2810 N Church St STE 88810, Wilmington, DE 19802, United States. Contact: [email protected].

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data when you visit our website, create an account, use the OXYGEN platform, connect integrations, run workflows, use the OXYGEN CLI/MCP/API, or purchase done-for-you services.

2. Data Roles

For website, account, billing, security, support, product-administration, and marketing data, OXYGEN is an independent controller.

For customer-submitted workspace data, lead/contact data, campaign data, messages, table rows, workflow inputs, integration payloads, and provider outputs processed to provide the Service, Customer is the controller and OXYGEN acts as processor or service provider under the Data Processing Agreement.

Customer determines the purposes and means of outbound campaigns, including recipient selection, legal basis, consent evidence, suppression handling, and message content. OXYGEN processes that data to provide customer-directed software and operational assistance.

3. Information We Collect

  • Account data: name, business email, mobile number if you give one, organization, role, authentication identifiers.
  • Billing data: plan, invoices, payment status, billing identifiers handled with Stripe.
  • Usage and log data: product interactions, IP address, device/browser data, timestamps, diagnostics.
  • Support and communication data: emails, messages, tickets, call notes, and related metadata.
  • Customer content: tables, rows, columns, prompts, workflows, files, contacts, leads, messages, approvals, and run logs.
  • Integration data: CRM, email, LinkedIn, enrichment, calendar, provider, and AI-model inputs and outputs you authorize.
  • Outbound compliance data: legal-basis fields, consent/source evidence, unsubscribe and suppression data, campaign approvals, spend caps, and provenance.
  • Session recordings of the signed-in OXYGEN application: pages viewed, clicks and navigation, and the content rendered on screen during your session, where you have allowed optional analytics. See section 13 for what is recorded and what is excluded.
  • Tool-call telemetry for the OXYGEN MCP server: the name of each tool called, its outcome, timing, and the arguments sent to the tool and the result it returned. Because arguments and results are the working data of the call, they can contain workspace content such as contact records, search terms, and message content. See section 13 for what is removed before transmission and what is withheld entirely.
  • Cookie and analytics preferences for the public website.

4. Sources

We collect data from you and your organization, from your authorized users and agents, automatically through the Service, from connected integrations you authorize, from service providers and subprocessors, from public business sources where lawful, and from providers you or OXYGEN use under your instructions.

5. How We Use Information

  • Provide, operate, secure, maintain, and support the Service.
  • Authenticate users, manage organizations, issue API tokens, and enforce permissions.
  • Run customer-directed tables, workflows, enrichments, AI columns, provider calls, and done-for-you operations.
  • Record approvals, provenance, logs, errors, cost, credits, suppression state, and run history.
  • Process payments, invoices, taxes, subscriptions, and credits.
  • Detect abuse, prevent fraud, enforce policies, and protect users and recipients.
  • Improve the Service using sanitized product telemetry and aggregate analytics.
  • Send service notices, security notices, support replies, and marketing where permitted.
  • Comply with law, preserve rights, and respond to valid legal process.

WhatsApp offers

As our Terms of Service describe, we may send OXYGEN product news and offers to the mobile number you give when you sign up, including on WhatsApp. You can stop these messages at any time by replying STOP or by contacting us at [email protected]. Stopping them does not affect your access to OXYGEN.

6. Legal Bases

Where GDPR or similar law applies to OXYGEN as controller, we rely on:

  • contract necessity for account, billing, support, and Service delivery;
  • legitimate interests for security, abuse prevention, service improvement, diagnostics, and legal defense;
  • consent for optional analytics cookies and marketing where required;
  • legal obligation for tax, accounting, compliance, and valid legal process.

Where OXYGEN acts as processor, Customer is responsible for selecting and documenting the lawful basis for customer data and outbound processing.

7. Sharing & Subprocessors

We share information with:

  • service providers and subprocessors for hosting, databases, identity, billing, analytics, logging, AI, enrichment, communication, and integrations;
  • third-party platforms and providers you connect or instruct us to use;
  • payment processors acting as independent controllers for payment processing;
  • legal authorities or third parties where required by law or necessary to protect rights;
  • successors in a merger, acquisition, financing, reorganization, or asset sale.

See the Subprocessor page for the current public list.

8. International Transfers

OXYGEN is a Delaware corporation and uses global service providers. Data may be transferred to the United States and other countries. Where required, we use appropriate safeguards such as EU Standard Contractual Clauses, the UK Addendum or IDTA, transfer assessments, encryption, access controls, and contractual subprocessor obligations.

9. Retention

  • Account and billing data: contract term plus applicable tax/accounting retention periods.
  • Security, diagnostic, and operation logs: typically 90 to 180 days unless needed longer for security, billing, legal, or abuse review.
  • Customer content and contact data: contract term plus deletion/export windows under the DPA or workspace controls.
  • Provider events, run provenance, approvals, and credit records: retained as needed for observability, billing reconciliation, compliance evidence, and dispute handling.
  • Support records: typically up to 24 months unless needed longer for legal or business reasons.

10. Security

We use technical and organizational measures designed to protect data, including TLS, encryption at rest where supported, role-based access, audit logging, least-privilege controls, credential encryption, vendor review, backups, and incident-response processes. No system is completely secure.

11. Your Rights

Depending on your location and role, you may have rights to access, correct, delete, export, restrict, or object to processing of personal data, and to withdraw consent where processing relies on consent. To exercise rights, contact [email protected].

For customer workspace data, we may direct you to the Customer organization that controls the data or assist the Customer under the DPA.

Where GDPR or UK GDPR applies, you also have the right to lodge a complaint with a supervisory authority, in particular in the EU member state or UK jurisdiction of your habitual residence, place of work, or the place of an alleged infringement.

12. Automated Decision-Making

OXYGEN provides AI and workflow tools for customers to evaluate leads, write copy, enrich data, and run GTM operations. OXYGEN does not make solely automated decisions about individuals that produce legal or similarly significant effects as an independent controller.

13. Cookies, Analytics, Session Recording & Tool-Call Telemetry

We use necessary cookies for core functionality. Optional analytics and marketing cookies are used only where configured and where you have granted consent through the cookie banner or preferences control.

Where configured, optional analytics is provided by PostHog (product analytics and website analytics), Vercel Web Analytics, and Google Analytics 4, and optional marketing measurement by the LinkedIn Insight Tag. These load only after you grant the corresponding consent category, and you can change or withdraw your choice at any time via the Cookie Preferences control in the footer or account menu.

With marketing consent, the LinkedIn Insight Tag measures public website visits, completed signups and the first paid OXYGEN plan subscription for advertising attribution and website-visitor audiences. It uses cookies and receives the event, page URL, referrer, IP address, browser and device information. On public marketing pages, LinkedIn Website Actions can also collect button layout and engagement data and the public page URL, including URL parameters. Our explicit pageview and conversion calls omit query strings and fragments and do not include workspace records, messages, email addresses or payment details. Signup and payment measurement can also run when those milestones complete inside the application, using event-only image pixels with no private page URL or referrer. The full Insight library runs only on public marketing pages. Optional browser storage prevents repeat conversion reports from the same browser.

Session recording. Where you have allowed optional analytics, PostHog also records your sessions inside the signed-in OXYGEN application. A recording reproduces the pages as they were displayed to you: navigation, clicks, keyboard interaction, and the text and data rendered on screen. Recording is not limited to anonymized elements, so workspace content visible during your session, including table cells, records, and message content, can appear in a recording. The public marketing website is not recorded.

Recording is excluded on the surfaces where credentials and payment data appear: authentication and sign-in screens, credential, API-token and vault screens, and billing and payment screens. A recording captures the rendered page only, never network traffic: no request or response bodies, no provider payloads, and no AI prompts or model outputs are recorded. Product-analytics events other than the tool-call telemetry described below remain restricted and carry no prompts, request bodies, table rows, secrets, or stack traces.

CLI and MCP diagnostics. To operate, secure and improve the Service, we automatically record commands, tool and protocol calls, discovery requests, their business inputs and returned results, timing and failures. CLI diagnostics include command arguments, stdout and stderr, exit status and network failures. These records can contain contact and company records, search terms, prompts, message content and other workspace data. This server and CLI processing does not depend on browser analytics consent or a per-call approval.

Where complete diagnostics is enabled, content is stored in OXYGEN's private diagnostic storage for 30 days. Access requires staff authentication. PostHog receives metadata and protected evidence references, retained for 90 days, with daily aggregates retained for 13 months. Diagnostic uploads can remain in a private local CLI buffer for up to 72 hours and 512 MiB when offline; expired or capacity-exceeding evidence may be lost. Uploads preserve the original identity and environment and do not repeat the product action. Older or unconfigured MCP capture uses bounded, filtered arguments and results in PostHog under its existing retention; historical events are not rewritten.

Automated filters exclude credential-named fields, recognized credential strings, known active CLI credentials and credential-bearing tool arguments or results. Binary attachments retain metadata only. Payment card data remains with our payment processor. Business contents are otherwise recorded in full; partial or lost capture is marked. Prompts or model outputs returned through a CLI/MCP call may occur in these diagnostics as well as in the separate tracing for hosted AI features.

We do not claim more protection than this provides. The filter works on field names and on the recognizable shape of a credential. It does not identify personal data, so a name or an email address written inside a subject line, a note, or a search term is transmitted as written, and it is not a guarantee that every credential is removed, because a secret supplied in a field that is not named like one may not be recognized. Assume that tool arguments and results reaching this telemetry may contain personal data of the people in your workspace.

Because both a session recording of the signed-in application and MCP tool-call telemetry can contain customer workspace content, PostHog acts as a subprocessor for that content under the Data Processing Agreement, and is listed on the Subprocessor page. Withdrawing optional analytics consent stops further recording of your sessions. It does not stop the server-side tool-call telemetry described above, which is processed to operate, secure, and improve the Service; to discuss that processing for your organization, contact us at the address in section 11.

14. Changes

We may update this Privacy Policy. Material changes will be announced by email, in-product notice, changelog, or updated effective date. Continued use after the effective date means the updated policy applies.