Legal

Privacy Policy

Last updated 20 September 2026

This Privacy Policy explains how Sageo SIA ("Sageo", "we", "us") collects, uses, and protects personal data when you visit our website, create an account, or use the Sageo performance management platform (the "Service"). It is written with the EU General Data Protection Regulation (GDPR) as its primary framework.

Sageo is built so that structured, auditable performance management is possible without exposing your people's personal data to unnecessary risk. Privacy is part of the product design, not an afterthought.

Who We Are and Our Two Roles

For personal data about website visitors and the individuals who administer a Sageo account, Sageo acts as a data controller.

For the employee and performance data that a customer uploads or creates in the platform (employee records, competencies, review scores, feedback, development plans, goals and 1:1 notes), the customer is the data controller and Sageo acts as a data processor, processing that data only on the customer's documented instructions under a Data Processing Agreement.

The Data We Process

  • Website and usage data: pages visited, device and browser information, and cookie identifiers, used to run and improve the site.
  • Account and billing data: the name, work email, organisation, and role of the people who set up and administer Sageo, plus billing contact details.
  • Customer content (as processor): employee records, reporting lines, competency assessments, scores and ratings, written feedback, development plans, goals and 1:1 notes, processed on behalf of the customer.
  • Support data: information you provide when you contact us.

Legal Bases for Processing

Where Sageo is a controller, we rely on: performance of a contract (to provide the Service and manage your account); our legitimate interests (to secure, operate and improve the Service and the website); consent (for non-essential cookies and marketing email, which you can withdraw at any time); and compliance with legal obligations.

Where Sageo is a processor, the customer is responsible for establishing the legal basis for processing its employees' data and for providing the required notices to those employees.

How We Use Data

We use data to provide and operate the Service, generate and refine competency frameworks and development plans, authenticate users and scope access by role, keep an audit trail of sensitive actions, provide support, secure the platform, and communicate with account administrators.

We do not sell personal data, and we do not use customer content to train AI models for other customers.

AI Processing and De-Identification

Sageo uses a third-party AI provider to generate competency frameworks and development plans. Employee names and personal feedback are de-identified before any content is sent to the AI: framework generation uses only organisation-level inputs such as your values, functions and level structure, and development plans are generated about the employee, never about a named person.

Content sent to our AI provider through its API is not used by that provider to train its models. A person reviews and approves AI output before it applies to any individual.

Sub-Processors

We use a small set of vetted sub-processors to deliver the Service, each under appropriate data protection terms. These include cloud hosting and database infrastructure, our AI provider for framework and plan generation, and an email delivery provider for transactional email. A current list of sub-processors is available on request.

Sharing and Disclosure

We share personal data only with the service providers described above under contract, where required by law or to respond to valid legal process, and in connection with a merger or acquisition subject to this Policy. We never sell your data.

International Transfers

Where personal data is transferred outside the European Economic Area, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses, together with additional measures where needed.

Data Retention

We retain account and billing data for as long as your account is active and as needed to meet legal obligations. Customer content is retained according to the customer's instructions and is deleted or returned after the end of the customer's subscription, subject to short, documented backup cycles.

Security

We protect data with encryption in transit, role-scoped access controls, tenant isolation, and an audit trail of sensitive actions. No system is perfectly secure, but we work to protect your data in line with recognised industry practice.

Your Rights

Subject to applicable law, you have the right to access, correct, erase, restrict or object to the processing of your personal data, to data portability, and to withdraw consent. You also have the right to lodge a complaint with your local data protection supervisory authority, for example, in Latvia, the Data State Inspectorate (Datu valsts inspekcija).

If you are an employee whose data was uploaded by your employer, that employer is the controller. Please direct your request to them; we will support them in responding.

To exercise your rights where Sageo is the controller, contact us at privacy@sageo.ai.

Cookies

We use essential cookies to run the website. With your consent, we also use Google Analytics 4 to understand how the site is used. Analytics cookies are set only after you accept them, never before.

You can change or withdraw your choice at any time using the "Cookie Preferences" link in the footer, or by clearing cookies in your browser.

Children

The Service is intended for use by organisations and their staff. It is not directed at children under 16, and we do not knowingly collect their data.

Changes to This Policy

We may update this Policy from time to time. We will post the updated version here and change the date above. Material changes will be communicated to account administrators.

Contact Us

For any privacy question or request, contact privacy@sageo.ai.

Sageo is a service of Sageo SIA (registration number 40203775716), registered at Prūšu iela 23B - 13, Rīga, LV-1057, Latvia.