Legal

MCP Server Privacy Notice

Effective Date: May 15, 2026

Prelude Research, Inc. (d/b/a Origin Technology) (“Origin,” “we,” “us,” or “our”) provides a Model Context Protocol (“MCP”) server, identified to clients as origin-analytics-mcp and reached at https://mcp.prod.originhq.com (the “MCP Server”). This Privacy Notice describes the categories of data the MCP Server processes, how that data is used and retained, the sub-processors involved, and the rights available to data subjects under applicable privacy laws, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, “CCPA”).

This Notice supplements, and should be read together with, the Origin Privacy Policy and the Origin Sub-Processor List. In the event of any direct conflict with respect to data processed exclusively through the MCP Server, this Notice controls.

1. Scope and What the MCP Server Does

The MCP Server is an authenticated, Origin-hosted endpoint that allows an end user’s AI client (for example, Claude Desktop or Claude.ai) to query analytics derived from the customer’s own endpoint and AI-activity telemetry already collected by the Origin platform under the customer’s subscription agreement. The MCP Server exposes two read-only tools:

  • analytics_describe_schema — returns a static catalogue of entities, fields, edges, and metrics available to query. This tool takes no input parameters and returns no customer-specific data.
  • analytics_query — accepts a structured query expressed in Origin’s analytics domain-specific language (entities, joins, filters, metrics, time range, sample) and returns rows drawn from the authenticated tenant’s analytics dataset.

Both tools are read-only, idempotent, and non-destructive. The MCP Server does not accept free-text natural-language prompts; all tool inputs are validated against a strict JSON schema before execution. The MCP Server does not write to, modify, or delete any customer record.

This Notice does not apply to (a) the broader Origin platform, agent, or dashboard, which are governed by the Origin Privacy Policy and the customer’s applicable order form and agreement; or (b) the third-party MCP client software used to connect to the MCP Server, which is governed by the client vendor’s own privacy practices.

2. Information We Process

2.1 Authentication and Identity Data

The MCP Server authenticates requests using OAuth 2.1 with bearer JSON Web Tokens (“JWTs”) issued by Origin’s identity provider, WorkOS, pursuant to RFC 9728 (Protected Resource Metadata), RFC 7591 (Dynamic Client Registration), and RFC 8707 (Resource Indicators). Tokens are bound to a resource-specific audience and cannot be replayed against other Origin endpoints.

For the duration of a request, the MCP Server reads the following claims from the presented JWT into request-scoped memory in order to authorize the call: internal user identifier, identity-provider subject identifier, electronic mail address, tenant identifier, tenant display name, tenant role, and organization identifier. Of these, only the internal user identifier and tenant identifier are persisted to the audit log described in Section 4; the remaining claims are not written to storage by the MCP Server.

2.2 Request Data

For each invocation of analytics_query, the MCP Server receives a structured JSON object describing the query the user’s AI client wishes to execute. Filter literals supplied in that object may, depending on the query, contain operational values such as endpoint host names, process names, or identity strings that originate from telemetry the customer has already provided to Origin under the main service. Request payloads are validated against a strict schema, reject unknown fields, and are capped at 256 KiB.

The MCP Server does not accept and is not designed to receive special categories of personal data within the meaning of GDPR Article 9 or sensitive personal information within the meaning of the CCPA.

2.3 Response Data

The analytics_query tool returns columnar result sets drawn from the authenticated tenant’s analytics dataset, together with metadata describing the query (column names, whether the result was truncated, and an internal cost figure). The contents of returned rows are not separately retained by the MCP Server beyond the underlying analytics store and the diagnostic counts described in Section 4.

2.4 Operational and Diagnostic Data

In the ordinary course of operating the MCP Server, Origin processes operational signals associated with each request, including the time of the request, the tool invoked, the duration of execution, the number of rows returned, the number of bytes scanned, and a success or error outcome. Origin also emits structured application logs and Prometheus-format service metrics for operational health. Application logs include the tenant identifier, user identifier, tool name, and request method as span fields; the user-supplied contents of tool arguments are not written to application log output. Service metrics are aggregated and use a bounded set of labels that do not include personal data.

CCPA Categories. The categories of personal information processed by the MCP Server are: identifiers (user and tenant identifiers, and the email claim presented at authentication but not persisted by the MCP Server); commercial information (which Origin product features were invoked); electronic network activity information (operational request metadata); and professional or employment information to the limited extent reflected in the customer’s underlying tenant configuration.

3. How We Use This Information

3.1 Legal Bases for Processing

Contract Performance. Processing is necessary to authenticate users, authorize access, execute the requested analytics queries, and deliver the contracted MCP service.

Legitimate Interests. Audit logging, security monitoring, abuse prevention, debugging, and capacity planning are performed in furtherance of Origin’s and its customers’ legitimate interests in operating a secure and reliable analytics interface, balanced against the limited and operational nature of the data processed.

Legal Compliance. Origin may process and retain MCP Server data where necessary to comply with applicable law, regulatory obligations, or lawful governmental requests.

3.2 Purposes

MCP Server data is processed to: authenticate and authorize requests; execute the requested analytics queries against the authenticated tenant’s data; record an immutable audit trail of MCP activity for security forensics and incident response; investigate and remediate errors, performance regressions, and abuse; produce aggregate operational metrics; and satisfy contractual or legal recordkeeping obligations.

Origin does not use MCP Server data to train, fine-tune, or otherwise improve machine-learning models, including any models offered by Origin or by third-party model providers, and does not transmit MCP request or response payloads to third-party model providers.

4. Audit Logging and Retention

Each invocation of the analytics_query tool results in the insertion of one row into Origin’s mcp_audit table in ClickHouse. That row contains: the observation timestamp; the tenant and user identifiers derived from the JWT; the tool name; a non-cryptographic hash of the canonicalized arguments (for query deduplication and pattern analysis); the canonicalized argument payload, compressed at rest and capped in size; the elapsed execution time in milliseconds; the number of rows returned; the number of bytes scanned; an outcome status; and, where applicable, an error message produced by the planner.

Audit rows are insert-only and are retained for thirty (30) days, after which the underlying partition is dropped automatically by a time-to-live policy enforced at the database. The audit table does not record client Internet Protocol (IP) addresses, user-agent strings, bearer tokens or other credentials, the electronic mail address claim from the JWT, or the contents of returned result rows.

The thirty-day retention period reflects Origin’s balance between (a) the legitimate need to investigate security incidents, abusive query patterns, and operational regressions, and (b) the principle of data minimization. The argument payload is retained, rather than only its hash, because investigation of an incident or planner regression typically requires the specific values used in the query.

5. Disclosure to Third Parties and Sub-Processors

The MCP Server itself does not transmit request or response payloads to third-party large-language-model providers, vector databases, third-party analytics platforms, or advertising networks. The third parties that participate in the operation of the MCP Server are limited to the following sub-processors:

  • WorkOS — identity provider and OAuth 2.1 authorization server. WorkOS issues, refreshes, and validates the bearer tokens presented to the MCP Server and processes related authentication metadata.
  • ClickHouse Cloud — managed analytics datastore. ClickHouse Cloud stores the customer’s underlying analytics tables and the mcp_audit table described in Section 4, and provides encryption at rest using cloud-managed key management.
  • Cloud infrastructure providers — the underlying compute, networking, and storage infrastructure on which the MCP Server runs, as further described in the Origin Sub-Processor List.

Origin maintains written agreements with each sub-processor that include appropriate confidentiality, security, and (where applicable) data-protection terms. Origin may also disclose MCP Server data in connection with a corporate transaction (such as a merger, acquisition, financing, or sale of assets), to professional advisors, or as required to comply with applicable law, regulation, or a lawful governmental request.

CCPA Categories Disclosed: identifiers, commercial information, and electronic network activity information, in each case to the categories of recipients enumerated above and for the purposes described in Section 3.

Origin does not “sell” or “share” personal information processed by the MCP Server as those terms are defined under the CCPA, and does not engage in cross-context behavioral advertising using that data.

6. International Transfers

The MCP Server, its audit log, and its sub-processors operate from infrastructure located in the United States. Where personal data is transferred from the European Economic Area, the United Kingdom, Switzerland, or other jurisdictions to the United States, Origin relies on appropriate transfer mechanisms, which may include the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum) and supplemental technical and organizational measures. Additional information regarding international transfers is available on request at the address in Section 13.

7. Security

The MCP Server is reachable only over Transport Layer Security (TLS 1.2 or higher), terminated by Origin’s ingress infrastructure. All requests must present a valid OAuth 2.1 bearer token that is cryptographically bound to the MCP Server’s resource audience; tokens issued for other Origin endpoints are rejected, and tokens issued for the MCP Server cannot be replayed against other endpoints. Audit log and analytics data are encrypted at rest using the storage provider’s default key-management infrastructure. Origin operates the MCP Server within the security and access-control framework described in the Origin Privacy Policy, including multi-factor authentication for administrative access, least-privilege role assignments, and ongoing monitoring.

No system can be made entirely impervious to unauthorized access; Origin does not warrant absolute security but is committed to using commercially reasonable measures appropriate to the sensitivity of the data processed.

8. Tenant Isolation

The MCP Server enforces tenant isolation at the query-planning layer. The tenant identifier used to scope every database query is derived exclusively from the validated JWT presented with the request and is never read from the request body or any client-controlled header. Each generated query against the analytics datastore is rewritten to include the authenticated tenant identifier as a mandatory predicate. A user authenticated to one tenant cannot, by construction, retrieve data belonging to another tenant through the MCP Server.

9. Your Rights Under GDPR

Individuals whose personal data is processed through the MCP Server and who are protected by the GDPR have the following rights, subject to the qualifications and exemptions set out in the GDPR:

  • Access. Confirmation of processing and a copy of the personal data processed.
  • Rectification. Correction of inaccurate or incomplete personal data.
  • Erasure. Deletion of personal data, subject to applicable exceptions, including those relating to legal recordkeeping.
  • Restriction. A limit on processing in specified circumstances.
  • Portability. Receipt of personal data in a structured, commonly used, machine-readable format.
  • Objection. The right to object to processing carried out on the basis of legitimate interests.
  • Automated Decision-Making. Origin does not make decisions producing legal or similarly significant effects through solely automated processing of MCP Server data.
  • Consent Withdrawal. Where processing is based on consent, the right to withdraw that consent at any time.
  • Complaint Authority. The right to lodge a complaint with a competent supervisory authority.

Because much of the personal data processed by the MCP Server belongs to a corporate customer’s authorized end users, requests to exercise these rights should ordinarily be directed first to the controller of that data (typically the data subject’s employer). Origin will support its customers in fulfilling those requests in accordance with the applicable data-processing agreement.

10. Your Rights Under CCPA and U.S. State Privacy Laws

Residents of California and of other U.S. states with comparable privacy laws have the following rights with respect to personal information processed through the MCP Server, subject to applicable exceptions:

  • Right to Know. A right to request the categories and specific pieces of personal information collected in the preceding twelve months and the purposes for which they are used.
  • Right to Delete. A right to request deletion of personal information, subject to statutory exceptions.
  • Right to Correct. A right to request correction of inaccurate personal information.
  • Right to Limit Use of Sensitive Personal Information. Although the MCP Server is not designed to process sensitive personal information, residents may exercise this right where applicable.
  • Non-Sale and Non-Sharing. Origin does not “sell” or “share” personal information processed by the MCP Server, as those terms are defined by the CCPA.
  • Non-Retaliation. Origin will not discriminate against any consumer for exercising privacy rights.

As with GDPR requests, requests under U.S. state privacy laws relating to data processed by the MCP Server on behalf of a corporate customer should ordinarily be directed first to the relevant customer; Origin will support its customers in responding to verifiable consumer requests in accordance with applicable law.

11. Children’s Privacy

The MCP Server is intended exclusively for use by authenticated business users of Origin’s commercial customers and is not directed to, intended for, or offered to children. Origin does not knowingly collect personal data from individuals under the age of 13 (or under 16 in jurisdictions where that higher threshold applies) through the MCP Server. If Origin becomes aware that it has inadvertently processed such data, it will take appropriate steps to delete it.

12. Changes to This Notice

Origin may update this Notice from time to time to reflect changes in the operation of the MCP Server, in applicable law, or in industry practice. The “Effective Date” at the top of this Notice will be revised to indicate when the changes take effect. Material changes will be communicated through reasonable means, which may include posting on the Origin website or providing direct notice to affected customers.

13. Contact

Questions, requests, or complaints regarding this Notice or the privacy practices of the MCP Server should be directed to contact@originhq.com. Where required by applicable law, Origin will respond to verifiable requests within the time periods prescribed by the relevant statute.

Last Updated May 2026