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Data processing outline (draft)

This is an operational outline of processing roles for early-access customers. It is not a signed Art. 28 DPA. Have counsel review before relying on it in a procurement pack.

Roles

• Customer organization: controller for recipient data it uploads and for credentials it issues.
• Platform operator: processor for that recipient data; controller for account, lead and platform audit data.

Subject matter

Hosting of issuer accounts, encrypted recipient contacts, credential issuance and delivery, public verification, status lists, and operational logs.

Sub-processors (typical self-hosted stack)

On this deployment the stack is operator-hosted (application, database, identity provider, mail relay). If a managed mail or hosting provider is introduced later, it will be listed here before use for customer data.

Instructions

The customer issues, revokes and erases through the panel and APIs we expose; the platform does not issue credentials on the customer's behalf from the platform console.

Early-access draft. These pages describe the product as shipped today. They are not a substitute for a signed contract or a reviewed DPA where one is required.