Data processing agreement

Subject matter & durationArt. 28(3)

Processing of customer content for the purpose of providing distributed object storage, for the duration of the service agreement.

Nature & purposeArt. 28(3)(a)

Storage, retrieval, deletion, integrity verification, and repair of encrypted objects. No other processing occurs — no analysis, no indexing, no derivation.

Processing on instruction onlyArt. 28(3)(a)

We process only on your documented instruction, which for content means your API calls. We notify you if an instruction appears to us to conflict with data protection law.

ConfidentialityArt. 28(3)(b)

Personnel with access are bound by confidentiality obligations that survive the engagement.

Security measuresArt. 32

Client-side encryption before transmission, fragmentation across independent providers with no provider holding a reconstructable portion, integrity verification by Merkle root, signed and expiring request authentication, tenant isolation, encrypted control-plane storage, and continuous repair. Described in full on our security page.

SubprocessorsArt. 28(2), 28(4)

General authorisation with a published list and 30 days notice of additions affecting personal data, with a right to object. Each subprocessor is bound by equivalent obligations.

Data subject rightsArt. 28(3)(e)

We assist you in responding to requests. Because content is encrypted before it reaches us, we cannot locate a data subject within content and will route such requests to you.

Breach notificationArt. 33(2)

Notification to you without undue delay after becoming aware, with the information available at that time and updates as the investigation proceeds.

Audit & informationArt. 28(3)(h)

On request we provide our security documentation, completed CAIQ, and our hosting provider's data-processing agreement. On-site or third-party audit rights beyond this are not offered on the public site today.

Deletion & returnArt. 28(3)(g)

On termination, content is deleted from the manifest on your instruction or when the account's storage contracts are not renewed following suspension, and the underlying shards are queued for pruning. Billing records are retained as described in the privacy notice.

International transfersCh. V

The control plane and its backups are hosted on a Kamatera cloud server in Singapore; encrypted off-site backup copies (GPG, AES-256) are held on a second Kamatera server in Hong Kong. Processing under this agreement therefore takes place in Singapore and Hong Kong. We have not yet executed Standard Contractual Clauses for those transfers; if your programme requires a transfer mechanism for regulated personal data, contact us before storing it. Encrypted content is never held as a reconstructable whole in any single jurisdiction.

Email [email protected] with your legal entity name and address, and we will return a copy for signature. We can execute either our DPA or yours; if yours, expect us to redline anything that asserts capabilities we do not have.