Data Processing Addendum
This addendum applies where Trustedcopy processes personal data on behalf of a customer (the “controller”) in connection with the service. It forms part of the agreement between you and Trustedcopy.
Roles
For personal data contained in documents you submit, you are the controller and Trustedcopy is the processor. For account and billing data, Trustedcopy acts as an independent controller as described in our Privacy Policy.
Scope and nature of processing
Trustedcopy processes personal data only to provide the service: registering documents, generating irreversible fingerprints, returning verification verdicts, and the related account operations you instruct. Documents themselves are processed transiently and discarded — Trustedcopy does not retain document contents.
Data minimization
By design, Trustedcopy retains fingerprints and verification results rather than documents. This substantially limits the categories of personal data at rest and the impact of any incident.
Sub-processors
You authorize Trustedcopy to engage vetted sub-processors (for example, cloud infrastructure and payments providers) under written terms no less protective than this addendum. We maintain a current list and will give notice of material changes so you can object.
Security measures
Trustedcopy maintains technical and organizational measures appropriate to the risk, including encryption in transit and at rest, access controls, logging, and the data-minimizing architecture that avoids storing documents.
International transfers
Where personal data is transferred across borders, Trustedcopy relies on an appropriate transfer mechanism (such as Standard Contractual Clauses) as required by applicable law.
Assistance and breach notification
Trustedcopy will reasonably assist you with data-subject requests and with your security and impact-assessment obligations, and will notify you without undue delay after becoming aware of a personal-data breach affecting your data.
Return and deletion
On termination, Trustedcopy will delete or return personal data processed on your behalf, subject to fingerprints and results retained to keep previously registered documents verifiable, and to any retention required by law.
Contact
To request a signed copy or ask about data processing: legal@trustedcopy.com.