Data Processing Agreement (template)

Template, pending counsel review. This is a placeholder DPA for future signed pilots. It has not been reviewed by legal counsel and is not enforceable in its current form. A counsel-reviewed DPA will be negotiated per-pilot before any signed customer agreement.

1. Scope of processing

Under the public-beta sandbox, AgentTrust is not a processor of customer personal data; the sandbox is not designed for, and not certified for, processing personal data. Customers are asked not to submit personal data into the sandbox.

Under a future signed pilot, AgentTrust may process limited metadata (request hashes, receipt ids, audit chain entries) in the customer’s scope. The exact processing list will be named in the per-pilot DPA.

2. No SOC 2 / ISO / HIPAA / PCI claim

AgentTrust does not currently claim SOC 2, ISO 27001, HIPAA, or PCI certification. The pilot DPA will name the actual security posture in effect at signing, not a certification we have not commissioned.

3. Sub-processors, template

• Fly.io (compute), sandbox API hosting.
• Vercel (static hosting), marketing site + console.
• Postgres provider, durable sandbox store; specific provider named per pilot.
• Redis provider, rate-limit + idempotency counters; specific provider named per pilot.

The full sub-processor list will be enumerated in the per-pilot DPA at signing.

4. Security controls, template

• HTTPS everywhere; TLS 1.2+; no plaintext upstream payments.
• HttpOnly · SameSite=Lax · Secure cookies for the sandbox session.
• Ed25519 receipt signing; per-provider hash-chained audit log.
• No raw secrets persisted; sha256 hashing at rest for tokens.
• Bounded enum surface for receipt / audit / proof / SIEM events.

Specific control attestation (penetration test report, vendor audit, SOC reports if any exist) will be exchanged per pilot under NDA.

5. Data subject rights, template

The pilot DPA will name the data-subject-rights handling channel, response window, and applicable law. For sandbox public-beta: the safest path is do not submit personal data.

6. Term and termination, template

This template will be replaced per-pilot with a counsel-reviewed DPA bound to a Master Services Agreement. The MSA template is not currently published; it is exchanged on request once a pilot scope is agreed.

7. Contact

DPA / pilot questions: write to the support address on the homepage. We will share a counsel-reviewed DPA + MSA per pilot, under NDA, once a scope is agreed.