PRIVACY POLICY

How We Handle Your Data

Last updated: March 2026 · Version 1.0

CITAQ processes B2B product data only. We do not collect, store, or process consumer personal information. This policy describes how we handle operator account data and product catalog information under GDPR, CCPA, and applicable data protection law.

Regulatory Classification

GDPR ARTICLE 28 — CLASSIFICATION
CITAQ is NOT a data processor under GDPR Article 28.

CITAQ operates as a B2B verification infrastructure platform. We process product claims, evidence documents, and operator account data — not consumer personal data. Operators who use CITAQ remain the data controllers for their own customer data. CITAQ does not act as a sub-processor for consumer PII under any operator arrangement.

CITAQ ROLE
Data Controller (operator account data)
OPERATOR ROLE
Data Controller (their customer data)

No consumer PII processed. CITAQ does not track, profile, or store data about the end consumers who visit your store. No consumer cookies. No behavioral tracking. No personal data from third-party customers.

Data We Process

Operator Account Data

Name, email address, company name, store URL, and billing contact used for account management and authentication.

GDPR Art. 6(1)(b) — contract
Product Catalog Data

Product claims, descriptions, SKUs, attributes, and images you submit for verification analysis.

GDPR Art. 6(1)(b) — contract
Evidence Documents

Certifications, laboratory test reports, compliance records, and third-party attestations you upload.

GDPR Art. 6(1)(b) — contract
Session and Activity Logs

Authentication tokens, API call logs, and access records required for platform security and immutable audit trail.

GDPR Art. 6(1)(f) — legitimate interest
Financial Transaction Records

Credit wallet activity, payment records, and billing history. Required for regulatory compliance.

GDPR Art. 6(1)(c) — legal obligation
Platform Telemetry

Aggregated, anonymized operational metrics. Subject to k-anonymity (k=5). No individual operator identifiable.

GDPR Art. 6(1)(f) — legitimate interest

Data Retention Schedule

Data Type
Retention Period
Legal Basis
Access Logs
90 days hot
GDPR Art. 32 security
API Request Logs
30 days hot / 365 days cold
Security audit
MCP Invocation Logs
90 days hot / 2 years cold
Audit trail
Operational Telemetry
30–90 days (anonymized)
GDPR minimization
Financial Transactions
7 years
PCI DSS / IRS
Audit Trail Events
Permanent (immutable)
PROHIBITION-001
Evidence Vault Records
10+ years
EU DPP / audit integrity
SHA-256 Hash Records
Permanent (even after deletion)
PROHIBITION-001
Backup: WAL Continuous
7 days
Disaster recovery
Backup: 6-hour snapshots
7 days
Disaster recovery
Backup: Daily full
30 days
Disaster recovery
Backup: Weekly full
12 weeks
Disaster recovery
Backup: Monthly archive
24 months (Glacier Deep Archive)
Long-term recovery

Evidence Immutability

STRUCTURAL CONSTRAINT — PROHIBITION-001

Evidence documents, audit log events, verification credentials, and cryptographic hash records cannot be permanently deleted. This is a structural constraint of the platform, not a policy decision.

SOFT-DELETE

You may flag evidence as inactive within 30 days of upload. The document is removed from active verification status but retained in the immutable audit vault.

HARD-DELETE WINDOW

A 30-day grace period exists for flagging evidence submitted in error. After 30 days, no erasure is possible without a legal mandate (court order, regulatory requirement).

SHA-256 HASHES PERMANENT

Cryptographic hash fingerprints of all evidence documents are retained permanently, even if the underlying document is soft-deleted. This enables audit trail continuity without storing document content.

LEGAL MANDATE EXCEPTION

Full erasure is only possible with a court order or regulatory mandate. CITAQ will comply within 72 hours of receiving a valid legal instrument.

Metrics We Do Not Collect

CITAQ operator dashboards display only: compliance status, evidence expiry dates (absolute), policy violation counts (absolute), and pending review items (absolute). The following metrics are architecturally prohibited from operator-facing surfaces:

NOT COLLECTEDVerification rates (ratio of verified vs. unverified claims)
NOT COLLECTEDRequest volumes (number of agent queries about your products)
NOT COLLECTEDAgent type distribution (which AI systems query your catalog)
NOT COLLECTEDDrift detection rates (how often your claims are flagged)
NOT COLLECTEDEvidence tier consumption rates (breakdown by tier usage)

This is a constitutional constraint (PROHIBITION-004), not a configurable setting. These metrics cannot be enabled, requested via API, or provided through any channel.

Security Controls

ENCRYPTION AT REST
AES-256-GCM

All stored data encrypted using AES-256-GCM. Evidence vault encrypted with per-tenant envelope keys.

GDPR Art. 32
ENCRYPTION IN TRANSIT
TLS 1.3

All network connections use TLS 1.3 minimum. TLS 1.2 rejected. Certificate pinning on critical endpoints.

GDPR Art. 32
CRYPTOGRAPHIC HASHING
SHA-256

All evidence documents and audit events receive a SHA-256 hash fingerprint retained permanently.

PROHIBITION-001
TELEMETRY PRIVACY
K-Anonymity k=5

Operational telemetry subject to k-anonymity (minimum group size 5). Differential privacy with Laplace noise applied.

GDPR Art. 25
ACCESS LOGGING
90-Day Retention

All data access events logged with timestamp, user ID, and operation type. Immutable append-only store.

SOC 2 CC6
BREACH NOTIFICATION
72-Hour Window

Affected operators notified within 72 hours of confirmed breach per GDPR Article 33 requirement.

GDPR Art. 33
COMPLIANCE TARGETS
SOC 2 Type II (target)
ISO 27001:2022 Annex A
GDPR Article 32
PCI DSS (financial records)

Data Residency and Transfers

EU OPERATORS
eu-central-1 (Frankfurt, Germany)

EU operator data remains within the EU. Cross-region replication is disabled. Automatic PII redaction prevents EU data from routing to non-EU infrastructure. Complies with GDPR Article 44 (data transfer restrictions).

US / GLOBAL OPERATORS
us-east-1 (N. Virginia, USA)

US and global operator data processed in us-east-1. All data encrypted at rest and in transit. CCPA rights apply to California-based operators.

Isolation guarantee: Cross-tenant data access is prevented at the database level via row-level security (RLS). No operator can access another operator's catalog, evidence vault, or account data under any conditions.

Sub-Processors

CITAQ uses the following sub-processors. All sub-processors have executed Data Processing Agreements (DPAs) and maintain adequate safeguards under GDPR Article 46.

Processor
Purpose
Location
Safeguards
Amazon Web Services (AWS)
Infrastructure, storage, compute
EU (eu-central-1) / US (us-east-1)
SCCs + DPA
Auth provider
Authentication and session management
Follows operator region
DPA executed
Neon (PostgreSQL)
Database (serverless Postgres)
Follows operator region
DPA executed

Your Rights

Access (Art. 15)

Download all account data, product catalog records, and evidence metadata associated with your operator account in JSON or CSV format.

Rectification (Art. 16)

Update product claims, evidence metadata, account information, and contact details at any time via the platform dashboard.

Erasure (Art. 17)

Request account deletion. Evidence attestations, audit trail events, and SHA-256 hashes are excluded from erasure due to immutability constraints (PROHIBITION-001).

Data Portability (Art. 20)

Export your full account data in machine-readable JSON or CSV format. Evidence references export as URIs pointing to your uploaded documents.

Object to Processing (Art. 21)

Object to processing based on legitimate interest. We will evaluate and respond within 30 days.

Lodge a Complaint (Art. 77)

Contact your jurisdiction's data protection authority. EU operators may contact the relevant supervisory authority in their member state.

Rights requests are handled within 30 days (GDPR standard). Submit requests to privacy@citaq.io. Identity verification required before processing.

No Algorithmic Profiling

CITAQ is a deterministic evidence retrieval system. We perform no machine learning inference on your data. We do not build behavioral profiles, make predictions about your product performance, or make automated decisions that affect your account status. Verification status changes only when you take an action (uploading evidence, modifying claims) or when submitted evidence reaches its expiry date.

CONTACT

Privacy requests: privacy@citaq.io

Security incidents: security@citaq.io

72-hour breach notification commitment under GDPR Article 33.