Data Processing Statement

1. Scope and definitions

This data processing statement applies when you submit material through the AegisTrust public pre-clearance flow and AegisTrust processes personal data in that material on your instructions. You act as the controller and Shanghai Zhenfa Technology Co., Ltd. acts as the processor when providing the relevant processing service.

The terms personal data, processing, data subject and controller have the meanings given by the EU General Data Protection Regulation (GDPR) where it applies, or by applicable local law in other jurisdictions.

2. Nature and purpose of processing

3. Responsibilities of the parties

• You are responsible for a lawful basis, necessary authorisations and minimising personal and sensitive data in submissions.
• We process data only on your documented instructions and as necessary to provide the service.
• Personnel with access must be subject to appropriate confidentiality obligations.
• You must provide a new lawful basis and written notice before instructing us to use data for another purpose.

4. Processor obligations

• Apply reasonable technical and organisational measures proportionate to the risk.
• Engage sub-processors on the terms of the applicable agreement and remain accountable for their obligations.
• Assist with data subject requests and data protection impact assessments where required by law.
• Notify you without undue delay after becoming aware of a personal data breach that applicable law requires us to report, providing known information and reasonable remediation guidance.
• Return or delete data after termination under the agreement and applicable law, subject to lawful retention requirements.

5. Current security measures

• Transport: The public pre-clearance flow is served over HTTPS.
• Credentials: Object storage, database, email and alert credentials are configured server-side only.
• Input validation: Public pre-clearance limits file size and permitted types and checks basic file signatures.
• Integrity: A SHA-256 digest is calculated for received files, with an append-only hash chain recorded when the database is available.
• Minimisation: We do not request account credentials, production secrets or sensitive personal data unrelated to pre-clearance.

Encryption-at-rest algorithms, specific TLS versions, enforced multi-factor authentication, certification status or availability metrics not listed here are not commitments unless confirmed in a signed agreement or verifiable material.

6. Sub-processors

Depending on the enabled deployment, public pre-clearance may use Cloudflare R2 for file storage, Neon for database records, Resend for transactional email, Telegram for internal alerts, and an application hosting provider to run the site. A service that is not configured is not enabled merely because it is mentioned here.

The current sub-processor names, functions, locations and transfer mechanisms are determined by the production configuration, Privacy Policy and any signed data processing agreement. Changes are notified and consented to as required by the applicable agreement.

7. International transfers

Where cross-border services are used, the applicable mechanism is determined by applicable law and the signed agreement. This page does not claim that Standard Contractual Clauses or a specific transfer assessment have been executed; the executed documents control.

8. Data breaches

If a personal data breach occurs, we will take reasonable steps to contain it, preserve necessary records and notify you within the period required by applicable law or a signed agreement. Notice will include the known nature of the breach, affected data categories and actionable mitigation guidance.

9. Return and deletion

After termination or a valid request, we will return or delete relevant data under the Privacy Policy, signed agreement and applicable law. Data retained for disputes, security logs, legal obligations or technical backups remains subject to restricted processing for the period needed for that purpose.

10. Governing law

This statement is governed by the laws of the People's Republic of China. If an executed data processing agreement or mandatory law, including the GDPR, conflicts with this statement, the executed agreement and applicable law control.