GDPR

Revised · policies/GDPR.md ↗ · 0fa48e326878 ↗

isotope13 LLC is a US company with no EU establishment.

We are a processor for our customers' API requests, under our DPA. We are a controller for everything else, under our Privacy Policy: accounts, billing, uploads, verdicts, correspondence, and API requests made without a customer token.

Requirement Where
Notice and records of processing (Art. 13, 14, 30) Privacy Policy
Processor terms (Art. 28) DPA
Annex I: description of processing DPA, Scope
Annex II: security measures (Art. 32) Security Measures
Annex III: subprocessors Approved Subprocessors
International transfers (Chapter V) DPA, Transfers: Standard Contractual Clauses
Breach notification (Art. 33–34) Incident Response Plan
Impact assessment (Art. 35) DPIA
Data flows API Architecture
EU and UK representative (Art. 27) None. Exempt under Art. 27(2): business-to-business processing of account identifiers and an unlogged IP address, with no special-category data, is unlikely to put anyone at risk.