Compliance & trust
Built to clear a security review on day one.
SOC 2 Type I/II, ISO 27001, ISO 42001 and a GDPR-aware data layer — region-pinned to the EU when traffic requires it. The controls procurement asks for are on by default.
- SOC 2 Type II
- ISO 27001
- ISO 42001
- GDPR-aware data layer
The four controls we cover.
Each control maps to a claim we will sign in the security review packet — not a forward promise, a verifiable one.
In audit — Type II report under preparation
Data handling across Shopify + Meta + Google + TikTok feeds
- CCCommon CriteriaGovernance, risk and control environment across the platform.
- AAvailabilityUptime targets and incident response on every connected channel.
- CConfidentialityInformation classified, labelled and protected at the boundary.
- PIProcessing IntegrityLevers execute inside the merchant's rails and write back to the ledger.
- PPrivacyPersonal data handling consistent with the GDPR-aware data layer.
In certification — Annex A controls mapped, SoA in draft
Access control: RBAC, MFA, audit logs, just-in-time admin
- ACRBAC + MFA + JIT adminEvery privileged action requires role + MFA; admin scopes past 24h go through just-in-time elevation with a ticket.
- AUAudit logging & retentionEvery privileged action writes to an append-only trail (who, what, on which resource, against which guardrail), retained for the contractual window.
- VRVendor risk reviewsEach sub-processor is reviewed annually — SOC 2 / ISO 27001 evidence, data-flow scope, region of processing, exit plan if the vendor fails.
- CMChange management & secure SDLCEvery lever-deploying change ships through peer review, automated tests and a security gate before it reaches production.
In certification — AI risk register under preparation
AI governance: model risk register, dataset lineage, prompt-injection controls
- MRModel risk registerEvery AI model that pulls a lever is registered with risk tier, named owner, tolerable residual risk and a quarterly review.
- DLDataset lineageEach model carries a versioned lineage pointer on its training / eval data, so a retrain stays reproducible and an audit can trace any decision back to the data it saw.
- PIPrompt-injection controlsInbound prompts pass an injection-screening layer before they reach model context; anything flagged is refused at the guardrail and journalised, never echoed.
- HOHuman override + eval suiteA human override at the guardrail layer logs who overrode what and the effect on the next bill; the eval suite runs on every model change and before every release.
GDPR-aware data layer — DPA available under mutual NDA
EU data residency: region-pinned processing + data minimisation
- LBLawful basis per purposeEach processing purpose names its lawful basis (Art. 6 GDPR) before the data-plane endpoint is wired — recorded in the DPA, not improvised at incident time.
- DMData minimisationOnly the fields the lever needs are pulled from Shopify, Meta, Google and TikTok — nothing broader is fetched, cached or written to the ledger.
- EUEU region pinningEU merchant traffic stays in EU-managed Postgres + EU object storage; US traffic stays in US — no cross-region replication of customer rows.
- SPSub-processor transparency & SCCsThe full sub-processor list ships with the DPA; every cross-border transfer runs on the EU Standard Contractual Clauses, with transfer impact assessment on record.
GDPR data-subject rights.
Each of the six rights below is wired into the data-plane endpoint — not improvised at incident time. The Art. 15–22 enumeration below is the same set the DPA carries.
- Art. 15Right of accessConfirm whether personal data is processed and obtain a copy in a portable format within 30 days of a verified request.
- Art. 16Right to rectificationCorrect inaccurate personal data without undue delay; the corrected row replaces the previous one in the audit trail with a timestamped journal entry.
- Art. 17Right to erasureDelete personal data on a verified request once the processing purpose no longer applies; the action is journalised, not silent, and propagates to active sub-processors within the contractual window.
- Art. 18Right to restrictionPause processing of a specific data row while a dispute is open; the row stays in storage, but no lever reads or writes it until the dispute closes.
- Art. 20Right to data portabilityReceive personal data in a structured, machine-readable format, and transmit it to another controller where technically feasible.
- Arts. 21–22Right to object & opt-out of automated decisionsObject to processing based on legitimate interest and opt out of decisions taken solely by automated means — the lever layer is built so a human can take the decision back at the guardrail.
How the data is handled.
Every lever runs on data that has already passed the controls above. Encryption at rest uses AES-256 across managed Postgres and managed object storage. Encryption in transit uses TLS 1.2 or higher between Helmsway, the connected channels and your storefront — older versions are refused at the boundary. Access is role-segmented: every privileged action writes to an audit trail of who acted, what action, on which resource and against which guardrail — and that trail is retained for the contractual window.
- AES-256 at rest
- TLS 1.2 or higher in transit
- Audit trail on every privileged action
Incident response — tiered timeline.
Every confirmed security or privacy event runs through the same on-call flow, regardless of severity. The timeline below is what gets posted in the customer advisory — containment, regulator notification, customer notification, post-mortem.
- T+1hContainmentOn-call isolation of the affected service, key rotation on impacted credentials, and a halt to all open levers that touch the affected data path — no further write-backs until scope is bounded.
- T+24hNotify DPALead supervisory authority notified via the in-DPA escalation channel; the notification carries scope, affected data categories, and the containment steps already taken.
- T+72hNotify customerEvery affected customer notified in plain language, with the row on the data they can verify and the workaround available until the post-mortem is published.
- T+30dPost-mortemRoot cause, the control that failed, the new control that closes the gap, and the named owner for ongoing remediation — published to the customer and to internal compliance.
Audit log export
Every resolved action is downloadable as a timestamped CSV. Logged-in users can pull any date window directly from the dashboard.
AI model governance — cross-cutting.
Beyond the ISO 42001 AI management system above, every model that pulls a lever is governed by the same four controls below. They sit at the data plane, not the policy plane — so they fire on every invocation, not at every audit.
- MKModel keys (own-keys to platform)OpenAI / Anthropic / vendor keys do NOT live in the customer's repo — your billing IS the platform's billing. Keys are rotated on every model change, never reused across customers, and scoped to the platform, not the customer.
- MPModel provenanceProvider, model identifier and version are locked per release. A lever cannot load an undeclared model, and an eval drift between two versions of the same model blocks the release.
- OROutput review (corridor re-confirmation)Every model output about to write back is re-confirmed against the merchant's corridor (MAP floor, MAP ceiling, ROAS floor, brand voice) before the lever moves. Out-of-corridor outputs are never written, even when the model produces them.
- PIPrompt-injection screeningInbound prompts pass an injection-screening layer before they reach model context; flagged inputs are refused at the guardrail and journalised with intent labels — never echoed, never written back.
What this gets you. What it doesn't.
In scope
- SOC 2 Type II annual letter
- ISO 27001 statement of applicability
- ISO 42001 AI risk register
- GDPR DPA + sub-processor list + SCCs
- Region-pinned EU processing
- RBAC, MFA, audit logs
- Encryption in transit + at rest
- Named CISO contact
- Downloadable audit-log export (CSV)
Out of scope
- HIPAA / BAA
- FedRAMP / IL5
- 24/7 hotline (incidents go through support SLA)
- On-demand pen test
- SOC 2 letter without a mutual NDA
The right-hand list is deliberate. Telling procurement what you DON'T cover buys more trust than claiming you do.
Last reviewed: 2026-08-01 → Next review 2026-Q4
Talk to security
Security review packet, on request.
The packet ships same-day, on a mutual NDA — SOC 2 letter, ISO SoA, ISO 42001 risk register, GDPR DPA + sub-processor list, data-flow diagram.