Data Processing Agreement

This agreement is between Camada Labs, LLC ("camada") and the customer. It forms part of the terms of service and applies whenever camada processes personal data on the customer's behalf.

1. Roles

The customer is the controller of personal data contained in traffic to its applications. camada is the processor. For the cross-customer reputation and TLS fingerprint popularity data described in section 6, camada acts as an independent controller of the minimal datasets described there.

2. Subject matter and duration

Processing of request metadata sent by the SDK (IP addresses, session identifiers, hashed user identifiers the customer reports, request paths and query strings with credential-like values replaced, selected headers, and device characteristics from the optional beacon; the privacy policy has the full list), including analysis by language models running on Cloudflare Workers AI, for the purpose of detecting and blocking abusive traffic, for the duration of the customer's use of the service and the retention periods in section 7.

3. Instructions

camada processes personal data only on the customer's documented instructions, which are the settings in the app (trusted proxy, rules, learning policy, allow-list, blocks) and these terms. camada will tell the customer if it believes an instruction breaches data protection law.

4. Confidentiality and security

Staff with access to customer data are bound by confidentiality. Technical measures include: redaction inside the SDK before transmission; hashed project keys; encrypted transport; service-to-service calls over private bindings; audit logging of every change in the app; access limited to named operators. The security page describes these in more detail and is updated when they change.

5. Sub-processors

The customer authorises the sub-processors listed on the sub-processors page. camada will give at least 30 days' notice by email before adding one; the customer may object, and if the objection cannot be resolved may terminate the affected service.

6. Reputation data

When a project's analysis reaches a malicious verdict on an IP address or TLS fingerprint, camada keeps the key, the verdict and counts for seven days. An IP address scores higher at another customer only when at least three other paying organizations flagged it in that time. To tell rare TLS fingerprints from common ones, camada also keeps, for eight days, a shortened hash of each client network seen with a fingerprint. The reputation record holds no customer identifier and no request content. A popularity record names the project it came from, so a project's own networks can be counted apart, and is never shown to another customer. The customer may ask for its project's contributions to be excluded.

7. Retention and deletion

Raw events: 7 days. Analysis rows: 7, 30, 90 or 365 days by plan (Free, Starter, Growth, Enterprise). On project deletion, or at the end of the agreement, camada deletes all customer data within 30 days, except where law requires retention. Export as JSON is available on request.

8. Assistance

camada will assist the customer with data subject requests, security incident notification (without undue delay and within 72 hours of becoming aware), and impact assessments, to the extent the information is available to camada.

9. Audit

camada will make available the information needed to demonstrate compliance and will allow audits by the customer or an agreed auditor, at most once a year unless required by a supervisory authority, with reasonable notice.

10. Transfers

Data is processed on Cloudflare's global network. Where a transfer mechanism is required, the parties rely on the standard contractual clauses [to be attached by counsel].