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Processor terms

Under legal review. This document describes the system's real architecture and is published for transparency while counsel finalizes the wording. Questions: privacy@glemo.io.

Clauses that fix Glemo's role as a processor (not a controller) in the B2B terms of service:

  1. Documented instructions. Glemo processes personal data only to issue, anchor, and verify credentials on the customer's instruction (the API calls are the documented instruction).
  2. No own purposes. Glemo does not use holder data for its own purposes; analytics and reputation run on aggregates without claims.
  3. Confidentiality. Staff with access are under a confidentiality duty; production access is restricted and audited.
  4. Subprocessors. A public list (see the DPA); changes are notified 30 days ahead for objection.
  5. Holder rights. Glemo runs the technical erasure (CNIL pattern) on the customer's instruction within the SLA; the customer answers to the holder.
  6. Return or deletion at contract end. Export of the customer's credentials plus deletion of personal data; on-chain anchors become unlinkable through key destruction.
  7. Audit. Reasonable information to demonstrate compliance (erasure log, CI security gates, compliance docs).