Data Processing Addendum (DPA)

Data Processing Addendum (DPA)

Effective Date: June 12, 2026

Website: https://anonime.io

This Data Processing Addendum supplements our Privacy Policy and Terms of Service, and applies to the processing of personal data through the Anonime Service by Leatra Technologies LTD.

For most personal use, Anonime acts as a Data Controller for the limited account and operational data it determines the purpose of. Where you use Anonime to process data on behalf of others, for example in a professional or corporate capacity, Anonime acts as a Data Processor following your instructions, and you act as the Data Controller.

1. Scope and roles

This Addendum describes how personal data is handled when using the Anonime Service. It is intended to explain the respective responsibilities of the controller and processor in ordinary usage, as well as the limited operational data that is necessary for the Service to function.

The scope of this Addendum is limited to the processing operations described in this document and any related terms referenced by our Privacy Policy or Terms of Service.

2. Categories of data

In accordance with our privacy-first architecture, the data processed is intentionally minimal.

• Account Data: Identity provider session metadata, login timestamps, and account status.
• Identity Profiles (Nyms): Nym aliases, labels, display names, and necessary mail-routing metadata.
• Billing Data: Subscription status and billing references managed securely by our payment processor.
• Operational Metadata: Minimal security signals, IP-derived coarse locations, and abuse-prevention logs.
• Encrypted Content: Whispers, Private Drops, Vault items, and sealed messages, stored strictly in encrypted formats we cannot read.

3. Purposes of processing

We process this data solely to:

• Provide and maintain your account, Nyms, and email routing infrastructure.
• Deliver, secure, and expire Whispers and Private Drops as configured by you.
• Process subscription transactions and prevent network fraud or abuse.
• Meet binding legal obligations and respond to your technical requests.

4. Zero-knowledge cryptographic boundary

Anonime’s zero-knowledge architecture ensures that the encryption keys for Vault items, Drops, and Whispers are generated on your device and never reach our active servers. We therefore process this encrypted content purely as opaque data blobs, which we store, transmit, and delete without the technical ability to read them.

As detailed in our Security Overview, inbound emails arriving from external networks are encrypted ("sealed") server-side immediately upon receipt, ensuring they remain unreadable at rest.

This boundary is a deliberate architectural design: it strictly limits what can ever be exposed, subpoenaed, or misused, because the plaintext simply isn’t available to our infrastructure.

5. Sub-processors

We engage a strictly vetted set of third-party sub-processors to deliver the Service. Each is bound by contractual data-protection obligations and may process operational data only on our documented instructions.

• Identity & Access Management: Secure handling of authentication sessions.
• Cloud Hosting & Object Storage: Infrastructure that stores encrypted blobs and runs the Service.
• Payment Processing: Secure handling of subscription payments, including PCI-DSS compliant processing.
• Transactional Email Delivery: Routing of inbound and outbound Nym email.

We will provide reasonable notice of material changes to our sub-processors. To request the current specific list of vendors, contact privacy@anonime.io.

6. Security measures

We apply robust technical and organizational measures appropriate to the risk, including:

• Client-side encryption of secret content with local key generation.
• Encryption of data at rest and TLS 1.2+ for all data in transit.
• Least-privilege access controls and separation of sensitive systems from operational metadata.
• Secure identity provider integration and session management.
• Server-side authorization checks.
• Rate limiting and structured audit logging.
• Absolute data minimization and automated infrastructure retention schedules.

7. International transfers

Where operational personal data is transferred across borders, we systematically minimize the personal data transferred. Where required, we rely on appropriate contractual, legal, or technical safeguards, and compliance with the Nigeria Data Protection Act (NDPA).

Client-side encrypted content remains unreadable regardless of the physical geographic location where the ciphertext is stored.

8. Retention and return

We retain personal data only as long as necessary for the operational purposes stated above. Ephemeral content is deleted upon expiry, self-destruct configuration, or upon reaching our infrastructure’s absolute maximum retention limit of seventy-two (72) hours.

On termination or deletion of your account, we disable access immediately and permanently purge all associated data and operational metadata from active production systems within 72 hours, except where retention is required by applicable law, accounting obligations, fraud prevention, or unresolved disputes.

9. Data subject rights

Where Anonime acts as a Data Processor, we will assist the Data Controller in responding to data-subject requests using commercially reasonable efforts. Where Anonime acts as the Data Controller, you may directly exercise your rights of access, correction, deletion, portability, and objection by utilizing the tools within the application or by contacting privacy@anonime.io.

Please note: We cannot produce, recover, or export plaintext content protected by cryptographic keys we do not hold.

10. Breach notification

If we become aware of a confirmed personal data breach affecting your operational data, we will notify affected users and, where required by law, the relevant regulatory authorities without undue delay. We will provide the necessary information required to understand, evaluate, and respond to the incident.

11. Contact information

For data-processing questions, to exercise your privacy rights, or to request our current sub-processor list, please contact our privacy team at:

• Email: privacy@anonime.io
• Corporate Entity: Leatra Technologies LTD (RC Number: 7062719)
• Registered Address: Lagos, Nigeria