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Home/Legal & privacy

Counsel-reviewable engineering draft

Data Processing Addendum Draft

Draft processor terms and security commitments; no DPA is effective until executed by approved entities.

Not effective or legally approved

Qualified legal approval and a recorded effective version are required before commercial launch.

Document code
data_processing_addendum
Version
2026-08-02-draft.1
Locale
en-US
Status
engineering_draft_counsel_review_required
Product scope
Nook Cloud, Customer Portal
Canonical SHA-256
cebacf966a4d9263074e20ea6ddfd83fc7b6da9ea4784b2e2d6cef7fcfe29faf

Candidate processing instructions

Where Nook acts as processor, it is intended to process personal data only on documented customer instructions needed to provide, secure, support, and maintain the contracted service, subject to law and the final agreement.

  • Subject matter, duration, nature, purposes, data categories, and data-subject categories must be completed in an executed order or schedule.
  • Personnel access must be least-privilege, authenticated, logged, and confidentiality-bound.
  • Subprocessor engagement, transfer mechanisms, assistance, deletion/return, audits, and government-request handling require approved clauses.

Security and incidents

The product uses tenant scoping, role-based authorization, passkeys for high-risk Portal operations, action-bound step-up, immutable commercial evidence, signed entitlements, encrypted transport, sanitized audit, and bounded recovery capabilities.

A contractual incident-notification period, risk assessment procedure, customer cooperation process, and audit evidence package remain legal and operational launch gates.

This exact draft can be referenced by document code, version, locale, product scope, and digest. A future approved version must use a new immutable version and record whether existing customers must reaccept it.

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