Data processing terms

Last updated 30 July 2026

Roles

Your firm is the controller of its clients' personal data. Trueband is the processor and acts only on your firm's documented instructions, which in practice means the credentials you connect and the settings you choose. If we ever believe an instruction breaks applicable law, we will say so instead of quietly complying.

Scope of processing

• Subject matter: computing portfolio drift and preparing client communications for advisor review.
• Duration: for as long as your firm's account is active, plus the deletion window below.
• Categories of data subject: your firm's advisors, and your firm's clients.
• Categories of data: household and account names, account counts and values, holdings by asset class, computed drift, performance figures, client email addresses where your firm holds one, advisor recorded video, and advisor written email text.

What we do not process

No account numbers, no tax identifiers, no dates of birth, no transaction history, and no special category data. The product has no use for any of it, so we do not read it.

Sub-processors

• Cloudflare: compute, key value storage, object storage, and access control.
• Microsoft: receives the draft email, because the draft is created inside your own tenant.

We will give notice before adding a sub-processor, and your firm may object.

Security

Data is encrypted in transit and at rest by the underlying Cloudflare services. Access to the application requires a signed identity from your firm's own identity provider, checked against an allowlist your firm controls. The current state of our wider security posture, including what is not yet in place, is set out on the security page rather than glossed over here.

Assistance

We will help your firm respond to data subject requests, and we will tell you without undue delay if we become aware of a personal data breach affecting your data. We will not wait to work out how it looks first.

Deletion and return

On termination we will delete or return your firm's data at your election. Configurable retention during the term is designed and not yet shipped, and we would rather you knew that before signing than after.

International transfers

Processing happens on Cloudflare's global network. Where a transfer requires a lawful mechanism, the relevant standard contractual clauses will be incorporated once counsel has reviewed this document.