Legal

Data Processing Addendum

Torvanis LLC. Version 1.0, September 2026. Draft — counsel review pending.

This DPA applies where Torvanis processes personal data on behalf of a customer in connection with janusedge.com services. Because Janus Edge is self-hosted, Torvanis is a processor only for the limited data the customer sends through the portal, support and optional sync features.

  1. Roles. Customer is controller; Torvanis is processor for portal account data, support content and optional sync telemetry.
  2. Scope. Categories: business contact data of customer staff; instance metadata (instance ID, version, seat counts, site label) where sync is enabled. No prompt, response or end-user traffic data is processed.
  3. Instructions. Torvanis processes only to provide the services and as documented.
  4. Security. Encryption in transit and at rest, access limited to named staff, audit logging, 72-hour breach notification.
  5. Sub-processors. Listed in the Privacy Policy; 30 days' notice of changes with right to object.
  6. Transfers. Data is stored in the United States. For EU/UK data, the EU Standard Contractual Clauses (Module 2) and UK Addendum are incorporated by reference.
  7. Deletion. On termination, portal data is deleted or returned within 90 days, except records retained by law.
  8. Audit. Annual written assurance on request; on-site audit at customer cost if a regulator requires it.

To execute the DPA with your entity name and signatory, email [email protected].