Privacy, subprocessors, and incidents
Who processes Seal data, customer DPA posture, and what we do if something goes wrong
Privacy, subprocessors, and incidents
Enterprise / CompAI foundation (SEA-69). This is the publishable privacy surface for RFPs — not a substitute for counsel (SEA-57) and not a HIPAA offering (HIPAA scoping).
What Seal processes
Seal processes account data (names, emails), document files you upload, signing field values, IP/user-agent on signing events, and webhook delivery metadata. Completed envelopes and sealed audit rows are retained as evidentiary records (see Trust & evidence and Backup & DR).
Subprocessors (hosted seal.nyc)
| Subprocessor | Role | Data involved |
|---|---|---|
| Cloudflare | API Workers, D1 database, R2 file storage, DNS, TLS, email routing hooks | Document bytes, metadata, account identifiers, logs |
| Vortex Auth / Better Auth stack (as deployed with Seal) | Authentication and sessions | Email, session tokens, org membership |
| Transactional email (Cloudflare Email / configured sender) | Invite and notification mail | Recipient email, document title, signing links |
Self-host customers run the same software on their Cloudflare account — they
are the operator; Seal Inc. is not in the data path unless they use hosted
api.seal.nyc.
Optional features that send document bytes to additional workers when enabled:
| Feature | Worker / service | When it runs |
|---|---|---|
| Office → PDF convert | Seal convert worker | Upload of DOCX/XLSX/PPTX/CSV |
| Document AI / field candidates | Seal anydoc worker | When org uses AI field tools |
Turn those features off (or do not call them) if your policy forbids extra processing of file bytes.
Customer agreement posture (DPA)
For hosted customers that need a Data Processing Agreement: contact
privacy@vortex.nyc (or your Seal sales path). Seal’s default commercial terms
plus this page describe processing; formal DPA countersign is available for
enterprise contracts. This page is not itself a signed DPA.
We do not offer a HIPAA Business Associate Agreement for general signup — see HIPAA scoping.
Data subject / privacy requests
Hosted:
- Account holders can update profile data in-app.
- Org admins control members and can void/delete documents per product rules (retention locks may prevent immediate destroy of locked R2 objects — see backup/DR runbook).
- For erasure or export requests that exceed self-serve tools, email
privacy@vortex.nycwith the workspace slug and request type. We respond within 30 days (faster when legally required).
Breach / security incident runbook (ops)
If Seal discovers unauthorized access to hosted customer document or account data:
- Contain — revoke keys, rotate secrets, isolate affected Worker/version, disable compromised webhook endpoints.
- Assess — what orgs, what object classes (PDFs, audit rows, emails), time window.
- Notify — affected workspace owners/admins without undue delay, and within 72 hours of confirming a personal-data breach where GDPR-style duties apply; follow US state timelines where applicable.
- Record — incident ticket, timeline, systems touched, customer comms.
- Remediate — patch, rotate, post-mortem; update this page if subprocessors or practices change.
On-call / security contact for hosted Seal: security@vortex.nyc.
Publish /.well-known/security.txt on seal.nyc / api.seal.nyc as the
machine-readable pointer (SEA-54 / bounty track).
What this page does not claim
- SOC 2 / ISO report availability (roadmap, not asserted here)
- HIPAA compliance or BA relationship
- Customer-managed encryption keys
- EU data residency pin (Cloudflare region choice is limited; self-host for stricter control)
Related
- HIPAA scoping
- eIDAS levels
- Trust & evidence
- Production checklist
- Enterprise backlog notes:
docs/enterprise-readiness.mdin the Seal repo