Our role
Kagliostro acts as a data processor for customer data and as data controller for account data.
Lawful basis
Contract performance for service delivery; legitimate interest for security telemetry; consent for optional analytics.
Data residency
EU customers' data is stored exclusively in Frankfurt (eu-central-1). No cross-border transfer without SCCs and adequacy.
Sub-processors
Full, up-to-date list with locations and DPAs on the Sub-processors page.
Your rights
- Right to access, rectification, erasure
- Right to data portability (JSON export, on-demand)
- Right to restrict or object to processing
- Right to lodge a complaint with your supervisory authority
DPA
We sign a DPA with every customer on request. Pre-signed copy available at /dpa.
Data Protection Officer
Priya Ravindran — dpo@kagliostro.cloud
Breach notification
Customers are notified within 24 hours of confirmed breach affecting their data, well under the 72-hour GDPR requirement.

