How data is processed

Roles

Servlets is the data controller for account, verification and platform activity data. Where an organisation sponsors jobs for its employees, the organisation is a separate controller for the enrolment list it uploads; Servlets processes job data on the employee’s behalf, not the organisation’s.

Sub-processors

• Cloud hosting & managed Postgres (in-region).
• Object storage for verification documents (private ACL, encryption at rest).
• Email/SMS delivery for transactional notifications.
• Payment & escrow provider (PCI-DSS; Servlets never stores card data).

Retention

• Account data: for the life of the account, then 90 days.
• Approved KYC records: statutory retention period, then deletion.
• Rejected KYC documents: 30 days.
• Job, agreement and payout records: 7 years (tax/dispute).
• Audit log: 2 years.

Security measures

• Passwords hashed with bcrypt (cost 12); session tokens are signed, HTTP-only, short-lived and revocable.
• Role-based access control on every route; least-privilege reviewer access to documents.
• PII masking in provider-facing views; ID numbers truncated to last 4 digits.
• Rate limiting on auth and write endpoints; security headers and a strict content policy.
• Append-only audit logging of logins, KYC decisions, signatures, admin actions and data requests.

International transfers

Production data stays in-region. Any transfer for support is covered by standard contractual clauses.