Status: v1, in force from 2026-10-13.

Data Processing Addendum

Version 1.0.2 · Effective 2026-10-13 · Posted 2026-10-13 · Last updated 2026-10-13

In plain English (this summary is not part of the agreement; the full text below controls)

1. Parties and scope

1.1 This Data Processing Addendum ("DPA") forms part of the Tartan Networks Terms of Service (https://tartannetworks.com/legal/terms), or of another written agreement for the hosted Tartan service (the "Agreement").

1.2 This DPA applies only where TechSolve processes Customer Personal Data on Customer's behalf while providing the hosted service. That covers the hosted control plane, the console, the hosted lighthouses and relays, and hosted DNS for the Customer's org zone.

It does not apply to:

1.3 Definitions:

2. Roles

2.1 Customer is the controller of Customer Personal Data, or a processor acting for its own controller. TechSolve is a processor of Customer Personal Data and, under the CCPA, a service provider.

2.2 Customer is responsible for the lawfulness of the Customer Personal Data it provides or causes to be provided. This includes giving any notice to, and getting any consent from, its own people and device users. Examples include:

3. Instructions

3.1 TechSolve processes Customer Personal Data only on Customer's documented instructions. Those instructions are:

The only exception is processing that the law requires of TechSolve. In that case TechSolve tells Customer first, unless the law forbids it.

3.2 TechSolve will tell Customer if, in its opinion, an instruction breaks Data Protection Laws. It may suspend that instruction until the matter is resolved.

4. Product improvement and limits on use

<!-- data-use --> 4.1 TechSolve will not:

4.2 Aggregated and de-identified data. Besides running the service, TechSolve may create the following from the service and use them to operate, secure, maintain and improve its services:

For de-identified data, TechSolve will:

Data that meets this section is not Customer Personal Data.

4.3 TechSolve will widen section 4.1 only by agreement with Customer, or under the change process in the Agreement. A change that widens what TechSolve may do:

It applies to data collected before then only with Customer's affirmative consent. Continued use of the service never counts as that consent. <!-- /data-use -->

5. Confidentiality

TechSolve ensures that everyone it authorises to process Customer Personal Data is bound by an appropriate duty of confidentiality, contractual or statutory. Access is limited to people who need it to provide, support or secure the service.

6. Security

6.1 TechSolve implements and maintains the technical and organizational measures in Annex II. Those measures give a level of security appropriate to the risk, taking into account:

6.2 TechSolve may update those measures over time, provided an update does not materially reduce the overall security of the service.

7. Subprocessors

7.1 Customer gives general authorisation for TechSolve to engage subprocessors. The current list is section 2 of https://tartannetworks.com/legal/subprocessors, which is Annex III.

7.2 TechSolve will give at least 30 days' notice before a new subprocessor processes Customer Personal Data. It gives notice in two ways:

7.3 Customer may object on reasonable data-protection grounds within that 30-day period, by writing to privacy@tartannetworks.com.

7.4 TechSolve will impose on each subprocessor data-protection obligations that are no less protective than this DPA. TechSolve remains liable for its subprocessors' performance of those obligations, subject to the Agreement.

8. Assistance

8.1 Data-subject requests. TechSolve will help Customer, by appropriate measures and so far as possible, to respond to requests from data subjects who exercise their rights.

Today, Customer can:

For anything else, Customer writes to privacy@tartannetworks.com. TechSolve verifies the request with an Owner and acts within 30 days. We are building self-serve deletion in the console.

8.2 Other assistance. Taking into account the information available to it, TechSolve will give reasonable help with:

9. Personal data breaches

9.1 TechSolve will notify Customer of a personal data breach affecting Customer Personal Data without undue delay, and where feasible within 72 hours after becoming aware of it.

9.2 TechSolve will give Customer the information it reasonably needs to meet its obligations, as that information becomes available. This includes:

9.3 Notice goes to Customer's Owners in the console and to any contact address Customer has given us.

9.4 A notification is not an admission of fault or liability.

10. Deletion and return

10.1 While the service is active, Customer may export its org state with the tools the service provides. Today that export is designed for moving an org to a control plane that Customer runs.

10.2 After the Agreement ends, or on Customer's written request to privacy@tartannetworks.com:

10.3 Some records outlast that deletion. They are not used except as stated:

These records stay subject to this DPA until they are deleted.

11. Audits

11.1 TechSolve will make available the information reasonably needed to show compliance with this DPA. It does this first through:

11.2 If that is not enough to meet a requirement of Data Protection Laws or of a regulator, Customer may audit TechSolve. The audit is subject to all of the following:

12. International transfers

12.1 TechSolve stores Customer Personal Data in Microsoft Azure regions in the United States. Its subprocessors may process it in the locations listed in Annex III.

12.2 For now, TechSolve offers the hosted service to organizations outside the European Economic Area and the United Kingdom.

The clauses below apply if, despite that, Customer Personal Data that is subject to the GDPR is transferred to TechSolve in a country without an adequacy decision. In that case the Standard Contractual Clauses adopted by Commission Implementing Decision (EU) 2021/914 apply, incorporated by reference, as follows:

12.3 For transfers subject to the UK GDPR, the International Data Transfer Addendum to the EU Standard Contractual Clauses, issued by the UK Information Commissioner, applies and is incorporated by reference.

13. CCPA service-provider terms

To the extent the CCPA applies, TechSolve:

TechSolve certifies that it understands these restrictions and will comply with them.

14. Liability and precedence

14.1 Each party's liability under or in connection with this DPA is subject to the limitations and exclusions of liability in the Agreement.

14.2 If this DPA and the Agreement conflict, this DPA controls for the processing of Customer Personal Data. If the Standard Contractual Clauses and this DPA conflict, the Clauses control.

14.3 TechSolve may update this DPA under the change process in the Agreement. An update will not reduce the protection of Customer Personal Data without Customer's affirmative consent.


Annex I: Details of processing

Parties:

Categories of data subjects:

Categories of personal data:

Special categories: none intended. Customer should not put sensitive data in names or free-text fields.

Not processed:

Nature and purpose (business purposes):

Frequency: continuous while the service is used.

Duration:

We are building retention limits for:

Competent supervisory authority: as clause 13 of the Standard Contractual Clauses sets out, where they apply.

Annex II: Technical and organizational measures

  1. Traffic encryption. Network traffic is end-to-end encrypted between Customer's devices. Relays forward it without being able to read it.
  2. Certificate authority custody. In hosted mode, TechSolve's signing service holds each org's network CA keys in managed key stores, with recovery copies held offline. They are used only to issue that org's certificates and configuration.
  3. No passwords. People sign in with passkeys (WebAuthn) or through Customer's own identity provider. TechSolve stores only public keys.
  4. Hardware-backed device keys.
    • Device keys are created on the device and are never exported to TechSolve.
    • They are kept in hardware-backed storage where the device has it: TPM or CNG on Windows, StrongBox or TEE on Android.
  5. Org isolation. Row-level security separates each org's records in the database.
  6. Tamper-evident audit. The audit log is hash-chained and append-only. The service's database role cannot alter or delete its entries.
  7. Encryption in transit and at rest.
    • All control traffic uses TLS or Nebula.
    • Databases, backups and key stores use the cloud provider's encryption at rest.
  8. Backups.
    • The database is backed up nightly to immutable (WORM) storage in a second US region.
    • There are also 14 days of point-in-time recovery.
  9. Hosting. Microsoft Azure, in the East US 2 and Central US regions, USA.
  10. Access control.
    • Staff access is limited, needs strong authentication and is logged.
    • The console has role-based access (Owner, Admin, Tech, Viewer) and step-up authentication for sensitive changes.
  11. Minimisation.
    • The Windows agent does not read usernames, serial numbers or MAC addresses.
    • The Android app has no analytics, crash-reporting or advertising SDKs.
    • The in-app DNS resolver does not log query names.
    • Edge splash pages log only the time, the requested TLS server name (SNI hostname) and the status.
  12. Vulnerability handling.
  13. Monitoring. Operational alarms are retained for 30 days.

Annex III: Subprocessors

Section 2 of https://tartannetworks.com/legal/subprocessors, as updated under section 7.