tokencoup
Edition: International · 国内版 Language: EN · ZH
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Draft v0.1 · not legal advice

GDPR Notice

Legal basis, data minimisation, EU rights and cross-border transfers for the international edition.

Draft — not legal advice. This is a design description, not an Art. 13/14 notice. Controller identity, EU representative, DPO, retention periods and contact details are undecided, and no live service processes EU personal data yet. Counsel must review before launch.

1. Status of this notice

This page records how the international edition is designed to meet GDPR so that the engineering choices are auditable. It is not a substitute for a reviewed privacy notice or a data-processing agreement.

2. Who this applies to

This page addresses users in the EU/EEA using the international edition. The domestic edition is not covered here — see the PIPL section and the Cross-border notice.

3. Roles

PartyRoleData
tokencoup (operating entity TBD)Controller for gateway account & billing dataKey hash, plan, usage ledger, audit metadata
Baidu Qianfan InternationalIndependent upstream providerRequest bodies you send
Cloudflare (Pages + AI Gateway)Infrastructure / edge processorTLS metadata; not request or response bodies (collect_logs=false)
You (B2B customer)Controller of the content in your promptsPrompt content
Role allocation between tokencoup and Qianfan is not contractually settled. A DPA and sub-processor list must be executed before live EU traffic.

5. Data minimisation by design

  • log_prompt=false — prompts are not persisted by the gateway.
  • collect_logs=false on Cloudflare AI Gateway — no request or response bodies stored at the edge.
  • Gateway keys are stored as SHA-256 hashes, never in plaintext.
  • Audit records contain only edition, mode, key id and token counts.
  • Requests are tagged X-Data-Region: overseas.

These are implemented in gateway/config.py, gateway/auth.py and gateway/common.py. See the API reference.

6. Your rights

  • Access (Art. 15) and rectification (Art. 16).
  • Erasure (Art. 17) and restriction (Art. 18).
  • Data portability (Art. 20) for data you provided.
  • Object to processing based on legitimate interests (Art. 21).
  • Withdraw consent at any time, where consent is the basis (Art. 7(3)).
  • Lodge a complaint with your supervisory authority (Art. 77).
Standard response time is one month. No request channel exists yet — one will be designated before launch.

7. International transfers

The EU has no adequacy decision for mainland China (confirmed 2026-10). A transfer of EU personal data to China would require EU Standard Contractual Clauses (2021/914), a transfer impact assessment under Schrems II, and supplementary technical measures.

The S1 design is intended to avoid that transfer: EU/US traffic is routed through an overseas gateway to the Qianfan International upstream, with the goal that no data enters mainland China. This is a design target, not a verified fact. The upstream's actual data-residency region has not been confirmed in writing, and third-party due diligence (Kaamel, terms checked to 2026-09-17) reports that some Qianfan International personal data is stored in China and that no public DPA is available. Until Baidu confirms residency and a DPA/SCC package is executed, EU personal data must not be sent through the live service. S3 — an international request using a domestic Qianfan key — is blocked in code with 403 key_edition_mismatch.

Not yet done: SCC execution, TIA documentation, and verification of the Qianfan International node's actual residency region. Until those are complete, no EU personal data should be sent through the live service. See Cross-border.

8. Sub-processors

Sub-processorFunctionLocationStatus
Cloudflare PagesStatic hosting / CDNGlobal edgeIn use
Cloudflare AI GatewayEdge cache, rate limit, retryCloudflare edgeResource created; custom provider pending
Baidu Qianfan InternationalModel inference upstreamOverseas node — unverifiedTo be confirmed
Payment providerBilling—Not selected (Stripe / Paddle TBD)

9. Retention and breach notification

Retention periods are not fixed; the C2 plan proposes 30 days for operational metadata, with billing records kept for statutory tax periods. A personal-data breach notification procedure targeting the 72-hour deadline (Art. 33) is not implemented.

10. DPO, EU representative and contact

Whether a Data Protection Officer (Art. 37) or an EU representative (Art. 27) is required depends on the final entity, scale and target market — all undecided. No DPO, representative or data-request address has been appointed.

Contact: to be designated. This section is a checklist of outstanding obligations, not a claim of compliance.