GBoarse data processing annex
The shortest annex in the set, which is a fact about the product rather than an omission.
What this annex is
The Art. 28(3) specifics for hosted GBoarse. It is part of the data processing agreement, which carries the obligations.
This is the shortest annex in the set, and that is a fact about the product rather than an omission.
Nature and purpose
Operating a simulated market for you: running the matching engine, holding the simulation state, and serving the web interface and bot API.
Categories of data subjects
Your users — a handful of people — and the operators of any bot accounts they create.
Categories of personal data
Email address, display name, role, bot flag and interface preferences; the identity link to our self-hosted Stack Auth; account ownership and configuration; API key metadata with the secret as a hash; and admin audit entries naming the acting user.
Orders, positions, trades and balances are simulation state. They are attributable to an account and therefore to a person, but they are not information about a person in the world — nothing here corresponds to any real holding.
Special categories
None, and none can arise: the system has no free-text field a person writes about themselves in.
Sub-processors
Those named in the general agreement — IONOS SE and Contabo GmbH, both in Germany, plus our own hardware in Germany — and no others. Identity runs on our own self-hosted Stack Auth. No error reporting service, no analytics, no AI provider.
Security measures particular to this service
- API key secrets are stored as hashes; keys carry scopes, an instrument allowlist, a rate limit and an expiry, and can be revoked.
- Administrative actions are recorded with their parameters and the decision taken.
- Instrument mode is a declared property, so a manipulable instrument is distinguishable from one that is not.
Retention
Account and key records last as long as the account. Simulation state persists as the simulation; engine snapshots exist for restore.
On termination
As set out in the general agreement: return or deletion at your choice, 30 days of export availability by default, backups expiring on their own cycle.