## 📄 Personal Data & GDPR-Sensitive Information

Wallboard processes minimal personal data strictly necessary for authentication and system access.
This includes user email addresses and optionally display names or nicknames. No special categories of personal data are collected or processed,
as defined under Article 9 of the GDPR (e.g. health data, political opinions, biometric data, or racial/ethnic origin).
The platform does not require or handle any sensitive personal data beyond basic login credentials.
Customers are responsible for ensuring that the content they upload does not include personal or sensitive data unless appropriate legal safeguards are in place.

## 🧷 Sensitive Data in the Context of Digital Signage

While the Wallboard platform does not typically handle end-user personal data,
certain types of system-level and business-related information may be considered sensitive in the context of digital signage operations. This includes:

- **Administrative credentials and access tokens** used for managing signage content and system configurations.
- **Integration data**, such as API keys, webhook URLs, or connections to external systems (e.g., POS, IoT, dashboards).
- **Confidential content** scheduled for future display (e.g., unreleased product information, pricing strategies, internal communications).
- **Player metadata and operational logs** that may reveal deployment locations, device identifiers, or system behaviors.
- **Tenant structure and configuration** (e.g., team assignments, usage metrics, regional settings) that may expose organizational details.

This type of information is not classified as sensitive under GDPR but is still protected as part of our broader risk-based security posture.
Access to such data is restricted by role, team membership, and tenant boundaries, and all communication channels are encrypted in transit.

## 🤝 Vendor Access to Personal or Sensitive Data

Wallboard does not require access to customer content or personal data to deliver its core functionality.
The platform only processes minimal user information such as email addresses and optional display names for authentication purposes.
All other data — including signage content, external integrations, and uploaded media — is fully managed and controlled by the customer.

Processing of personal or sensitive data is not integral to the service and can be avoided.
In cloud deployments, vendor access can be restricted contractually or technically. In on-premises deployments,
vendor access is completely eliminated, as the customer hosts and controls the entire system. Wallboard does not by default access, monitor,
or process customer data unless explicitly requested for support or diagnostics under a separate agreement.

## 🧭 Data Residency and Hybrid Architecture

Wallboard does not provide hybrid data storage models where sensitive data is split between the customer and the vendor.
The system is designed to operate either as a fully cloud-hosted SaaS solution or as a fully self-managed on-premises installation.
In cloud deployments, all data is stored within the Wallboard-managed environment in a secure, region-specific infrastructure.
In on-premises deployments, all data — including user accounts, content, logs, and configurations — remains entirely under the customer’s control.
There is no technical model where personal or sensitive data is stored by the customer while using Wallboard’s cloud infrastructure for service delivery.

## 🧹 Data Deletion and Secure Disposal Upon Contract Termination

Wallboard follows a tiered approach to data deletion and disposal based on the deployment model:

In **private cloud or on-premises deployments**, complete and verifiable data destruction is possible, including full erasure of databases, file storage, and backups.

In **multi-tenant public cloud environments**, Wallboard deletes all tenant-specific data (databases, files, configuration) from the platform upon contract termination.
Backup retention policies are applied according to customer agreements, after which data is permanently deleted.
However, due to the nature of shared infrastructure and provider-controlled backups, **complete physical media sanitization cannot be guaranteed**,
as cloud providers manage underlying storage infrastructure.

Customers with strict requirements for full control over data lifecycle and disposal are advised to use private cloud or on-prem deployments where such guarantees can be fully enforced.

## 📘 Compliance, Notification Obligations, and Legal Safeguards

Wallboard is committed to data protection, operational transparency, and lawful handling of customer information. The following principles apply:

### 🔏 Confidentiality and NDA Commitments

- In **private or on-premise deployments**, Wallboard can enter into specific non-disclosure agreements (NDAs) for
  the personnel involved in maintaining or accessing the system (e.g. system administrators, support engineers).
- In **multi-tenant cloud deployments**, such per-customer NDAs are not feasible due to shared infrastructure and
  operational model. However, all Wallboard personnel are bound by company-wide confidentiality agreements and access control policies that meet GDPR expectations.

### ⚠️ Notifications and Incident Reporting

Wallboard commits to notifying customers in a timely manner regarding:
- Any breach, compromise, or unauthorized access to systems or data
- Any operational incident potentially resulting in data loss
- Results of security or vulnerability assessments upon request
- Requests from law enforcement or other third parties to access customer data
- Infrastructure or hosting provider changes that may impact data residency or security
- Organizational changes such as mergers, acquisitions, or critical subcontractor replacements

Such notifications are issued proactively and in accordance with applicable data protection regulations.

### 🌍 Data Residency and Transfer

- For EU-based tenants, all customer data (including backups) is stored exclusively within the **European
  Union/EEA**. This includes TimescaleDB, MySQL, MongoDB, Redis, and object storage.
- No customer data is routed through or replicated outside the EU during transit or at rest.
- Hosting locations are fixed per environment and can be explicitly documented in customer-specific contracts for private installations.

### 🆘 Disaster Recovery and Legal Compliance

- Wallboard maintains an internal **Disaster Recovery Plan**, which covers full environment restoration from secure off-site backups in case of system failure.
- Hosting and data management processes comply with applicable laws in the country of operation and within the EU/EEA.
- For enterprise customers Wallboard supports contractual documentation of hosting locations and
  legal compliance alignment as part of the onboarding or infrastructure planning process.