Legal · Enterprise Data Protection

Data Processing Addendum.

This Data Processing Addendum (“DPA”) forms part of the Terms of Service or Master Services Agreement between Customer (“Controller”) and EarlyBird AI, LLC d/b/a Threat.Blue (“Processor”) where Customer Materials contain Personal Data subject to GDPR, UK GDPR, Swiss FADP, or US state privacy laws.

Effective date: November 5, 2026 Processor: EarlyBird AI, LLC d/b/a Threat.Blue Countersigned PDF available via security@threat.blue
01

Roles & processing instructions

Customer acts as Controller (or Business under CCPA/CPRA) and EarlyBird AI, LLC d/b/a Threat.Blue acts as Processor (or Service Provider). Threat.Blue processes Personal Data incidentally contained in Customer repositories, commit histories, build logs, or engineering workflows (such as developer names, work email addresses, and code review metadata) strictly on Customer’s documented instructions for the sole purpose of discovering, reproducing, and patching software vulnerabilities.

  • No secondary use: Threat.Blue never sells, rents, combines, or retains Customer Personal Data for marketing or cross-customer profiling.
  • Zero AI training: Customer Materials and Personal Data are never used to train, fine-tune, or distill foundation models.
  • Confidentiality obligations: All personnel authorized to access engagement environments are bound by written confidentiality agreements, hardware MFA, and least-privilege role controls.
02

Annex I · Details of processing

Data Subjects Customer software engineers, repository maintainers, and security contacts.
Categories of Data Git author metadata, work email addresses, pull-request comments, and technical logs. Special-category data (PHI/PCI) is excluded by policy.
Duration Active engagement window only, followed by automated ephemeral teardown within 7 days of sign-off.
Cross-Border Mechanism EU SCCs (Module Two: Controller-to-Processor) and UK International Data Transfer Addendum incorporated by reference.
03

Annex II · Technical & organizational measures

Threat.Blue maintains technical and organizational security controls appropriate to high-sensitivity source code and vulnerability data:

  • Single-tenant ephemeral compute: Every customer audit runs inside dedicated, network-isolated compute instances with no cross-tenant filesystem, memory, or container sharing.
  • Encryption in transit & at rest: All external connections enforce TLS 1.2+ with modern AEAD cipher suites; EBS volumes and S3 buckets enforce AES-256 server-side encryption and aws:SecureTransport policies.
  • Hardware-backed access control: Administrative access requires phishing-resistant authentication over private overlay networks (zero public SSH/RDP exposure, IMDSv2 hop-limit 1, and IAM Permissions Boundaries).
  • Incident notification (48 hours): Threat.Blue notifies Customer without undue delay—and within forty-eight (48) hours—upon confirming any Personal Data Breach affecting Customer Materials, including root-cause forensics and containment actions.
  • Post-engagement deletion & certification: Within seven (7) calendar days of engagement completion (or immediately upon Customer’s written request), ephemeral volumes and cloned repositories are destroyed. Written deletion confirmation is available on request.
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Annex III · Authorized sub-processors

Customer authorizes the following infrastructure sub-processors. Threat.Blue provides at least thirty (30) days’ advance notice before engaging any new sub-processor handling Customer Materials:

Sub-processor Service Role Region
Amazon Web Services, Inc. Isolated ephemeral compute (EC2), encrypted storage (S3/EBS), edge security (CloudFront/WAF), and transactional mail (SES) in dedicated security account. United States (us-east-1)
Google LLC (Google Workspace) Encrypted corporate email and NDA/briefing correspondence for EarlyBird AI, LLC security personnel (no source-code sandbox processing). United States

Where an engagement uses dedicated self-hosted models on EarlyBird AI’s isolated AWS compute instances, no Customer source code leaves our dedicated VPC. If a specific engagement scope optionally invokes frontier commercial model APIs under zero-data-retention (ZDR) enterprise agreements, the applicable model provider is disclosed and approved in Customer’s Statement of Work prior to execution.

To request a countersigned PDF copy of this DPA or submit security audit inquiries, contact security@threat.blue.