Art. 28 GDPR · Version 1.0 · June 2026
Controller: the customer. Processor: 11data ("LongMem"), [email protected]. The processor processes personal data only on the controller's documented instructions (Art. 28(3)(a)) — in LongMem's case, instructions are expressed through API calls and configuration.
Provision of a memory/context API for AI applications: storage, indexing (embeddings + knowledge-graph extraction), retrieval, and lifecycle management of content the controller submits.
For the life of the customer account. On termination, data is deleted (or exported on request first) — see §8.
| Measure | Implementation |
|---|---|
| Tenant isolation | Postgres row-level security in FORCE mode on all tenant tables; non-privileged application database role |
| Credential protection | API keys stored as SHA-256 hashes only; customer-supplied credentials (BYO storage/DB/LLM) encrypted at rest (Fernet) |
| Transport | TLS for all external traffic |
| Hosting | EU (Germany, Hetzner); EU-resident object storage |
| Data minimisation | cookieless analytics (path/referrer only), no content in logs |
| Residency options | BYO storage, database, and LLM let the controller keep bytes and AI processing on their own infrastructure |
| Monitoring | uptime checks, per-route metrics, structured error logs (content-free) |
The current list is maintained in the privacy policy (Hetzner DE; OpenAI US — avoidable via BYO; Stripe; Resend; Cloudflare). The processor notifies the controller of intended changes and the controller may object on reasonable grounds.
The processor assists the controller with data-subject requests (export and erasure are self-service via the API), with security of processing, and with breach notification — undue-delay notice to the controller upon becoming aware of a personal data breach.
Self-service at any time: GET
/v1/memory/admin/export (full JSON) and POST
/v1/memory/admin/delete-account (irreversible erasure incl. stored files).
Backups expire within 30 days.
The processor makes available the information reasonably necessary to demonstrate compliance and allows audits by the controller or a mandated auditor, with reasonable notice and at most annually unless an incident warrants otherwise.
Persons authorised to process the data are bound to confidentiality (Art. 28(3)(b)).