Data Processing

This DPA is entered into between Twilight OS Inc. ("Processor") and the Institutional Client ("Controller").

1. Scope and Role

This Agreement applies to the processing of personal data by Twilight on behalf of the Client to facilitate digital asset clearing, liquidity unification, and settlement services.

2. Processor Obligations

Twilight agrees to:

• Instructions: Process personal data only on the documented instructions of the Client.
• Confidentiality: Ensure that personnel authorized to process the data have committed themselves to confidentiality.
• Security: Implement appropriate technical and organizational measures, including Zero-Knowledge Proofs where applicable (e.g., Twilight Shield), to ensure a level of security appropriate to the risk.
• Sub-processing: Only engage sub-processors (such as custodial partners or cloud providers) with prior notice to the Client and under written contract.

3. Data Subject Rights

Twilight shall assist the Client, insofar as possible, in fulfilling the Client’s obligation to respond to requests from data subjects exercising their rights (e.g., access or deletion), subject to the immutable nature of blockchain records.

4. Audit Rights

Twilight shall make available to the Client information necessary to demonstrate compliance with these obligations and allow for audits conducted by the Client or an independent auditor.

5. Data Deletion

Upon termination of services, Twilight shall, at the choice of the Client, delete or return all personal data, unless applicable law or the permanent nature of the blockchain requires continued storage.

Legal Entity: Twilight OS Inc.
Contact: legal@twilight.co