Global Privacy & Data Ownership Policy
Data Controller: JaLuMa Digital LLC (Wyoming, USA)
Compliance Frameworks: EU GDPR, US CCPA, A2P 10DLC
We operate under the absolute principle of Data Ownership. We collect only the data mathematically necessary to execute your infrastructure commands.
01. Ingestion Protocols & Authorized Sub-Processors
To provide zero-downtime redundancy, we utilize Google Cloud Platform (GCP Cloud Run, Pub/Sub, and Firestore) as our primary serverless framework, and Twilio/Telnyx for secure telecom routing. All data in transit is cryptographically protected via TLS 1.3.
02. Telecom & A2P 10DLC Compliance
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the Text Message services necessary to technically facilitate the communication.
03. User Commands (CCPA & GDPR Rights)
Under the EU GDPR and US CCPA, you retain root access to your identity data. You may request access, rectification, or absolute deletion ("Right to be Forgotten") by contacting us directly at jason@jalumadigital.com.
We operate under a strict "Zero-Harvest" pledge. We do not sell, lease, or share your personal information with data brokers or advertising networks. However, under the California Consumer Privacy Act (CCPA), you possess the absolute right to formally direct us not to sell or share your data. To execute this command in our system, email us with the subject line "DO NOT SELL".
04. Breach SLA & Data Sunset Protocol
- » Breach Notification: Guaranteed notification to the Data Controller within 72 hours of incident verification in the event of unauthorized access.
- » Sunset Purge: Upon contract termination, your isolated container is held in a suspended cold-storage state for 30 days to allow for data extraction, after which it is mathematically purged and overwritten.
- » Cookie Consent: We deploy active, physical cookie banners requiring explicit opt-in for tracking analytics per EU law.