A public summary of Infinihash's Records of Processing Activities (RoPA), in the spirit of GDPR Article 30. One row per activity: what data, why we touch it, what lets us, how long we keep it, and who else sees it.
Subprocessor names link to the full list and regions on the Trust Center rather than duplicating it here.
| Activity | Data categories | Purpose | Legal basis | Retention | Subprocessors |
|---|---|---|---|---|---|
| KYC identity verification | Identity documents, biometric/selfie images, extracted PII (name, DOB, document number, address) | Verify tenant end-customers to satisfy BSA/AML obligations | Legal obligation / Contract | ~7 years for BSA-eligible records (see /privacy) | AWS, Google (Gemini — document extraction). Not Anthropic: Claude is used only for AML narrative text and never receives document images. |
| KYT wallet screening | Wallet addresses, transaction hashes, chain identifiers, risk-decision metadata (pseudonymous on-chain data, not directly identifying on its own) | Sanctions screening and transaction monitoring for regulated counterparties | Legal obligation / Contract | ~5 years for audit trails, then anonymized (see /trust) | AWS, Cloudflare |
| Account & signup data | Email, name, organization, role, password hash, login IP | Provision and operate Infinihash accounts across products | Contract | Deleted within 30 days of account closure, except legal hold | AWS, Resend |
| Rails / BaaS tenant onboarding (KYB) | Business identifiers (legal name, entity type, tax identification number, incorporation and operating addresses, description, website); beneficial-owner and control-person personal data (name, date of birth, residential address, personal tax identification number, government-ID images); source-of-funds answers | Verify the business and its owners before it can transact, as required by the regulated payments partner and by BSA/AML rules | Legal obligation / Contract | Owner personal data and ID images are not retained by Infinihash — they stream through to the partner. Business-level identifiers and status are retained on the application record. | Bridge (regulated payments partner), Persona (Bridge's identity-verification vendor), AWS |
| Rails / BaaS settlement | Invoice and payer details, ACH collection instructions, destination wallet address and chain, amounts, screening and decision metadata | Collect a USD invoice and settle it as stablecoin to the tenant's own wallet, with sanctions screening of the destination wallet before any conversion | Contract / Legal obligation | Retained with financial and AML records; screening results follow the KYT retention above | Bridge, AWS, Cloudflare |
| Website analytics | Visitor IP address, cookie identifiers, pages viewed, referrer | Understand how visitors use the marketing site | Consent | Per Google Analytics retention settings; not linked to product accounts | Google (Analytics, Fonts), Cloudflare |
| Billing | Stripe customer ID, last-4 card digits, invoice and subscription history | Charge for and administer paid subscriptions | Contract | Per Stripe's own retention as payment processor; invoice records kept for financial recordkeeping | Stripe |
| Support correspondence | Email content, account identifiers referenced in a ticket, attachments the requester chooses to send | Respond to support and account requests | Contract / Legitimate interest | Retained for the life of the support relationship, then trimmed with other operational data | Resend |
| Security logging | IP addresses, request paths, response codes, auth events, error traces | Detect abuse, fraud, and security incidents; operational health | Legitimate interest | 90 days, then aggregated (see /privacy) | AWS, Cloudflare |
