International Data Transfers

1. Overview

WorkTwins may use cloud-assisted systems and subprocessors located in countries other than the user’s country.

2. Transfer Principles

WorkTwins should:

• minimize data transferred;
• prefer derived WorkFootPrint features over raw evidence;
• use encryption in transit and at rest where applicable;
• use contractual safeguards with processors;
• maintain a subprocessor list;
• support user rights.

3. EU/UK Transfers

Where required, WorkTwins should use Standard Contractual Clauses, UK transfer mechanisms, or other appropriate safeguards.

4. LATAM Transfers

Brazil, Argentina, Mexico, Chile, and other jurisdictions may impose transfer requirements. These should be reviewed before launch in each market.

5. Cloud-Assisted Today, Decentralized Goal

WorkTwins currently uses cloud-assisted features where necessary. The long-term goal is decentralized, privacy-preserving matching.