Enterprise Privacy Policy & Data Security Directive
NEXTRACE GLOBAL, INC. RESPECTS INSTITUTIONAL TRADE PRIVACY, DEFENSE PRIME SECRECY, AND EXPORT CONTROL CONFIDENTIALITY. THIS DIRECTIVE GOVERNS HOW SCREENED COUNTERPARTY DATA, BENEFICIAL OWNERSHIP TREES, SUPPLY CHAIN LINEAGES, MULTI-JURISDICTION SANCTIONS MATRICES, SEC EDGAR INGESTS, AND WORM AUDIT CERTIFICATES ARE PROCESSED, PURGED, ENCRYPTED, AND STATUTORILY RETAINED.
1.0 Institutional Privacy Commitment & Scope
NexTrace Global, Inc. ("NexTrace", "Company", "we", "us") delivers high-assurance, defense-grade corporate graph screening, supply chain lineage tracing, and export control coprocessing to regulated exporters, defense prime contractors, financial institutions, and global freight forwarders. Unlike commercial data brokers, NexTrace operates under strict business-to-business confidentiality covenants. We do not track users across the public web, deploy third-party advertising cookies, or commercialize search queries.
This Privacy Policy applies to all services provided across our digital infrastructure, including:
- The Nextrace Web Application and Screening Sandboxes (
https://nextraceglobal.com) - REST API endpoints (
/api/v1/screen,/api/v1/defense-shield/*,/api/v1/edgar/*,/api/v1/sanctions/*,/api/v1/audit/*) - ERP Compliance Pre-Check Webhook Integrations (
/api/v1/webhooks/erp-pre-check) - Inbound SMTP Mail Gateway and Email Webhooks (
/api/v1/webhooks/email/*, port 25/2525) - FastMCP and Model Context Protocol screening coprocessors
2.0 Categories of Ingested and Processed Compliance Data
In providing automated multi-jurisdiction trade and sanctions screening, we process the following specialized categories of data:
3.0 The "Context Economy" Protocol & Zero-LLM Privacy Guarantee
NexTrace enforces an automated Context Economy Protocol (backend.app.engine.context_cleaner and edgar_engine.py) to minimize data exposure and prevent context poisoning:
✓ Data Minimization: When resolving corporate structures from SEC EDGAR filings or commercial registries, our ingestion pipeline deterministically strips all raw HTML tags, styling blocks, embedded scripts, filing wrappers, and administrative debris before storage or analysis.
✓ Essential Graph Topology Only: We store solely the mathematical minimum required for deterministic NetworkX calculations: normalized entity ID, canonical legal name, sovereign jurisdiction ISO, equity percentage (equity_pct), and board control attributes.
✓ Zero-LLM Deterministic Guarantee: In accordance with Workspace Directive 1, corporate graph walks, ownership cascading, and OFAC 50% Rule determinations are computed deterministically in Python using NetworkX algorithms. Customer query entities and proprietary supply chains are NEVER transmitted to external Large Language Model (LLM) APIs (such as OpenAI, Anthropic, or public AI providers) for compliance calculations, and are NEVER used to train machine learning models.
4.0 Inbound Email & Webhook Ephemeral Processing (Zero-Retention Mode)
For customers utilizing our Inbound SMTP Gateway (ports 25/2525) or email webhook handlers (Postmark/Resend) for automated shipment clearance:
- In-Memory Compliance Extraction: Inbound message bodies and MIME attachments are parsed ephemerally in RAM to extract counterparty names, ECCN classifications, and destination countries.
- Immediate Deletion in Zero-Retention Mode: Once the screening verdict is computed and dispatched to the customer's ERP or compliance desk, the raw email body and attachments are permanently purged from memory and are never written to disk, unless Customer explicitly enables the Enterprise Extended Recordkeeping Vault.
- Encrypted Transport: All inbound mail streams require opportunistic or mandatory TLS encryption (STARTTLS) to protect transaction payloads against interception.
5.0 Statutory 5-Year WORM Retention (EAR § 762 & FRE 902(13))
5.1 Mandatory Federal Recordkeeping: Under 15 CFR § 762.6 (Export Administration Regulations) and 31 CFR § 501.601 (OFAC Recordkeeping), all records relating to export transactions, restricted party screenings, and beneficial ownership evaluations must be preserved for a mandatory period of five (5) years.
5.2 WORM Merkle Vault & Electronic Admissibility: Audit certificates generated across our platforms (Sanctions Clearance, Defense Shield CBP Form 28, and SEC EDGAR UBO Certificates) are anchored to an immutable Write-Once-Read-Many (WORM) Merkle tree ledger and sealed with a SHA-256 digital stamp. These records constitute self-authenticating electronic business records under Federal Rules of Evidence 902(13) and 902(14).
5.3 Caching Lifecycles: Dynamic registry lookup caches operate on a strict 14-day Time-To-Live (TTL) in isolated Redis instances. Expired cache trees are automatically purged.
6.0 Technical Safeguards & Multi-Tenant Security
NexTrace implements physical, administrative, and technical safeguards engineered for high-consequence enterprise environments:
- FIPS 140-2 Validated Encryption: All database storage volumes, WORM Merkle archives, and backups are encrypted at rest using AES-256.
- Transport Layer Security: All external API communications require TLS 1.3 with forward secrecy cipher suites.
- Multi-Factor Authentication (MFA): Administrative and customer control centers enforce mandatory TOTP / WebAuthn MFA with automated account lockouts.
- Multi-Tenant Row-Level Security: Customer screening data is partitioned using unique UUID tenant keys, preventing cross-tenant data leakage or horizontal IDOR vulnerabilities.
- HMAC Webhook Signatures: Outgoing ERP order-gating webhooks are signed with HMAC-SHA256 headers to ensure message authenticity.
7.0 Cross-Border Data Transfers & Global Compliance
While the Platform's core processing is hosted in secure U.S. data centers, we maintain compliance protocols for international allied customers:
- EU GDPR & UK Data Protection Act: Cross-border transfers of European corporate entity queries or individual officer names are governed by EU Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum.
- Swiss Federal Act on Data Protection (FADP): Screening data originating from Switzerland is processed in full compliance with revised Swiss FADP requirements.
- Middle East & UAE Free Zones: Screenings routed through Dubai (DIFC) or Abu Dhabi (ADGM) comply with DIFC Data Protection Law No. 5 of 2020 and UAE Federal Decree-Law No. 45/2021.
- California Consumer Privacy Act (CCPA / CPRA) & U.S. State Rights: NexTrace strictly collects only business-to-business identifiers (corporate email, account credentials, IP address) solely to provision screening services and maintain statutory compliance records under 15 CFR § 762. ZERO SALE OR SHARING: NexTrace does not sell, rent, or share personal information with third parties for commercial or cross-context behavioral advertising. Deletion requests are honored subject to mandatory statutory federal retention duties under 15 CFR § 762.6 and 31 CFR § 501.601.
8.0 Law Enforcement, Subpoena, & National Security Inquiries
NexTrace will not disclose Customer screening records or supply chain BOMs to third parties except where strictly mandated by applicable federal statute:
In the event NexTrace receives a formal subpoena, national security letter, or court order from the U.S. Department of Justice (DOJ), BIS Office of Export Enforcement (OEE), OFAC, or U.S. Customs and Border Protection (CBP), NexTrace will provide prompt advance notice to Customer prior to disclosure, unless explicitly prohibited from doing so by a statutory non-disclosure order issued by a federal court of competent jurisdiction.
9.0 Data Subject Rights & CISO / DPO Contact
Enterprise customers may request audit log verification, submit data correction requests, or report security vulnerabilities by contacting our Chief Information Security Officer (CISO) and Data Protection Officer at: