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Supplier and Subprocessor Management

Version
1.0
Owner
Founder
Approved by
Murilo Martins (Founder) · 09/28/2026
Next review
2027-09-28 (annual or on significant change)
Scope
Every third party that hosts, processes or can access SemantiqWall systems or data, and the software supply chain (open-source dependencies).

1. Supplier inventory

Supplier Purpose Data it can access Location Status
Hostinger VPS hosting (compute, disk, network, datacenter) All platform data, logs and backups Datacenter location to be confirmed Active - subprocessor
Resend Transactional e-mail (watch-list confirmation and vendor alerts) Recipient e-mail, name and message content Region sa-east-1 (São Paulo) Active - subprocessor
GoDaddy (Titan Mail) Company mailbox contato@semantiqwall.com Messages sent to us (support, privacy and security requests) To be confirmed Active - subprocessor
GitHub Private source code repository; deploy key; SemantiqWall GitHub App for customers who install it Our code; for App users, the files the customer allows and the pull requests we open United States Active - supplier; subprocessor only for GitHub App users
Anthropic AI provider for optional case triage and remediation proposals Case summary and evidence text, agent description, up to 4 files of the customer's code United States Optional - used only when configured
Meta (WhatsApp Cloud API) Optional approval messages Approver phone number, approval message Meta infrastructure Disabled
Certificate authorities (ACME, via Caddy) TLS certificates Domain names only - Active
Domain registrar semantiqwall.com registration and DNS DNS records - Registrar to be confirmed
Open-source packages (Composer, npm) Application and SDK dependencies None at runtime beyond the code itself - Pinned in lock files

The public list of subprocessors is kept in the privacy policy and updated before a new subprocessor starts receiving personal data. Customers can object by writing to contato@semantiqwall.com.

2. Shared responsibility with suppliers

Area Supplier is responsible for SemantiqWall is responsible for
Hosting (Hostinger) Datacenter physical and environmental security, hardware, hypervisor, network up to the VPS, media disposal Everything inside the VPS: OS hardening and updates, firewall, SSH, application, database, backups, encryption, monitoring
E-mail (Resend, Titan) Delivery infrastructure and security of their platforms Account MFA, API key protection, content we send, domain authentication records
Code hosting (GitHub) Platform security Repository access, MFA, deploy keys, App permissions (least privilege: contents, pull requests, metadata)
AI provider Model hosting and their data handling commitments Sending only the minimum, treating output as untrusted, never letting AI decide allow/deny, turning the feature off if terms change

3. Selecting a new supplier

Before a supplier receives customer or personal data, the Founder checks and records in the security register:

  1. purpose and the minimum data needed;
  2. security evidence - SOC 2 or ISO 27001 report or a public security page;
  3. data processing terms, including international transfer clauses when outside Brazil, breach notification and subprocessors;
  4. data location and retention;
  5. MFA available on the account;
  6. how to leave: export and deletion.

A supplier handling customer data with no security evidence needs an exception (policy 00).

4. Requirements for suppliers

Suppliers must keep customer data confidential, use it only to provide their service to SemantiqWall, notify us of breaches affecting our data, and delete it at the end of the service. For today's suppliers these obligations come from their standard online terms, which are accepted rather than negotiated.

5. Review

6. Software supply chain