Legal Changelog

Narrowed the international-transfers section after moving our application hosting to London.

• Application hosting moved to Vercel's London region; the database and its backups already ran in Ireland. Section 10 now states both locations explicitly.
• Section 10 previously listed Vercel alongside Stripe, Resend and Anthropic as processors that may process data outside the UK/EEA. It now names those three, and separately notes that Vercel's global edge network and operational logging may still route or store limited technical data outside the UK and EEA.
• No sub-processor was added or removed, and no change to what data is processed, why, or how long it is kept. The revision reduces the transfers we make rather than expanding them.

Published the DPA we hold with each sub-processor, and named a contact for procurement reviews.

• Added a "DPA" column to the sub-processor table, linking each vendor's publicly available Data Processing Agreement (Supabase, Vercel, Stripe, Resend, Anthropic).
• Stated that we hold a countersigned DPA on file with every sub-processor listed, meeting Article 28 UK GDPR requirements.
• Added hello@trustalma.com as the contact for enterprise customers who need copies for procurement review.
• Transparency only - no change to who processes your data, what they process, or why.

Documented how the kiosk recognises returning donors by phone or name, what data is matched and the safeguards we apply.

• Added a new section 5b describing the donor recognition feature in plain English.
• Listed the safeguards in place: per-charity isolation (no cross-charity searching), on-screen privacy mode (only first name + surname initial + masked postcode shown), donor escape hatch ("This isn't me"), rate limiting, and a minimised set of fields returned to the kiosk.
• Added the recognition lookup as a named example under the legitimate-interests bullet in section 4.
• Filed a written Legitimate Interests Assessment internally and referenced it from the policy.
• No change to how donor data is processed operationally - this is a transparency update making explicit something the product was already doing.

Initial published version of the Trust Alma legal pack. All charities active before this date are recorded as accepting a baseline pack labelled "legacy-pre-2026-04-16".

• Established Terms of Service, Privacy Policy and Data Processing Agreement as the formal legal pack covering use of Trust Alma.
• Introduced an audit trail recording the date, name, email and IP of the person who accepted the legal pack on behalf of each charity.