Records of processing
GDPR Art. 30(2) requires the processor to keep a record of the categories of processing it carries out on behalf of each controller. This page is that record for Cowliss, stated once and applicable per tenant organization.
Processor: Capital Enesti Inc., registered in Canada at 1185 rue De Bougainville, Saint-Bruno-de-Montarville (Québec) J3V 3E8. NEQ 1181686743. Contact: [email protected].
Controller: each organization holding a Cowliss workspace.
Categories of processing, per tenant
Section titled “Categories of processing, per tenant”| Category of processing | Personal data |
|---|---|
| Profile and trait storage | User identifiers, traits, email addresses |
| Event stream storage | Event names, properties, timestamps, anonymous and identified IDs |
| Identity resolution | Links between a profile’s identifiers |
| Consent state | One answer per purpose on each profile, kept per app, and revocation events |
| Segmentation | Predicate evaluation over traits and event history |
| Automation execution | Per-user workflow state, timers, step history |
| Email delivery | Recipient address, rendered message, delivery, bounce and complaint status |
| Webhook delivery | Event payloads to the controller’s webhooks |
| Suppression | Suppressed addresses and reasons |
| Usage metering | Aggregate counts (events, emails, webhooks, automation runs) and wallet balance |
| Team accounts | The controller’s team members: names, emails, roles |
Consent is kept per app, on the profile. A profile answers two fixed roots, marketing and transactional, and the named purposes its own app declares under them. A marketing purpose is off until the controller records a yes. A named transactional purpose is on until the recipient or the controller turns it off. Bare transactional mail, such as a receipt or a password reset, is service mail that no recipient can withhold.
Transfers, retention, security
Section titled “Transfers, retention, security”- Transfers: to Capital Enesti Inc. in Canada under the EU adequacy decision for Canada (commercial organizations subject to PIPEDA). Subprocessor hosting locations are on the subprocessor list.
- Retention: the controller configures event retention per organization; profiles and state persist until erasure or termination.
- Security: the measures in the DPA’s Annex B (Data processing agreement).