Questions from IT and data protection
Short answers to the questions IT leads and data protection officers ask before a rollout, with pointers to the authoritative documents.
These are the questions IT leads and data protection officers ask us most often. The answers are short and point to the page or document with the details.
Data and processing
No. Custodos does not train AI models on your data. It uses the models in the EU and Switzerland through the business services of AWS, Google Cloud and Microsoft Azure, whose terms rule out using customer input to train models.
In Switzerland. The application and its database, with chats, files, Company Brain and user accounts, run in Switzerland. Backups are encrypted before upload and stored in Zurich. See Where your data lives.
In the region your admins choose: "Switzerland", "European Union", "EU + Switzerland" (the default) or "Global". Models outside the region are not offered and are refused by the server. Every model shows where it runs. Admins also see whether the location is technically enforced, verified or committed by contract. See Where your data lives.
Content does only if your admins choose the "Global" processing region, which adds models without a residency commitment, for example at OpenAI in the USA. For paid use, a payment provider processing in the EU and the USA receives billing data, never chat, file or prompt content.
Connected accounts such as Outlook, Google Drive or Microsoft 365 are yours. Whatever Custodos saves there, a draft email for example, lives wherever your own account is hosted.
Yes. AWS, Google Cloud and Microsoft Azure belong to groups based in the USA. They run the models for Custodos in data centres in the EU and Switzerland, and the contracting parties are their European companies. Only the "Global" region adds models without a residency commitment. The backups at AWS are stored encrypted only, with no access to the plain text. Pseudonymisation is an additional safeguard: detected personal data reaches the model provider only as placeholders. The details are in annex 3 of the DPA (in German).
The full list, with registered office, service, data location and transfer basis, is in annex 3 of the DPA (in German) and in the privacy policy. Some are used only if you switch on the option concerned, such as the "Global" region. Custodos informs you of intended changes in advance, and you can object on important data protection grounds.
Account data (email address, name, roles), the content of your workspace (prompts, files, replies), usage and billing data without prompt content, and technical logs plus a log of administrative actions, both without prompt content. Depending on how you use it, the content can include any category of personal data, sensitive data included. For that content, your company is the controller and Custodos the processor.
As long as your admins decide. A retention period set per workspace is enforced every night; without one, chats stay until someone deletes them. Usage and billing data stays for ten years under the bookkeeping obligation. See Access, retention and deletion.
Contract and evidence
Yes. The DPA (in German) under Art. 28 GDPR and Art. 9 of the Swiss FADP is automatically part of the terms. It contains the technical and organisational measures (annex 2) and the subprocessors (annex 3). You can get a countersigned copy by writing to [email protected].
No. Custodos currently has no certification of its own under ISO 27001 and no SOC 2 report. It demonstrates compliance with the DPA through self-disclosure and the documented measures in annex 2. Where there is good reason, you can carry out further audits yourself or through an auditor bound to confidentiality, including on site with advance notice.
Custodos reports personal data breaches without undue delay after becoming aware of them, and supports you with your own notification duties. This is set out in section 7 of the DPA (in German).
No. Custodos provides the service with reasonable care but does not commit to a specific service level. Planned maintenance is announced in advance where possible. The availability of individual models also depends on their providers.
Yes, on request. Custodos provides an export of your workspace data before or at the end of the contract. After that the content is deleted, unless a statutory retention obligation applies.
Access and technical security
The person who writes a chat, and the members they share it with. Admins do not see the content of private chats. Shares only work for signed-in members of the same workspace, and there are no public links. The Custodos team does not join your workspace. See Access, retention and deletion.
In the database itself. Every table holding customer data is protected with row-level security, and the workspace is set afresh for each transaction, so a reused database connection cannot carry over another customer's context. Automated tests check the separation between customers continuously. The context cache at the model provider is also kept apart per workspace, with its own key.
All connections use TLS. The pseudonymisation link, stored provider keys and the access tokens of connected accounts are encrypted with AES-256-GCM. Backups are encrypted before upload. Chats and documents are not end-to-end encrypted, because Custodos has to read them to send them to the chosen model.
No. Server logs and the activity log hold only metadata, meaning who did what and when, never prompt content.
Yes. With Require SSO, every member must sign in with Google or Microsoft, and email sign-in links no longer work. Invitations can also be restricted to one domain. Other identity providers through SAML, and user provisioning through SCIM, are not supported at the moment. See Sign-in and access.
No. The application uses only functional cookies, for example for sign-in and the language setting. There are no trackers and no advertising or analytics cookies from third parties.
Personal data and professional secrecy
That depends on your own legal basis, and this page is not legal advice. For the content, your company remains the controller and must make sure it may process the data this way. Custodos processes it as a processor under the DPA and gives you the tools for it: pseudonymisation, the "Block" mode, security mode, the choice of region and a retention period.
Whether you may process such data, as a law firm, fiduciary or medical practice for example, is for you to assess; Custodos gives no legal advice on it. For especially sensitive conversations there is security mode: only the model your admins set, every detected detail pseudonymised without exception, no web search and no images. Choose a model for it in the region that meets your requirements. See Setting up security mode.
No. Custodos keeps the link between placeholder and real value in order to restore the reply. The data can therefore still be tied to a person. See How pseudonymisation works.