// DATA PROCESSING · v1 · LAST UPDATED 2026-05-12

Data Processing Agreement

Last updated: 2026-05-12

A signed DPA is available on request. The summary below describes the operative DPA terms.

1. Scope

This Data Processing Agreement ("DPA") applies to all processing of customer personal data by Sovereign Hybrid Compute LLC in connection with the provision of our infrastructure services.

2. Roles

The customer is the Data Controller. SHC acts as a Data Processor, processing data only as necessary to provide the contracted services.

3. Processing Activities

SHC processes data exclusively for the purpose of:

  • Provisioning and maintaining infrastructure services
  • Account management and billing
  • Security monitoring and incident response
  • Technical support when initiated by the customer

4. Data Access

SHC does not access customer data stored on VPS instances or colocation servers. Server contents are encrypted at rest and are inaccessible to SHC personnel without customer authorization.

5. Sub-Processors and Payment Processors

SHC does not use sub-processors for the storage or processing of customer data on our infrastructure. All compute and storage infrastructure is owned and operated by SHC.

There is no third-party payment processor. Bitcoin is the only money SHC accepts — no cards, no wire transfers, no ACH, no fiat rails — so no payment intermediary exists to share data with.

  • BTCPay Server — Self-hosted by SHC on SHC-owned infrastructure for Bitcoin and Lightning payments. Not a third party, not a sub-processor, and no personal data leaves SHC infrastructure to process a payment.

A payment rail that carries a bank or cardholder name is a rail that creates records somebody can later be compelled to produce. SHC does not run one.

6. Security Measures

Technical and organizational measures are detailed in our Security Overview. These include encryption at rest and in transit, access controls, monitoring, and incident response procedures.

7. Data Breach Notification

In the event of a data breach affecting customer data, SHC will notify the affected customer within 72 hours of becoming aware of the breach, including details of the breach, data affected, and remediation steps taken.

8. Data Deletion

Upon termination of services, customer data is retained for 30 days to allow retrieval. After 30 days, all data is permanently and irrecoverably deleted from our systems, including backups.

9. Audit Rights

Customers may request information about our data processing practices and security measures. On-site audits may be arranged with reasonable notice. Contact compliance@sovereignhybridcompute.net to initiate an audit request.

─── Diff against previous version · Last updated 2026-05-12