Enterprise Security Packet
1. Company Overview
CAIRL is a privacy-first identity verification platform operated by reAPPlicate Incorporated, a Florida corporation. The platform provides:
- Identity verification using government-issued documents and biometric matching
- Secure encrypted document storage
- OAuth 2.0-based verification claims delivery (PKCE enforced, no raw PII exposure)
- Proxy email services (CAIRL/mail)
- Passkey-first authentication (CAIRL/keys)
CAIRL provides verification signals and infrastructure, not legal identity certification. CAIRL does not act as a financial intermediary, data broker, or custodian of funds.
2. Data Handling Model
2.1 Data Minimization
CAIRL is designed to collect only the data necessary to verify identity, prevent fraud, and provide authorized services.
2.2 Claims-Based Architecture
Connected services receive verification claims only (e.g., "age_18_plus: true", "identity_verified: true"). No raw identity documents, biometric data, or full personal details are shared with connected services unless explicitly authorized by the user through a comparison claim.
CAIRL APIs do not expose raw identity documents or biometric data to connected services.
Claims are generated per request and are not reused across services without user authorization.
2.3 Pairwise Identifiers
Each integration receives a unique, non-correlatable identifier (HMAC-SHA256) for each user. Raw user IDs never leave the CAIRL platform. This prevents cross-platform user correlation.
2.4 Biometric Data Handling
| Attribute | Detail |
|---|---|
| Collection trigger | User-initiated identity verification |
| Consent mechanism | Explicit UI consent screen, separate from ToS acceptance |
| Processor | AWS Rekognition (under CAIRL control and instruction) |
| AWS model training | AWS processes biometric data solely on CAIRL's behalf and under its instructions. CAIRL does not permit the use of this data for model training. |
| Session data retention | Not retained beyond what is required to complete the session |
| Biometric reference (embedding) | May be retained for uniqueness enforcement and fraud prevention |
| Encryption | AES-256 at rest |
| Deletion trigger | Account closure, deletion request, or consent withdrawal |
| Deletion timeline | Within 30 days of trigger event |
| Sale/sharing | Not permitted and not part of CAIRL's data processing practices |
| Use for tracking/profiling | Not permitted and not part of CAIRL's data processing practices |
| Use for AI/ML training | Not permitted and not part of CAIRL's data processing practices |
3. Infrastructure
3.1 Architecture
| Component | Provider | Purpose |
|---|---|---|
| Application hosting | Vercel | Edge-distributed hosting with DDoS protection |
| Cloud infrastructure | AWS | Compute, storage (S3), identity verification (Rekognition, Textract), serverless (Lambda) |
| Database | PostgreSQL (Supabase) | Primary data store |
| Caching / rate limiting | Upstash Redis | Session management, rate limiting, abuse prevention |
| Bot protection | Cloudflare | Turnstile challenge on sensitive flows |
| Payments | Stripe | Billing, subscription, wallet management |
| Bank linking | Plaid | Bank account verification |
| Mailgun | Transactional email and proxy relay (CAIRL/mail) | |
| Phone verification | Twilio | OTP delivery and phone number verification |
3.2 Environment Isolation
| Environment | Database | Storage | URL |
|---|---|---|---|
| Development | cairl-dev | cairl-dev-documents | localhost / Vercel preview |
| Staging | cairl-staging | cairl-staging-documents | staging.cairl.app |
| Production | cairl-production | cairl-production-documents | cairl.app |
Development, staging, and production environments are fully isolated with separate databases, storage buckets, credentials, and access controls. No development data touches production systems.
3.3 Shared Responsibility
Underlying infrastructure providers (AWS, Vercel) operate under a shared responsibility model. CAIRL secures application-layer systems and access controls, while providers secure the underlying cloud infrastructure.
4. Encryption
| Layer | Standard | Detail |
|---|---|---|
| Data at rest | AES-256 | All stored data including documents, biometric references, and database records |
| Data in transit | TLS 1.3 | All connections between client, server, and third-party services |
| Key management | Dedicated KMS | Strict access controls, automatic rotation |
5. Access Controls
5.1 Internal Access
| Control | Implementation |
|---|---|
| Access model | Role-based access control (RBAC) |
| Privilege | Least privilege — minimum access required for task |
| Authentication | Multi-factor authentication required for all staff with data access |
| Logging | All access to user data is logged |
| Audit | Subject to periodic review |
| Data access scope | Need-to-know only — support, technical resolution, fraud investigation, legal compliance |
5.2 User Access
| Control | Implementation |
|---|---|
| Password storage | Secure hash (never plain text) |
| Primary authentication | Passkey-first (WebAuthn) with password fallback |
| Session management | Scoped, time-limited, revocable |
| Consent enforcement | Platform-level — connected services cannot bypass user consent |
6. Application Security
| Control | Implementation |
|---|---|
| OAuth | PKCE with S256 enforcement on all flows |
| CSRF | Protection on all state-changing operations |
| Rate limiting | All sensitive and user-data endpoints |
| Token model | Short-lived, scoped tokens for integration endpoints |
| Bot protection | Cloudflare Turnstile on verification and login flows |
| Identifier isolation | Pairwise HMAC-SHA256 — no raw user IDs exposed to connected services |
7. Incident Response
CAIRL maintains internal incident response procedures covering:
- Detection — Monitoring and alerting on anomalous access patterns
- Containment — Isolation of affected systems and credentials
- Remediation — Root cause analysis and patching
- Post-incident review — Documentation and process improvement
Incident response procedures are tested periodically as part of internal security practices.
Breach Notification
| Obligation | Detail |
|---|---|
| User notification | As required by applicable law, without unreasonable delay |
| Controller notification (DPA) | Within 72 hours of becoming aware of the breach |
| Regulatory notification | As required by applicable federal and state law |
| Content | Nature of breach, data types affected, approximate scope, mitigation steps |
8. Compliance Posture
| Framework | Status | Detail |
|---|---|---|
| SOC 2 Type II | In preparation | Actively preparing for first formal audit engagement |
| GDPR | Active | Data controller / processor hybrid model. Consent (biometric) and legitimate interest (service delivery) as legal bases. SCCs in place for international transfers. |
| CCPA | Active | No sale of personal data. Authorized agent support. Non-discrimination. |
| BIPA (Illinois) | Active | Explicit consent, published retention/destruction schedule, deletion on request, private right of action acknowledged |
| Texas CUBI | Active | Biometric consent and deletion practices in place |
| Washington | Active | Biometric identifier practices in place |
| COPPA | Active | Guardian-managed participation for minors through circles with verifiable parental consent |
| HIPAA | Not applicable | CAIRL is not a covered entity or business associate unless explicitly contracted under a BAA |
CAIRL does not claim certification until audits are complete and the auditor's report is received.
9. Payments
| Attribute | Detail |
|---|---|
| Payment processor | Stripe |
| Card storage | CAIRL does not store full card numbers |
| Financial role | Not a financial intermediary, payment processor, or custodian of funds |
| Wallet | Prepaid service balance only — not a deposit account or stored value instrument |
10. Data Retention
| Data Type | Retention | User Control |
|---|---|---|
| Raw identity documents | Until user deletes or account closure + 30 days | User-deletable subject to applicable legal, security, and fraud prevention requirements |
| Biometric session data | Duration of verification session only | Ephemeral |
| Biometric reference (embedding) | Until deletion request or account closure + 30 days | User-deletable subject to applicable legal, security, and fraud prevention requirements |
| Verification records | Up to 7 years (regulatory/audit/fraud) | Cannot be deleted due to legal retention |
| Usage logs | 90 days | Automatic expiry |
| Account information | Until account deletion | User-deletable |
| Proxy email metadata | 90 days | Automatic expiry |
11. Third-Party Subprocessors
| Subprocessor | Purpose | Role | Location |
|---|---|---|---|
| AWS | Infrastructure, Rekognition, Textract, Lambda, S3 | Data processor / subprocessor | United States |
| Stripe | Payments and billing | Data processor | United States |
| Vercel | Hosting and content delivery | Data processor | United States (global edge) |
| Plaid | Bank account verification | Data processor | United States |
| Mailgun | Email delivery and proxy relay | Data processor | United States |
| Cloudflare | Bot protection (Turnstile) | Data processor | United States (global edge) |
| Upstash | Rate limiting and caching | Data processor | United States |
| Twilio | Phone verification (OTP delivery) | Data processor | United States |
| Supabase | Primary database (PostgreSQL) | Data processor | United States |
All subprocessors operate under contractual and security obligations consistent with CAIRL's Privacy Policy and Data Processing Agreement. CAIRL remains responsible for the performance of its subprocessors. Material subprocessor changes are communicated with 30 days' notice.
12. Available Documentation
| Document | Location |
|---|---|
| Privacy Policy | cairl.app/legal/privacy |
| Terms of Service | cairl.app/legal/terms |
| Security Overview | cairl.app/security |
| Cookie Policy | cairl.app/legal/cookies |
| Refund Policy | cairl.app/legal/refund |
| Acceptable Use Policy | cairl.app/legal/acceptable-use |
| Data Processing Agreement | cairl.app/legal/dpa |
| Trust Center | cairl.app/trust |
13. Contact
| Purpose | Contact |
|---|---|
| Enterprise security inquiries | security@cairl.app |
| Legal and DPA inquiries | legal@cairl.app |
| Privacy and data rights | privacy@cairl.app |
| General | info@cairl.app |
Address: reAPPlicate Incorporated, 3200 NW 62nd Avenue #22, Margate, FL 33063