GDPR Everywhere

IronShard is GDPR compliant. That covers the whole service, not only the way files are stored: how the company behind it handles personal data, the agreement it gives you, the suppliers it uses, where data is processed, and the storage design itself. This page sets out each part and links to the legal document behind it.

The Whole Service, Not Only Storage

IronShard is operated by Chocolate Cloud ApS, a Danish company supervised by the Danish Data Protection Agency (Datatilsynet). It meets its GDPR obligations in both of the roles it holds:

As controller, for the data it needs to run the service, such as account, usage, and network data. The Privacy Policy sets out what is collected, the legal basis for each purpose, how long it is kept, and how to exercise your rights.
As processor, for the personal data you store. The Data Processing Agreement meets Article 28 and applies automatically when you accept the Terms of Service. No signature is needed.

GDPR requirement	How IronShard meets it
Processor agreement (Article 28)	The Data Processing Agreement applies to every customer who stores personal data, with documented instructions, confidentiality, and assistance duties.
Sub-processors (Article 28(2) and (4))	A published list with each sub-processor's purpose and location, and 30 days' notice before one is added or replaced.
Security of processing (Article 32)	AES-256 encryption, erasure-coded fragments spread across independent storage providers, keys held separately in Frankfurt, TLS 1.2 or higher in transit, staff access limited by role, and request logging.
International transfers (Chapter V)	The EU-US Data Privacy Framework where the recipient is certified, the adequacy decisions for the United Kingdom and Canada, and otherwise Standard Contractual Clauses with a transfer impact assessment.
Breach notification (Article 33)	Customers are notified without undue delay, where possible within 48 hours of IronShard becoming aware.
Data subject rights (Chapter III)	Requests about data IronShard controls go to contact@ironshard.ai. For content you store, you act through the service's own listing, retrieval, and deletion, and IronShard assists.
Erasure	Fragments are deleted from storage providers within 30 days of an object being deleted. Remaining content and keys are deleted within 30 days of termination.
Audits (Article 28(3)(h))	The information needed to demonstrate compliance, including the Trust Center, and an audit right once a year.
Tracking	No cookies and no advertising or tracking technologies on the website, console, or API.

Where Data Is Processed

Encryption keys, bucket and object identifiers, logs, and account records are processed in Frankfurt, Germany. Content passes through IronShard's gateways before it is encrypted and split. The gateways operate in Amsterdam, Frankfurt, Stockholm, London, Toronto, Ashburn, Chicago, and Los Angeles. Your content can pass through some of them.

Your Responsibilities

You remain the controller of the personal data you store. Having a legal basis for it, informing the people it concerns, and answering their requests are yours to do. IronShard being GDPR compliant gives you a compliant processor and the agreement, records, and controls that go with one. It does not by itself make your own processing compliant.

A Cloud Provider-Independent Privacy Model

Instead of relying on the privacy policy of any single cloud provider, IronShard applies a sovereignty layer above them. Every object stored in IronShard is transformed into encrypted fragments and dispersed across multiple storage providers and geographic regions. Each provider holds fewer encrypted fragments than it takes to reconstruct an object, never a complete file. On their own, these fragments reveal nothing and cannot be reconstructed or interpreted.

This design guarantees that:

No individual provider can ever rebuild a full file, even with full access to their infrastructure.
No single storage provider or storage region sees raw personal data, removing accidental residency violations.
Protection does not depend on where buckets live; IronShard enforces it independently of the underlying storage.
GDPR-regulated data can safely span multi-cloud and cross-border architectures, without exposing file contents or breaching local restrictions.

It is IronShard's assessment, supported by external legal advice, that fragments held by an individual storage provider are not personal data for that provider, because identifying anyone from them is practically impossible. That is why storage providers are not sub-processors.

Data Sovereignty Through Fragmentation

Traditional storage systems tie GDPR obligations to physical location. IronShard flips the model: protection comes from how data is stored, not where. Because encrypted fragments are meaningless individually, underlying providers cannot inspect, extract, or infer anything about the file.

This makes it possible to use:

Global cloud regions
Mixed cloud providers

…without putting personal or regulated data at risk.

The Coordination Layer That Supports Your Compliance

IronShard coordinates access, reconstruction, and policy enforcement through its own coordination layer.

Storage providers remain passive fragment hosts: they never participate in reassembly, governance, or inspection.

The result is a system where:

Providers only hold encrypted, partial fragments
IronShard alone orchestrates policies, access decisions, and fragment retrieval
Data is reconstructed only for authorized users inside the governed environment

This architecture is what lets IronShard be GDPR compliant everywhere, even in storage configurations that would otherwise raise residency or access questions.

Why This Matters

Organizations can finally modernize their storage strategy (e.g., multi-cloud, global, cost-optimized) without compromising privacy obligations. IronShard keeps your data protected and aligned with your obligations across:

Borders
Providers
Infrastructures
Future regulatory shifts

Your data stays yours. Your obligations stay covered. Your storage options stay wide open.