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| Original file line number | Diff line number | Diff line change |
|---|---|---|
| @@ -0,0 +1,47 @@ | ||
| # Rybbit transfer documents | ||
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| This directory contains a counsel-ready draft of Rybbit's EU transfer package. | ||
| It is not legal advice and is not executed merely because it exists in the | ||
| repository. | ||
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| ## Files | ||
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| - `rybbit-eu-scc-addendum.md` — prefilled Module Two/Module Three SCC completion | ||
| schedule, Annexes I–III, and signature blocks. | ||
| - `rybbit-eu-scc-addendum.docx` — Word version generated from the Markdown draft. | ||
| - `source/eu-standard-contractual-clauses-2021-official.doc` — unmodified | ||
| English Annex containing the European Commission's official SCC text. | ||
| - `source/eu-scc-implementing-decision-2021-official.doc` — unmodified English | ||
| Commission Implementing Decision downloaded with the SCCs. | ||
|
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| Official source: | ||
| https://commission.europa.eu/publications/publications-standard-contractual-clauses-sccs_en | ||
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| SHA-256 checksums at download time: | ||
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| - SCC Annex: `beb2e873edd0d34edc8c5eca5b688e5d51cb6e6f63d4f7759333a6a26f8bd1de` | ||
| - Implementing Decision: `29a194e32353edfba0ad5d74fa1cd595e4ea39a22f7a4664cdafa9fd4f3e3f1c` | ||
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| ## Required before execution or publication | ||
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| 1. Have privacy counsel confirm whether Rybbit's relevant processing falls | ||
| within GDPR Article 3(2), because the 2021 international SCCs are not designed | ||
| for an importer whose relevant processing is already directly subject to the | ||
| GDPR. | ||
| 2. Decide whether Tomato.gg LLC will certify under the EU-U.S. Data Privacy | ||
| Framework and, if so, update the transfer-mechanism language. | ||
| 3. Reconcile the post-termination deletion promise: the current DPA says 30 | ||
| days; the current Terms and Security page say 60 days. | ||
| 4. Confirm that each security statement in Annex II matches production, | ||
| especially encryption at rest, backup handling, employee training, and | ||
| deletion propagation. | ||
| 5. Confirm the complete subprocessor inventory, legal names, processing | ||
| locations, transfer mechanisms, and contracts. In particular, confirm | ||
| OpenRouter/model-provider coverage and Stripe's role. | ||
| 6. Update the Terms so the DPA and SCC Addendum are expressly part of the | ||
| Agreement and establish an order of precedence. | ||
| 7. Add a binding acceptance mechanism or obtain signatures. Publishing an | ||
| unsigned document alone does not execute the SCCs. | ||
| 8. Complete and retain a transfer impact assessment for any transfer relying on | ||
| the SCCs. | ||
|
|
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📐 Maintainability & Code Quality | 🟠 Major | ⚡ Quick win
🔎 Supported by static analysis
🏁 Script executed:
Repository: rybbit-io/rybbit
Length of output: 33927
🏁 Script executed:
Repository: rybbit-io/rybbit
Length of output: 22160
🏁 Script executed:
Repository: rybbit-io/rybbit
Length of output: 45490
🏁 Script executed:
Repository: rybbit-io/rybbit
Length of output: 28162
Correct the IP-retention disclosure and localize it.
trackIpcan enable raw IP storage. The tracker writespv.ipAddressto the database when this setting is enabled. Replace the unconditional “never stored” claim with the default behavior and the customer opt-in behavior.const t = useExtracted()and add its translation key.🤖 Prompt for AI Agents
Source: Coding guidelines