Effective for the Threadkin research practice.

How Threadkin handlesthe materials you send.

A plain-language notice for the subjects and clients of a Threadkin engagement — what is held, why, for how long, who sees it, and the channel for asking us to do something about it.

Open intake Engagement tiers

Scope

This notice covers the practice — not the brokers.

Threadkin is the custodian of the materials produced during a research engagement. The data brokers, search engines, and record offices that Threadkin writes to on a subject's behalf each publish their own privacy notices — this document does not speak for them. Where a request travels outside Threadkin, that other party's notice applies from the moment of transfer.

What we collect

Only what is needed to open and run the engagement.

Intake brief — the four fields we ask you to send

Subject name — the person this engagement concerns, as you wish them identified.
Engagement scope — Tier I, Tier II, or Tier III.
Primary jurisdiction — the territory that governs the record request.
Optional notes — timeline, conflicts, or constraints the custodian should know on first read.

Materials produced during an engagement

Source dossier — open-record findings, OSINT citations, and the chain-of-custody log.
Engagement dossier — the sealed report held until the close-out of the engagement.
Outbound correspondence — takedown letters, GDPR/CCPA requests, and the receipts they return.
Billing records — the invoice line and the payment receipt. Card data is not held on Threadkin systems; payment is delegated to Stripe Checkout.

Lawful basis (GDPR Art. 6)

Two bases — both tested against the subject's reasonable expectations.

Art. 6(1)(b) — Performance of contract

When an engagement is opened through the intake form, the brief and the materials sent are processed on the legal basis of performing that contract — acknowledging the scope, scheduling the work, returning the sealed dossier. The intake form's four fields are processed on this basis from the moment of submission.

Art. 6(1)(f) — Legitimate interest

Securing the engagement — source provenance, the chain-of-custody log, and the practitioner's own ledger of completed work — is processed on the basis of legitimate interest. That interest is balanced against the subject's reasonable expectations at every stage: only the minimum data needed to substantiate a record request is collected, and the subject (or their counsel) retains a clear opt-out via the contact channel below.

Retention windows

Held only as long as the engagement requires.

Intake brief: Intake brief — archived for the duration of the acknowledgement period. Sealed on close-out of the acknowledgement.
Engagement dossier: Engagement dossier — held while the engagement is active, plus a defined close-out window after closing. Access is read-only by the custodian after sealing.
Billing records: Billing records — held for the standard statutory period (seven years from the close of the engagement) to satisfy tax, audit, and anti-money-laundering obligations.
Inquiry logs: Marketing and contact-form logs — short window only, retained for the period required to resolve the inquiry and then deleted.

Subprocessors

Three categories of infrastructure — no fabricated vendors.

Email delivery

Transactional mail only — intake acknowledgements, sealed dossier delivery, and billing receipts are sent via the platform's authenticated email proxy. The proxy is operated by the hosting platform; Threadkin does not see or store your email client credentials.

Payments

Stripe Checkout, delegated via the platform billing module. Card data is handled by Stripe on a hosted checkout surface — Threadkin systems store no card numbers, no CVCs, and no bank details. Stripe's own privacy notice covers the payment data they receive.

Hosting and encryption at rest

Platform-managed. The database sits inside a private, encrypted-at-rest volume in the request region; access is gated to the custodian role. Subprocessors do not change during an engagement — there is no per-engagement transfer of the engagement store to a third party.

Cross-border transfer posture

Genealogy records — engineered to stay inside the custody boundary.

Only the minimum data needed to substantiate a record request is collected: subject identifiers, the relevant dates, and the jurisdictional context that points to the record office that holds the record.

When a request must reach an out-of-region archive — for example, an Estonian parish register, a UK General Register Office certificate, or a United States state civil registry — the request is filed in that jurisdiction by the custodian. Records come back over a sealed intake boundary; the custody boundary does not change as a result.

Where personal data moves from the EEA to a jurisdiction without an adequacy decision, transfers are governed by the European Commission's Standard Contractual Clauses (or an equivalent mechanism recognised under the GDPR), and a record of the transfer is held alongside the engagement dossier.

California (CCPA / CPRA)

What a California resident can ask, and how.

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) give you the rights listed below. Submit any request through the contact channel at the foot of this page — we acknowledge within two business days and complete verifiable requests within the statutory period.

Right to opt out of sale or sharing — Threadkin does not sell or share personal information, and has not done so. There is no sale or share to opt out of, but the right is preserved in writing for the record.

Threadkin does not sell personal information, does not share it for cross-context behavioural advertising, and does not retain personal information longer than the windows above require.

Right to know — the categories of personal information collected, the categories of sources, the business purpose, and the categories of third parties with whom it is shared.
Right to delete — personal information held about you, subject to the statutory exceptions.
Right to correct — inaccurate personal information held about you.
Right to non-discrimination — Threadkin will not deny service, charge a different price, or provide a different level of quality for exercising a CCPA right.

Your choices

Six data-subject rights — one inbox to exercise them.

The rights below are available regardless of jurisdiction. Send a single message to the contact inbox — we acknowledge within two business days and respond in plain language.

Right of access — request a copy of the personal data Threadkin holds about you.
Right to rectification — correct inaccurate data we hold about you.
Right to erasure — request deletion, taking the engagement's statutory retention windows into account where they apply.
Right to restriction — pause processing of specific fields while a question is resolved.
Right to portability — receive your data in a structured, machine-readable form.
Right to object — object to processing based on legitimate interest, including the source-provenance ledger; we will stop unless we can demonstrate a compelling legitimate ground that overrides your interests.

Contact for data requests

One inbox. Two-business-day acknowledgement.

We acknowledge within two business days. Verifiable requests are completed within the statutory period — one calendar month under the GDPR, forty-five days under the CCPA (extendable once with notice).

Contact for data requests

threadkin-5@polsia.app

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