# Trellis™ — Client Data Protection & Risk Management

**One-pager for founders, incubators, and procurement**  
**Entity:** Hortiki Plants LLC (d/b/a Trellis / Hortiki Innovations)  
**Contact:** info@trelliscompliance.co  
**Version:** October 2026 · Aligns with Client MSA v2 draft & Expert Independent Contractor Agreement  

*This is a plain-language summary for conversations and diligence. It is not legal advice. Binding terms are in the Client MSA, Privacy Policy, and (when required) a signed DPA.*

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## 1. What we protect

Client laboratory and business materials used to deliver a fixed-scope project: Certificates of Analysis, identity/sequence files, intake answers, draft and final deliverables, Q&A, and verification audio.

We do **not** sell client files or personal data. We do **not** store full payment card numbers (Stripe) or expert bank accounts (Wise email/tag only).

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## 2. How information is protected (controls)

| Control | Practice |
| --- | --- |
| **Where it lives** | Cloudflare Pages/Functions; **R2** private vault for files; **D1** for project metadata; HTTPS/TLS in transit. Cloudflare documents AES-256 at rest for D1 and SOC 2 / ISO 27001 for covered Cloudflare services. **Hortiki itself is not SOC 2 certified.** |
| **Who can open files** | Only (1) the client on that engagement, (2) the **assigned** Network Expert, (3) Trellis admin for QC/support. Experts cannot browse other clients’ projects. |
| **Platform-contained review** | Experts open files inside the Trellis Expert Workspace. No expert download of Client Materials by design. Work must stay on-platform; pasting client data into public AI tools is a material breach. |
| **Identity of experts** | Clients see an **anonymized reviewer ID** plus credentials/expertise—not the expert’s legal name—on a normal basis. |
| **Access logging** | The platform logs which reviewer (by ID) opened which vault file and when. Clients may request an **access summary**. |
| **AI** | Optional Cloudflare Workers AI / heuristics may help extract CoA fields for the engagement. Client files are **not** used to train public AI models. Humans review low-confidence fields. |
| **Sign-in** | Email magic link + HttpOnly session cookie. |

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## 3. Risk management plan (what we do when something goes wrong)

**Prevention**

- Least-privilege access (assignment-gated vault).  
- Expert confidentiality, acceptable-AI, and conflict rules in a written Expert Agreement.  
- Training before vault unlock; annual refresh.  
- Simple automated **vault-access monitors** email Ops on unusual patterns (e.g. burst opens, opens across many projects, opens on closed projects, opens by a non-assigned expert).

**Detection & response**

- Experts must report suspected incidents to Ops within **24 hours**.  
- Trellis reviews logs and alerts; may suspend expert access during investigation.  
- If Trellis becomes aware of unauthorized access to or disclosure of a client’s confidential information, Trellis notifies the client’s named contact **within 72 hours of becoming aware**, describes what is known and what is being done, and cooperates reasonably with the client’s investigation.

**Accountability (when someone does harm on purpose)**

- Trellis keeps the map from anonymized ID → real expert identity for ops, security, and legal duties.  
- Real names may be disclosed **only as needed** to investigate or respond to a security incident, confidentiality breach, IP/legal claim, or when required by law/subpoena/regulator—typically to the affected client, counsel, insurers, or authorities—not as a routine disclosure.  
- Intentional external export of client data can result in removal from the project and the expert network; liability carve-outs apply to intentional confidentiality breaches under the MSAs.

**Retention & exit**

- Materials retained in the client portal about **24 months** after delivery (or longer while a subscription is active), subject to the Client MSA.  
- On written request: delete from active systems within about **30 days**, except records law requires (e.g. invoices).  
- Institutional buyers may request a signed **DPA**.

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## 4. Residual risks (honest)

- Hortiki is founder-operated and does **not** currently hold its own SOC 2 / ISO certification; infrastructure relies on Cloudflare’s attested controls.  
- No independent penetration test has been commissioned yet.  
- Experts are independent contractors worldwide under the same confidentiality rules; residual human risk is managed by contract, logging, monitoring, and suspension—not eliminated.  
- Client Materials are only as reliable as what the client uploads (attested at intake).

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## 5. Where to go deeper

| Document | Link |
| --- | --- |
| Security & privacy summary (buyer) | `/buyer/security-privacy.html` |
| Data storage outline | `/buyer/data-storage.html` |
| Client MSA (v2 draft) | `/docs/client-msa-v2-draft.md` |
| Privacy / Terms | `/legal.html` |
| Buyer center | `/buyer.html` |

**Ask us:** info@trelliscompliance.co  
**COI / W-9:** available via Buyer center (request or download when filed).