Clear roles for data in the CUTO Service

Roles by processing purpose

No single role applies to all data. The deciding factor is who determines the specific purpose and essential means of processing.

Project and collaboration data

The customer determines purposes, content, user groups and permitted use. CUTO processes this data to provide the service on the customer's documented instructions.

Project memberships and customer-assigned roles

The customer decides who joins a project and which project permissions apply. CUTO implements those assignments technically.

Account, sign-in and service security

CUTO determines the purposes for account provision, authentication, misuse prevention, integrity and the security of its own service operations.

Support and troubleshooting

CUTO processes support requests to manage the support case. Where a case requires access to customer-controlled project data, that access occurs within the agreed support scope and on the customer's documented request or instruction.

Contracting, procurement and billing

CUTO determines the purposes for contract administration, procurement coordination, billing and compliance with its own legal obligations.

Privacy and security communications

CUTO processes incoming privacy and security requests for its own secure handling. If a request concerns customer-controlled project data, it is routed to the responsible customer and CUTO assists under the agreed terms.

Customer instructions and responsibilities

Customers decide which personal data is processed for their projects, who receives access and how long content is needed within the agreed scope. They provide documented, lawful instructions and ensure that users and data may be included for the intended purpose.

Customers should include only data necessary for the relevant project purpose and permitted for the intended recipients.

User, administrator and authorization boundaries

Customer administrators manage memberships and project roles within their area of responsibility. CUTO's internal administrative permissions are separate, limited to operational duties and granted under the defined authorization and revocation process.

Authentication and security data do not become customer-controlled project content merely because a user belongs to a customer project.

Support access to customer data

Support access to customer-controlled data occurs only for a specific support case, with the required authorization, within the agreed scope and with traceable logging. Access ends when it is no longer needed for the case.

Export, deletion, return and end of contract

During the contract term, the designated export and deletion paths are available to the relevant authorized roles. After the contract ends, customer-controlled data is returned or deleted according to the agreed choice. Legal retention obligations and documented expiry periods for backup copies are identified separately.

Subprocessors, locations and transfers

The subprocessor list identifies providers, services, purposes, data access, processing locations and effective date. Information on international transfers identifies the affected scope and applicable safeguard.

DPA and contract documents

Where CUTO processes personal data on documented instructions, the applicable contract documents cover subject matter, duration, nature and purpose, data types, data subjects, instructions, security measures, subprocessors, assistance, and deletion or return.

Route data-subject requests correctly

If your request concerns data controlled by a customer in a CUTO project, contact that customer first. The customer decides on the request; CUTO assists under the agreed terms.

If your request concerns account, security, support, contract or other data CUTO processes for its own purposes, use the CUTO privacy contact.

Privacy and security incidents

Report a suspected privacy or security incident through the designated contact route. Do not include passwords or unnecessary personal data in the initial message.

Effective date and changes

We update this page when purposes, roles, service functions, support access, lifecycle rules, subprocessors or contract documents change materially.