Record of Processing Activities

GDPR Article 30(2) — Processor Record
Version 1.1 | October 28, 2026

1. Processor Details

Processor nameLamb and Flag TopCo Corp (dba AtlanticM&A)
Registered address159 N Wolcott St, Ste 133, Casper, WY 82601, United States
Data protection contactprivacy@atlanticma.ai
Representative in the EUTo be appointed when required under Article 27

2. Categories of Processing

#Processing ActivityCategories of Data SubjectsCategories of Personal DataTransfers to Third CountriesRetention
1User account managementCustomer employees and contractorsName, email, hashed password, MFA config, session tokens, login timestampsN/A. Processed in the account's hosting region (US East or London). SCCs apply where data is processed in the United States.While account active + 30 days post-termination
2Project managementCustomer employees, project team members, governance participantsNames, email addresses, job titles, project role assignments, task assignments, workstream ownershipN/A. Processed in the account's hosting region (US East or London). SCCs apply where data is processed in the United States.While subscription active + 30 days
3Meeting transcript analysis (AI)Meeting attendees, individuals discussed in meetingsNames, statements attributed to individuals, action item assignments, opinions expressedTranscript → AWS Bedrock in the account's hosting region via VPC private endpoint (US East accounts: may route within us-east-1, us-east-2 and us-west-2; London accounts: eu-west-2 only). Not used for model training.While subscription active + 30 days. Transcript stored in S3 (encrypted).
4AI dependency analysisN/A — processes task titles, not personal dataTask titles and workstream names (may incidentally contain personal names if used in task titles)Task data → AWS Bedrock in the account's hosting region via VPC private endpoint (US East accounts: may route within us-east-1, us-east-2 and us-west-2; London accounts: eu-west-2 only). Not used for model training.AI results are ephemeral (session state). Task data follows project retention.
5Report generation & distributionReport recipients (email addresses), individuals named in report contentEmail addresses of distribution list members, project data included in generated reportsEmail sent via AWS SES in the account's hosting region (us-east-1 or eu-west-2)Distribution config while subscription active. Generated reports not retained server-side.
6Document storageIndividuals named in uploaded documents (TSA addendums, templates)Document content (may contain personal data uploaded by Controller)N/A. Stored in AWS S3 in the account's hosting region (us-east-1 or eu-west-2), encrypted AES-256While subscription active + 30 days
7Governance & team managementSteering committee members, IMO members, workstream leadsNames, roles, organisational side (acquirer/target), governance positionsN/A. Processed in the account's hosting region (US East or London).While subscription active + 30 days
8Payment processingAccount billing contactsProcessed entirely by Paddle (Merchant of Record). AtlanticM&A does not receive or store payment card data.Paddle processes in UK/Global (PCI DSS Level 1)Managed by Paddle per tax regulations
9Customer feedbackUsers submitting feedbackEmail address, feedback text, browser info, page URLN/A. Processed in the account's hosting region (US East or London).Until resolved or deleted by administrator
10Audit loggingAll platform usersUser ID, action performed, timestamp, IP addressN/A. Processed in the account's hosting region (US East or London). CloudTrail logs in the same region.Application logs: while subscription active. CloudTrail: 90 days.
11Connector — customer-configured API accessProject owners and RAID owners (by name), individuals named in project, risk or document textRead-only. Project names and descriptions, RAID entries (title, description, mitigation plan) and their owners' names, work-plan tasks, meeting titles and timings, and excerpts of documents the Controller has imported for this purpose. Meeting organiser email addresses, meeting join and recording links, and legal-hold detail are withheld from this channel by column-level projection.Disclosed to a recipient the CONTROLLER selects and authenticates. AtlanticM&A does not choose the destination and cannot enumerate it; the transfer is made on the Controller's documented instruction under Art. 28(3)(a). See the DPA.AtlanticM&A retains nothing additional. Access lasts only while the Controller's token is live (owner-set expiry, capped at 365 days) and stops immediately on revocation, subscription lapse, or the removal of the person who created it.

3. Sub-Processors

The full list of sub-processors, with processing purposes and locations, is published on the Sub-Processors page. The table below summarises those that process Customer personal data.

Sub-ProcessorProcessingLocationSafeguards
AWS (multiple services)Compute, database, storage, email, monitoringThe account's hosting region: us-east-1 (N. Virginia) or eu-west-2 (London). CloudFront edge access logs for both regions are stored in us-east-1.SOC 2 II, ISO 27001, SCCs, EU-US DPF
AWS Bedrock (Anthropic Claude + DeepSeek)AI transcript analysis, work plan generation, dependency analysis. Claude Sonnet 4.6 and DeepSeek V3.2 / R1 routed per feature.US East accounts: us-east-1, and may route within us-east-2 and us-west-2. London accounts: eu-west-2 only.SOC 2 II, ISO 27001, no model training
Recall.aiMeeting notetaker, calendar sync and transcription. Off by default; enabled per project by the Customer.US East accounts: us-east-1. London accounts: eu-central-1 (Frankfurt).SOC 2 II, SCCs, EU-US DPF
PaddlePayment processing (MoR)UK / GlobalPCI DSS Level 1
GitHubCI/CD pipeline triggerUSSOC 2 II, no customer data

Services the Customer connects to the platform itself (Microsoft, Google, Atlassian Jira, Slack) receive data only on the Customer's instruction and are not sub-processors engaged by the Processor. They are listed in Section 3 of the sub-processor list.

4. Technical and Organisational Security Measures

A description of the technical and organisational security measures implemented pursuant to GDPR Article 32 is provided in the Security Technical Addendum and the Data Protection Impact Assessment.

Key measures include:

5. International Transfers

Each Customer account is hosted in one AWS region, chosen when the account is created: US East (us-east-1, N. Virginia, United States) or London (eu-west-2, United Kingdom). Personal data is stored and processed in that region, except as described on the Sub-Processors page. For personal data from the EEA/UK/Switzerland that is processed in the United States, the following safeguards are in place:

Full details of the international transfer mechanism are set out in the Data Processing Agreement (Section 5).

6. Document Control

Version1.1
DateOctober 28, 2026
Next reviewMarch 2027 or upon material change in processing
Approved byRichard Parry, Director

Lamb and Flag TopCo Corp (dba AtlanticM&A) · 159 N Wolcott St, Ste 133, Casper, WY 82601, United States
For enquiries: privacy@atlanticma.ai