This Local Data Governance Statement establishes the operational boundaries, data localization frameworks, and jurisdictional accountabilities for the digital assets and software distribution pipelines of Workflow Native Apps LTD ("the Company"), a legal entity registered in England and Wales.
1. SCOPE OF DIGITAL GOVERNANCE
This statement governs the sovereign boundaries of data handling across:
• The Company's static web domains and edge routing layers.
• Inbound corporate communications and technical support flows.
• Global software distribution via independent third-party marketplaces.
2. SOVEREIGN BOUNDARIES & JURISDICTIONAL MATRIX
The Company operates under a strict territorial data allocation structure to ensure full cross-border compliance without cross-contaminating user records:
A. Corporate and Communication Sovereignty
• Data Category: Inbound email correspondence, technical support inquiries, and corporate business records.
• Primary Jurisdiction: England & Wales (United Kingdom).
• Governance Framework: Governed strictly under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. All persistent corporate records are structurally centralized and retained within secure communication infrastructure subject to UK corporate law.
B. Technical Web Infrastructure and Edge Localization
• Data Category: Transient network connection metadata and routing internet protocol (IP) logs.
• Jurisdiction: Dynamic / Geographically Localized.
• Governance Framework: The Company utilizes a decentralized global routing infrastructure and Content Delivery Network (CDN) enforcing a strict Same-Origin Policy (SOP). Web request processing occurs dynamically at the regional network edge node geographically closest to the end-user (e.g., traffic originating in the European Economic Area is processed at EEA edge nodes). No analytical aggregation or centralized consolidation of global user IP histories occurs.
C. Distribution and Transactional Isolation
• Data Category: Purchasing details, software licensing validation, billing addresses, and transactional records.
• Jurisdiction: Controlled independently by the relevant third-party Merchant of Record (MoR) or Native Digital Storefront.
• Governance Framework: The Company does not maintain Application Programming Interfaces (APIs), shared databases, or data-sharing connections with its third-party marketplaces (including the Microsoft Store, Apple App Store, and Snapcraft). The legal responsibility for local fiscal collection (such as global VAT/Sales Taxes), transaction privacy, and local consumer rights compliance rests 100% with the respective marketplace acting as an independent Data Controller within its domestic jurisdiction.
3. CROSS-BORDER TRANSFER SAFEGUARDS
The Company does not execute bulk cross-border data transfers of consumer records. For transient infrastructure metadata routed globally through our network edge partners, data protection compliance is secured via:
• Reliance on approved global adequacy regulations.
• Incorporation of standard contractual clauses (SCCs) and the UK International Data Transfer Agreement (IDTA) within our infrastructure vendor frameworks.
4. COMPLIANCE ASSURANCE AND REVIEW
Ultimate accountability for this Data Governance framework rests with the Board of Directors of Workflow Native Apps LTD. This statement is evaluated annually to ensure continued alignment with shifting global privacy rules and native store distribution guidelines.