Technical and Organizational Measures
Measures under Article 32 GDPR for Tomorrowfy services
Tomorrowfy GmbH · Version 2.2 · Effective 21 August 2026
About these measures
These measures describe the baseline controls used for Tomorrowfy’s hosted services as of the effective date. They are risk-based and may be improved or replaced without materially reducing the overall level of protection.
1. Security organization and responsibility
- Security matters are coordinated through security@tomorrowfy.com; privacy matters through privacy@tomorrowfy.com.
- Access to Customer Data is limited to personnel who need it for engineering, operations, support, security, or legal compliance.
- Authorized personnel are subject to confidentiality obligations.
- Security requirements are considered when changing infrastructure, application code, and vendors.
2. Physical access
- Tomorrowfy operates cloud-first and does not host production servers at its office.
- Office access is restricted using electronic key fobs.
- Production infrastructure is hosted in provider-operated data centers with physical and environmental security controls and independent assurance programs.
- Company devices are securely wiped or reset when retired or reassigned.
3. Identity and access management
- Google Workspace is the central identity platform for internal access.
- Multi-factor authentication is required for sensitive tools, production environments, and administrative consoles.
- Access is role-based and granted on a need-to-know and least-privilege basis.
- Access is changed or removed when responsibilities change or personnel leave.
- Unique credentials are used; shared administrative credentials are avoided where the provider supports individual accounts.
- Production application credentials and tokens are kept out of source code and supplied through managed secrets or protected environment configuration.
4. Application and environment controls
- Development, staging, and production environments are separated.
- Production Customer Data is not used in development unless anonymized or otherwise specifically protected and authorized.
- Source code is version-controlled in private GitHub repositories.
- Backend deployments use automated tests and a controlled CI/CD workflow before deployment to Google Cloud.
- Authentication, request validation, and authorization checks are implemented for administrative, merchant, storefront, and webhook interfaces according to their trust model.
- Dependencies and infrastructure can be updated through version-controlled application and Terraform configuration.
5. Encryption and secrets
- External network traffic is protected with HTTPS using TLS 1.2 or later where supported.
- Google Cloud and Vercel encrypt stored production data using their platform encryption controls.
- Sensitive Shopify tokens and integration credentials stored by the application are encrypted using application keys or protected provider secret storage.
- Encryption and signing keys are separated from application source code and access is restricted.
- Full payment-card numbers are not intentionally stored by Tomorrowfy; payment processing remains within Shopify's payment environment.
6. Logging, monitoring, and traceability
- Google Cloud Logging, Monitoring, Trace, and service audit capabilities are used for production operations and investigation.
- Vercel provides deployment and runtime logs for the hosted frontend; Vercel Speed Insights is enabled for production performance monitoring.
- Application logs include operational context needed to diagnose events and are access-restricted.
- Administrative and infrastructure changes are traceable through cloud audit records, version control, and deployment history.
- Logs are protected against unauthorized access and retained according to provider and service configuration.
7. Availability and recovery
- Primary backend services, Firestore, and BigQuery are deployed in Google Cloud region europe-west3 (Frankfurt), using provider replication within the region.
- The service can be redeployed from version-controlled code and infrastructure configuration.
- Firestore point-in-time recovery (PITR) retains recoverable document versions for the preceding seven days, with recovery points available at one-minute granularity. Historical data can be read, exported, or cloned using provider-native recovery mechanisms.
- No separate scheduled Firestore backup, cross-region replica, or independently administered recovery copy is included in the standard service. Unless an Order Form states otherwise, Firestore recovery points older than the seven-day PITR window are not retained.
- BigQuery is configured with a seven-day time-travel window and may contain application logs or revision history for forensic analysis. It is not a Firestore backup or automatic continuity mechanism.
- Where the Customer enables Reverse ETL, selected datasets are copied daily to a Customer-designated BigQuery project. The Customer controls retention and recovery for that destination. Reverse ETL is not a Firestore backup, Firestore replica, or guaranteed disaster-recovery mechanism.
- Tomorrowfy tests recovery procedures at least annually and after material changes to the recovery configuration, and documents the results.
- Recovery relies on provider resilience and available native recovery mechanisms. No fixed recovery point objective (RPO) or recovery time objective (RTO) is promised unless expressly stated in an Order Form.
- The standard availability objective is defined in the Service Level and Support Policy.
8. Incident management
- Reported or detected security events are triaged, contained, investigated, remediated, and documented according to severity.
- Access, logs, and relevant evidence are preserved where needed for investigation and legal duties.
- Affected credentials are rotated or revoked when compromise is suspected.
- Personal data breaches are communicated to affected Customers under the DPA, without undue delay and where feasible within 24 hours after awareness.
- Corrective actions are tracked after material incidents.
9. Data minimization, separation, and deletion
- Customer tenants are logically separated using shop-specific identifiers and access controls.
- Only data needed for configured product functions, support, security, and legal compliance is processed.
- Customer-directed exports and integrations are separated by Customer configuration and credentials.
- Authorized personnel perform deletion and redaction requests; Customer personal data in Tomorrowfy-controlled active production systems is deleted within 30 days after termination or a lawful instruction, subject to legal retention.
- Residual provider-managed copies age out under the applicable provider retention cycle and remain protected until deletion.
10. Vendor and transfer management
- Service providers are reviewed for their role, security commitments, data locations, and data-protection terms before material production use.
- Subprocessors are contractually bound to appropriate confidentiality, security, assistance, and deletion obligations.
- Restricted international transfers use an adequacy decision, the 2021 Standard Contractual Clauses, or another valid Chapter V GDPR mechanism.
- The current vendor roles, locations, and transfer mechanisms are documented in the Subprocessor and Data Location List.
11. Current architecture summary
Frontend
- Standard service
- Next.js application hosted on Vercel; production server functions currently execute in iad1 (Washington, D.C., USA), with global edge delivery.
Backend
- Standard service
- FastAPI services on Google Cloud Run in europe-west3 (Frankfurt).
Primary data
- Standard service
- Google Cloud Firestore and BigQuery in europe-west3 (Frankfurt).
Messaging and jobs
- Standard service
- Google Cloud Pub/Sub and Cloud Tasks in the configured Google Cloud environment.
Optional/conditional services
- Standard service
- Vertex AI for AI Insights; Google Maps Platform for geocoding; DeepL for translation; SendGrid for transactional email; Slack for selected operational alerts.
| Layer | Standard service |
|---|---|
| Frontend | Next.js application hosted on Vercel; production server functions currently execute in iad1 (Washington, D.C., USA), with global edge delivery. |
| Backend | FastAPI services on Google Cloud Run in europe-west3 (Frankfurt). |
| Primary data | Google Cloud Firestore and BigQuery in europe-west3 (Frankfurt). |
| Messaging and jobs | Google Cloud Pub/Sub and Cloud Tasks in the configured Google Cloud environment. |
| Optional/conditional services | Vertex AI for AI Insights; Google Maps Platform for geocoding; DeepL for translation; SendGrid for transactional email; Slack for selected operational alerts. |
Contacts
- Security: security@tomorrowfy.com
- Privacy: privacy@tomorrowfy.com
- Support: support@tomorrowfy.com
