Trust and data handling

The model in one paragraph

Sellers keep ownership of their source records. Under a written agreement, Galena inspects and anonymizes eligible operational data in Brazil, produces a privacy-reviewed derivative, and licenses that derivative to vetted buyers, primarily research labs. Buyers never receive, view, or sample the source records. This page is a plain-language summary of how we handle data; the written agreements govern.

Source data is minimized, then destroyed

We keep source data briefly, and we destroy it on a clock:

• Send records as they are: no pre-cleaning required. Detecting and removing direct identifiers (names, government IDs, emails, phone and account numbers) is the first step of our processing pipeline.
• Source records are processed only to produce the anonymized derivative, inside our processing environment in Brazil.
• Once processing finishes, whether the dataset is approved or rejected, the source records are destroyed within 72 hours. We do not keep archives or backups of raw submissions, and the seller receives written confirmation of deletion.

Minimization is not a disclaimer

Under Brazil's LGPD, anonymizing data is itself processing. While source records are in our pipeline, we are a processing agent with security and incident-notification duties, and we operate as one. Keeping that window small reduces real risk; it does not exempt us from responsibility, and we do not claim it does. We make decisions about how derivatives are produced and listed, and we accept the responsibilities those decisions carry.

Every listing carries its anonymization report

A dataset is only listed with a documented anonymization report: the techniques applied, the parameters used, and an assessment of residual re-identification risk. Qualified buyers can review it under NDA.

Listings display only safe metadata: country, industry, date range, approximate record count, field inventory, and quality indicators. Preview samples are synthetic, generated to match the shape of the data; they are never drawn from source records.

Only anonymized derivatives leave Brazil. We do not create or retain re-identification keys.

What buyers receive, and what they cannot do

Buyers receive a restricted license to an anonymized derivative, not ownership of data.

Every license includes audit rights, incident-notice duties, and flow-down of these restrictions to affiliates and contractors, and prohibits:

• Attempting to re-identify any person or business present in the data.
• Linking the data against other sources to narrow in on individuals.
• Redistributing the data or sublicensing it beyond the agreed terms.
• Retaining the data after termination: deletion must be certified in writing.

Sellers are verified too

A marketplace is only as trustworthy as what enters it. Before we accept a dataset, we verify the selling business, confirm its authority to submit the records, and ask about the legal basis under which the data was collected. We can decline or remove any dataset, and sellers approve their listing before it is published.

Certifications: what we claim and what we do not

We do not display compliance badges we have not earned. A SOC 2 report is an independent audit, not a slogan; if and when we complete one, the report will be available to counterparties under NDA. The same goes for expert certification of de-identification.

We benchmark our anonymization against recognized standards, including the de-identification methodology used under U.S. health-privacy rules (HIPAA Expert Determination), as a quality bar. That is a design target we test against, not a certification we hold, and we will say so plainly for as long as that is true.

No guarantees, on purpose

Submitting a dataset does not guarantee acceptance, listing, valuation, buyer interest, or sale, and estimates are non-binding until a written agreement says otherwise. Only submit data your business is authorized to process and disclose.

Questions

This page will change as our controls and audits mature. If you want the current detail behind any statement here, write to [email protected]; under NDA, we will show you.