Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / transfer-impact-assessment-memo.docx
transfer-impact-assessment-memo.docx
Parties
HARKNESS LLP
Skybridge Fintech Ltd
Kestrel Services Inc
Ireland Ltd
Transaction Background Skybridge Fintech Ltd
Federal Deposit Insurance Corp
Ironvault Security Group LLC
Ketchum LLP
Dates
December 8, 2025
July 16, 2020
June 18, 2021
June 4, 2021
July 1, 2025
March 1, 2024
January 15, 2026
November 10, 2020
July 10, 2023
October 7, 2022
Amounts
$10
$20
Obligations
For purposes of GDPR compliance, particular attention must be given to the anti-fraud behavioral biometric data
Furthermore, the CLOUD Act implications of data stored at the Frankfurt location (operated by Osprey Cloud, a US corporation) must be considered, as discussed in Section VII below
If no supplementary measures can be identified that would provide such protection, the transfer must be suspended or terminated
However, several important limitations must be noted: First, the DPF adequacy does not extend to Osprey Cloud Infrastructure, Inc
" EO 14086 introduced binding requirements of proportionality and necessity for US signals intelligence activities directed at foreign persons' data, explicitly providing that signals intelligence shall be conducted only to the extent necessary and proportionate to a validated intelligence priority
Under this model, the Controller (Meridian) provides general written authorization for Skybridge to engage sub-processors, subject to the following conditions: Skybridge must provide the Controller with at least 30 days' prior written notice before engaging any new sub-processor or replacing an existing sub-processor; the notice must identify the sub-processor, the nature of the processing to be performed, and the location of processing; the Controller has the right to object to the engagement of a proposed sub-processor on reasonable data-protection grounds within the 30-day notice period; and Skybridge is required to flow down equivalent data protection obligations to all sub-processors through written contracts