Fleet Integrity — Multi-Merchant Auction Independence and Data Residency

Status: Active spec (v1.0, 2026-08-11) · Owner directive: Master v4.0 §3.5 "Fleet integrity", review finding N4 (High — legal/architectural) · Lane: MIZOKI Signal for Shopify Rule of precedence: this spec must be satisfied before pooled priors ship (P4 / B4). Nothing in it is a performance claim; the platform ceiling stays built, pre-benchmark (TRUTH.md). Sources: docs/product/SIGNAL_SHOPIFY_MASTER_v4.md §2.7, §3.5; docs/product/SIGNAL_OVERVIEW_v5.md §2.6; owner decisions 5, 14, 15 (master §3.6).

Why this spec exists

As merchant count grows, MIZOKI merchants will meet in the same ad auctions and product categories. Two structural exposures follow: (1) pooled cross-merchant learning could leak one merchant's strategy to another, and (2) anything that even resembles coordinated bidding between merchants is auction-collusion legal exposure. Both are closed by construction, not by policy promise, and the immutable ledger is the proof surface.

(a) Pooled priors are DP-aggregated — merchant strategy is non-inferable

(b) No cross-merchant bid coordination — independence by construction, ledger-provable

(c) EU data residency — options memo for counsel (owner decision 14)

The platform runs in us-central1. EU-merchant onboarding requires a transfer-mechanism determination before EU go-to-market (master §3.5; currently unscheduled). Options for counsel, with engineering consequences:

Option Mechanism Engineering consequence Notes for counsel
1. SCCs + supplementary measures EU→US transfer under Standard Contractual Clauses; HMAC-tokenized identifiers (pseudonymized personal data, GDPR/CCPA locked decision) + Secret-Manager-held keys as supplementary measures Lowest engineering cost: no new infrastructure; DPIA + transfer-impact assessment documents the pseudonymization boundary Fastest path; carries Schrems-line legal-review burden per assessment cycle
2. Regional processing (EU region) EU merchant data processed in an EU region (e.g. europe-west*) end to end Highest engineering cost: regional duplicates of the ingest → BigQuery → graph → ledger path; per-region Cloud Run fleet, per-region secrets; cross-region control plane must carry zero personal data Strongest residency posture; multiplies operating surface — sequencing decision vs. EU demand
3. Hybrid (regional landing + tokenized processing) Raw identifiers land and are tokenized in-region; only HMAC-tokenized, non-reversible records cross to us-central1 Moderate cost: a small EU tokenization/consent front end; the core stack stays single-region Middle path — counsel must confirm tokenized records qualify as adequately safeguarded for transfer

Enforcement hooks

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