Information Security Program

GLBA Safeguards Rule · 16 C.F.R. Part 314 · v1

Designated coordinator

A named Information Security Coordinator oversees this program and reports annually.

Risk assessment

Reviewed at least annually and after any material system change. Threats include: credential theft, key loss, insider misuse, third-party compromise, and Stellar network outages.

Technical safeguards

  • TLS 1.2+ in transit. AES-256 at rest for sensitive payloads.
  • Row-level security on every customer-facing table; service-role access scoped to verified webhooks.
  • SHA-256 hashing of every legally significant document; hashes anchored to Stellar memos.
  • Webhooks authenticated with HMAC-SHA256 and constant-time comparison.
  • Daily seal-integrity job re-verifies document hashes against the ledger.

Administrative safeguards

  • Role-based access (grantor, trustee, beneficiary, attorney, admin).
  • Quarterly access review.
  • Mandatory background screening for any role with admin database access.
  • Incident response runbook with 72-hour notification target.

Service provider oversight

Database hosting, KYC, OFAC, payments, and notary partners are contractually bound to safeguards consistent with this program. We review their attestations annually.

ZENTRU

Fiduciary-SaaS for West Virginia Irrevocable Community Trust Funds. Powered by Stellar. Settled by Stripe.

Compliance
  • WV Uniform Trust Code §44D
  • NAICS 523991 · 525920 · 511210
  • SOC2-aligned RBAC · US data residency
Stellar
  • Testnet · Horizon
  • 2-of-3 multisig · Master key weight 0
  • SHA-256 anchored memos
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Zentru is an administrative software provider operating under W. Va. Code § 30-2-4 guidelines. It does not provide formal legal or tax counsel. All legal instruments must be verified with an attorney licensed in your home jurisdiction.

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Zentru is recordkeeping and workflow software for grantors, trustees, and beneficiaries of West Virginia Irrevocable Community Trust Funds. It helps users draft, sign, anchor, and audit trust documents and on-chain disbursements under the WV Uniform Trust Code.

It does not provide legal, tax, or investment advice, custody client funds, act as a bank or trust company, or move real money on a production blockchain. All Stellar activity occurs on the public testnet.

Zentru is a technology platform provided by Zentru Inc., a West Virginia corporation. Not a bank. Not legal advice. (SaaS Safe Harbor — W. Va. Code §30-2-4.) Terms of ServicePrivacy Policy

Automated Fiduciary Logic is governed by W. Va. Code §44D and executed via the Stellar Network. Stellar transactions are executed on the public testnet — no real value is moved.