Applies To
Setell ITAR Edition — the dedicated AWS GovCloud (US) enclave. It does not apply to the standard Setell platform, which may not be used for export-controlled data.
Processor / Environment Provider
Timber Ridge Capital LLC, a Washington limited liability company, operating as Setell.
Customer / Exporter of Record
The Setell ITAR Edition customer, who remains the export-responsible party for its technical data under the ITAR / EAR.
Note.This page is a transparency summary of the Export-Control Addendum executed during ITAR Edition onboarding. It is not a standalone binding contract and is not an offer to process export-controlled data through the standard platform. Final addendum terms are provided and counter-signed at onboarding. ITAR compliance is self-determined; Setell does not hold or claim any government “ITAR certification,” because none exists. Email sales@setell.aiwith the subject “ITAR Edition” to begin.
1. Scope & Roles
How the parties relate
Setell is the environment provider
Setell provides and operates the ITAR Edition enclave and the enforcing controls (US data residency, US-persons access, AI-in-boundary, logging). Setell processes technical data only on the customer's documented instructions.
Customer is the exporter of record
The customer determines what technical data enters the enclave and remains the party responsible for its own ITAR / EAR obligations, licenses, and exemptions. Setell does not assume the customer's export-control liability.
2. Customer Representations
What the customer attests
On upload of controlled technical data, the customer represents that:
- It is authorized under the ITAR / EAR to possess and to transfer the technical data to Setell for processing
- The technical data is properly identified and marked as export-controlled
- The individuals it authorizes to access the enclave are US persons or are otherwise authorized recipients
- It will not use ITAR Edition to effect any transfer that would require an export authorization it does not hold
3. Setell Obligations
The controls Setell maintains
US data residency
Technical data in ITAR Edition is stored, transmitted, and processed within AWS GovCloud (US). It is not replicated to commercial AWS regions.
US-persons access
Access to the enclave and to controlled technical data — including operations, support, and any prod debugging — is restricted to US persons.
AI inside the boundary
Model inference runs inside the GovCloud boundary via Amazon Bedrock. Controlled technical data is not sent to a commercial model API.
Logging & no re-export
Setell maintains access logs of who touched controlled data and does not re-export or re-transfer that data outside the controlled boundary.
4. Flow-down, Spill & Audit
Prime-contract obligations, incidents, and records
Flow-down clauses
Where the customer is a subcontractor to a prime, the addendum accommodates export-control clauses the customer is required to flow down from its prime contract.
Spill notification
Setell notifies the customer without undue delay on discovery of any suspected unauthorized access to, or disclosure of, controlled technical data, and cooperates with the customer's response and any voluntary disclosure it elects to make.
Audit & recordkeeping
The customer may audit Setell's ITAR Edition controls on reasonable notice. Setell retains records relevant to the handling of controlled technical data for the period required by the ITAR / EAR.
Get in touch
Request Setell ITAR Edition
ITAR Edition is provisioned per engagement. To begin onboarding and receive the full counter-signed Export-Control Addendum, email sales@setell.ai with the subject “ITAR Edition.”
This summary is provided for transparency and does not constitute legal advice. Export-control obligations depend on your specific facts; consult your export-control counsel.