Policy Observatory
UAE Partner Briefing — Authorized Access Only
Confidential — 2026. This document is shared under NDA.
Not for public distribution.
Kaiko Studios · UAE
● Confidential — 2026

Data Privacy & Security

Customer-Controlled Deployment, Sovereignty Model & Shared Responsibility

Prepared byKaiko Studios
DateApril 2026
PartnerUAE Government
Section 01

Executive Summary

Policy Observatory is designed for customer-controlled deployment. The platform supports topologies in which enterprise and government customers retain operational control of data, cryptographic keys, and network egress. For UAE government workloads, the reference posture is a sovereign deployment where data, keys, and operational state reside on customer-operated infrastructure in the UAE, and external integrations are controlled and allow-listed by the customer.

This document is written to pass technical due diligence, not to market. It distinguishes clearly between what the platform provides today, what can be configured for enterprise and sovereign deployments, and what the customer operates. Aspirational and forward-looking items are labelled as such.

MVP stack note. The current platform (the "MVP" maturity level defined in Section 02) relies on two external providers reached via allow-listed egress: Kimi K2.5 (Moonshot AI) for LLM inference and Brave Search for news and grounding data. Both can be substituted with customer-approved, in-jurisdiction alternatives. The swap is scoped during Discovery (Section 13, Phase 1) and adds development time proportional to the replacement chosen. Commercial terms, IP arrangement, and programme milestones are defined in the accompanying proposal document (KAIKO-IMPL-2026-001), not in this technical brief.
Customer
Key Custody
Allow-Listed
Egress Control
AES-256
At-Rest Encryption
TLS 1.3
In-Transit Encryption
Hash-Chained
Audit Log
Row-Level
Tenant Isolation
Section 02

Deployment Maturity Levels

Policy Observatory is deployable across three maturity levels. Each level represents a different operational posture, not a different product. Security properties scale with the deployment — the same platform runs under all three, with controls enabled and operated differently at each tier.

LevelPostureTarget UseStatus Today
MVPMulti-tenant SaaS; encryption at rest, RBAC, hash-chained audit log, tenant isolation via row-level security. Uses Kimi K2.5 (LLM) and Brave Search (news) via allow-listed external egressPilots, non-sensitive analysis, research evaluationsIn production
Enterprise HardenedSingle-tenant deployment; customer identity provider; customer-provided HSM/KMS; private networking; SIEM exportSensitive workloads, enterprise IT governanceAvailable via engagement
Sovereign DeploymentOn-prem or air-gapped inside customer infrastructure; customer-held keys; controlled egress; in-country dataGovernment and regulated sectors requiring jurisdictional controlSupported topology; joint engagement
The MVP is what Kaiko Studios operates for current SaaS customers. The Enterprise and Sovereign tiers are delivered through deployment engagements: the customer owns the infrastructure; Kaiko Studios provides the platform, reference configurations, and implementation support. Security properties at each tier come from how the platform is deployed and operated — not from proprietary hardware. Moving from MVP to a Sovereign deployment typically involves swapping the LLM and news-feed providers for customer-approved, in-jurisdiction alternatives; this substitution is scoped during Discovery.
Section 03

Sovereign Deployment Topologies

Three topologies are available within the Sovereign tier. All three keep the data plane inside customer jurisdiction; they differ in egress posture and operational flexibility.

TopologyWhere It RunsEgress PostureBest For
Air-Gapped On-PremCustomer data centre, physically isolatedNo default egress; update channel separately authorisedClassified workloads; maximum isolation
Sovereign Private CloudCustomer-licensed sovereign cloud inside jurisdictionAllow-listed, auditedSensitive workloads needing operational elasticity
HybridOn-prem data plane; isolated control planeControlled, per-flow auditedMixed classification; phased migration
A typical starting posture for UAE government workloads is air-gapped on-prem for the data plane, with a separately authorised update channel for patches and model updates. This keeps the customer in full custody of data while still allowing the platform to evolve.
Section 04

On-Prem Reference Architecture

The reference on-prem deployment uses standard, hardened building blocks. Security properties come from how the components are composed and operated — not from proprietary hardware. Every component shown is replaceable with an equivalent customer-approved option.

On-Prem Reference Architecture Customer-controlled boundary — ingress and egress are allow-listed at deployment ● Customer-Controlled Boundary (UAE) External Network — Controlled Ingress, Allow-Listed Egress Authorised Partners over mTLS + VPN Licensed Data Feeds allow-list only 01 · Perimeter / DMZ · Customer-Operated Ingress Controls & Threat Filtering Firewall stateful + IDS WAF (optional) if required Reverse Proxy TLS termination Edge Controls customer edge 02 · Application Tier · Segmentation-Compatible Container Orchestration — mTLS Service Mesh (Configurable) API Gateway JWT + RBAC + audit Core AI Engine NCS + Council Model Suite 26 models Agent Swarm 1,535 agents Scheduler / Orchestrator event pipeline 03 · Data Tier · AES-256 at Rest Encrypted Storage — Tenant-Isolated · Keys Held by Customer Graph DB Neo4j / encrypted Relational DB Postgres / RLS Object Storage S3-compat / SSE Audit Log hash-chained 04 · Key Management · Customer-Held HSM / KMS Integration HSM customer-procured KMS / Vault envelope keys 05 · Management & Observability · Customer-Operated Admin Access · SIEM · Identity · Backup Bastion Host MFA + session recording (opt.) Identity Provider customer IdP SSO + MFA SIEM (customer) log ingestion + alerting Monitoring / APM metrics + traces on-prem Backup & DR encrypted, in-country customer-operated
Customer-controlled boundary — ingress & egress allow-listed Data / control flow Customer-operated management plane
Components inside the boundary run on customer-owned or customer-leased infrastructure under the customer's jurisdictional control. Cryptographic keys remain in the HSM under customer custody. The platform does not require or maintain a persistent vendor access path into the environment — any access for support is customer-authorised, time-bounded, and auditable.
Section 05

Infrastructure Reference Sizing

Reference capacities for a single-country advisory workload with continuous monitoring and a 1,535-agent swarm. All values are sizing guidance, not hard requirements; every component is compatible with the customer's approved hardware and software stack.

TierReference SizingNotes
Application compute~48 vCPU, ~192 GB RAM across 3 nodesCompatible with Kubernetes, OpenShift, or equivalent orchestration
GPU / accelerator2–4 GPUs if hosting LLM inference locallyOptional; customer may use an approved LLM service instead
Graph DB storage~500 GB NVMe (encrypted)Neo4j or compatible graph store
Relational DB storage~1 TB NVMe (encrypted, RLS-enabled)Postgres 16+ recommended
Object storage~5 TB S3-compatible with server-side encryptionMinIO, Ceph, or customer-approved storage
Key managementCompatible with customer HSM / KMSe.g., FIPS 140-3 validated; customer procures and custodies
NetworkZero-trust segmentation compatibleService mesh optional (e.g., Istio, Linkerd); mTLS when enabled
DR siteGeo-separated, customer-operatedRPO / RTO targets are customer-configurable
The stack is designed to run on commodity, customer-approved hardware and standard container platforms. The sensitive state lives inside the encrypted data tier and the customer-held HSM; the compute layer is replaceable.
Section 06

Customer-Controlled Sovereignty

Sovereignty properties emerge from how the platform is deployed and operated by the customer. The following primitives are what the platform enables; the customer operates them and defines the policy.

ControlWhat the Platform EnablesCustomer Operates
Data ResidencyAll data storage can be configured to customer infrastructure in-countryInfrastructure location, storage provisioning, capacity
Key CustodyEnvelope encryption with customer-held keys via HSM/KMS integrationHSM procurement, key custody, rotation policy
Jurisdictional ControlPlatform does not require data to leave customer infrastructureContractual jurisdiction, legal framework, counsel
Egress ControlNo default outbound telemetry. The MVP uses allow-listed egress to reach the configured LLM (Kimi K2.5) and news feed (Brave Search); both can be substituted with customer-approved, in-jurisdiction alternatives during DiscoveryFirewall rules, egress policy enforcement, periodic review of the allow-list
Operational ControlDocumented administration surface; no persistent vendor access pathAdmin staffing, training, break-glass authorisation
Data PortabilityDocumented export APIs in open, non-proprietary formatsExport execution, downstream system integration
Right to DestructionCryptographic erasure via HSM key destruction renders storage unreadableDestruction authorisation, verification, evidence retention
Supply Chain TransparencySigned SBOM published per platform releaseSBOM review, third-party attestation if required
Section 07

Shared Responsibility Model

Sovereign deployments are a partnership. The platform provides the application, reference configurations, and security primitives; the customer operates the infrastructure and the surrounding controls. The table below defines the split for a Sovereign deployment. The split shifts for Enterprise Hardened and MVP tiers — more of the customer column moves to Kaiko Studios in the MVP (SaaS) deployment.

DomainKaiko Studios (Platform)Customer
IdentityRBAC model, SSO/OIDC integration points, JWT issuanceIdentity provider (Azure AD, Okta, etc.), MFA policy, user lifecycle, access reviews
NetworkSegmentation-compatible design, mTLS supportNetwork topology, firewall rules, egress allow-list, WAF if required
CryptographyEnvelope encryption, HSM/KMS integrationHSM procurement, key custody, rotation policy, hardware lifecycle
MonitoringStructured logs, metrics, audit events, health checksSIEM ingestion, alerting rules, SOC operations, dashboards
PatchingPlatform component updates, CVE notifications, tested patchesOS patching, container runtime, base images, patch windows
Backup / DRBackup hooks, restore procedures, consistency checksBackup storage, DR site, failover drills and cadence
ComplianceArchitecture aligned with standards, control evidence, design docsAudit execution, certification, policy and procedure documentation
Incident ResponseTriage workflow, forensic artefacts, vendor-side notificationSOC operations, customer-side response, external communications
In the MVP (SaaS) deployment, Kaiko Studios operates identity broker services, network controls, patching, backups, and our own incident response. In a Sovereign deployment, those responsibilities shift almost entirely to the customer — the platform provides the primitives and evidence surface, the customer runs operations.
Section 08

Threat Model

Security investment is prioritised against the threats that actually affect this class of system. The table below lists what the platform architecture is primarily designed to mitigate. Not every generic enterprise threat is addressed at the platform layer — some (e.g., volumetric DDoS) are more appropriately handled at the customer edge and are noted as out-of-scope for platform-provided defences.

ThreatWhy It MattersPrimary Mitigation
Data leakage / tenant isolation failurePolicy data and model outputs are sensitive; cross-tenant leakage would be a critical breachRow-level security in Postgres, namespace isolation in the app tier, per-tenant encryption context
Unauthorized accessCredential compromise or privilege escalation is the most common real-world breach vectorSSO + MFA (customer IdP), RBAC with least-privilege defaults, just-in-time elevation, session recording on admin paths (configurable)
Model misuse / adversarial inputsUser-authored custom models could attempt data exfiltration or adversarial behaviourSandboxed execution (no network, restricted PATH, CPU/memory limits, 30-second timeout); tenant-admin review before production use
Auditability of outputsPolicy recommendations must be traceable — from which inputs, by which model, with which seedHash-chained audit log; every model run stores inputs, outputs, seeds, and model version
Supply chain compromiseDependency or build-time compromise could introduce backdoorsSigned container images, SBOM per release, dependency scanning in CI, pinned versions
Privileged insider misuseAdmin access is the highest-impact internal vectorSession recording (configurable), just-in-time elevation, audit log outside admin write scope, separation of duties
Out of scope for platform-provided defences: Volumetric (DDoS) attacks — this is not a public-facing consumer service; DDoS protection is appropriately handled at the customer edge. The platform does not ship a dedicated anti-DDoS component. Physical security of infrastructure is the customer's responsibility in any sovereign deployment.
Section 09

Security Architecture — Defense in Depth

Protection is layered across network, identity, data, application, and audit planes. Controls are modular and configurable — customers select the subset that fits their maturity level. Items below are labelled as built-in (enabled by default in every deployment), configurable (shipped with the platform, enabled via deployment configuration), or customer-operated (depends on customer infrastructure or policy).

Network

Identity & Access

Data Protection

Application

Audit & Monitoring

Section 10

Compliance Alignment

The platform is designed to support enterprise and government audit programs. Kaiko Studios is a startup; we do not yet hold the certifications below. The architecture is aligned with their principles, and certification is delivered through customer-driven deployment engagements rather than presented as a pre-existing stamp. Statements about certification in this document are forward-looking.

UAE IA (aligned) NESA / SIA (aligned) UAE PDPL (aligned) ISO 27001 (aligned) ISO 27017 (aligned) ISO 27018 (aligned) SOC 2 (aligned) NIST 800-53 (aligned) FIPS 140-3 (HSM integration)
StandardScopeCurrent Status
UAE Information AssuranceGovernment information systemsArchitecture aligned; formal attestation via deployment engagement
NESA / SIA StandardsCritical infrastructure protectionArchitecture aligned
UAE PDPL (Federal Decree-Law 45/2021)Personal data protectionData minimisation and residency primitives built in
ISO 27001 / 27017 / 27018ISMS, cloud services, PII protectionAligned with principles; formal certification available as an optional parallel workstream at customer request
SOC 2 Type IISecurity, availability, confidentialityAligned with principles; audit engagement available as an optional parallel workstream at customer request
NIST 800-53Federal security control familiesAligned with applicable control families
FIPS 140-3Cryptographic module validationPlatform integrates with FIPS-validated HSMs procured by the customer
Honesty note: as a startup, we are not yet certified to ISO 27001 or SOC 2 Type II. The architecture is designed to support these controls. Both are long, audit-driven processes (typically 6–12 months for a SOC 2 Type II observation window; 12–18 months for ISO 27001 ISMS implementation and certification) and are not included in the core pilot timeline. Certification can be run as an optional parallel workstream at the customer's request, with separate scope, budget, and timeline agreed up front so it does not block the pilot go-live.
Section 11

Operational Security

AreaPlatform Practice · Customer Integration
Change managementProduction changes go through peer review, automated tests, and security scans. Customer-side approval workflows can be integrated at deployment.
Patch cadenceCVE notifications issued to customers; severity-based update cadence. OS and infrastructure patching is the customer's responsibility in sovereign deployments.
Vulnerability disclosurePublished responsible-disclosure policy with defined triage SLAs. Relevant findings are communicated to affected customers.
Incident responsePlatform-side triage, forensic artefacts, and vendor notification workflow. Designed to integrate with the customer SOC; the customer operates 24/7 response in sovereign deployments.
Penetration testingSupports customer-directed pen testing and independent third-party reviews. Kaiko Studios runs pre-release security testing on the platform itself.
Red-team exercisesSupports red-team workflows; scope and execution are customer-coordinated.
PersonnelKaiko Studios staff with platform access are screened per internal policy; customer can request attestation and, where required, additional vetting as part of the engagement.
TrainingInternal security training for engineers. Customer-side user training is delivered as part of onboarding.
Section 12

Continuity & Resilience

Continuity properties are configurable targets, not contractual SLAs at the platform layer. The reference architecture and operating procedures are designed to meet enterprise-grade targets when deployed on appropriate infrastructure and operated by a capable team.

CapabilityReference TargetHow It Is Achieved
High availabilityPilot target ~99.5%; 99.9%+ achievable when deployed multi-node across AZs in a hardened reference topologyMulti-node cluster per tier; zero-downtime rolling updates
Recovery Point Objective (RPO)Configurable; ~15 minutes typicalContinuous encrypted backup replication to customer DR site
Recovery Time Objective (RTO)Configurable; ~4 hours for full servicePre-staged DR environment; tested failover runbook
Backup retentionCustomer-definedEncrypted with customer-held keys; stored per customer policy
DR testingCustomer-scheduledJoint drill with customer operations team; post-drill report
Graceful degradationCore advisory remains usable under partial outageContinuous monitoring can pause without affecting historical reports
Section 13

Deployment Process — Phased Rollout

Deployment is sequenced so both parties can validate at each gate before proceeding. Each phase has defined exit criteria jointly agreed with the customer security team.

1
Discovery & Threat Model — Joint workshop with customer security team: classify data, define threat model, finalise deployment topology and maturity level, and confirm LLM and external data source preferences. Platform defaults (Kimi K2.5, Brave Search) can be swapped for customer-approved alternatives; the substitution is scoped here and adds development time to Phase 3 proportional to the replacement chosen
2
Infrastructure Provisioning — Customer procures and racks hardware; Kaiko Studios provides reference configurations and hardening guidance
3
Platform Deployment — Install containerised platform; configure HSM integration; wire customer identity provider; enable SIEM export pipeline
4
Security Validation — Independent pen test, configuration audit, cryptographic review. Joint sign-off gate with the customer security team before any data is loaded
5
Data Migration & Go-Live — Load grounding data; run validation simulations; phased user onboarding; first advisory output
6
Hypercare & Handover — Intensive support window; operational training for the customer team; transition to steady-state with the agreed support model
Security Validation is a joint gate: the deployment does not progress to data migration until the customer security team has reviewed and signed off on the pen-test report and configuration audit. No customer data is loaded before that gate is passed. Timing note: pen-test vendor booking begins in Phase 2 and the test runs in parallel with late Phase 3 platform deployment to avoid blocking go-live. A ~2-week remediation window is budgeted between report delivery and go-live. Similar parallelisation applies to UAE data-access authorisations and compliance mapping — dependencies that sit outside our direct control are identified early and tracked as scheduling risk items.