ABT-C  ·  Counsel Reference  ·  For attorney review

Transaction Protocol, Data Custody,
and Structural Retention Enforcement

Six-stage walkthrough of a concrete ABT-C transaction annotated with the legal significance of each stage. Covers plaintext custody allocation, per-tier structural retention destruction, and the architectural property that makes first-party authorization a structural requirement — not a policy promise.

This document is a technical reference prepared for counsel review. It does not constitute legal advice. Statements about data custody, retention, and production compellability reflect the technical architecture of the ABT-C protocol as currently implemented at cinematiccard.com. Counsel should independently assess applicability to specific regulatory or litigation contexts.

Protocol
ABT-C v2
 
Patent
US Prov. 64/056,353
Filed May 4, 2026
 
Reference impl.
cinematiccard.com
 
Verified
May 8, 2026
28+ scenarios
 
Version
v1.0 · May 2026
Core property Plaintext never moves over the wire. Ciphertext and tokens move. Decryption happens at endpoints. No party holds plaintext they did not generate locally.
01

Maya purchases a $4.50 coffee

The consumer's device holds a persistent cryptographic key. From it, the device derives a tokenized decryption key scoped to this single transaction. Neither the root key nor any plaintext leaves the device during this stage.

Data flow — transaction initiation
Consumer · Maya's device
Phone
api_key_maya
never leaves device
↓ derives per-transaction token
tx_token_a3f2
encrypted envelope · tx_a3f2
Merchant · Cafe Reverie
Receives ciphertext
encrypted bytes only
no decryption token
cannot read envelope
The encrypted envelope travels over the network. The cafe receives ciphertext. No plaintext is transmitted. The on-device root key (api_key_maya) from which all per-transaction tokens are derived exists only on Maya's device.
Legal significance
Data custody allocation. The merchant does not receive, hold, or process plaintext consumer data during transaction initiation. The ciphertext they receive is not "personal data" in the functional sense — it cannot be read, correlated, or acted upon without a key they do not hold.
Transit liability. No plaintext traverses the network at any stage. Any interception of the transmitted envelope yields only ciphertext. The merchant's exposure for a network-layer breach of this transaction is limited to the interception of encrypted bytes with no corresponding key.
Relevant to: GDPR Art. 32 (technical measures); CCPA §1798.150 (reasonable security); breach notification threshold analysis.
Root key custody. The persistent root key (api_key_maya) exists exclusively on the consumer's device. No party — merchant, vault operator, registry — ever holds or can compel production of this key from any system other than Maya's device.
02

Encrypted envelope stored in vault; tokenized key controlled by consumer

The vault stores the encrypted envelope and the tokenized decryption key. The vault holds ciphertext — not plaintext. The decryption key is released only upon authorization from the consumer's device. The merchant holds neither the envelope nor the key.

Vault entry — tx_a3f2
envelope_ciphertext [encrypted: operational_consumer + operational_merchant + taxation + 15 placeholder tiers]
tokenized_decryption_key tx_token_a3f2 — released only on Maya's device authorization
retention_expires T + 30 days (consumer identity tier)
refund_pathway structurally requires Maya's device participation
The vault operator holds ciphertext, not plaintext. The 18-tier envelope is in the vault, but no party — including the vault operator — can read it without the corresponding token slice authorized by Maya's device.
The 18 ABT-C tier categories include: operational_consumer, operational_merchant, taxation, and 15 placeholder reservations for future tier authorities (regulatory, compliance, audit, etc.) not yet onboarded to the registry.
Legal significance
What "holding data" means here. The vault holds encrypted bytes. In the technical and, arguably, functional sense, the vault does not hold personal data — it holds data that cannot be read, correlated, or acted upon. The vault operator is not in a position to disclose the plaintext contents of any tier, because they do not possess the decryption material.
Relevant to: Third-party subpoena analysis; GDPR processor vs. controller distinction; CCPA service provider designation.
Key control allocation. The tokenized decryption key is held in the vault, but it cannot be released without authorization from Maya's device. A subpoena directed to the vault operator for the decryption key would produce a token that is still gated by Maya's device authorization — it does not produce the ability to decrypt.
Retention structure. The 30-day retention window for the consumer identity tier is structurally enforced — it is not a policy promise by the vault operator. At day 30, the decryption pathway for that tier is destroyed. The vault operator cannot extend or override this.
03

Merchant receives only their authorized tier; consumer identity remains sealed

The cafe requests the merchant-tier token slice. The vault forwards the request to Maya's device. Maya's device verifies the merchant and releases a scoped slice — restricted to the merchant tier only. Decryption occurs at the cafe's endpoint. The consumer identity and taxation layers remain cryptographically sealed to the merchant at all times.

Data flow — tier-specific decryption
Merchant · Cafe Reverie
Token request
"release merchant-tier
slice for tx_a3f2"
token request
Vault
Forwards to device
consumer auth required
authorize?
Consumer · Maya's device
Authorizes
verifies merchant identity
releases: merchant tier only
Merchant · decryption result at endpoint
Cafe reads their tier
$4.50 · oat latte · pickup
consumer identity: sealed
taxation layer: sealed
15 placeholders: sealed
The merchant decrypts their tier at their own endpoint. They receive the transaction data needed to complete the sale: amount, item, and pickup instruction. The consumer identity layer and taxation layer are cryptographically sealed — the merchant does not receive, hold, or process them.
Legal significance
Per-tier access as technical access control. The merchant's access is structurally limited to the merchant-tier projection of the envelope. This is not a permission policy enforced by software that could be misconfigured or bypassed — the merchant-tier token slice cannot decrypt any other tier's ciphertext. The access boundary is cryptographic.
Relevant to: Data minimization analysis; "least privilege" access arguments; GDPR Art. 25 (data protection by design); CCPA business purpose limitations.
What the merchant "holds." After transaction completion, the merchant holds: amount ($4.50), item description, and pickup instruction. They do not hold the consumer's identity, address, payment instrument details, or any data from sealed tiers. A subpoena to the merchant can compel production only of what they hold — which is limited by design.
Endpoint-only decryption. The plaintext appears only at the merchant's endpoint, briefly, and for the authorized tier only. It does not traverse the network in plaintext at any point in this flow.
04

Day 30 — consumer identity tier destroyed; taxation and merchant tiers retained

At retention expiration, the decryption pathway for the consumer identity tier is irreversibly destroyed. This is structural: no policy override, no administrative extension, no recovery. The merchant and taxation tiers remain accessible to their respective authorized parties.

Vault entry — tx_a3f2 — day 30+
operational_consumer key destroyed — consumer identity unrecoverable
operational_merchant amount, item, jurisdiction — retained per merchant-tier schedule
taxation $4.50 · taxable food · jurisdiction — retained for tax compliance
tx_token_a3f2 (consumer slice) destroyed — authorization pathway closed
refund_pathway requires Maya's device to reconstruct (fresh token required)
The destruction is structural. The decryption material for the consumer identity tier has been destroyed. No party — merchant, vault operator, registry, or any third party — can recover Maya's identity from this envelope. The capability to decrypt no longer exists in any system.
The taxation authority, if registered as a tier authority in the registry, retains access to their tier only: $4.50, taxable food, jurisdiction, merchant identity. They can decrypt their tier for compliance purposes. They have never had access to Maya's identity, and post-destruction, that access is permanently unavailable to everyone.
Legal significance
"Right to erasure" as architectural guarantee. The structural destruction of the consumer identity tier is, technically, erasure of the only material from which Maya's identity could be recovered. This is not a deletion record that could be challenged — the cryptographic decryption pathway is gone.
Relevant to: GDPR Art. 17 (right to erasure); CCPA §1798.105; deletion obligation verification in litigation.
Third-party production compellability. A court order or subpoena directed to the merchant, vault operator, or registry on day 31 seeking Maya's identity information would be served on parties that do not possess the decryption material. They cannot produce what they cannot access. The destruction is not subject to administrative override.
Relevant to: Third-party subpoena defense; government production requests; discovery obligations.
Retained tiers remain accessible. The merchant tier (amount, item, jurisdiction) and taxation tier are retained per their respective schedules. The destruction of the consumer tier does not affect these. The taxation authority can still audit the tax record — they just cannot access identity they never had.
05

Day 45 — Maya initiates a refund; merchant cannot proceed without her device

The consumer identity tier is destroyed. The merchant cannot bind a refund to the original buyer without Maya's participation. The refund request, signed by Maya's device, travels through the registry for signature verification and is forwarded to the merchant. The merchant awaits a fresh token from Maya's device.

Data flow — refund initiation
Consumer · Maya's device
Issues signed request
"refund tx_a3f2"
Ed25519 signed
signed refund request
Registry
Verifies & routes
verifies signature
routes to merchant
no decryption material
verified refund request
Merchant · Cafe Reverie
Awaiting token
PII layer: destroyed
cannot proceed alone
The merchant cannot process the refund unilaterally. The consumer identity tier is structurally inaccessible. There is no key, no subpoena target, no administrative escalation path that can produce the binding between "refund" and "Maya" without a fresh token from Maya's device.
The registry's function in this stage is signature verification and routing. The registry does not hold decryption material, cannot authorize the refund, and cannot produce the consumer identity information. Its role is to verify that the refund request was signed by the key that corresponds to the original transaction.
Legal significance
Structural first-party requirement. A refund — post-retention-expiration — structurally requires the consumer's device participation. This is not a policy that the merchant or vault operator can waive. There is no administrative escalation path to the merchant that bypasses this requirement.
Relevant to: Consumer right to dispute / charge-back analysis; structural impossibility as defense to production compellability.
What a subpoena to the merchant would yield. The merchant holds: amount ($4.50), item, jurisdiction, and the fact that a refund request exists. They cannot produce Maya's identity, cannot produce the original consumer ciphertext in decrypted form, and cannot process the refund without Maya's device generating a fresh token.
Registry role limitation. The registry verifies Maya's signature and routes the request. A subpoena directed to the registry would yield: a signed refund request, a routing record, and the public key used for verification. The registry does not hold the decryption material for any tier of the original transaction.
06

Maya's device releases a fresh token; refund processes; consumer tier returns to destroyed state

Maya's device derives a refund-scoped token from the on-device root key. The vault uses it to reconstruct the consumer identity layer with a 7-day retention window. The merchant processes the refund. After 7 days, the new window closes and the consumer identity returns to destroyed state.

Data flow — refund completion
Consumer · Maya's device
Issues refund token
api_key_maya
↓ derives
tx_token_a3f2_refund
scoped: refund only
refund-scoped token
Vault
Reconstructs consumer tier
re-encrypts consumer layer
retention: 7 days
re-enabled envelope
Merchant · Cafe Reverie
Processes refund
refund $4.50 → Maya
window: 7 days
The refund-scoped token is derived from the on-device root key — the only material that can produce it. No third party can derive or compel production of this token from any system other than Maya's device. After the refund processes and the 7-day window closes, the consumer identity layer returns to destroyed state.
The refund event is recorded in both the merchant's transaction record and the registry's hash-chained witness log. The taxation tier record now reflects the refund, and any subsequent taxation authority audit would see a verified legitimate refund rather than an unexplained revenue discrepancy.
Legal significance
Impossibility as structural defense. No court order, subpoena, or administrative demand directed to the merchant, vault operator, or registry can produce a refund-scoped token — because none of those parties can derive one. Only Maya's device can. This is a structural property of the cryptographic architecture, not a policy assertion.
Relevant to: Third-party production limits; structural impossibility doctrine; government compulsion analysis.
Post-refund state. After the 7-day window closes, the consumer identity layer is again structurally inaccessible. The system returns to the same state as day 31 — with the addition of a refund record in the merchant and registry logs. No ongoing access to consumer identity is retained by any third party.
Audit trail integrity. The refund event extends the hash chain in the registry's witness log. The chain is tamper-evident. The record of the refund — including the signature verification and routing — is immutable and independently verifiable, without requiring access to the consumer's identity data.
Relevant to: Transaction record authenticity; audit log admissibility; regulatory compliance documentation.
Counsel Summary

Structural legal properties of the ABT-C protocol

Property Technical basis and legal relevance
No plaintext in transit Plaintext is never transmitted over the network at any stage. What moves is ciphertext and per-tier token slices. Interception of network traffic at any point in the protocol yields only encrypted bytes. Relevant to: breach notification threshold; negligence analysis; GDPR Art. 32 technical measures.
Merchant access limited by cryptographic structure The merchant receives only the merchant-tier projection of the transaction envelope. The consumer identity and taxation tiers are cryptographically sealed to the merchant — not by access policy, but by the cryptographic structure of the envelope itself. A subpoena to the merchant produces only what they can decrypt, which is limited to their tier by design.
Vault holds encrypted bytes, not personal data The vault operator holds ciphertext that cannot be read without decryption material controlled by the consumer's device. In the functional sense, the vault is not in possession of personal data — it is in possession of data that cannot be acted upon or disclosed in intelligible form without consumer participation.
Retention enforcement is structural At retention expiration, the decryption pathway for the consumer identity tier is cryptographically destroyed. This is not a deletion policy — the cryptographic material is gone. No administrative override, no extension, no recovery is possible by any party. Relevant to: right-to-erasure compliance; deletion verification; data minimization.
Post-retention production is impossible After day 30, no party — merchant, vault operator, registry operator, or any compelled third party — can produce Maya's identity from this transaction. A subpoena served after retention expiration on any system in the protocol cannot compel production of information that no longer exists in decryptable form in any system.
Refund requires first-party participation Post-retention refunds structurally require Maya's device to derive a fresh token. No third party can derive this token. No court order directed to the merchant, vault, or registry can compel a refund that binds to Maya's identity. The first-party requirement is architectural, not policy-based.
Registry is witness, not controller The registry maintains hash-chained witness logs. It verifies signatures and routes refund requests. It does not route or gate transactions. It does not hold decryption material for any tier. A subpoena to the registry produces: signature verification records, routing records, and the public side of the key pair — not decryption capability.
Tamper-evident audit log All registry-witnessed events extend a hash chain. The chain is tamper-evident: any modification of a prior record breaks the chain in a verifiable way. Records in the chain can be authenticated without access to the plaintext content of any tier.