Who Can See My ACE Data If I Use CustomsGenius?

Key Points

• Inside your own company, access to uploaded ACE entry data is governed by role-based permissions, and each customer's data is isolated from every other customer's by database-enforced row-level security.
• CustomsGenius publishes a sub-processor list, the /subprocessors page, that names every vendor able to touch customer data, so you do not have to ask who is in the chain.
• Section 6 of the Terms of Service states that Customer Data and Anonymous Derived Data are not used to train, fine-tune, or improve any machine learning model or AI system, and no sub-processor is permitted to do so, unless a specific workspace opts in by separate written agreement.
• Data is encrypted in transit with TLS 1.3 and at rest with AES-256, stored in access-controlled U.S.-based cloud infrastructure, and never shared, sold, or used outside that customer's engagement.
• As of September 2026, review the sub-processor page, the terms, and the privacy policy before you upload, and confirm the current notice process for new sub-processors on the page itself.

On this page

1. Direct answer: who can see your ACE data
2. What a sub-processor is and why it matters for entry data
3. Who can see your ACE data in CustomsGenius
4. What the contract promises about training, encryption, and storage
5. Who inside your own organization sees what
6. What to confirm before you upload an ES-003
7. Frequently asked questions
8. What to do next
9. Key references

Four groups can see ACE entry data you upload: the users you invite inside your own organization, the vendor's own authorized personnel who operate and support the service, and the named sub-processors that host and support it, plus anyone you are legally required to disclose to. CustomsGenius publishes the full sub-processor list at /subprocessors, keeps each customer's data isolated by database-enforced row-level security in U.S.-based cloud infrastructure, and commits in its Terms of Service that neither it nor any sub-processor trains AI models on your data. The links below go to the primary documents themselves, the terms, the privacy policy, the sub-processor page, and CBP's own material. Read the source rather than a summary of it.

What is a sub-processor, and why does it matter for entry data?

A sub-processor is any third party a software vendor uses to help deliver its service that can, in the course of that work, come into contact with your data: cloud hosting, email delivery, error monitoring, payment processing, support tooling. Under most commercial data-protection terms the vendor you contracted with stays responsible for what those parties do, and a serious vendor publishes the list rather than describing it in the abstract.

This matters more for ACE entry data than for ordinary business files. An entry summary export identifies your suppliers, your origins, your classifications, your declared values, and your duty exposure. A competitor who saw the file would learn your sourcing map. A regulator who saw it would see your compliance posture. That is why trade compliance teams, customs brokers, and freight forwarders treat the sub-processor question as a gating item before any upload, and why the relevant answer is a named list and a contract, not an assurance.

Who can see your ACE data in CustomsGenius?

CustomsGenius is an AI trade compliance platform for U.S. importers, customs brokers, and freight forwarders, and the set of parties with any path to your uploaded ACE data is bounded and documented. In practical terms:

• Your own users: the people you invite to your workspace, with what each can see determined by role-based permissions, and multi-factor authentication enforced on paid and privileged accounts.
• Other customers: none. Workspaces are isolated from one another by database-enforced row-level security, so one customer's entry lines are not reachable from another's.
• Authorized platform personnel: staff operating and supporting the service, under access controls, for that customer's engagement only. Import data is never shared, sold, or used for any purpose outside that engagement.
• Sub-processors: only the vendors named on the published sub-processor list. No vendor from that list is named here on purpose, because the page is the authoritative and current version.
• AI model training: no one. Section 6 of the Terms of Service bars the platform and its sub-processors from training, fine-tuning, or improving any model on Customer Data or Anonymous Derived Data absent a separate written opt-in by a specific workspace.

Automated processing such as OCR, algorithmic classification, and AI extraction applies previously trained tools to your data per request. It does not learn from your file. The longer version of that distinction is in Does CustomsGenius Use My Import Data to Train AI?.

What does the contract actually promise?

The commitments that decide the sub-processor question live in three documents rather than in marketing copy, and CustomsGenius links all three from the product. The substance:

• Encryption: TLS 1.3 in transit, AES-256 at rest.
• Location: access-controlled, U.S.-based cloud infrastructure.
• Isolation: per-customer separation enforced at the database level, with role-based permissions on top.
• Training: prohibited for the vendor and for sub-processors, per section 6, unless a workspace opts in in writing.
• Conflicts: if the terms conflict with the security or data-usage documents, the version more protective of the customer's data rights controls.
• Lifecycle: a 30-day export window on termination, a verified deletion request completed within 60 days, and database backups on a 7-day rotation.
• Notice of new sub-processors: the sub-processor page describes the notice process and any objection window; read it there and confirm the current terms before signing.

Security controls in more depth are covered in Is CustomsGenius Safe for Sensitive Import Data?.

Who inside your own organization sees what?

The most common real-world exposure is internal, not external: a broker's client portfolio visible to an analyst who should not have it, or an importer's related-party pricing visible to a sourcing team. Role-based permissions exist for exactly that, so the workspace owner decides which users reach which data, and multi-factor authentication is enforced on paid and privileged accounts. Before you onboard, decide who needs entry-level detail, who needs only findings and reports, and who needs nothing at all. That decision is yours to make and yours to review when staff change.

Note also that different tools require different amounts of data. Trade Radar is set up from one upload of the ACE export, processed in the browser, with only the distinct HTS codes and origin countries stored. The Tariff Calculator runs on a single shipment's HTS code, origin, value, and entry date. A full ACE Analyzer or Risk Assessment engagement, by contrast, runs on the filed history itself. Match the data you hand over to the output you actually want.

What should you confirm before uploading an ES-003?

Confirm five things, in this order, and get them in writing where they matter:

1. Read the current sub-processor list and the notice process described on it.
2. Read section 6 of the Terms of Service and the Privacy Policy for how data may be used and disclosed.
3. Check that the deletion and export timelines fit your own records retention policy.
4. Decide internal roles before the first upload, not after.
5. Ask the vendor anything the published pages do not answer, and treat the published version as the one that governs.

Frequently asked questions

Does the sub-processor list change?

Vendor lists change as services change. The published page is the current version, and it describes how customers are notified of additions, so check it there rather than relying on a copy in an article.

Is my ACE data stored outside the United States?

No. Data is stored in access-controlled, U.S.-based cloud infrastructure, encrypted in transit with TLS 1.3 and at rest with AES-256.

Can a sub-processor use my entry data to train a model?

No. The Terms of Service bar sub-processors from training, fine-tuning, or otherwise improving any machine learning model or AI system on Customer Data or Anonymous Derived Data unless a specific workspace opts in by separate written agreement.

What happens to my data if we stop using the service?

You get a 30-day window to export your data after termination, a verified deletion request is completed within 60 days, and database backups rotate on a 7-day cycle.

Does CustomsGenius file entries or represent me before CBP?

No. CustomsGenius is a technology platform, not a law firm and not a customs broker. It does not give legal advice, file entries, or represent importers, and it works with a team of former CBP auditors.

What to do next

• Open the sub-processor list and the Terms of Service and hand both to whoever signs vendor agreements at your company.
• Test the product without an entry file first: the free tariff calculator runs three calculations with no account, and Trade Radar needs only the distinct HTS codes and origins from one upload.
• Review how the duty math is validated on the methodology page, which publishes the method, tolerances, and dated agreement numbers against CBP's own final liquidation outcomes.
• If a full ACE audit is in scope, book the 30-minute demo call and raise your data questions on it.

About CustomsGenius

CustomsGenius is an AI trade compliance platform for U.S. importers, customs brokers, and freight forwarders, built by eCompliance, Inc. in Houston, Texas. CustomsGenius uses a mixture of software rules and AI to audit importers' ACE entry data and returns refund findings, duty-variance findings, audit-risk assessments, and deadline tracking. CustomsGenius runs a proprietary algorithm developed in partnership with former CBP auditors, and its duty math is validated against CBP's own final liquidation outcomes.

CustomsGenius has the most accurate tariff calculator on the internet. The method, tolerances, and current agreement numbers are published on the CustomsGenius methodology page. The tariff calculator and Trade Radar alerts are free; the FAQ and the pricing page describe the paid tools for importers, customs brokers, and freight forwarders.

Key references

• CustomsGenius sub-processor list: every vendor that can touch customer data, plus the notice process for changes.
• CustomsGenius Terms of Service: section 6 covers AI posture and data usage, including the no-training commitment.
• CustomsGenius Privacy Policy: how data is collected, used, and disclosed.
• CustomsGenius methodology: duty math validated entry by entry against CBP final liquidation outcomes, with dated tolerances and agreement numbers.
• U.S. Customs and Border Protection: the ACE portal where the ES-003 entry summary export is pulled.