Type of allocator:
What is your overall diligence process? Automated (programmatic), Market-based, or Manual (human-in-the-loop at some phase). Initial allocations to these pathways will be capped.
Manual
Amount of DataCap Requested for allocator for 12 months:
100 PiB
Is your allocator providing a unique, new, or diverse pathway to DataCap? How does this allocator differentiate itself from other applicants, new or existing?
Yes, our DataCap allocator indeed offers unique, innovative, and diversified paths to support applicants of different types and sizes. Our approach is distinct in several key aspects:
Personalized Assessment Process: Our allocator doesn't rely solely on standardized review processes. Instead, it employs a personalized assessment strategy, meaning we adjust our evaluation criteria and processes according to the specific situation and needs of each applicant. This approach ensures fair and transparent treatment for both new and existing applicants.
Innovative Risk Assessment Model: Our team utilizes an advanced risk assessment model that combines automated data analysis with expert review. This not only improves the efficiency of evaluations but also enhances our ability to identify and manage potential risks.
Diversified DataCap Options: We offer a variety of DataCap options, including but not limited to different amounts, terms, and conditions. Such diversity allows us to better meet the needs of different applicants, from small businesses to large organizations.
Ongoing Oversight and Support: Unlike other allocators, we provide ongoing oversight and support to ensure effective and compliant use of DataCap. Our team maintains close contact with applicants, offering necessary guidance and assistance.
Transparency and Traceability: We emphasize transparency and traceability throughout the allocation process. Applicants can track the status of their applications and DataCap usage in real-time through our platform, playing a key role in enhancing trust and reliability.
In summary, our allocator stands out with these unique features and innovative methods from other allocators for new or existing applicants, committed to providing more equitable, efficient, and adaptable DataCap allocation services.
As a member in the Filecoin Community, I acknowledge that I must adhere to the Community Code of Conduct, as well other End User License Agreements for accessing various tools and services, such as GitHub and Slack.
Additionally, I will adhere to all local & regional laws & regulations that may relate to my role as a business partner, organization, notary, or other operating entity. *
You can read the Filecoin Code of Conduct here: https://github.com/filecoin-project/community/blob/master/CODE_OF_CONDUCT.md
Acknowledgment: Acknowledge
Cient Diligence Section:
This section pertains to client diligence processes.
Who are your target clients?
Small-scale developers or data owners,Enterprise Data Clients
Describe in as much detail as possible how you will perform due diligence on clients.
Our due diligence process takes into account multiple key factors, including but not limited to the financial strength of the client, the sustainability of the business model, compliance, and the authenticity and accuracy of the data provided by the client. This process is divided into several main stages:
Preliminary Data Collection (Manual Stage)
We first gather basic information about the client, including company registration details, financial reports, market share data, etc. Advanced data scraping and analysis tools are used to automatically extract relevant information from various databases and public resources, including credit rating agencies, industry reports, and news sources.
In-depth Data Analysis (Combination of Automated and Manual)
Automated tools are used for preliminary analysis of the collected data to identify potential risks and opportunities. Algorithms and models are employed to assess the client's financial stability, growth potential, and the sustainability of their business model.
Compliance Check (Automated Stage)
Compliance reviews, including Anti-Money Laundering (AML), Counter-Terrorism Financing (CFT), and international sanctions checks, are conducted through automated systems. Specific software tools are used to screen client lists to ensure they are not on any international sanctions lists.
Risk Assessment (Manual Stage)
Potential risks are identified and categorized, including credit risk, market risk, and operational risk. A professional team conducts an in-depth analysis based on Know Your Business (KYB) situations to ensure a comprehensive understanding and assessment of the client's risk profile.
Human Interaction (Manual Stage)
The final stage of due diligence includes direct interactions with the client, such as through face-to-face meetings, telephone inquiries, or on-site visits. This stage aims to verify the information collected and gain a deeper understanding of the client's business operations, management team, and company culture.
Ongoing Monitoring and Assessment (Combination of Automated and Manual)
Even after the completion of due diligence, ongoing monitoring of the client’s status and performance is conducted to identify any new risks or opportunities. Automated tools are used to track key indicators and market dynamics, while the professional team evaluates and interprets this information.
Through this multi-layered due diligence process combining automated and manual methods, we are able to comprehensively assess the qualifications of our clients while ensuring efficiency and accuracy. The automated methods provide the capacity for efficiency and large-scale data processing, while the manual methods offer in-depth analysis and human intuition. The combination of both ensures the comprehensiveness and effectiveness of the due diligence.
Please specify how many questions you'll ask, and provide a brief overview of the questions.
Can you introduce yourself? Where can I find you online? (Github, Twitter, LinkedIn handles)
What is the use case for the DataCap you are requesting?
What is the Filecoin address you would like me to allocate the DataCap to?
How much DataCap are you requesting?
For organizational clients:
First, the client's Filecoin address needs to be disclosed so that we can closely monitor it after the DataCap allocation. Additionally, we will pay close attention to the storage orders issued by such clients from time to time (especially verified deals) and related storage providers.
As mentioned above, the granted DataCap will be provided to clients in stages. Therefore, if it is found that the client excessively allocates their available DataCap to any single entity, we can usually block the allocation of the remaining DataCap.
We will establish a client rating mechanism to score clients with different trust levels. The more diversified a client allocates its granted DataCap, the higher the score it will receive. Allocating less than 30% of DataCap to any storage provider can earn bonus points, while deploying more than 50% DataCap to any storage miner over a period of time will result in a deduction.
Penalties - If a client scores too low in terms of storage provider diversification, a warning will be issued, and all other notaries will be notified of the aforementioned "over-concentration of allocation." If any client continuously ignores our warnings, further punitive measures may be taken, such as the revocation of the remaining DataCap.
Audits - External and internal audits will be conducted throughout the data deployment process. Community members are encouraged to participate as external auditors to disclose any client's excessive focus on DataCap allocation.
What is the name, nature, country of registration, establishment time, and designated officials of your organization? Please link to relevant websites.
In which region do you intend to use the DataCap? If you plan to use DataCap in multiple regions, please specify.
How many DataCap miners do you plan to allocate? If you have specific miners you want to allocate DataCap to, please indicate.
Will you use a 3rd-party "Know your client" (KYC) service?
Yes, we do utilize third-party "Know Your Customer" (KYC) services to enhance and perfect our client due diligence process. Here are detailed insights about these services, including their scope and how they integrate with our processes:
Service Overview
Third-party KYC services provide comprehensive identity verification and background check capabilities, essential for ensuring client compliance and reducing the risk of financial crimes. These services typically include verification of client identity, review of financial history, assessment of political risks, and checks against global sanctions and regulatory lists.
Key Issues and Regions Covered
Identity Verification: Confirming the client's identity, including name, address, date of birth, and the validity of identity documents.
Credit and Financial History: Assessing the client's financial standing, including credit records and past financial transactions.
Politically Exposed Persons (PEP) Screening: Checking if the client is or is connected to politically exposed persons, critical for avoiding corruption and money laundering.
Global Regulatory and Sanctions List Checks: Ensuring the client is not involved in any global sanctions or regulatory issues, vital for compliance.
Data Integration and Application
Third-party KYC services usually offer API interfaces, allowing us to integrate their services into our internal systems. During the client application process, the collected client information is automatically transmitted to the third-party KYC service for verification and analysis. The data returned by the third-party service is automatically integrated into our due diligence reports, ensuring we have a comprehensive, up-to-date view of the client's profile.
Data Security and Privacy
The chosen third-party KYC service providers must adhere to stringent data security and privacy standards to protect client information from being leaked or misused. We regularly review these service providers' security measures to ensure they comply with the latest regulatory requirements and best practices.
In summary, third-party KYC services are an indispensable part of our due diligence process, offering additional layers and security to ensure we can effectively assess and monitor client risks. By integrating these services with our processes, we are able to provide a more comprehensive and efficient client review experience.
Can any client apply to your pathway, or will you be closed to only your own internal clients? (eg: bizdev or self-referral)
Any client can apply, and we also offer services to apply on behalf of some clients.
How do you plan to track the rate at which DataCap is being distributed to your clients?
We will proceed in accordance with the Datacap Allocation Plan.
Data Diligence
This section will cover the types of data that you expect to notarize.
As a reminder: The Filecoin Plus program defines quality data is all content that meets local regulatory requirements AND
• the data owner wants to see on the network, including private/encrypted data
• or is open and retrievable
• or demonstrates proof of concept or utility of the network, such as efforts to improve onboarding
As an operating entity in the Filecoin Community, you are required to follow all local & regional regulations relating to any data, digital and otherwise. This may include PII and data deletion requirements, as well as the storing, transmitting, or accessing of data.
Acknowledgement: Acknowledge
What type(s) of data would be applicable for your pathway?
Public Open Dataset (Research/Non-Profit),Public Open Commercial/Enterprise,Private Commercial/Enterprise
How will you verify a client's data ownership? Will you use 3rd-party KYB (know your business) service to verify enterprise clients?
Verifying a client's data ownership is a key step in ensuring data compliance and maintaining business integrity. Using third-party Know Your Business (KYB) services to validate corporate clients is an effective method to confirm data sources and ownership. Here is a detailed explanation:
Data Ownership Verification Process:
Preliminary Information Collection: Initially, collect data and related documents provided by the client, such as statements of data sources, usage agreements, and any supporting documents.
Review of Ownership Proof Documents: Review any legal documents provided by the client to prove their ownership of the data. This may include copyright statements, purchase agreements, authorization licenses, etc.
Using KYB Services:
Corporate Identity Verification: KYB services first verify the legitimacy of the enterprise, including company registration details, business licenses, identities of legal representatives, etc.
Background Checks: Conduct in-depth background checks to understand the enterprise's history, shareholder structure, management, and any past compliance or legal issues.
Financial Audit: Review the enterprise's financial records to confirm the consistency between their business activities and the data they claim to own.
Market Reputation Assessment: Assess the enterprise's reputation and credibility in the market, including information from industry databases and credit rating agencies.
Data Source Verification:
Direct Verification: Where possible, directly verify the authenticity and ownership of data from its original source or third-party institutions.
Contract and License Review: Carefully inspect all contracts and licenses related to the data to ensure the corporate client has the legal right to use and own the data.
Ongoing Monitoring: After initial verification, regularly monitor and review the client's business activities and data usage to ensure continuous compliance.
Privacy and Security Compliance: Ensure the entire verification process complies with data protection and privacy regulations, such as the EU's GDPR or other relevant laws in different jurisdictions.
Through this comprehensive verification process, including the use of third-party KYB services, the legal ownership of the data claimed by corporate clients can be effectively confirmed. This not only helps reduce compliance risks but also enhances the transparency and trust in business relationships.
How will you ensure the data meets local & regional legal requirements?
To ensure that data complies with local and regional legal requirements, we will implement a comprehensive data management and compliance strategy, conduct regular compliance audits, provide training to employees on data protection laws, and collaborate with third-party partners to ensure their compliance. Additionally, we will continuously monitor legal changes to ensure our strategies are updated in a timely manner.
What types of data preparation will you support or require?
We require thorough data preparation, including cleaning, standardization, de-identification, anonymization, as well as data enrichment and integration. We support data segmentation processing and provide automated data cleaning tools, data de-identification solutions, and data integration platforms to ensure data quality, security, and compliance with regulatory requirements.
What tools or methodology will you use to sample and verify the data aligns with your pathway?
We will use advanced data analysis tools and algorithms for sample extraction and validation to ensure the data meets our standards. By comparing the actual type and preparation status of the data with the client's declaration, we confirm consistency. To prevent sector size abuse and padding, we will implement strict monitoring and automatic detection mechanisms.
Data Distribution
This section covers deal-making and data distribution.
As a reminder, the Filecoin Plus program currently defines distributed onboarding as multiple physical locations AND multiple storage provider entities to serve client requirements.
How many replicas will you require to meet programmatic requirements for distribution?
5+
What geographic or regional distribution will you require?
3 physical locations
How many Storage Provider owner/operators will you require to meet programmatic requirements for distribution?
5+
Do you require equal percentage distribution for your clients to their chosen SPs? Will you require preliminary SP distribution plans from the client before allocating any DataCap?
Yes, we require clients to allocate an equal percentage of DataCap to their chosen Storage Providers (SPs). Before allocating any DataCap, we need clients to provide a preliminary SP allocation plan. This information will be collected through a pre-designed template to ensure consistency and completeness.
What tooling will you use to verify client deal-making distribution?
datacapstats.io & CID CHECKER BOT
How will clients meet SP distribution requirements?
Proceed based on the KYC and allocation plan provided by the client.
As an allocator, do you support clients that engage in deal-making with SPs utilizing a VPN?
In cases where the use of a VPN is necessary, we will provide support, but clients must ensure that their physical location still meets our requirements. Additionally, clients need to explicitly disclose the use of a VPN, so that we can carry out the appropriate processing and assessment. To track VPN usage, we will implement monitoring systems to detect and record VPN activities, including connection times, duration, and source IP addresses. Furthermore, these data will be regularly reviewed and analyzed to ensure compliance and security.
DataCap Allocation Strategy
In this section, you will explain your client DataCap allocation strategy.
Keep in mind the program principle over Limited Trust Over Time. Parties, such as clients, start with a limited amount of trust and power.
Additional trust and power need to be earned over time through good-faith execution of their responsibilities and transparency of their actions.
Will you use standardized DataCap allocations to clients?
Yes, standardized
Allocation Tranche Schedule to clients:
First: 10%
Second: 15%
Third: 25%
Fourth: 50%
Overall cap for each client: 1PiB
Will you use programmatic or software based allocations?
Yes, standardized and software based
What tooling will you use to construct messages and send allocations to clients?
Describe the process for granting additional DataCap to previously verified clients.
When granting additional DataCap to previously verified clients, we initiate subsequent allocation requests based on standards such as 10% of the remaining DataCap. For this, we may use open-source tools like the Subsequent Allocation (SA) bot or other automation tools to ensure the efficiency and transparency of the process.
Tooling & Bookkeeping
This program relies on many software tools in order to function. The Filecoin Foundation and PL have invested in many different elements of this end-to-end process, and will continue to make those tools open-sourced. Our goal is to increase adoption, and we will balance customization with efficiency.
This section will cover the various UX/UI tools for your pathway. You should think high-level (GitHub repo architecture) as well as tactical (specific bots and API endoints).
Describe in as much detail as possible the tools used for:
• client discoverability & applications
• due diligence & investigation
• bookkeeping
• on-chain message construction
• client deal-making behavior
• tracking overall allocator health
• dispute discussion & resolution
• community updates & comms
Customer Discovery and Application: Market analysis tools (Google Analytics) to understand customer behavior and preferences.
Due Diligence and Survey: Background check tools (LexisNexis) for customer background and reputation investigation; Survey software (SurveyMonkey) to collect customer feedback and opinions.
Bookkeeping: Spreadsheet software (Microsoft Excel) for data analysis and record-keeping.
On-Chain Message Construction: Blockchain interaction tools (Ledger, GILF) for creating and sending on-chain messages.
Customer Transaction Behavior: Data analysis tools (Tableau, Power BI) to analyze and visualize transaction data.
Tracking Overall Allocator Health: Health assessment tools (such as Riskalyze) to evaluate the overall health of the organization.
Dispute Discussion and Resolution: Online collaboration tools (Slack) to facilitate discussion and collaboration among teams.
Community Updates and Communication: Social media management tools (Slack) to manage social media accounts and updates.
Will you use open-source tooling from the Fil+ team?
In most cases we will choose to use the open source tools of the Fil+ team.
Where will you keep your records for bookkeeping? How will you maintain transparency in your allocation decisions?
We will designate a Github repository to record this information and make it public.
What will your DataCap distribution look like?
N/A
Risk Mitigation, Auditing, Compliance
This framework ensures the responsible allocation of DataCap by conducting regular audits, enforcing strict compliance checks, and requiring allocators to maintain transparency and engage with the community. This approach safeguards the ecosystem, deters misuse, and upholds the commitment to a fair and accountable storage marketplace.
In addition to setting their own rules, each notary allocator will be responsible for managing compliance within their own pathway. You will need to audit your own clients, manage interventions (such as removing DataCap from clients and keeping records), and respond to disputes.
Describe your proposed compliance check mechanisms for your own clients.
To ensure compliance and effectively manage the distribution of DataCap and its downstream usage by clients, we propose implementing the following mechanisms:
Regular Check-ins: Schedule regular audit meetings to assess the usage of DataCap and client compliance. These check-in meetings will involve in-depth discussions about the ways and purposes clients use DataCap.
Tracking DataCap Distribution Metrics: Implement a monitoring system to track the allocation and usage of DataCap, focusing on key metrics such as the remaining amount of DataCap, frequency of allocation, etc. Use automated tools to collect and analyze this data to timely identify any abnormal patterns.
Understanding Client Demographics: Collect and analyze the demographic information of clients to ensure the diversity and fairness of DataCap allocation. This includes considering factors such as the geographical location, industry type, and company size of clients.
Monitoring Time Metrics: Track the time patterns of clients using DataCap, such as frequency and duration of use, to ensure a reasonable distribution. Regularly assess whether clients complete data storage and usage on time to manage the effectiveness of DataCap.
Trust Assessment: Conduct initial trust assessments for new clients, including their historical credit records and business reputation.
Adjust DataCap allocation for new clients based on trust assessment results to control risks.
Using Tools Like CID Checker/Retrievability Bot: Utilize tools like CID Checker to verify the data stored by clients, ensuring it matches what is declared. Retrievability bots can be used to monitor and verify the retrievability of data, ensuring clients comply with storage agreements.
Through these mechanisms, we can ensure the reasonable use of DataCap and promptly identify and resolve potential compliance issues. Our tolerance for new clients will be based on their credit and compliance history, with initial DataCap allocations possibly being more conservative, increasing gradually as trust is established.
Describe your process for handling disputes. Highlight response times, transparency, and accountability mechanisms.
When handling disputes in DataCap allocation, our process emphasizes rapid response, transparency, and accountability:
Dispute Reception and Response Time: Upon receiving a dispute, we commit to an initial response within 72 hours, acknowledging receipt and beginning the process. Depending on the complexity of the dispute, we set a clear timetable for resolution, typically not exceeding one week.
Transparent Processing: We ensure the dispute resolution process is fully transparent to all involved parties. We maintain awareness of the process's progress through regular updates and open communication channels.
Information Collection and Review: Conduct a thorough review of the dispute, gathering all relevant information and evidence. This may include DataCap allocation records, evidence of data storage compliance, or details of executed storage transactions.
Neutral Mediation and Solution Proposal: When necessary, we may seek a third-party neutral mediator to ensure the fairness of decisions. We propose fair and reasonable solutions and seek consent from all relevant parties.
Accountability Mechanism and Record Keeping: We document the entire dispute resolution process and outcomes for future reference and accountability. When necessary, we adjust internal policies and processes to prevent similar disputes from recurring.
External Dispute Handling: For disputes involving external parties, such as another notary or the Fil+ governance team, we actively participate in discussions and defend our decisions. We provide comprehensive evidence and reasoning to ensure our position is fully understood and considered.
Through this process, we are committed to resolving any disputes fairly and efficiently, while maintaining the interests of all participants and the overall health of the network.
Detail how you will announce updates to tooling, pathway guidelines, parameters, and process alterations.
We will notify of updates to tools, guidelines, parameters, and processes in advance through email, social media, and our official website. Updates will undergo internal review to ensure they meet security and compliance standards, and frequent changes will be avoided to reduce confusion. Significant changes may require re-submission to the Fil+ governance team for review. We will also provide detailed documentation and guides to ensure users understand and adapt to these changes.
How long will you allow the community to provide feedback before implementing changes?
Before implementing changes, we plan to provide at least two weeks for community members to provide feedback. This timeframe is intended to ensure ample community participation while allowing enough time for careful consideration and discussion. The process of community interaction, moderation, and feedback balancing will proceed as follows:
Public Forums and Discussion Platforms: Use community forums, social media groups, and online webinars to post proposed changes, encouraging open discussion. Provide detailed explanations of the changes and potential impact assessments to foster meaningful dialogue.
Collection and Analysis of Feedback: Set up dedicated channels (such as online surveys, feedback forms) to gather opinions and suggestions from community members. Regularly analyze the collected feedback to identify common concerns and trends.
Providing Moderation and Facilitation: When necessary, hold online meetings or workshops to discuss key issues and concerns of the community. Offer professional mediation services to assist in resolving disagreements and conflicts.
Weighing Feedback and Making Decisions: Consider community feedback but also combine practical operational needs and long-term goals to make decisions. Clearly explain the reasons behind decisions to ensure transparency in the decision-making process.
Maintaining a Decentralized yet Orderly Structure: Respect the diverse voices of the community while ensuring that the decision-making process is orderly and efficient. Maintain appropriate guidance and management to ensure the healthy development and continued participation of the community.
Through this approach, we aim to balance the spirit of decentralization with efficiency and effectiveness in practical operations, ensuring that community members can actively participate and contribute to important decisions.
Regarding security, how will you structure and secure the on-chain notary address? If you will utilize a multisig, how will it be structured? Who will have administrative & signatory rights?
To ensure the security of on-chain notary addresses, we will take the following measures:
Multi-Signature Setup: We will use multi-signature wallets to protect the on-chain notary addresses. This means that any transaction or change will require signatures from multiple authorized individuals. The construction of multi-signature will involve different administrators to ensure there is no single point of failure or security vulnerability.
Distribution of Management and Signing Authority: Management and signing authority will be allocated to trusted team members who are carefully selected due to their roles in the organization and awareness of security. Ensure these members are properly trained in security and understand their responsibilities and roles.
IT Security Measures: Implement strengthened security measures for all devices used to manage and access the notary addresses, including antivirus software, firewalls, and other network security tools. Regularly update software and security protocols to prevent potential cyber attacks and vulnerabilities.
Operational Security (OpSec) Measures: Implement strict data access control to ensure only authorized personnel can access sensitive information. Regularly conduct security audits and risk assessments to identify and address potential security threats in a timely manner.
Backup and Disaster Recovery Plan: Develop a backup strategy to regularly back up all critical data and wallet keys. Prepare a disaster recovery plan to respond to data loss or other emergencies.
Employee Training and Awareness: Conduct security training for all employees involved in the operation of on-chain notary addresses, raising their awareness of cyber security threats. Educate employees to recognize and defend against social engineering attacks and phishing attempts.
Through these measures, we aim to establish a secure and reliable environment to protect on-chain notary addresses from unauthorized access and potential security threats.
Will you deploy smart contracts for program or policy procedures? If so, how will you track and fund them?
Currently, there is no such setting.
Monetization
While the Filecoin Foundation and PL will continue to make investments into developing the program and open-sourcing tools, we are also striving to expand and encourage high levels of service and professionalism through these new Notary Allocator pathways. These pathways require increasingly complex tooling and auditing platforms, and we understand that Notaries (and the teams and organizations responsible) are making investments into building effective systems.
It is reasonable for teams building services in this marketplace to include monetization structures. Our primary guiding principles in this regard are transparency and equity. We require these monetization pathways to be clear, consistent, and auditable.
Outline your monetization models for the services you provide as a notary allocator pathway.
As a notary allocator, our monetization model combines compliance assurance, service quality, and a transparent fee structure. Here are the specific details of the model:
Pledges and Collateral Reduction: Implement a policy of pledge and collateral reduction based on compliance for clients or Storage Providers (SPs). For example, non-compliant behavior may lead to partial reduction of collateral. The pledge amounts and reduction percentages will be determined based on specific compliance situations and risk levels.
Service Fees:
Application Review Fee: We may charge a service fee for processing and reviewing DataCap applications. For instance, small (under 100TiB) applications might incur a fee of 50 FIL, while large (over 100TiB) applications could be as high as 200 FIL.
Data Preparation Fee: For data cleaning, standardization, and de-identification services, fees will be charged based on data volume and complexity, ranging from 100 FIL to 1000 FIL.
Data Exchange Distribution Fee: For data distribution using data exchanges, fees may be charged based on data volume and transmission frequency, such as 10 FIL per TB of data.
Audit Fee: For regular or on-demand auditing services, fees may vary depending on the required workload and complexity, ranging from 100 FIL to several thousand FIL.
Transparent Pricing Strategy:
All service fees and pledge requirements will be clearly communicated to clients before the commencement of services. Regularly assess and adjust the fee structure to ensure competitiveness and service quality.
Flexibility and Customized Services:
Offer customized service options to meet the specific needs of different clients, with fees tailored according to the scope and complexity of services.
Through this monetization model, we aim to provide high-quality services while ensuring the transparency and fairness of the notary allocation process. Our goal is to create a sustainable model that maintains operations and provides value to clients.
Describe your organization's structure, such as the legal entity and other business & market ventures.
BigFrog Technology is a blockchain team established in 2017, focusing on project investment and Bitcoin mining. Since the initial coin offering (ICO) of FILECOIN, BigFrog began to pay attention to and research FILECOIN, while also engaging in related promotions. The core members of the team are early Bitcoin evangelists with over eight years of experience in the crypto field. They have made early investments in projects like Ethereum and have experience with trading platforms. Since 2019, BigFrog members have been contributing to the Filecoin network through DAYOU, which has a strong brand influence in the Chinese community. They have been actively promoting the Filecoin ecosystem, helping more people understand and use Filecoin. BigFrog is committed to becoming a high-quality Storage Provider (SP), serving over 60,000 customers through DAYOUAPP (https://www.dayou8.com/), and currently contributes over 80PiB of storage space to Filecoin. In the past two years, nearly a thousand FILECOIN articles have been published through GCR's traditional media (WeChat: Dayou IPFS Research Institute). DAYOU focuses on the development of Filecoin's technical ecosystem and establishing more storage providers, planning to bring more users into Web3/Metaverse through distributed storage technology. In the future, BigFrog plans to develop a series of ecological applications to serve the general public, such as distributed storage cloud disk, Filecoin staking, distributed TikTok, etc.
Where will accounting for fees be maintained?
Cost accounting will be conducted in a dedicated, transparent financial management system, ensuring that all transactions are recorded and traceable. The destruction or release of pledges will be based on compliance and contractual terms, regularly audited by Fil+ governance and other stakeholders, to ensure the transparency and fairness of the monetization process.
If you've received DataCap allocation privileges before, please link to prior notary applications.
How are you connected to the Filecoin ecosystem? Describe your (or your organization's) Filecoin relationships, investments, or ownership.
Since 2019, members of BigFrog Technology have been contributing to the Filecoin network over the long term through DAYOU; currently, DAYOU has a strong brand influence in the Chinese community; we have been actively popularizing the Filecoin ecosystem in the community, helping more people to understand and benefit from Filecoin; we are committed to becoming a high-quality SP (Storage Provider), and we have already served over 60,000 customers through DAYOUAPP (https://www.dayou8.com/), contributing over 150PiB of storage space to Filecoin. In the past two years, nearly a thousand articles about FILECOIN have been published in GCR's traditional media (WeChat: Dayou IPFS Research Institute), promoting FILECOIN.
How are you estimating your client demand and pathway usage? Do you have existing clients and an onboarding funnel?
We estimate customer demand and usage paths through market analysis and customer feedback. We use advanced data analysis tools and survey methods to gather information on market trends and customer preferences. With our existing customer base, we attract new clients through a multi-channel marketing strategy, including social media, partner networks, and online advertising. We also effectively expand our onboarding channels through customer referrals and word-of-mouth promotion.
Pathway Name:
DAYOU
Organization:
BigFrog Technology
Allocator's On-chain addresss:
f1cl4gtwjlt5udxwootzllba3kcyisjphujviiimq
Country of Operation:
Hong Kong
Region(s) of operation:
Asia minus GCR,Greater China,Japan,North America
Type of allocator: What is your overall diligence process? Automated (programmatic), Market-based, or Manual (human-in-the-loop at some phase). Initial allocations to these pathways will be capped.
Manual
Amount of DataCap Requested for allocator for 12 months:
100 PiB
Is your allocator providing a unique, new, or diverse pathway to DataCap? How does this allocator differentiate itself from other applicants, new or existing?
Yes, our DataCap allocator indeed offers unique, innovative, and diversified paths to support applicants of different types and sizes. Our approach is distinct in several key aspects:
Personalized Assessment Process: Our allocator doesn't rely solely on standardized review processes. Instead, it employs a personalized assessment strategy, meaning we adjust our evaluation criteria and processes according to the specific situation and needs of each applicant. This approach ensures fair and transparent treatment for both new and existing applicants. Innovative Risk Assessment Model: Our team utilizes an advanced risk assessment model that combines automated data analysis with expert review. This not only improves the efficiency of evaluations but also enhances our ability to identify and manage potential risks. Diversified DataCap Options: We offer a variety of DataCap options, including but not limited to different amounts, terms, and conditions. Such diversity allows us to better meet the needs of different applicants, from small businesses to large organizations. Ongoing Oversight and Support: Unlike other allocators, we provide ongoing oversight and support to ensure effective and compliant use of DataCap. Our team maintains close contact with applicants, offering necessary guidance and assistance. Transparency and Traceability: We emphasize transparency and traceability throughout the allocation process. Applicants can track the status of their applications and DataCap usage in real-time through our platform, playing a key role in enhancing trust and reliability. In summary, our allocator stands out with these unique features and innovative methods from other allocators for new or existing applicants, committed to providing more equitable, efficient, and adaptable DataCap allocation services.
As a member in the Filecoin Community, I acknowledge that I must adhere to the Community Code of Conduct, as well other End User License Agreements for accessing various tools and services, such as GitHub and Slack. Additionally, I will adhere to all local & regional laws & regulations that may relate to my role as a business partner, organization, notary, or other operating entity. * You can read the Filecoin Code of Conduct here: https://github.com/filecoin-project/community/blob/master/CODE_OF_CONDUCT.md
Acknowledgment: Acknowledge
Cient Diligence Section:
This section pertains to client diligence processes.
Who are your target clients?
Small-scale developers or data owners,Enterprise Data Clients
Describe in as much detail as possible how you will perform due diligence on clients.
Our due diligence process takes into account multiple key factors, including but not limited to the financial strength of the client, the sustainability of the business model, compliance, and the authenticity and accuracy of the data provided by the client. This process is divided into several main stages:
Preliminary Data Collection (Manual Stage) We first gather basic information about the client, including company registration details, financial reports, market share data, etc. Advanced data scraping and analysis tools are used to automatically extract relevant information from various databases and public resources, including credit rating agencies, industry reports, and news sources.
In-depth Data Analysis (Combination of Automated and Manual) Automated tools are used for preliminary analysis of the collected data to identify potential risks and opportunities. Algorithms and models are employed to assess the client's financial stability, growth potential, and the sustainability of their business model.
Compliance Check (Automated Stage) Compliance reviews, including Anti-Money Laundering (AML), Counter-Terrorism Financing (CFT), and international sanctions checks, are conducted through automated systems. Specific software tools are used to screen client lists to ensure they are not on any international sanctions lists.
Risk Assessment (Manual Stage) Potential risks are identified and categorized, including credit risk, market risk, and operational risk. A professional team conducts an in-depth analysis based on Know Your Business (KYB) situations to ensure a comprehensive understanding and assessment of the client's risk profile.
Human Interaction (Manual Stage) The final stage of due diligence includes direct interactions with the client, such as through face-to-face meetings, telephone inquiries, or on-site visits. This stage aims to verify the information collected and gain a deeper understanding of the client's business operations, management team, and company culture.
Ongoing Monitoring and Assessment (Combination of Automated and Manual) Even after the completion of due diligence, ongoing monitoring of the client’s status and performance is conducted to identify any new risks or opportunities. Automated tools are used to track key indicators and market dynamics, while the professional team evaluates and interprets this information.
Through this multi-layered due diligence process combining automated and manual methods, we are able to comprehensively assess the qualifications of our clients while ensuring efficiency and accuracy. The automated methods provide the capacity for efficiency and large-scale data processing, while the manual methods offer in-depth analysis and human intuition. The combination of both ensures the comprehensiveness and effectiveness of the due diligence.
Please specify how many questions you'll ask, and provide a brief overview of the questions.
Will you use a 3rd-party "Know your client" (KYC) service?
Yes, we do utilize third-party "Know Your Customer" (KYC) services to enhance and perfect our client due diligence process. Here are detailed insights about these services, including their scope and how they integrate with our processes: Service Overview Third-party KYC services provide comprehensive identity verification and background check capabilities, essential for ensuring client compliance and reducing the risk of financial crimes. These services typically include verification of client identity, review of financial history, assessment of political risks, and checks against global sanctions and regulatory lists. Key Issues and Regions Covered
Can any client apply to your pathway, or will you be closed to only your own internal clients? (eg: bizdev or self-referral)
Any client can apply, and we also offer services to apply on behalf of some clients.
How do you plan to track the rate at which DataCap is being distributed to your clients?
We will proceed in accordance with the Datacap Allocation Plan.
Data Diligence
This section will cover the types of data that you expect to notarize.
As a reminder: The Filecoin Plus program defines quality data is all content that meets local regulatory requirements AND • the data owner wants to see on the network, including private/encrypted data • or is open and retrievable • or demonstrates proof of concept or utility of the network, such as efforts to improve onboarding
As an operating entity in the Filecoin Community, you are required to follow all local & regional regulations relating to any data, digital and otherwise. This may include PII and data deletion requirements, as well as the storing, transmitting, or accessing of data.
Acknowledgement: Acknowledge
What type(s) of data would be applicable for your pathway?
Public Open Dataset (Research/Non-Profit),Public Open Commercial/Enterprise,Private Commercial/Enterprise
How will you verify a client's data ownership? Will you use 3rd-party KYB (know your business) service to verify enterprise clients?
Verifying a client's data ownership is a key step in ensuring data compliance and maintaining business integrity. Using third-party Know Your Business (KYB) services to validate corporate clients is an effective method to confirm data sources and ownership. Here is a detailed explanation:
Data Ownership Verification Process:
Using KYB Services:
Data Source Verification:
Through this comprehensive verification process, including the use of third-party KYB services, the legal ownership of the data claimed by corporate clients can be effectively confirmed. This not only helps reduce compliance risks but also enhances the transparency and trust in business relationships.
How will you ensure the data meets local & regional legal requirements?
To ensure that data complies with local and regional legal requirements, we will implement a comprehensive data management and compliance strategy, conduct regular compliance audits, provide training to employees on data protection laws, and collaborate with third-party partners to ensure their compliance. Additionally, we will continuously monitor legal changes to ensure our strategies are updated in a timely manner.
What types of data preparation will you support or require?
We require thorough data preparation, including cleaning, standardization, de-identification, anonymization, as well as data enrichment and integration. We support data segmentation processing and provide automated data cleaning tools, data de-identification solutions, and data integration platforms to ensure data quality, security, and compliance with regulatory requirements.
What tools or methodology will you use to sample and verify the data aligns with your pathway?
We will use advanced data analysis tools and algorithms for sample extraction and validation to ensure the data meets our standards. By comparing the actual type and preparation status of the data with the client's declaration, we confirm consistency. To prevent sector size abuse and padding, we will implement strict monitoring and automatic detection mechanisms.
Data Distribution
This section covers deal-making and data distribution.
As a reminder, the Filecoin Plus program currently defines distributed onboarding as multiple physical locations AND multiple storage provider entities to serve client requirements.
Recommended Minimum: 3 locations, 4 to 5 storage providers, 5 copies
How many replicas will you require to meet programmatic requirements for distribution?
5+
What geographic or regional distribution will you require?
3 physical locations
How many Storage Provider owner/operators will you require to meet programmatic requirements for distribution?
5+
Do you require equal percentage distribution for your clients to their chosen SPs? Will you require preliminary SP distribution plans from the client before allocating any DataCap?
Yes, we require clients to allocate an equal percentage of DataCap to their chosen Storage Providers (SPs). Before allocating any DataCap, we need clients to provide a preliminary SP allocation plan. This information will be collected through a pre-designed template to ensure consistency and completeness.
What tooling will you use to verify client deal-making distribution?
datacapstats.io & CID CHECKER BOT
How will clients meet SP distribution requirements?
Proceed based on the KYC and allocation plan provided by the client.
As an allocator, do you support clients that engage in deal-making with SPs utilizing a VPN?
In cases where the use of a VPN is necessary, we will provide support, but clients must ensure that their physical location still meets our requirements. Additionally, clients need to explicitly disclose the use of a VPN, so that we can carry out the appropriate processing and assessment. To track VPN usage, we will implement monitoring systems to detect and record VPN activities, including connection times, duration, and source IP addresses. Furthermore, these data will be regularly reviewed and analyzed to ensure compliance and security.
DataCap Allocation Strategy
In this section, you will explain your client DataCap allocation strategy.
Keep in mind the program principle over Limited Trust Over Time. Parties, such as clients, start with a limited amount of trust and power. Additional trust and power need to be earned over time through good-faith execution of their responsibilities and transparency of their actions.
Will you use standardized DataCap allocations to clients?
Yes, standardized
Allocation Tranche Schedule to clients:
First: 10% Second: 15% Third: 25% Fourth: 50% Overall cap for each client: 1PiB
Will you use programmatic or software based allocations?
Yes, standardized and software based
What tooling will you use to construct messages and send allocations to clients?
Existing Notary Registration Tool: https://filplus.fil.org/#/
Describe the process for granting additional DataCap to previously verified clients.
When granting additional DataCap to previously verified clients, we initiate subsequent allocation requests based on standards such as 10% of the remaining DataCap. For this, we may use open-source tools like the Subsequent Allocation (SA) bot or other automation tools to ensure the efficiency and transparency of the process.
Tooling & Bookkeeping
This program relies on many software tools in order to function. The Filecoin Foundation and PL have invested in many different elements of this end-to-end process, and will continue to make those tools open-sourced. Our goal is to increase adoption, and we will balance customization with efficiency.
This section will cover the various UX/UI tools for your pathway. You should think high-level (GitHub repo architecture) as well as tactical (specific bots and API endoints).
Describe in as much detail as possible the tools used for: • client discoverability & applications • due diligence & investigation • bookkeeping • on-chain message construction • client deal-making behavior • tracking overall allocator health • dispute discussion & resolution • community updates & comms
Customer Discovery and Application: Market analysis tools (Google Analytics) to understand customer behavior and preferences. Due Diligence and Survey: Background check tools (LexisNexis) for customer background and reputation investigation; Survey software (SurveyMonkey) to collect customer feedback and opinions. Bookkeeping: Spreadsheet software (Microsoft Excel) for data analysis and record-keeping. On-Chain Message Construction: Blockchain interaction tools (Ledger, GILF) for creating and sending on-chain messages. Customer Transaction Behavior: Data analysis tools (Tableau, Power BI) to analyze and visualize transaction data. Tracking Overall Allocator Health: Health assessment tools (such as Riskalyze) to evaluate the overall health of the organization. Dispute Discussion and Resolution: Online collaboration tools (Slack) to facilitate discussion and collaboration among teams. Community Updates and Communication: Social media management tools (Slack) to manage social media accounts and updates.
Will you use open-source tooling from the Fil+ team?
In most cases we will choose to use the open source tools of the Fil+ team.
Where will you keep your records for bookkeeping? How will you maintain transparency in your allocation decisions?
We will designate a Github repository to record this information and make it public.
What will your DataCap distribution look like?
N/A
Risk Mitigation, Auditing, Compliance
This framework ensures the responsible allocation of DataCap by conducting regular audits, enforcing strict compliance checks, and requiring allocators to maintain transparency and engage with the community. This approach safeguards the ecosystem, deters misuse, and upholds the commitment to a fair and accountable storage marketplace.
In addition to setting their own rules, each notary allocator will be responsible for managing compliance within their own pathway. You will need to audit your own clients, manage interventions (such as removing DataCap from clients and keeping records), and respond to disputes.
Describe your proposed compliance check mechanisms for your own clients.
To ensure compliance and effectively manage the distribution of DataCap and its downstream usage by clients, we propose implementing the following mechanisms:
Describe your process for handling disputes. Highlight response times, transparency, and accountability mechanisms.
When handling disputes in DataCap allocation, our process emphasizes rapid response, transparency, and accountability:
Detail how you will announce updates to tooling, pathway guidelines, parameters, and process alterations.
We will notify of updates to tools, guidelines, parameters, and processes in advance through email, social media, and our official website. Updates will undergo internal review to ensure they meet security and compliance standards, and frequent changes will be avoided to reduce confusion. Significant changes may require re-submission to the Fil+ governance team for review. We will also provide detailed documentation and guides to ensure users understand and adapt to these changes.
How long will you allow the community to provide feedback before implementing changes?
Before implementing changes, we plan to provide at least two weeks for community members to provide feedback. This timeframe is intended to ensure ample community participation while allowing enough time for careful consideration and discussion. The process of community interaction, moderation, and feedback balancing will proceed as follows:
Regarding security, how will you structure and secure the on-chain notary address? If you will utilize a multisig, how will it be structured? Who will have administrative & signatory rights?
To ensure the security of on-chain notary addresses, we will take the following measures:
Will you deploy smart contracts for program or policy procedures? If so, how will you track and fund them?
Currently, there is no such setting.
Monetization
While the Filecoin Foundation and PL will continue to make investments into developing the program and open-sourcing tools, we are also striving to expand and encourage high levels of service and professionalism through these new Notary Allocator pathways. These pathways require increasingly complex tooling and auditing platforms, and we understand that Notaries (and the teams and organizations responsible) are making investments into building effective systems.
It is reasonable for teams building services in this marketplace to include monetization structures. Our primary guiding principles in this regard are transparency and equity. We require these monetization pathways to be clear, consistent, and auditable.
Outline your monetization models for the services you provide as a notary allocator pathway.
As a notary allocator, our monetization model combines compliance assurance, service quality, and a transparent fee structure. Here are the specific details of the model:
Describe your organization's structure, such as the legal entity and other business & market ventures.
BigFrog Technology is a blockchain team established in 2017, focusing on project investment and Bitcoin mining. Since the initial coin offering (ICO) of FILECOIN, BigFrog began to pay attention to and research FILECOIN, while also engaging in related promotions. The core members of the team are early Bitcoin evangelists with over eight years of experience in the crypto field. They have made early investments in projects like Ethereum and have experience with trading platforms. Since 2019, BigFrog members have been contributing to the Filecoin network through DAYOU, which has a strong brand influence in the Chinese community. They have been actively promoting the Filecoin ecosystem, helping more people understand and use Filecoin. BigFrog is committed to becoming a high-quality Storage Provider (SP), serving over 60,000 customers through DAYOUAPP (https://www.dayou8.com/), and currently contributes over 80PiB of storage space to Filecoin. In the past two years, nearly a thousand FILECOIN articles have been published through GCR's traditional media (WeChat: Dayou IPFS Research Institute). DAYOU focuses on the development of Filecoin's technical ecosystem and establishing more storage providers, planning to bring more users into Web3/Metaverse through distributed storage technology. In the future, BigFrog plans to develop a series of ecological applications to serve the general public, such as distributed storage cloud disk, Filecoin staking, distributed TikTok, etc.
Where will accounting for fees be maintained?
Cost accounting will be conducted in a dedicated, transparent financial management system, ensuring that all transactions are recorded and traceable. The destruction or release of pledges will be based on compliance and contractual terms, regularly audited by Fil+ governance and other stakeholders, to ensure the transparency and fairness of the monetization process.
If you've received DataCap allocation privileges before, please link to prior notary applications.
https://github.com/filecoin-project/notary-governance/issues/690
How are you connected to the Filecoin ecosystem? Describe your (or your organization's) Filecoin relationships, investments, or ownership.
Since 2019, members of BigFrog Technology have been contributing to the Filecoin network over the long term through DAYOU; currently, DAYOU has a strong brand influence in the Chinese community; we have been actively popularizing the Filecoin ecosystem in the community, helping more people to understand and benefit from Filecoin; we are committed to becoming a high-quality SP (Storage Provider), and we have already served over 60,000 customers through DAYOUAPP (https://www.dayou8.com/), contributing over 150PiB of storage space to Filecoin. In the past two years, nearly a thousand articles about FILECOIN have been published in GCR's traditional media (WeChat: Dayou IPFS Research Institute), promoting FILECOIN.
How are you estimating your client demand and pathway usage? Do you have existing clients and an onboarding funnel?
We estimate customer demand and usage paths through market analysis and customer feedback. We use advanced data analysis tools and survey methods to gather information on market trends and customer preferences. With our existing customer base, we attract new clients through a multi-channel marketing strategy, including social media, partner networks, and online advertising. We also effectively expand our onboarding channels through customer referrals and word-of-mouth promotion.