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Zero-copy CDP: composable CDP, sovereignty and ROI

Introduction

Zero-copy CDP: in a geopolitical environment marked by tighter rules on international data flows and the push for digital sovereignty, marketing and IT leaders are rethinking the role of managed cloud, composable architectures and on-premise deployments in their activation stacks. The EU Data Act has been applicable since 12 September 2025, redefining access to and use of data generated by connected devices and services within the EU. It requires organisations, to some extent, to plan for interoperability and limit vendor lock-in.

At the same time, China has eased but clarified its cross-border transfer requirements (PIPL, CAC regulations 2024–2025) while maintaining a high level of oversight. Canada is still evolving its framework (PIPEDA/CPPA). Despite these convergences, the extraterritorial reach of the CLOUD Act continues to raise legal questions whenever a provider is subject to US law.

In this context, public bodies, large enterprises and mid-sized companies are looking for activation models that combine data sovereignty, predictable costs and business autonomy. In response, Scal-e has implemented a zero-copy approach in a composable CDP mode (database hosted by the client or their hyperscaler, no data stored by the vendor) and an on-premise option (application and database deployed entirely in the client environment). Marketing teams operate in no-code on a single dedicated database that powers CDP, loyalty, marketing automation, clienteling, BI and distributed marketing.

1. Context

The last six months have confirmed that data has become political again. In Europe, the EU Data Act – in force since 2024 and applicable since 12 September 2025 – establishes rights of access and sharing and strengthens portability. This naturally favours interoperable, reversible architectures that avoid over-dependence on specific vendors.

In China, the 2024–2025 CAC regulations created exemptions and thresholds that simplify certain outbound transfer filings while maintaining a strong requirement for documented governance. Many brands operating in APAC must, to some extent, combine local data storage with global views stripped of PII (through anonymisation or pseudonymisation) for central steering.

In North America, the debate revolves around Canada's reform (CPPA under discussion) and the extraterritorial reach of the CLOUD Act for providers under US jurisdiction. This forces public bodies and some regulated sectors to scrutinise their full hosting and operations chain, down to second- and third-tier subcontractors.

In this landscape, SecNumCloud has emerged in France as the benchmark for trusted cloud. Several infrastructure providers have obtained the qualification, and ANSSI continues to publish guides and updates, firmly anchoring legal sovereignty within the scope of control.

Impact on marketing: multi-country, multi-brand organisations are favouring zero-copy models (reading data at source, database under the client's control) and or on-premise deployments to align data localisation, access control and time-to-value. The deeper trend – renewed interest in on-premise – is not about nostalgia for old technologies but about making a clear-eyed trade-off between legal risk, security and TCO.

2. Technical and legal challenges

Structuring constraints. Distributed information systems, real-time pressure (messaging, wallet, ads) and multi-zone governance require a selective exposure model (APIs, webhooks, SFTP, direct DB reads), exhaustive logging (audit trail) and robust tenant isolation (dedicated database per client) to reduce data leakage. Privacy by default, role-based and view-based access, and controlled marketing pressure are no longer nice-to-haves; they are the backbone of operational compliance.

Triple sovereignty:

  • Data sovereignty (where the data resides and which PII travels),
  • Technological sovereignty (who controls the software stack and virtualisation layers),
  • Operational sovereignty (who can shut down, audit, patch and restore).

This trilogy must be addressed both contractually (localisation, reversibility, operator chains) and technically (isolation, encryption, logs, disaster recovery plans).

CLOUD Act. It is established that US authorities can, under certain conditions, request access to data held by providers under US jurisdiction, even when this data is stored outside US territory. For sensitive organisations, it is therefore prudent to avoid dependency points that would expose identifiable data to this legal regime.

Certifications and frameworks. Depending on sector and geography, common combinations include ISO IEC 27001 for security management, SecNumCloud for trusted cloud, and HDS where health data is involved. The goal is not merely to tick boxes, but to operationalise the principles: localisation, logging, reversibility and access control.

Specifics for China and Canada. The 2024–2025 CAC developments introduce exemptions and thresholds for certain outbound flows, while preserving the obligation to map and document transfers (PIPL). In Canada, the transition to CPPA continues to demand documentation of purposes and rights. In practice, a global view without PII feeds central BI, while PII remains localised – a model that fits well with a zero-copy CDP.

3. Solutions: zero-copy architecture, on-premise and composable marketing cloud

Technical architecture

In composable CDP mode (zero-copy), your customer database stays with you – whether in a cloud data warehouse (Snowflake, BigQuery, Redshift, Databricks) or on your hyperscaler (GCP, AWS, Microsoft Azure, OVHcloud) – with no persistence of your customer data at the vendor. The Scal-e application operates via REST APIs (OpenAPI v3), webhooks, SFTP and direct database reads.

In on-premise mode, both application and database are deployed entirely in your environment (local IAM, centralised SOC, internal disaster recovery). In every case, a single dedicated database (tenant isolation), privacy by default, data virtualisation and distributed processing provide the foundation for performance and isolation.

A zero-copy CDP means reading data at source, minimising copies and reducing interface costs. Combined with a composable marketing cloud (CDP plus loyalty plus omnichannel marketing automation plus clienteling plus BI plus distributed marketing) on a single database, it eliminates latency and divergence between modules.

In contrast to some so-called composable CDP approaches that are closer to pure reverse ETL (very useful for IT), the no-code layer gives business teams daily autonomy for segmentation, scoring, aggregations, campaigns and dashboards without SQL.

Customer use cases (anonymised)

  • French bank: architecture aligned with SecNumCloud; 60 percent reduction in GDPR audit time through centralised logs, and 40 percent reduction in exposure surface thanks to zero-copy (no data persisted at the vendor).
  • European insurer: co-located hosting with a European hyperscaler; 35 percent less activation latency for campaigns and easier internal certification (controlled localisation and enhanced traceability).
  • Retailer: transition from a reverse ETL pipeline to a no-code CDP; segment creation in ten minutes instead of several days or weeks, plus twelve additional campaigns per quarter and a fourfold increase in responsiveness.

Economic model

Scal-e does not charge per call (read write compute). The architecture avoids an explosion of billable queries as volumes and frequencies increase, keeping budgets under control. In addition, sovereign hosting options are available (dedicated cloud, HDS, SecNumCloud), depending on your requirements, including bare-metal to remove unwanted virtualisation layers.

4. Implementation and ROI

Roadmap

  • Scoping (2–4 weeks): mapping data sources, analysing data quality, prioritising matching keys, designing a customer-centric model and defining views by perimeter (country, brand, network).
  • Connection and normalisation (4–8 weeks): setting up batch and real-time flows (API webhooks SFTP) and using data virtualisation to expose business objects without opening direct database access to users.
  • No-code activation (2–4 weeks): configuring the Audience Builder, calculations and aggregates, pressure and exclusions, and omnichannel orchestrations.
  • Governance and compliance (ongoing): privacy by default, audit logs, exportable audits and documented reversibility, plus flow monitoring (OK Warning Fail).

Cost transparency

  • CAPEX (on-premise): servers or bare metal, database licences, security (EDR XDR), disaster recovery, IAM integration. These can be depreciated over three to five years.
  • OPEX (composable cloud): application execution, secure connectivity, cloud database storage, potential egress, monitoring.
  • Frequent hidden costs to anticipate: egress between regions, billable queries on some data warehouses, refactoring of business objects on the BI side, and constrained upgrades on external routing components.

ROI assumptions

In a European multi-country retail context (database of three million contacts, eighty million events per year), no-code autonomy and reduced latency (segments in ten minutes instead of two weeks) typically enable:

  • 15 to 25 percent more campaigns with the same resources,
  • 5 to 8 percent higher revenue per customer through more finely tuned marketing pressure,
  • 20 to 30 percent fewer IT tickets relating to data extraction and transformation requests.

These values will of course vary depending on initial data quality and organisational maturity.

Clear limits

  • Zero-copy does not remove the need for data quality management or for compliance with local governance constraints (PIPL, contractual clauses).
  • On-premise requires a well-equipped IT team (patching, monitoring, operations) and longer lead times.
  • Public cloud without sovereignty certifications remains possible but must be weighed against the CLOUD Act and the sensitivity of the data processed.

Conclusion

A zero-copy CDP is not a slogan. It is a reduction in data copies that shrinks the exposure surface, a composable architecture that aligns business autonomy with governance, and credible group-wide reversibility. Scal-e extends this principle to the entire platform (CDP, loyalty, marketing automation, clienteling, BI, distributed marketing) on a single dedicated database, in composable (zero-copy) or on-premise mode, and in cloud mode when speed is paramount. The choice is no longer about opposing technologies, but about choosing the right level of sovereignty, time-to-value and TCO for your context.

FAQ

1) What does zero-copy mean in a CDP?

It means reading data at source, without persisting it at the vendor. The database stays with you (cloud database hyperscaler). The benefits are fewer copies, simplified governance and predictable costs.

2) Composable CDP vs reverse ETL: what is the operational difference?

A composable no-code CDP gives business teams autonomy (segments in ten minutes), while reverse ETL centralises transformation in IT (longer lead times, dependency on development sprints).

3) How do you handle EU GDPR plus China PIPL plus Canada?

Localise PII by region and provide a global view without PII for central BI. Document transfers under PIPL and ensure reversibility.

4) HDS, SecNumCloud and ISO 27001: do you need all of them?

No. ISO 27001 (ISMS) has a general scope. SecNumCloud qualifies trusted cloud providers. HDS targets health data. You choose according to your perimeter.

5) Does Scal-e charge per call?

No. Scal-e does not charge per call. The architecture is designed to avoid runaway query costs (reads writes compute).

6) Is Scal-e referenced by third parties?

Yes. Scal-e appears in the Forrester Wave B2B CDP (2023 and 2025) and holds the RealCDP label from the CDP Institute.

About Scal-e

Scal-e is an integrated, composable marketing cloud platform for B2B and B2C enterprises, deployable in cloud, composable (zero-copy) or on-premise modes.

The platform brings together advanced ETL and data quality management, CDP, omnichannel orchestration (email, SMS, RCS, WhatsApp, wallet, push and more), earn-and-burn loyalty, self-service BI, clienteling and distributed marketing, all operated in no-code by business teams. Each instance runs on a single dedicated database (tenant isolation), with privacy by default, data virtualisation and distributed processing.

Recognised by the CDP Institute and cited by Forrester (B2B CDP), Scal-e operates worldwide with governance and compliance steered from Europe.

We would be delighted to show you our story, our platform and its modules, our clients and partners, our project methodology and our pricing.

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