Data Processing Agreement

The Data Processing Agreement (DPA, the Agreement), which includes the Standard Contractual Clauses adopted by the European Commission, as applicable, reflects the parties’ agreement with respect to the terms governing the Processing of Personal Data under Docsify’s Terms of Service (the Terms).

This DPA is an addendum to the Terms and is effective from the moment of agreeing and accepting the Terms and Docsify’s Privacy Policy.

Terminology of this DPA shall follow the terminology used in Docsify’s Terms of Service. Terms not otherwise defined herein shall have the meaning as set forth in the Docsify’s Terms of Service.

The terms of the Data Processing Agreement shall apply to the situations where Docsify processes any personal data as part of Your Content.

 

If you are located in the European Union or the European Economic Area, the Standard Contractual Clauses adopted by the European Commission, attached to the Data Processing Agreement apply.

YOU ACKNOWLEDGE IN ALL CASES THAT DOCSIFY ACTS AS THE DATA PROCESSOR OF YOUR CONTENT AND YOU ARE THE DATA CONTROLLER OF YOUR CUSTOMERS PERSONAL DATA UNDER APPLICABLE DATA PROTECTION REGULATIONS IN THE EUROPEAN UNION AND EUROPEAN ECONOMIC AREA.  YOU WILL OBTAIN AND MAINTAIN ANY REQUIRED CONSENTS NECESSARY TO PERMIT THE PROCESSING OF PERSONAL DATA OF YOUR CUSTOMERS UNDER THIS AGREEMENT.

This DPA includes:

(i) Standard Contractual Clauses attached hereto as EXHIBIT 1.

(a) Appendix 1 to the Standard Contractual Clauses, which includes specifics on the Personal Data transferred by the data exporter to the data importer.

(b) Appendix 2 to the Standard Contractual Clauses, which includes a description of the technical and organizational security measures implemented by the data importer as referenced.

 

Definitions

“Controller” means the natural or legal person, public authority, agency or other body that alone or jointly with others determines the purposes and means of the Processing of Personal Data.

“Data Protection Law” means all applicable legislation relating to data protection and privacy including without limitation the EU Data Protection Directive 95/46/EC and all local laws and regulations that amend or replace any of them, including the GDPR, together with any national implementing laws in any Member State of the European Union or, to the extent applicable, in any other country, as amended, repealed, consolidated, or replaced from time to time. The terms “process,” “processes,” and “processed” will be construed accordingly.

“Data Subject” means the individual to whom Personal Data relates.

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“Instruction” means the written, documented instruction, issued by Controller to Processor, and directing the same to perform a specific action with regard to Personal Data (including, but not limited to, depersonalizing, blocking, deletion, making available).

“Personal Data” means any information relating to an identified or identifiable individual where such information is contained within Client Data and is protected similarly as personal data or personally identifiable information under applicable Data Protection Law.

“Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.

“Processing” means any operation or set of operations that is performed on Personal Data, encompassing the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available alignment or combination, restriction or erasure of Personal Data.

“Processor” means a natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of Controller.

“Standard Contractual Clauses” means the clauses attached hereto as Exhibit 1 pursuant to the European Commission’s decision (C(2010)593) of 5 February 2010 on Standard Contractual Clauses for the transfer of personal data to processors established in third countries that do not ensure an adequate level of data protection.

 

2. Details of Processing

a. Categories of Data Subjects. Controller customers and/or controller employees.

b. Types of Personal Data. Full name, phone number, email, address, IP address, username, notes in emails and documents in emails attached.

c. Subject Matter, Nature and Purpose of Processing. In connection with and for the purposes of provision of the Services to Controller under the Terms.

d. Duration of Processing. During the term of use of the Services and thirty (30) calendar days after its termination or cancellation.

 

3. Your Responsibility.

Within the scope of the Terms and in its use of the Services, Controller shall be solely responsible for complying with the statutory requirements relating to data protection and privacy, in particular regarding the disclosure and transfer of Personal Data to the Processor and the Processing of Personal Data. For the avoidance of doubt, Controller’s instructions for the Processing of Personal Data shall comply with the Data Protection Law. This DPA is yours as Controller complete and final instruction to us as Processor in relation to Personal Data and that additional instructions outside the scope of this DPA would require prior written agreement between the parties.

Controller shall inform Processor comprehensively and without undue delay about any errors or irregularities related to statutory provisions on the Processing of Personal Data.

 

4. Obligations of Processor

a. Compliance with Instructions. Processor shall collect, process, and use Personal Data only within the scope of Controller’s Instructions. If the Processor believes that an Instruction of Controller infringes on the Data Protection Law, it shall immediately inform Controller without delay. If Processor cannot process Personal Data in accordance with the Instructions due to a legal requirement under any applicable European Union or Member State law, Processor will (i) promptly notify Controller of that legal requirement before the relevant Processing to the extent permitted by the Data Protection Law; and (ii) cease all Processing (other than merely storing and maintaining the security of the affected Personal Data) until such time as Controller issues new instructions with which the Processor is able to comply. If this provision is invoked, Processor will not be liable to Controller under the Agreement for any failure to perform the applicable services until such time as Controller issues new instructions in regard to the Processing.

b. Security. Processor shall take the appropriate technical and organizational measures to adequately protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data described under Appendix 2 to the Standard Contractual Clauses. Such measures include, but are not be limited to:

  • the prevention of unauthorized persons from gaining access to Personal Data Processing systems (physical access control),
  • the prevention of Personal Data Processing systems from being used without authorization (logical access control),
  • ensuring that persons entitled to use a Personal Data Processing system gain access only to such Personal Data as they are entitled to access in accordance with their access rights, and that, in the course of Processing or use and after storage, Personal Data cannot be read, copied, modified, or deleted without authorization (data access control),
  • ensuring that Personal Data cannot be read, copied, modified or deleted without authorization during electronic transmission, transport or storage on storage media, and that the target entities for any transfer of Personal Data by means of data transmission facilities can be established and verified (data transfer control),
  • ensuring the establishment of an audit trail to document whether and by whom Personal Data has been entered into, modified in, or removed from Personal Data Processing systems (entry control),
  • ensuring that Personal Data is Processed solely in accordance with the Instructions (control of instructions),
  • ensuring that Personal Data is protected against accidental destruction or loss (availability control).

Processor will facilitate Controller’s compliance with Controller’s obligation to implement security measures with respect to Personal Data, by (i) implementing and maintaining the security measures described under Appendix 2, (ii) complying with the terms of Section 4 (d) (Personal Data Breaches); and (iii) providing Controller with information in relation to Processing in accordance with Section 5 (Audits).

c. Confidentiality.  Processor shall ensure that any personnel whom Processor authorizes to process Personal Data on its behalf is subject to confidentiality obligations with respect to that Personal Data. The undertaking to confidentiality shall continue after the termination of the above-entitled activities.

d. Personal Data Breaches. Processor will notify Controller as soon as practicable after it becomes aware of any Personal Data Breach affecting any Personal Data. At Controller’s request, Processor will promptly provide Controller with all reasonable assistance necessary to enable Controller to notify relevant competent authorities and/or affected Data Subjects of Personal Data Breaches, if Controller is required to do so under the Data Protection Law.

e. Data Subject Requests. Processor will provide reasonable assistance, including by appropriate technical and organizational measures and taking into account the nature of the Processing, to enable Controller to respond to any request from Data Subjects seeking to exercise their rights under the Data Protection Law with respect to Personal Data (including access, rectification, restriction, deletion, or portability of Personal Data, as applicable), to the extent permitted by the law.  If such request is made directly to Processor, Processor will promptly inform Controller and will advise Data Subjects to submit their request to Controller. Controller shall be solely responsible for responding to any Data Subjects’ requests. Controller shall reimburse Processor for the costs arising from this assistance.

f. Sub-Processors. Processor shall be entitled to engage Sub-Processors to fulfil Processor’s obligations defined in the Terms and Pricing Plan.  All sub-processors are listed herein:

Google Analytics

Hotjar

Albacross

Leadworx

Google Optimize

Google Tag Manager

Amplitude

Mixpanel

Facebook

Autopilot

Recurly

Intercom

SendPulse

FirstPromoter

Hotjar

Albacross

Leadworx

Zapier

Poptin

Heap

SendGrid

Mixpanel

Mailshake

The list of sub-Processors might be updated from time to time. For the avoidance of doubt, the above authorization constitutes Controller’s prior written consent to the sub-Processing by Processor for purposes of Clause 11 of the Standard Contractual Clauses.

Where Processor engages Sub-Processors, Processor will enter into a contract with the Sub-Processor that imposes on the Sub-Processor the same obligations that apply to Processor under this DPA. Where the Sub-Processor fails to fulfil its data protection obligations, Processor will remain liable to Controller for the performance of such Sub-Processor’s obligations.

The provisions of this Section 4(e) shall mutually apply if Processor engages a Sub-Processor in a country outside the European Economic Area (“EEA”) not recognized by the European Commission as providing an adequate level of protection for personal data.  If, in the performance of this DPA, Docsify transfers any Personal Data to a sub-processor located outside of the EEA, Docsify shall, in advance of any such transfer, ensure that a legal mechanism to achieve adequacy in respect of that processing is in place.

g. Deletion or Retrieval of Personal Data. Other than to the extent required to comply with the Data Protection Law, following termination or cancellation of the Services and thirty (30) calendar days after it, Processor will delete all Personal Data (including copies thereof) processed pursuant to this DPA, provided no other ground for processing the Personal Data exists. If Processor is unable to delete Personal Data for technical or other reasons, Processor will apply measures to ensure that Personal Data is blocked from any further Processing.

 

5. Audits

Processor shall, upon Controller’s written request and within a reasonable period of time, provide Controller with all information necessary for an audit of processing, to the extent that such information is within Processor’s control and Processor is not precluded from disclosing it by applicable law, a duty of confidentiality, or any other obligation owed to a third party.

 

6. General Provisions

With respect to updates and changes to this DPA, the terms that apply in the section “Miscellaneous” in the Terms shall apply.

In case of any conflict, this DPA shall take precedence over the regulations of the Terms. Where individual provisions of this DPA are invalid or unenforceable, the validity and enforceability of the other provisions of this DPA shall not be affected.

Upon the incorporation of this DPA into the Agreement, the parties to this DPA are agreeing to the Standard Contractual Clauses (where and as applicable) and all appendixes attached thereto. In the event of any conflict or inconsistency between this DPA and the Standard Contractual Clauses in Exhibit 1, the Standard Contractual Clauses shall prevail.

Effective 25 May 2018 Docsify will process Personal Data in accordance with the GDPR requirements contained herein.

This DPA may be executed in counterparts, each of which, when so executed and delivered, will be deemed an original, and all of which together shall constitute one and the same agreement. Counterparts may be executed and delivered by facsimile, electronic mail (including PDF) or other transmission method, and any counterpart so delivered shall be deemed to have been duly and validly delivered and be valid and effective for all purposes.

 

7. Parties to this DPA

This DPA is an addendum to the Terms of Services.  Upon the incorporation of this DPA into the Terms (i) You, the User (the Controller) and Docsify (the Processor) that are each a party to Terms of Services are also each a party to this DPA.

 

EXHIBIT 1

Standard Contractual Clauses

NOW, THEREFORE, for a good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties hereto

HAVE AGREED to add the following Contractual Clauses (the Clauses) to the Docsify’s Terms of Use in order to adduce adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of individuals for the transfer by the data exporter to the data importer of the personal data specified in Appendix 1.

Clause 1

Definitions:

For the purposes of the Clauses:

(a) ‘personal data’, ‘special categories of data’, ‘process/processing’, ‘controller’, ‘processor’, ‘data subject’ and ‘supervisory authority’ shall have the same meaning as in Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the movement of such data;

(b) ‘the data exporter’ means the controller who transfers the personal data;

(c) ‘the data importer’ means the processor who agrees to receive from the data exporter personal data intended for processing on his behalf after the transfer in accordance with his instructions and the terms of the Clauses and who provides sufficient guarantees on appropriate technical and organizational measures in such a manner that processing will meet the requirements of Directive and ensure the protection of the rights of the data subject;

(d) ‘the sub-processor’ means any processor engaged by the data importer or by any other sub-processor of the data importer who agrees to receive from the data importer or from any other sub-processor of the data importer personal data exclusively intended for processing activities to be carried out on behalf of the data exporter after the transfer in accordance with his instructions, the terms of the Clauses and the terms of the written subcontract;

(e) ‘the applicable data protection law’ means the legislation protecting the fundamental rights and freedoms of individuals and, in particular, their right to privacy with respect to the processing of personal data applicable to a data controller in the Member State in which the data exporter is established;

(f) ‘technical and organizational security measures’ means those measures aimed at protecting personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.

Clause 2

Details of the transfer

The details of the transfer and in particular the special categories of personal data where applicable are specified in Appendix 1 which forms an integral part of the Clauses.

 

Clause 3

Third-party beneficiary clause

  1. The data subject can enforce against the data exporter this Clause, Clause 4(b) to (i), Clause 5(a) to (e), and (g) to (j), Clause 6(1) and (2), Clause 7, Clause 8(2), and Clauses 9 to 12 as third-party beneficiary.
  2. The data subject can enforce against the data importer this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where the data exporter has factually disappeared or has ceased to exist in law unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law, as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity.
  3. The data subject can enforce against the sub-processor this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent, unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity. Such third-party liability of the sub-processor shall be limited to its own processing operations under the Clauses.
  4. The parties do not object to a data subject being represented by an association or other body if the data subject so expressly wishes and if permitted by national law.

 

Clause 4

Obligations of the data exporter

The data exporter agrees and warrants:

(a) that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;

(b) that it has instructed and throughout the duration of the personal data-processing services will instruct the data importer to process the personal data transferred only on the data exporter’s behalf and in accordance with the applicable data protection law and the Clauses;

(c) that the data importer will provide sufficient guarantees in respect of the technical and organisational security measures specified in Appendix 2 to this contract;

(d) that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;

(e) that it will ensure compliance with the security measures;

(f) that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC;

(g) to forward any notification received from the data importer or any sub-processor pursuant to Clause 5(b) and Clause 8(3) to the data protection supervisory authority if the data exporter decides to continue the transfer or to lift the suspension;

(h) to make available to the data subjects upon request a copy of the Clauses, with the exception of Appendix 2, and a summary description of the security measures, as well as a copy of any contract for sub-processing services which has to be made in accordance with the Clauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information;

(i) that, in the event of sub-processing, the processing activity is carried out in accordance with Clause 11 by a sub-processor providing at least the same level of protection for the personal data and the rights of data subject as the data importer under the Clauses; and

(j) that it will ensure compliance with Clause 4(a) to (i).

 

Clause 5

Obligations of the data importer

The data importer agrees and warrants:

(a) to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;

(b) that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the Clauses, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;

(c) that it has implemented the technical and organizational security measures specified in Appendix 2 before processing the personal data transferred;

(d) that it will promptly notify the data exporter about:

(i) any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation;

(ii) any accidental or unauthorised access; and

(iii) any request received directly from the data subjects without responding to that request, unless it has been otherwise authorised to do so;

(e) to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with regard to the processing of the data transferred;

(f) at the request of the data exporter to submit its data-processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;

(g) to make available to the data subject upon request a copy of the Clauses, or any existing contract for sub-processing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;

(h) that, in the event of sub-processing, it has previously informed the data exporter and obtained its prior written consent;

(i) that the processing services by the sub-processor will be carried out in accordance with Clause 11;

(j) to send promptly a copy of any sub-processor agreement it concludes under the Clauses to the data exporter.

 

Clause 6

Liability

  1. The parties agree that any data subject, who has suffered damage as a result of any breach of the obligations referred to in Clause 3 or in Clause 11 by any party or sub-processor is entitled to receive compensation from the data exporter for the damage suffered.
  2. If a data subject is not able to bring a claim for compensation in accordance with paragraph 1 against the data exporter, arising out of a breach by the data importer or his sub-processor of any of their obligations referred to in Clause 3 or in Clause 11, because the data exporter has factually disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract of by operation of law, in which case the data subject can enforce its rights against such entity. The data importer may not rely on a breach by a sub-processor of its obligations in order to avoid its own liabilities.
  3. If a data subject is not able to bring a claim against the data exporter or the data importer referred to in paragraphs 1 and 2, arising out of a breach by the sub-processor of any of their obligations referred to in Clause 3 or in Clause 11 because both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent, the sub-processor agrees that the data subject may issue a claim against the data sub-processor with regard to its own processing operations under the Clauses as if it were the data exporter or the data importer, unless any successor entity has assumed the entire legal obligations of the data exporter or data importer by contract or by operation of law, in which case the data subject can enforce its rights against such entity. The liability of the sub-processor shall be limited to its own processing operations under the Clauses.

 

Clause 7

Mediation and jurisdiction

  1. The data importer agrees that if the data subject invokes against it third-party beneficiary rights and/or claims compensation for damages under the Clauses, the data importer will accept the decision of the data subject:

(a) to refer the dispute to mediation, by an independent person or, where applicable, by the supervisory authority;

(b) to refer the dispute to the courts in the Member State in which the data exporter is established.

  1. The parties agree that the choice made by the data subject will not prejudice its substantive or procedural rights to seek remedies in accordance with other provisions of national or international law.

 

Clause 8

Cooperation with supervisory authorities

  1. The data exporter agrees to deposit a copy of this contract with the supervisory authority if it so requests or if such deposit is required under the applicable data protection law.
  2. The parties agree that the supervisory authority has the right to conduct an audit of the data importer, and of any sub-processor, which has the same scope and is subject to the same conditions as would apply to an audit of the data exporter under the applicable data protection law.
  3. The data importer shall promptly inform the data exporter about the existence of legislation applicable to it or any sub-processor preventing the conduct of an audit of the data importer, or any sub-processor, pursuant to paragraph 2. In such a case the data exporter shall be entitled to take the measures foreseen in Clause 5(b).

 

Clause 9

Governing law

The Clauses shall be governed by the law of the Member State in which the data exporter is established, namely the Netherlands.

 

Clause 10

Variation of the contract

The parties undertake not to vary or modify the Clauses. This does not preclude the parties from adding clauses on business related issues where required as long as they do not contradict the Clause.

 

Clause 11

Sub-processing

  1. The data importer shall not subcontract any of its processing operations performed on behalf of the data exporter under the Clauses without the prior written consent of the data exporter. Where the data importer subcontracts its obligations under the Clauses, with the consent of the data exporter, it shall do so only by way of a written agreement with the sub-processor which imposes the same obligations on the sub-processor as are imposed on the data importer under the Clauses (3). Where the sub-processor fails to fulfil its data protection obligations under such written agreement the data importer shall remain fully liable to the data exporter for the performance of the sub-processor’s obligations under such agreement.
  2. The prior written contract between the data importer and the sub-processor shall also provide for a third-party beneficiary clause as laid down in Clause 3 for cases where the data subject is not able to bring the claim for compensation referred to in paragraph 1 of Clause 6 against the data exporter or the data importer because they have factually disappeared or have ceased to exist in law or have become insolvent and no successor entity has assumed the entire legal obligations of the data exporter or data importer by contract or by operation of law. Such third-party liability of the sub-processor shall be limited to its own processing operations under the Clauses.
  3. The provisions relating to data protection aspects for sub-processing of the contract referred to in paragraph 1 shall be governed by the law of the Member State in which the data exporter is established, namely the Netherlands.
  4. The data exporter shall keep a list of sub-processing agreements concluded under the Clauses and notified by the data importer pursuant to Clause 5(j), which shall be updated at least once a year. The list shall be available to the data exporter’s data protection supervisory authority.

 

Clause 12

Obligation after the termination of personal data-processing services

  1. The parties agree that on the termination of the provision of data-processing services, the data importer and the sub-processor shall, at the choice of the data exporter, return all the personal data transferred and the copies thereof to the data exporter or shall destroy all the personal data and certify to the data exporter that it has done so, unless legislation imposed upon the data importer prevents it from returning or destroying all or part of the personal data transferred. In that case, the data importer warrants that it will guarantee the confidentiality of the personal data transferred and will not actively process the personal data transferred anymore.
  2. The data importer and the sub-processor warrant that upon request of the data exporter and/or of the supervisory authority, it will submit its data-processing facilities for an audit of the measures referred to in paragraph 1.

 

Appendix 1 to the Contractual Clauses

This Appendix forms part of the Clauses and must be completed and signed by the parties

 

Data exporter. The data exporter is the User.

Data importer. The data importer is Docsify.

Data subjects. Categories of data subjects set out under Section 2 of the Data Processing Agreement to which the Clauses are attached.

 

Categories of data

Categories of personal data set out under Section 2 of the Data Processing Agreement to which the Clauses are attached.

 

Special categories of data (if appropriate)

The parties do not anticipate the transfer of special categories of data.

 

Processing operations

The processing activities set out under Section 2 of the Data Processing Agreement to which the Clauses are attached.

 

 

Appendix 2 to the Contractual Clauses

This Appendix forms part of the Clauses.

Description of the technical and organizational security measures implemented by the data importer in accordance with Clauses 4(d) and 5(c) (or document/legislation attached):

We prevent unauthorized access to the personal data by the following means: (i) by implementing Docsify’s password policy; (ii) by usage of traditional firewall rules and instruments; (iii) by encryption of data; (iv) by implementing antivirus systems; (v) by restriction of  access to account data based on the network address of the user (IP).

Our personnel have access to user data via controlled interfaces. The intent of providing access to a subset of personnel is to provide effective customer support, to troubleshoot potential problems, to detect and respond to security incidents and implement data security. Personnel is granted access by role, and reviews of high risk privilege grants are initiated daily. Personnel roles and passwords are reviewed at least once every six months.

User data is stored in multi-tenant storage systems accessible to users via only application user interfaces and application programming interfaces. Users are not allowed direct access to the underlying application infrastructure. The authorization model in our Services is designed to ensure that only the appropriately assigned individuals can access relevant features, views, and customization options. Authorization to data sets is performed through validating the user’s permissions against the attributes associated with each data set.

Network access control mechanisms are designed to prevent network traffic using unauthorized protocols from reaching the product infrastructure. The technical measures implemented differ between our infrastructure  providers.

We implemented a Web Application Firewall (WAF) solution to protect our product. The WAF is designed to identify and prevent attacks against publicly available network services.

We host our infrastructure with multi-tenant, outsourced infrastructure providers, such as Amazon Web Services residing at US East (N.Virginia) region.

We rely on contractual agreements, privacy policies, and third parties (vendors) compliance programs in order to protect  data processed or stored by these third parties (vendors).

We make HTTPS (also referred to as SSL or TLS), SSH and STTP encryption. Our HTTPS implementation uses industry standard algorithms and certificates.

We maintain relationships with industry-recognized, penetration-testing service providers for four annual penetration tests. The intent of the penetration tests is to identify and resolve foreseeable attack vectors and potential abuse scenarios.

Ours personnel, including security, operations, and support personnel, are responsive to known incidents. Suspected and confirmed security incidents are investigated by security personnel, and appropriate resolution steps are identified and documented.

If we become aware of unlawful access to personal data, we will: 1) notify you (the Controller) of the incident; 2) provide a description of the steps we are taking to resolve the incident; and 3) provide status updates to you (the Controller).

Backup and replication strategies of Amazon Web Services are designed to ensure redundancy and failover protections during a significant processing failure.

We currently observe the security practices described in this Appendix 2. Notwithstanding any provision to the contrary otherwise agreed to by you, a data exporter (the Controller), we may modify or update these practices at its discretion provided that such modification and update does not result in a material degradation in the protection offered by these practices. All capitalized terms not otherwise defined herein shall have the meanings as set forth in the Terms.

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