Privacy Policy

This privacy notice is issued on behalf of the AttackBound PTY LTD who owns the “AttackBound” trademark, so when we mention “AttackBound”, “we”, “us” or “our” in the privacy notice, we are referring to the parent company in our group responsible for handling your personal information.

AttackBound is the controller and responsible for this website.

We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data protection officer by email at privacy@attackbound.com

This Privacy Policy does not apply to the “content” processed, stored, or hosted by our customers using our products (AttackBound Software) in connection with the provided services.

The Privacy Policy does not apply to Your Content. You may specify the service regions in which Your Content will be stored. You consent to the storage of Your Content in, and transfer of Your Content into, the service regions you select. We will not access or use Your Content except as necessary to maintain or provide the Service Offerings, or as necessary to comply with the law or a binding order of a governmental body. We will not (a) disclose Your Content to any government or third party except in each case as necessary to comply with the law or a binding order of a governmental body. We will only use your Account Information in accordance with the Privacy Policy, and you consent to such usage.

What Data We Collect

We collect your personal information in the course of providing our service offerings to you. We rely on the following principles when collecting your personal information:
– Our clients’ data is our most important asset and our IT systems are built with this in mind.
– We only hold data while it’s required to provide our services.
– We never share information with third parties or transfer data outside of Australia without first seeking our clients’ consent, and making sure it’s adequately protected.
– When requested by an individual we will disclose all information held on that individual.

Service Provisioning:

– When you become a client of AttackBound, we will use your personal information to provide the services you have purchased. The details we collect from you when you sign up to our services are: name, address, email address, organisation, phone number and details required for making payment.
– To complete your purchase and provide the services to you, we share your personal information with our payment processing and data storage subcontractors, on some occasions we may share business details with credit reference agencies who we use to assess fraud, credit and/or security risks.

When you phone us or use our website chat service

– When you phone us or contact us by email with general queries, we may also handle your personal information (your name, contact details and the other details you provide to us) in order to provide the customer services you have asked us to. This could be when you ask us to provide more information about our software, or explain how our search tools work.

We rely on your consent to handle your personal information in this way. If you do not provide us with the personal information we request from you for customer services purposes, we may not be able to fully answer your queries.

When you have expressed an interest in AttackBound:

– This section applies if you have opted in to receive marketing communications from us, or have previously expressed an interest in AttackBound and not opted out.
– We will handle your personal information (such as your name, email address, postal address, telephone number and preferences) to provide you with marketing communications in line with any preferences you have told us about.
– When we send you marketing emails because you have opted-in to receive them, we rely on your consent to contact you for marketing purposes.
– If you have not opted-in and we send you marketing emails, we do this because of our legitimate interest to promote our business.
– Every email we send to you for marketing purposes will also contain instructions on how to unsubscribe from receiving them.
– You are not under any obligation to provide us with your personal data for marketing purposes.
– You can tell us that you do not want your personal information to be processed in this way at any time by contacting us at privacy@attackbound.com or, where relevant, by following the unsubscribe link shown in every marketing communication you receive from us.

To make our website better:

– We will also use your personal information to provide you with a more effective user experience (such as by displaying articles and links we think you will be interested in). Our use of your information in this way means that your experience of our site will be more tailored to you, and that the articles and links you see on our site may differ from someone accessing the same site with a different history or browsing habits.
– We also share your aggregated, anonymous data with third party analytics and search engine providers that assist us in the improvement and optimisation of our site.
– We will also use your personal information for the purposes of making our site more secure, and to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
– We process your data for this reason because we have a legitimate interest to provide you with the best experience we can, and to ensure that our site is kept secure.
– You can prevent us from using your personal information in this way by using the ‘do not track’ functionality in your internet browser. If you enable do not track functionality, our site may be less tailored to your needs and preferences.

Automatic Information

We collect information automatically when you:
– visit, interact with, or use our services;
– download content from us;– open emails or click on links in emails from us; and
– interact or communicate with us (such as when you attend a AttackBound event or when you request customer support).

Examples of the information we automatically collect include:
– network and connection information, such as the Internet protocol (IP) address used to connect your computer or other device to the Internet and information about your Internet service provider;
– computer and device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting;
– the location of your device or computer;
– authentication and security credential information;
– content interaction information, such as content downloads, streams, and playback details, including duration and number of simultaneous streams and downloads;
– Service Offering metrics, such as offering usage, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs;
– the full Uniform Resource Locators (URL) clickstream to, through, and from our website (including date and time), content you viewed or searched for, page response times, download errors, and page interaction information (such as scrolling, clicks, and mouse-overs);
– email addresses and phone numbers used to contact us; and
– identifiers and information contained in cookies.

Cookies

Our site uses cookies and other similar technologies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We only use (and store) non-essential cookies on your computer’s browser or hard drive if you provide your consent.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, which we do not have any control over. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Except for essential cookies, all cookies will expire after 2 years.

How We Store Personal Information

AttackBound Pty Ltd. is located in Australia, and our affiliated companies are located throughout the world. Depending on the scope of your interactions with our services, your personal information may be stored in or accessed from multiple countries, including Australia. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by applicable data protection laws.

Where you are a client of AttackBound, we will retain your data for a period of 2 years to ensure that we are able to assist you should you have any questions, feedback or issues in connection with your membership or if any legal issues arise.

We keep your personal information to enable your continued use of our services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required by law (including for tax and accounting purposes), or as otherwise communicated to you. How long we retain specific personal information varies depending on the purpose for its use, and we will delete your personal information in accordance with applicable law.

In some circumstances we may anonymise your personal data (so that it cannot longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

How We Secure Personal Information

– We protect the security of your information during transmission to or from our websites, applications, products, or services by using encryption protocols and software.
– We follow the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data.
– We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal information. Our security procedures mean that we may request proof of identity before we disclose personal information to you.

Rights

You have various rights under the data protection laws, which you can exercise by contacting us. If you have any concern about privacy at AttackBound, please contact us at privacy@attackbound.com with a thorough description, and we will try to resolve it.

Right of access

You are entitled receive confirmation as to whether your personal information is being processed by us, as well as various other information relating to our use of your personal information.

You also have the right to access your personal information which we are handling.

Right to rectification

You have the right to require us to rectify any inaccurate personal information we hold about you. You also have the right to have incomplete personal information we hold about you completed, by providing a supplementary statement to us.

Right to restriction

You can restrict our processing of your personal information where:
– you think we hold inaccurate personal information about you;
– our handling of your personal information breaks the law, but you do not want us to delete it;
– we no longer need to process your personal information, but you want us to keep it for legal reasons; or
– where we are handling your personal information because we have a legitimate interest (as described in the “How We Use Your Data” section above, and are in the process of objecting to this use of your personal information. – Where you exercise your right to restrict us from using your personal information, we will then only process your personal information when you agree, except for storage purposes and to handle legal claims.

Right to data portability

You have the right to receive your personal information in a structured, standard machine readable format and to send this to another organisation controlling your personal information.

This right only applies to your personal information we are handling because you consented to us using it or because there is a contract in place between us.

Right to erasure

You have the right to require us to erase your personal information which we are handling in the following circumstances:
– where we no longer need to use your personal information for the reason we told you we collected it for;
– where we needed your consent to use your personal information, you have withdrawn your consent and there is no other lawful way we can continue to use your personal information;
– when you object to our use of your personal information and we have no compelling reason to carry on handling it;
– if our handling of your personal information has broken the law; and
– when we must erase your personal information to comply with a law we are subject to.

Policy Changes

Our business changes constantly, and our Privacy Notice may also change. You should check our website frequently to see recent changes. You can see the date on which the latest version of this Privacy Notice was posted. Unless stated otherwise, our current Privacy Notice applies to all personal information we have about you and your account. We stand behind the
promises we make, however, and will never materially change our policies and practices to make them less protective of personal information collected in the past without informing affected customers and giving them a choice.

EU Model Contract Clauses

Standard Contractual Clauses (processors)

For the purposes of Article 26(2) of Directive 95/46/EC for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection, the non-AttackBound legal entity accepting the Clauses (the “Data Exporter”) and AttackBound Pty Ltd. (AttackBound), Level 23, International Tower 3, 300 Barangaroo Avenue, Sydney, NSW 2000, Australia (the “Data Importer”) each a “party”; together “the parties”,

have agreed on the following Contractual Clauses (the “Clauses”) 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.

The Clauses (including Appendices 1 and 2) are effective from the date the non-AttackBound entity has both: (i) executed a valid “AttackBound Service Agreement” (collectively the “Service Agreement”) or is otherwise an authorized customer affiliate under such Services Agreement; and (ii) accepted these Clauses. A “AttackBound Service Agreement” means an Secure Logic Service Agreement entered into with AttackBound.

If you are accepting on behalf of the Data Exporter, you represent and warrant that: (i) you have full legal authority to bind your employer, or the applicable entity, to these terms and conditions; (ii) you have read and understand the Clauses; and (iii) you agree, on behalf of the party that you represent, to the Clauses. If you do not have the legal authority to bind the Data Exporter, please do not accept the Clauses below. The Clauses shall automatically expire on the termination or expiry of the AttackBound Service Agreement. The parties agree that where Data Exporter has been presented with these Clauses and clicked to accept these terms electronically, such acceptance shall constitute execution of the entirety of the Clauses by both parties, subject to the effective date described above.

Clause 1

Definitions

For the purposes of the Clauses:

‘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 free movement of such data [1];
‘the data exporter’ means the controller who transfers the personal data;
‘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 is not subject to a third country’s system ensuring adequate protection within the meaning of Article 25(1) of Directive 95/46/EC;
‘the subprocessor’ means any processor engaged by the data importer or by any other subprocessor of the data importer who agrees to receive from the data importer or from any other subprocessor 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;
‘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;
‘technical and organisational 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

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.
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.
The data subject can enforce against the subprocessor 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 subprocessor shall be limited to its own processing operations under the Clauses.
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:

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;
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;
that the data importer will provide sufficient guarantees in respect of the technical and organisational security measures specified in Appendix 2 to this contract;
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;
that it will ensure compliance with the security measures;
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;
to forward any notification received from the data importer or any subprocessor 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;
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 subprocessing 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;
that, in the event of subprocessing, the processing activity is carried out in accordance with Clause 11 by a subprocessor 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
that it will ensure compliance with Clause 4(a) to (i).

Clause 5

Obligations of the data importer [2]

The data importer agrees and warrants:

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;
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;
that it has implemented the technical and organisational security measures specified in Appendix 2 before processing the personal data transferred;
that it will promptly notify the data exporter about:
1. 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,
2. any accidental or unauthorised access, and
3. any request received directly from the data subjects without responding to that request, unless it has been otherwise authorised to do so;
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;
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;
to make available to the data subject upon request a copy of the Clauses, or any existing contract for subprocessing, 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;
that, in the event of subprocessing, it has previously informed the data exporter and obtained its prior written consent;
that the processing services by the subprocessor will be carried out in accordance with Clause 11;
to send promptly a copy of any subprocessor agreement it concludes under the Clauses to the data exporter.

Clause 6

Liability

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 subprocessor is entitled to receive compensation from the data exporter for the damage suffered.
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 subprocessor 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 subprocessor of its obligations in order to avoid its own liabilities.
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 subprocessor 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 subprocessor agrees that the data subject may issue a claim against the data subprocessor 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 subprocessor shall be limited to its own processing operations under the Clauses.

Clause 7

Mediation and jurisdiction

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:
1. (a) to refer the dispute to mediation, by an independent person or, where applicable, by the supervisory authority;
2. (b) to refer the dispute to the courts in the Member State in which the data exporter is established.
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

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.
The parties agree that the supervisory authority has the right to conduct an audit of the data importer, and of any subprocessor, 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.
The data importer shall promptly inform the data exporter about the existence of legislation applicable to it or any subprocessor preventing the conduct of an audit of the data importer, or any subprocessor, 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.

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

Subprocessing

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 subprocessor which imposes the same obligations on the subprocessor as are imposed on the data importer under the Clauses [3]. Where the subprocessor 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 subprocessor’s obligations under such agreement.
The prior written contract between the data importer and the subprocessor 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 subprocessor shall be limited to its own processing operations under the Clauses.
The provisions relating to data protection aspects for subprocessing 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.
The data exporter shall keep a list of subprocessing 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

The parties agree that on the termination of the provision of data processing services, the data importer and the subprocessor 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.
The data importer and the subprocessor 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.

[i] Parties may reproduce definitions and meanings contained in Directive 95/46/EC within this Clause if they considered it better for the contract to stand alone.

[ii] Mandatory requirements of the national legislation applicable to the data importer which do not go beyond what is necessary in a democratic society on the basis of one of the interests listed in Article 13(1) of Directive 95/46/EC, that is, if they constitute a necessary measure to safeguard national security, defence, public security, the prevention, investigation, detection and prosecution of criminal offences or of breaches of ethics for the regulated professions, an important economic or financial interest of the State or the protection of the data subject or the rights and freedoms of others, are not in contradiction with the standard contractual clauses. Some examples of such mandatory requirements which do not go beyond what is necessary in a democratic society are, inter alia, internationally recognised sanctions, tax-reporting requirements or anti-money-laundering reporting requirements.

[iii] This requirement may be satisfied by the subprocessor co-signing the contract entered into between the data exporter and the data importer under this Decision.

Appendix 1

Appendix 1 to the Standard Contractual Clauses

This Appendix forms part of the Clauses of the Standard Contractual Clauses and is to be considered as part of any agreement to the Standard Contractual Clauses.

Data Exporter.

The data exporter has purchased authentication Services from the data importer which include the processing of personal data.

Data Importer

The Data Importer, a global provider of technology services for businesses, has agreed to provide authentication Services to data exporter (on a
software-as-a-service basis) including the processing of personal data.

Data Subjects

The personal data transferred by the data exporter to the data importer concerns the following categories of data subjects:

Data exporter’s customers and end-users

Data exporter’s employees, consultant and agents authorized by data exporter to use the Services and/or identified to serve as customer contacts.

Categories of data

Data exporter may provide names, emails, street addresses, and phone numbers with respect to its employees, consultants and agents authorized by data exporter to use the Services and/or identified to serve as customer contacts.

Data exporter selects the categories of data collected by, and/or provided to, data importer for purposes of providing the authentication Services and related processing. All these activities are conducted electronically, so data importer has no visibility into the selections by data exporter, but assumes that the categories of data would be those commonly used for authentication purposes, such as log-in credentials, first name, last name and email address.

Special categories of data (if appropriate)

Not applicable.

Processing operations

The personal data transferred will be subject to the following basic processing activities:

Scope of Processing

Personal data may be processed only to comply with Instructions by (or at the direction of) Data Exporter (and as defined in the Terms of Service or Service Agreement) in order to provide the Services.

Storage

Personal data will be stored by data importer.

Access

Data exporter will have the ability to configure the Services, access, correct, block, export and delete data from the Services in accordance with the Terms of Service or Service Agreement.

Termination

After termination or expiry of the applicable Services Agreement, data importer will delete the data exporter’s data from the Service.

Appendix 2

Appendix 2 to the Standard Contractual Clauses

This Appendix forms part of the Clauses of the Standard Contractual Clauses and is considered to be part of any agreement to the Standard Contractual Clauses.

Description of the technical and organisational security measures implemented by the Data Importer in accordance with Clauses 4(c) and 5(c) (or document/legislation attached):

The Data Importer currently abides by the security standards in this Appendix 2. The Data Importer may update or modify these security standards from time to time provided such updates and modifications will not result in a degradation of the overall security of the Services during the term of the Service Agreement.

1. Hosting Infrastructure.
  - The Data Importer hosts its services in geographically distributed,
    secure data centers.
  - Redundancy. The services are replicated across multiple data centers within a geographic region to eliminate single points of failure using an active/passive configuration in order to minimize the impact of environmental risks.
  - Monitoring. The services are protected by automated monitoring which is designed to detect a variety of failure conditions and which will, when appropriate, trigger failover mechanisms.
  - Backups. Backups are performed on a regular basis and stored in a secondary site within the same geographic region.
  - Business Continuity. The Data Importer replicates its service and data over multiple data centers within a geographic region to protect against loss of service or data. The Data Importer conducts periodic tests of failover and data backup procedures to ensure readiness for business continuity and disaster recovery.
  - Data Transmission. All interactions between users, administrators and application modules are done using the Secure Socket Layer (SSL) or Transport Layer Security (TLS) standard cryptographic protocols.
  - Network Security. The Data Importer employs multiple layers of perimeter security, including Intrusion Detection, Rate Limiting and other network security services.
  - Encryption Technologies. The Data Importer makes HTTPS encryption (also referred to as SSL or TLS connection) available.
  - Policies and Procedures. The Data Importer has written, approved policies governing Account Management, Acceptable Use, Data Retention, Employee Code of Conduct, Encryption, Incident Response, Information Sensitivity, Use of Mobile Devices, Password Protection, Patch Management and Risk Management. Procedures. The Data Importer has written and approved procedures for Change Management, Disaster Recovery, System Backup and Recovery, and Monitoring.
  - Security Response. The Data Importer monitors a variety of communication channels for security incidents, and the Data Importer’s security personnel will react promptly to known incidents.
2. Access Controls.
  - The Data Importer maintains formal access procedures for allowing access to the production service and components involved in building the production service. Only authorized employees are allowed access to these restricted components and all access is approved by an employee’s manager and service owner. Only a small number of individuals are approved to access the restricted components. Audit records are maintained to indicate who has access to restricted components.
  - Access Mechanisms. Access to the Data Importer’s production service and build infrastructure occurs only over a secured channel and require two-factor authentication.
  - Logging. Access to the Data Importer’s production service and build infrastructure is done using unique IDs and is logged.
  - Infrastructure Security Personnel. The Data Importer maintains several security policies governing its personnel. The Data Importer’s infrastructure security personnel are responsible for the ongoing monitoring of the Data Importer’s security infrastructure, the review of the Services, and responding to security incidents.
3. Data Security.
  - Data Protection. Data Importer uses cryptographic hashing and encryption mechanisms to protect sensitive information such as cryptographic keys and application secrets. The Data Importer stores data in a secure environment within the Data Importer’s hosted infrastructure. The data and service are replicated across multiple hosted datacenters within the same geographic region.
  - Data Isolation. The Data Importer logically isolates the Data Exporter’s data, and the Data Exporter has a large degree of control over the specific data stored in the Service.
  - Data Deletion. The Data Importer provides to the Data Exporter a mechanism that can be used to delete the Data Exporter’s data.
  - Security Reviews. The Data Importer employs a security review process to improve the security of the security controls used to provide the Services.
  - Security Scan. The Data Importer employs a third party to scan the Service for security vulnerabilities on a periodic basis.
  - Staff Conduct and Security. The Data Importer personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, usage, compliance and professional standards.
  - Background Checks. The Data Importer conducts reasonably appropriate backgrounds checks to the extent legally permissible and in accordance with applicable local labor law and statutory regulations.
  - Subprocessor Security. Prior to onboarding Subprocessors that will handle any data provided by a Data Exporter, the Data Importer conducts an audit of the security and privacy practices of Subprocessors to ensure Subprocessors provide a level of security and privacy appropriate to their access to data and the scope of the services they are engaged to provide.
  - Data Privacy Office. The Data Privacy Office of the Data Importer can be contacted at privacy@attackbound.com (or via such other means as may
    be provided by the Data Importer)