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

TrustGrid 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@trustgrid.com

This Privacy Policy does not apply to the “content” processed, stored, or hosted by our customers using our products (TrustGrid 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 TrustGrid, 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 TrustGrid:
– This section applies if you have opted in to receive marketing communications from us, or have previously expressed an interest in TrustGrid 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@trustgrid.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 TrustGrid 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

TrustGrid 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 TrustGrid, 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 TrustGrid, please contact us at privacy@trustgrid.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-TrustGrid legal entity accepting the Clauses (the “Data Exporter”) and TrustGrid Pty Ltd. (TrustGrid), 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-TrustGrid entity has both: (i) executed a valid “TrustGrid
Service Agreement” (collectively the “Service Agreement”) or is otherwise
an authorized customer affiliate under such Services Agreement; and (ii)
accepted these Clauses. A “TrustGrid Service Agreement” means an Secure
Logic Service Agreement entered into with TrustGrid.

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
TrustGrid 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:

1. ‘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];
2. ‘the data exporter’ means the controller who transfers the personal
   data;
3. ‘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;
4. ‘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;
5. ‘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;
6. ‘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

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 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.
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:

1. 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;
2. 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;
3. that the data importer will provide sufficient guarantees in respect of
   the technical and organisational security measures specified in
   Appendix 2 to this contract;
4. 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;
5. that it will ensure compliance with the security measures;
6. 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;
7. 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;
8. 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;
9. 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
10. 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:

1. 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;
2. 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;
3. that it has implemented the technical and organisational security
   measures specified in Appendix 2 before processing the personal data
   transferred;
4. 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;
5. 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;
6. 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;
7. 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;
8. that, in the event of subprocessing, it has previously informed the
   data exporter and obtained its prior written consent;
9. that the processing services by the subprocessor will be carried out in
   accordance with Clause 11;
10. to send promptly a copy of any subprocessor 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 subprocessor 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 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.
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 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

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:

    

   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.
2. 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 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.
3. 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

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 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.
2. 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.
3. 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.
4. 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

1. 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.
2. 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.
• 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@trustgrid.com (or via such other means as may
  be provided by the Data Importer)