Third Party Index

Snapshot 12190

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Data processing addendum
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                                 DATA PROCESSING AGREEMENT

                                 FOR A EVERFOX ULTRA SERVICE
These Data Processing Terms and Conditions (“DPA”) are an integral part of the Agreement for the
provision on a trial or commercial basis of the Everfox ULTRA Service and are a legal agreement
between the relevant Everfox entity as set out in the Order (“Everfox”) and the legal entity being
provided access to and making use on a trial or commercial basis of the Everfox ULTRA Service
(”Customer”). Each a “Party” and together the “Parties”.

1     DEFINITIONS

In this Agreement, unless the context otherwise requires, the following words shall have the following
meanings:

Agreement          means the contract between Everfox and Customer for the provision on a trial or
                   commercial basis of the Everfox ULTRA Service to which this DPA is incorporated.
Data Controller    means Everfox in respect of Customer organisational data including name,
                   organisation, job, email address and phone numbers; and Customer in respect of all
                   other personal data set out in Appendix A.
Data Processor     means Everfox in respect of all personal data set out in Appendix A for which Everfox
                   is not the Data Controller.
Data Protection    means any laws, regulations, guidelines, and/or codes of practice that: (a) are
Laws               applicable to data processed by Data Processor regardless of jurisdiction or location;
                   and (b) govern the collection, use, processing, storage, transfer, and protection of
                   Personal Data or personal information. Data Protection Laws include the General
                   Data Protection Regulation 2016/679 (EU) (“GDPR”), Privacy and Electronic
                   Communications Directive 2002/58 (EU), Data Protection Act 2018 (UK) (“UK-
                   GDPR”), Privacy and Electronic Communications (EC Directive) Regulations 2003
                   (UK), California Consumer Privacy Act 2018 (California) (“CCPA”), and the
                   Personal Data Protection Act 2012 (Singapore) (“PDPA”). The terms “breach”,
                   “data subject”, “processing”, and “sensitive personal data” shall have the same
                   meaning as in and for Data Protection Laws.
Everfox Affiliates means any entity that controls, is controlled by or is under common control with
                   Everfox, where “control” means ownership of more than fifty percent of the
                   outstanding securities representing the right to vote for the election of directors or
                   other managing authority.
Everfox            means the web isolation service provided by Everfox to Customer under the
ULTRA              Agreement.
Service
Personal Data      means information that identifies, relates to, describes, or is capable of being
                   associated with a natural person, i.e., personal data as defined by Data Protection
                   Laws, arising out of or in connection with the Subject Matter, including as set out in
                   the Appendix A. Personal Data includes “sensitive personal data” as defined by Data
                   Protection Laws.
Subject Matter     means: (i) for the provision of Everfox ULTRA to Customer pursuant to the
                   Agreement; (ii) for each Party to meet their respective obligations as set out in this
                   DPA; and (iii) to comply with any legal obligation to which either Party is subject.
2     DATA PROCESSING
      2.1       In processing Personal Data on behalf of the Data Controller, unless otherwise required
                by applicable law the Data Processor shall:
               a) Comply with all applicable Data Protection Laws;
               b) Process Personal Data solely for the Subject Matter, and only to the extent
                  necessary for the Subject Matter;
               c) Process Personal Data in accordance with the instructions of the Data Controller;

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              d) Implement and maintain appropriate technical and organisational measures to
                 ensure the security, confidentiality, and integrity of Personal Data, taking into
                 account the state of the art, the costs of implementation, and the nature, scope,
                 context, and purposes of processing as set out in Appendix B;
              e) Ensure that all personnel who have access to Personal Data are subject to
                 confidentiality obligations and have received appropriate training on data
                 protection; and
              f)    Permanently delete Personal Data promptly upon receipt of a written request by the
                    Data Controller.
      2.2      Customer acknowledges and agrees that Everfox may process data that has been fully
               and irreversibly anonymised and aggregated for its own internal business purposes
               including for the purpose of analytics and/or to improve the Everfox ULTRA Service.
3     IMPACT ASSESSMENTS AND PRIOR CONSULTATION
      3.1      Data Processor taking into account the nature of the processing, and the information
               available to it, shall provide reasonable assistance to Customer with any data
               protection impact assessments, and prior consultations with competent data privacy
               authorities, which Data Controller reasonably considers to be required by Data
               Protection Laws.
4     DATA SUBJECT REQUESTS
      4.1      Data Processor shall promptly notify Customer if it receives a request from a data
               subject under Data Protection Laws. Data Processor shall assist the Data Controller to
               comply with any request for access, correction or removal of Personal Data required
               by Data Protection Laws.
5     UNAUTHORISED PROCESSING
      5.1      Data Processor shall notify the Data Controller promptly upon becoming aware of any
               unauthorised or unlawful processing, accidental or unlawful loss, destruction,
               alteration, or disclosure of Personal Data.
6     DATA BREACH
      6.1      Data Processor shall cooperate with the Data Controller to investigate and remediate
               any data protection incident, including any required notifications to data protection
               authorities or affected data subjects.
7     INTERNATIONAL DATA TRANSFERS
      7.1      Data Controller consents to the transfer by the Data Processor of Personal Data
               originating within a State to other States subject to compliance with the requirements
               for cross-border data transfers in any applicable Data Protection Laws and this clause.
               The Data Processor shall ensure that all cross-border transfers of Personal Data are
               conducted pursuant to a mechanism then considered to comply with applicable Data
               Protection Law requirements for cross-border transfers, including for Personal Data
               originating within:
               a)     European Economic Area, that the transfer is: (i) to a State the subject of an
                      adequacy decision by the European Commission, or (ii) pursuant to standard
                      contractual clauses set out in Commission Implementing Decision (EU)
                      2021/914 (“SCC”) which are incorporated into a written contract between the
                      Data Processor and the recipient;
               b)     United Kingdom, that the transfer is: (i) to a State the subject of an adequacy
                      decision by the UK Government, (ii) pursuant to standard contractual clauses set
                      out in the International Data Transfer Agreement 2022 which are incorporated
                      into a written contract between the Processor and the recipient, or (iii) pursuant
                      to the International Data Transfer Addendum 2022 addended to the SCC which
                      are together incorporated into a written contract between the Data Processor and
                      the recipient;
               c)     Singapore, that the transfer is to a State that provides a standard of data
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                     protection comparable to that provided under the PDPA; or
               d)    California, that the transfer is: (i) pursuant to a written agreement with the
                     recipient requiring the same level of data protection as required by the CCPA,
                     or (ii) to a recipient that is certified under an approved certification mechanism.
8     SUB-PROCESSORS
      8.1      Controller authorises Data Processor to pass Personal Data to sub-processors,
               including those identified in Appendix A, subject to compliance by the Processor with
               the terms of this DPA.
9     AUDIT RIGHTS
      9.1      Data Controller shall have the right to audit Data Processor’s compliance with this DPA.
               Such audit may be performed once per calendar year, at Data Controller’s expense,
               on at least 30 days prior written notice, during normal business hours, in a manner that
               does not unreasonably interfere with normal operations, and without compromising any
               confidential or proprietary information.
10    MISCELLANEOUS
      10.1     In this DPA reference to any: (a) statute or statutory provision is a reference to it as
               amended, extended, or re-enacted from time to time, and any subsidiary legislation
               and/or subordinate instrument made under it; (b) person includes natural persons,
               companies, partnerships, associations, governments, organisations, states,
               government or state agencies, foundations, charities, and trusts; (c) company shall
               include any company, corporation, or other body corporate, wherever and however
               incorporated or established; and (d) Party includes a reference to that Party’s
               successors in title, permitted assignees and transferees.
      10.2     In this DPA: (a) words denoting the singular shall include the plural and words denoting
               the plural shall include the singular; (b) headings are for convenience only and do not
               affect the interpretation of this Agreement; and (c) the word “including”, and similar
               expressions will not be construed as words of limitation and shall be read as “including,
               but not limited to”.
      10.3     No Party may assign this DPA to any other person without the prior written consent of
               the other Party, such consent not to be unreasonably withheld, delayed, or conditioned.
               Any purported assignment in breach of this clause shall be deemed null and void.
      10.4     This DPA constitutes the entire agreement between the Parties on matters of data
               protection and supersedes and merges all prior discussion and any prior agreement.
               Each Party acknowledges that in entering into this DPA it has not relied on any
               warranty, representation or other promise of any nature not contained in this DPA.
      10.5     This DPA and any disputes arising out of or in connection with it or its subject matter
               shall be construed in accordance with and governed exclusively by the laws of England
               and the acts of the Parliament of the United Kingdom which are applicable in England.
      10.6     The Parties irrevocably agree the courts of England and Wales shall have exclusive
               jurisdiction to settle any claim that arises out of or in connection with this DPA or its
               subject matter.

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                                                 APPENDIX A – DATA PROCESSING FOR THE EVERFOX ULTRA
                                                                       SERVICE

Type of Personal      Category of      Purpose             Nature                        Duration              Everfox      Customer     Sub -          Transferred
Data                  Data Subject                                                                                                       Processors?    outside
                                                                                                                                                        Customer home
                                                                                                                                                        region?
Customer              Customer         Service             Data stored on CRM            For the duration of   Data         Data         Everfox        Yes
organisational Data   representative   management,         system; email                 the Agreement,        Controller   Controller   Affiliates
(e.g., name,          s                customer            systems; files on             though details may
organisation, job,                     communication,      corporate                     be updated by
email address and                      including           network/intranet              Customer from
phone numbers)                         notification of                                   time to time.
                                       software                                          Commercial
                                       updates.                                          contacts may be
                                       Contract                                          retained for a
                                       management.                                       further 6 (six)
                                       Feature                                           years for contract
                                       improvements                                      management
                                       and product                                       purposes
                                       marketing
Username, email       Customer         For designated      Data stored and               For 36 (thirty-six)   Data         Data         Everfox        Customer must
address, first and    designated       Customer            encrypted by AWS              months from           Processor    Controller   Affiliates     choose the home
last name, and role   administrato     administrators to                                 expiry or                                                      region of their choice
in Customer           rs and           manage the                                        termination of the                                             at the start of
organisation          Authorised       service in the                                    Agreement or                                                   onboarding
                      Users            Everfox ULTRA                                     Customer’s
                                       Portal                                            request of                                                     If the elected home
                                                                                         deletion of the                                                region is not where
                                       For Authorised                                    license created for                                            the Customer
                                       Users to log into                                 Access whichever                                               designated
                                       Everfox ULTRA                                     occurs earlier                                                 administrator is
                                                                                                                                                        located, this will
                                                                                                                                                        necessitate a
                                                                                                                                                        transfer to a third
                                                                                                                                                        country
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Type of Personal        Category of     Purpose             Nature                       Duration               Everfox     Customer     Sub -          Transferred
Data                    Data Subject                                                                                                     Processors?    outside
                                                                                                                                                        Customer home
                                                                                                                                                        region?
Logs of Customer        Customer        For Customer        Data stored and              For 36 (thirty-six)    Data        Data         Everfox        Customer must
designated              designated      monitoring of       encrypted by AWS             months from when       Processor   Controller   Affiliates     choose the home
administrators          administrato    Customer                                         logs are generated                                             region of their choice
performing actions in   rs for the      designated                                                                                                      at the start of
the Everfox ULTRA       Everfox         administrators                                                                                                  onboarding
portal                  ULTRA
                        portal          For provision and                                                                                               If the elected home
                                        management of                                                                                                   region is not where
                                        Everfox ULTRA                                                                                                   the Customer
                                        by Everfox                                                                                                      designated
                                                                                                                                                        administrator is
                                                                                                                                                        located, this will
                                                                                                                                                        necessitate a
                                                                                                                                                        transfer to a third
                                                                                                                                                        country
Authorised User         Authorised      For the provision   Data processed on the        All Browsing data      Data        Data         Everfox        Yes – an active
browsing data           Users plus      of Everfox          Everfox node during          is securely wiped      Processor   Controller   Affiliates     session will
generated during        Personal        ULTRA               the browsing session         from the Everfox                                               ordinarily be in
the active browsing     Data of other                                                    node at the end of                                             the region the
session including       Data                                                             a session and                                                  Authorised User
Cookies, Browsing       Subjects that                                                    cannot be                                                      is in at the time
History, Passwords,     may exist                                                        accessed by                                                    of commencing a
Downloaded Files        within their                                                     anyone except the                                              session
                        browsing                                                         Authorised User
Downloaded Files        activity or                                                      that is currently on                                           Each region may
may include             downloads                                                        the node                                                       contain data
sensitive Personal                                                                                                                                      centres in multiple
Data                                                                                                                                                    countries and from
                                                                                                                                                        time to time a
                                                                                                                                                        different region
                                                                                                                                                        may be used for
                                                                                                                                                        operational
                                                                                                                                                        purposes

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Type of Personal      Category of     Purpose                 Nature                         Duration               Everfox     Customer     Sub -             Transferred
Data                  Data Subject                                                                                                           Processors?       outside
                                                                                                                                                               Customer home
                                                                                                                                                               region?
Authorised User       Authorised      For the provision of    Data processed on the          Browsing data at       Data        Data         Everfox           Yes - for
browsing data         Users plus      Everfox ULTRA           Everfox node during            rest will be           Processor   Controller   Affiliates and    performance
generated across      Personal        and in particular for   the browsing session           retained for 6 (six)                            AWS               reasons data
browsing sessions     Data of other   seamless                and then data stored in        months from when                                                  may be
including Cookies,    Data            browsing activity       an encrypted format in         it was last                                                       replicated
Browsing History,     Subjects that   between browsing        AWS. The storing of            accessed by the                                                   between regions
Passwords,            may exist       sessions                the data is subject to         Authorised User                                                   using the same
Downloaded Files      within their                            the relevant feature           unless Customer                                                   encryption
                      browsing                                being enabled by the           requests deletion                                                 standards
Downloaded Files      activity or                             Authorised User. The           or Authorised
may include           downloads                               data is transferred to a       User deletes it                                                   Customer has the
sensitive Personal                                            node and decrypted at          during a live                                                     ability to activate
Data                                                          the start of a session.        browsing session                                                  or deactivate
                                                              The encryption key                                                                               regions of their
                                                              that is used is                                                                                  choice.
                                                              generated from a
                                                              combination of the user
                                                              ID and a per-customer
                                                              secret. The per-
                                                              customer secret is
                                                              maintained in a
                                                              separate AWS
                                                              database and is itself
                                                              encrypted
Authorised User       Authorised      For the provision       Data stored and                For 36 (thirty-six)    Data        Data         Everfox           Customer must
browsing logs from    Users           of Everfox              encrypted by AWS               months from when       Processor   Controller   Affiliates and    choose the home
native browser (if                    ULTRA                                                  logs are generated                              AWS               region of their choice
Customer’s                                                                                                                                                     at the start of
designated                                                                                                                                                     onboarding
administrator
configures and                                                                                                                                                 If the elected home
enables the Trust                                                                                                                                              region is not where
Qualified Browsing                                                                                                                                             Authorised User is

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Type of Personal          Category of      Purpose            Nature                       Duration              Everfox     Customer     Sub -             Transferred
Data                      Data Subject                                                                                                    Processors?       outside
                                                                                                                                                            Customer home
                                                                                                                                                            region?
feature in the                                                                                                                                              browsing from, this
Everfox ULTRA                                                                                                                                               will necessitate a
Customer portal)                                                                                                                                            transfer to a third
                                                                                                                                                            country

Authorised User           Authorised       For Customer       Data stored and              For 7 (seven) days    Data        Data         Everfox           Customer must
browsing logs             Users            monitoring and     encrypted by AWS             from when the logs    Processor   Controller   Affiliates and    choose the home
within Everfox                             control of                                      were generated.                                AWS               region of their choice
ULTRA                                      corporate internet                                                                                               at the start of
                                           use                                                                                                              onboarding
URLs directly and
indirectly (if indirect                                                                                                                                     If the elected
URLs are enabled)                                                                                                                                           home region is not
visited by                                                                                                                                                  where Authorised
Authorised User,                                                                                                                                            User is browsing
including username,                                                                                                                                         from, this will
URL, time of                                                                                                                                                necessitate a
request and whether                                                                                                                                         transfer to a third
it was direct or not                                                                                                                                        country
Authorised User           Authorised       Customer can       If Customer chooses to       Once logs are         Data        Data         Everfox           If Customer chooses
browsing logs and         Users and        export logs from   export logs from             exported to           Processor   Controller   Affiliates and    to transfer the logs
administrator             Customer         Everfox ULTRA      Everfox ULTRA, the           Customer’s                                     AWS               outside Everfox
actions logs              designated       into its own       logs are exported to         environment,                                                     ULTRA the location
                          administrators   environment for    Customer’s                   Customer is solely                                               is solely within
                                           Customer’s own     environment either via       responsible for                                                  Customer’s control
                                           storage and        a management API or          those logs. In
                                           analysis           a Everfox provided log       accordance with
                                           purposes           connector                    the previous row of
                                                                                           this Appendix,
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Type of Personal      Category of    Purpose             Nature                        Duration               Everfox     Customer     Sub -             Transferred
Data                  Data Subject                                                                                                     Processors?       outside
                                                                                                                                                         Customer home
                                                                                                                                                         region?
                                                                                       Everfox retains
                                                                                       copies of the logs
                                                                                       for 7 (seven) days
                                                                                       from when the logs
                                                                                       were generated

Any content (e.g.     Authorised     For the provision   Content viewed as part        Content is             Data        Data         Everfox           Customer must
text and images       Users          of Everfox          of Authorised User            securely wiped         Processor   Controller   Affiliates and    choose the home
etc.) that can be                    ULTRA and in        Browsing data that can        from the Everfox                                AWS               region of their choice
copied or printed                    particular for      be copied or printed          Transfer Appliance                                                at the start of
by Authorised                        enabling copy /                                   and AWS after the                                                 onboarding
Users from the                       paste and           This data is securely         transfer is made
Internet using                       printing            transferred through a                                                                           The transfer will
Everfox ULTRA                        functionality of    Everfox Transfer                                                                                move from where
                                     text and images     Appliance and then via                                                                          Authorised User is
                                                         AWS to the Authorised                                                                           browsing from,
                                                         User’s local device                                                                             through the elected
                                                                                                                                                         home region and
                                                                                                                                                         then onward to
                                                                                                                                                         where Authorised
                                                                                                                                                         User physically is
Any content (e.g.     Authorised     For the provision   Content stored in             All data is            Data        Data         Everfox           The transfer will
text and images       Users          of Everfox          Authorised User               securely wiped         Processor   Controller   Affiliates and    move from where
etc.) that can be                    ULTRA and in        clipboard                     from the Everfox                                AWS               Authorised User is
copied by                            particular for                                    node at the end of                                                physically located to
Authorised Users                     enabling copy /     This data is securely         a session and                                                     where Authorised
to the Everfox                       paste               transferred from              cannot be                                                         User is browsing
ULTRA isolated                       functionality of    Authorised User’s local       accessed by                                                       from
environment from                     text and images     device to the Everfox         anyone except the
Customer                                                 ULTRA isolated                Authorised User
Environment                                              environment                   that is currently on
                                                                                       the node
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Type of Personal      Category of      Purpose             Nature                           Duration             Everfox     Customer     Sub -             Transferred
Data                  Data Subject                                                                                                        Processors?       outside
                                                                                                                                                            Customer home
                                                                                                                                                            region?
                                                           Once in the Everfox
                                                           ULTRA isolated
                                                           environment, the data
                                                           is no longer in the
                                                           Customer Environment
                                                           and therefore is
                                                           exposed to potential
                                                           risk

                                                           This functionality is
                                                           enabled by default

                                                           The Everfox ULTRA
                                                           Service does not
                                                           inspect this content
                                                           and Everfox expressly
                                                           disclaims any and all
                                                           liability for any losses
                                                           that may arise from
                                                           this functionality being
                                                           enabled. Customer is
                                                           responsible to
                                                           determine if this
                                                           functionality should
                                                           remain enabled or
                                                           disable it
Any files             Authorised       For the provision   Files downloaded                 File downloads are   Data        Data         Everfox           Customer must
downloaded by         Users plus       of Everfox          during or across                 stored for 2 (two)   Processor   Controller   Affiliates and    choose the home
Authorised Users      Personal         ULTRA and in        Authorised User                  days before being                             AWS               region of their choice
using Everfox         Data of other    particular for      Browsing sessions.               wiped unless they                                               at the start of
ULTRA                 Data Subjects    enabling            Where file downloads             are transferred to                                              onboarding
                      that may exist   download of files   to the local device are          Authorised User’s
Downloaded files      within their     from the Everfox    enabled, files are               profile, in which                                               The transfer will

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Type of Personal      Category of    Purpose             Nature                           Duration              Everfox     Customer     Sub -             Transferred
Data                  Data Subject                                                                                                       Processors?       outside
                                                                                                                                                           Customer home
                                                                                                                                                           region?
may include           browsing       ULTRA isolated      transferred then either          case the file                                                    move from where
sensitive Personal    activity or    environment         stored and encrypted             downloads are                                                    Authorised User is
Data                  downloads                          in AWS (if the file is           processed and                                                    browsing from,
                                                         large or Authorised              stored in                                                        through the elected
                                                         User elects to transfer          accordance with                                                  home region and
                                                         the file through the             row 5 of this                                                    then onward to
                                                         AWS platform) or                 Appendix A                                                       where Authorised
                                                         transferred and stored                                                                            User physically is
                                                         with Authorised User’s
                                                         profile in accordance
                                                         with row 5 of this
                                                         Appendix A

Any files emailed     Authorised     For the provision   Files downloaded                 Email transfers are   Data        Data         Everfox           Customer must
by Authorised         Users          of Everfox          during or across                 forwarded and not     Processor   Controller   Affiliates and    choose the home
Users using                          ULTRA and in        Authorised User                  stored                                         AWS               region of their choice
Everfox ULTRA                        particular for      Browsing sessions                                                                                 at the start of
                                     enabling email                                                                                                        onboarding
                                     transfer of files   When a file is sent via
                                     from the Everfox    email the file is relayed                                                                         The transfer will
                                     ULTRA isolated      through AWS and then                                                                              move from where
                                     environment         forwarded to                                                                                      Authorised User is
                                                         Authorised User’s                                                                                 browsing from,
                                                         email address of                                                                                  through the elected
                                                         choice                                                                                            home region and
                                                                                                                                                           then onward to
                                                         This functionality is                                                                             where the elected
                                                         enabled by default                                                                                email recipient
                                                                                                                                                           physically is
                                                         Files emailed in this
                                                         way may be malicious
                                                         and the Everfox

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Type of Personal      Category of    Purpose         Nature                         Duration              Everfox     Customer     Sub -             Transferred
Data                  Data Subject                                                                                                 Processors?       outside
                                                                                                                                                     Customer home
                                                                                                                                                     region?
                                                     ULTRA Service does
                                                     not enable any security
                                                     measures to prevent
                                                     this. Everfox expressly
                                                     disclaims any and all
                                                     liability for any losses
                                                     that may arise from
                                                     this functionality being
                                                     enabled

                                                     Customer is
                                                     responsible to
                                                     determine if this
                                                     functionality should
                                                     remain enabled or
                                                     disable it and where
                                                     enabled to ensure
                                                     such email transfer
                                                     occurs in accordance
                                                     with Customer
                                                     corporate policies and
                                                     Everfox’s AUP

Logs of Authorised    Authorised     For provision   Data stored and                For 36 (thirty-six)   Data        Data         Everfox           Customer must
User actions          Users          and             encrypted by AWS               months from when      Processor   Controller   Affiliates and    choose the home
against service                      management of                                  logs were                                      AWS               region of their choice
APIs                                 Everfox ULTRA                                  generated                                                        at the start of
                                     by Everfox                                                                                                      onboarding
Data includes the
Authorised User                                                                                                                                      If the elected home
username, the                                                                                                                                        region is not where
time and the action                                                                                                                                  Authorised User is
name                                                                                                                                                 located, this will

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Type of Personal       Category of    Purpose         Nature                      Duration              Everfox     Customer     Sub -             Transferred
Data                   Data Subject                                                                                              Processors?       outside
                                                                                                                                                   Customer home
                                                                                                                                                   region?
                                                                                                                                                   necessitate a
For example, if an                                                                                                                                 transfer to a third
Authorised User                                                                                                                                    country
transfers a file to
their local
machine, this
action will be
logged (but without
further details such
as the filename)
Logs of Authorised     Authorised     For provision   Data stored and             For 36 (thirty-six)   Data        Data         Everfox           Customer must
User actions within    Users          and             encrypted by AWS            months from when      Processor   Controller   Affiliates and    choose the home
the Everfox                           management of                               logs were                                      AWS               region of their choice
ULTRA service                         Everfox ULTRA                               generated                                                        at the start of
                                      by Everfox                                                                                                   onboarding
Data includes the
Authorised User                                                                                                                                    If the elected home
username, the                                                                                                                                      region is not where
time, and the                                                                                                                                      Authorised User is
action name                                                                                                                                        located, this will
                                                                                                                                                   necessitate a
For example, if an                                                                                                                                 transfer to a third
Authorised User                                                                                                                                    country
pastes content
from their local
machine, this
action will be
logged (but without
further details such
as the content)

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Type of Personal      Category of    Purpose         Nature                         Duration          Everfox     Customer     Sub -             Transferred
Data                  Data Subject                                                                                             Processors?       outside
                                                                                                                                                 Customer home
                                                                                                                                                 region?
Logs of Authorised    Authorised     For provision   Download of                    Anonymised data   Data        Data         Everfox           No transfer
User actions in       Users          and             anonymised data                will be kept      Processor   Controller   Affiliates and
Everfox ULTRA                        management of   stored and encrypted           indefinitely                               AWS
against service                      Everfox ULTRA   by AWS onto Everfox
APIs and in the                      by Everfox      corporate infrastructure
Everfox ULTRA                                        and analysis of such
web app                                              data

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                                APPENDIX B – DATA AND SYSTEM SECURITY POLICY FOR THE EVERFOX ULTRA SERVICE

 Domain                       Practices

                              Security Ownership: Everfox has appointed one or more security officers responsible for coordinating and monitoring the security
                              rules and procedures
 Organisation of Information
 Security                    Security Roles and Responsibilities: Everfox personnel with access to Personal Data are subject to confidentiality obligations

                              Risk Management Program: Everfox performed a risk assessment before launching

                              Everfox ULTRA      Everfox retains its security documents pursuant to its retention

                              requirements after they are no longer in effect

                          Asset Inventory: Everfox maintains an inventory of all assets used to provide the Everfox ULTRA service including those which
 Asset Management
                          are used to hold or process Personal Data. The inventory includes details of ownership, business criticality, service-level
                          expectations, and version history
                          Security Training: Everfox informs its personnel about relevant security procedures. Everfox also informs its personnel of
 Human Resources Security
                          possible consequences of breaching the security rules and procedures

                              Physical Access to Facilities: Everfox limits access to facilities where information systems that process Personal Data or
 Physical and                 Professional Services Data are located to identified authorised individuals
 Environmental Security
                              Protection from Disruptions: Everfox uses a variety of industry standard systems to protect against loss of data due to power
                              supply failure or line interference

                              Component Disposal: Everfox uses industry standard processes to delete Personal Data when it is no longer needed

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                              Operational Policy: Everfox maintains security documents describing its security measures and the relevant procedures and
                              responsibilities of its personnel who have access to Personal Data

                              Data Recovery Procedures:

 Communications and           - Everfox takes backups of the Everfox ULTRA infrastructure daily
 Operations Management
                              - Everfox maintains documented procedures on how to restore data from backups

                              Malicious Software: Everfox has anti-malware controls to help avoid malicious software gaining unauthorised access to Personal
                              Data

                              Data Beyond Boundaries: Everfox encrypts Personal Data that is transmitted over public networks

                              Event Logging: Everfox logs access and use of information systems containing Personal Data

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                              Access Policy: Everfox restricts access to Personal Data to identified authorised personnel only

                              Access Authorisation:

                              - Everfox maintains and updates records of personnel authorised to access systems containing Personal Data

                              - Everfox deactivates authentication credentials that have not been used for a period of time not to exceed six months

                              - Everfox identifies those personnel who may grant, alter, or cancel authorised access to data and resources

                              - Everfox ensures that where more than one individual has access to systems containing Personal Data, the individuals have
                               separate identifiers/log-ins
 Access Control
                              Least Privilege: Everfox restricts access to Personal Data to only those individuals who require such access to perform their job
                              function

                              Authentication:

                              - Everfox uses industry standard practices to identify and authenticate users who attempt to access information systems

                              - Where authentication mechanisms are based on passwords, Everfox requires the password to be at least fourteen characters
                               long

                              - Everfox ensures that de-activated or expired identifiers are not granted to other individuals

                              - Everfox maintains industry standard procedures to deactivate passwords that have been corrupted or inadvertently disclosed

                              - Everfox uses industry standard password protection practices, including practices designed to maintain the confidentiality and
                               integrity of passwords when they are assigned and distributed, and during storage
                              Network Design: Everfox has controls to avoid individuals assuming access rights they have not been assigned to gain access
                              to Personal Data they are not authorised to access

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                              Incident Response Process:

                              - Everfox maintains records of security events and incidents with a description of the breach, the time period, the consequences
 Information Security
                               of the breach, the name of the reporter, and to whom the breach was reported
 Incident Management
                              - For each security incident that concerns Personal Data, Everfox will notify Data Controllers without undue delay

                              Service Monitoring: Security logs are retained and are reviewed quarterly
                              - Everfox maintains emergency and contingency plans for the facilities in which Everfox information systems that process
 Business                      Personal Data are located
 Continuity
 Management                   - Everfox’s redundant storage and its procedures for recovering data are designed to attempt to reconstruct Personal Data in its
                               original or last replicated state from before the time it was lost or destroyed

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