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Offer Disclosure
Cisco Duo
This Offer Disclosure provides detailed information about data handling practices, security controls, and AI features
specific to this Cisco Offer. It complements the General Disclosure which outline Cisco’s overarching approach to
handling Customer Systems Information and Customer Content, and the Cisco Online Privacy Statement, which
offers a more in-depth explanation of how Cisco manages personal data. Together, these documents provide
transparency by addressing data handling at both a high level and an Offer specific level, helping you understand
how Cisco protects and processes information across its Offers.
Capitalized words not otherwise defined in this Offer Disclosure have the meanings set forth in the
Cisco General Terms or General Disclosures. To the extent this document differs from the Cisco Online Privacy
Statement or General Disclosures, this document will take precedence regarding Offer specific information. If there
is a difference in the translated, non-English versions of this document, the US-English version will take
precedence.
Cisco will review and update this disclosure on an annual basis, or as needed, to reflect material changes in the
processing of Customer Systems Information or Customer Content. For updates, subscribe via the “subscribe” link
in the upper right corner of the Trust Portal.
1. Overview
Cisco Duo provides a SaaS-based solution for runtime identity and access management (IAM) controls, including
Directory (IdP), multi-factor authentication (MFA), single sign-on (SSO), adaptive access authentication, and device
trust & health checks. Its platform helps organizations verify user identities and device trust before granting access
to applications, supporting both cloud and on-premises environments. Recently, Duo has fortified its offering with
posture management ISPM and ITDR functionality, additional options for passwordless authentication/phishing-
resistant MFA, and identity verification workflows. Duo enables organizations to enhance security and meet
compliance requirements.
The following paragraphs describe Cisco’s processing of Customer Content and Customer Systems Information in
connection with the delivery of Duo, the location and transfers of that data, and how it is secured in accordance
©2025 Cisco and/or its affiliates. All rights reserved Version 1.0, September 2025. Cisco Public
with privacy principles, laws, and regulations. If you choose to use the Duo services, you will need to disclose
personal data to Cisco. Cisco will use your personal data consistently with this Offer Disclosure.
Your use of Duo may include the option to use Cisco Identity Intelligence (CII). CII is an API-driven, cloud-native,
and agentless platform that provides a unified view of all the identities within, and interacting with, an organization
and then helps remediate risks at scale. Please see the Addendum for information on this capability and how it
processes Customer Content and Customer Systems Information.
Additionally, Duo may integrate with third-party products, such as Persona to enable Duo Identity Verification.
Cisco is not responsible for customer data once it leaves Cisco’s control for a non-Cisco product. Protection of data
within the applicable third-party system is governed by the contract(s) and policies of the applicable third party.
You may access the Cisco AI Assistant through Duo. The Cisco AI Assistant may include capabilities to assist
customers in making informed decisions, augmenting tool capabilities, automating complex tasks, and searching
Cisco documentation. Data related to your interactions with the Cisco AI Assistant is processed in accordance with
the Cisco AI Assistant Offer Disclosure.
Cisco AI Assistant services through Duo may direct your query entered in the AI Assistant outside your primary
Duo deployment region for processing by the AI Assistant. Depending on your Duo deployment region, your AI
Assistant query data may be routed to multiple locations within the same region (but not necessarily the same
country) for processing and redundancy. Below are examples to illustrate how AI Assistant query data flows:
Primary Duo Deployment Region Additional Cross-Region Routing for AI Assistant
US United States
Canada United States
EU France, Ireland, Germany, Sweden
UK France, Ireland, Germany, Sweden
DACH France, Ireland, Germany, Sweden
Australia Japan, Korea, Singapore, Australia, India
ASEAN Japan, Korea, Singapore, Australia, India
Japan Japan, Korea, Singapore, Australia, India
Middle East Japan, Korea, Singapore, Australia, India
India Japan, Korea, Singapore, Australia, India
Many Cisco Offers either require that the Offer be accessed through Cisco Security Cloud Control or optionally
allow access to the Offer through Cisco Security Cloud Control. If you access this Cisco Offer through Cisco Security
Cloud Control, please see the Cisco Security Cloud Control Offer Disclosure for further details regarding data
handling and security controls.
For more information about Duo, visit https://duo.com/docs
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
2. Data Handling
2a. Collection, Purpose & Retention
Cisco believes in transparency when it comes to how Cisco handles Customer Content and Customer Systems
Information. This disclosure provides details about the types of data Cisco collects, specific data elements involved,
the purposes for which they are used, and how long Cisco retains them for this Cisco Offer.
Table 1: Customer Content
Data Category Data Elements (Examples) Purposes Retention Period
• Account creation and
End-User Registration and Personal Data: activation ▪ 1 year (unless deleted sooner by
Authentication Information • Service authentication and customer)3
• Username
• Name login
• Date of birth1 • Deliver, support (including
• Telephone number technical support), maintain,
• Email address improve security functionality,
upgrade and otherwise
• A user’s Active Directory
username & password for improve the services
those users authenticating via
Duo hosted SSO (password is
processed only long enough to
complete each authentication
and not retained after
authentication)
• A user’s password if created for
use with Duo Directory2
• Custom Attributes defined and
configured by Customer in Duo
Directory (e.g., an employee’s
role, nickname, username, or
office location)
Table 2: Customer Systems Information
Data Category Data Elements (Examples) Purposes Retention Period
• Account creation and activation
End-User Registration and Non-Personal Data 1 year (unless deleted sooner by
• Service authentication and
Authentication Information login customer)3
• Organization name
• Group membership • Deliver, support, improve
• User directory source(s) security functionality, upgrade
• User identifiers and improve the services
• Authentication configuration &
status information (like locked
out, bypass, e.g.)
1 Duo provides customer administrators with the option to add a user’s date of birth for the purposes of enabling Duo Identity Verification. Use of Duo Identity
Verification requires integration with Persona. Customers must subscribe with Persona directly. For more information on Duo Identity Verification visit here:
https://help.withpersona.com/articles/1DfUf0PhctXPDY8s1sbOaI/duo-verify-with-persona.
2 Duo adheres to industry best practices for password security by using strong hashing algorithms, high iteration counts, uniqu e random salts for each password
before hashing, and a secret per-customer pepper. Duo stores password hashes and salts in databases with strict access controls that are encrypted at rest.
3 Debug logs may reside in Duo’s systems for up to 90 days after their creation for customer support purposes, security review, and to monitor and alert on patterns
of system performance.
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
• Account creation and activation
Account Registration Information Personal Data of Administrator: • Service authentication and 1 year (unless deleted sooner by
login customer)
• Name
• Username • Sending communications to
• Telephone number you, including for marketing or
• Email address customer satisfaction purposes,
• One-way hashed either directly from Cisco or
representations of password(s) from our partners
for the Duo Administrator Panel • Deliver, support (including
• Job title technical support), maintain,
• Billing and delivery address (if improve security functionality,
home address) upgrade and otherwise
improve the services
• Account creation and activation
Account Registration Information Non-Personal Data: • Service authentication and 1 year (unless deleted sooner by
login customer)
• Billing and delivery address (if
corporate address) • Sending communications to
• Organization name you, including for marketing or
• Role(s) customer satisfaction purposes,
• Group membership either directly from Cisco or
• Administrator directory from our partners
source(s) • Deliver, support (including
• Administrator identifiers technical support), maintain,
• Authentication configuration & improve security functionality,
status information (like locked upgrade and otherwise
out, bypass, e.g improve the services
• Deliver, support (including
End-User Device Metadata4 Personal Data: technical support), maintain, 1 year (unless deleted sooner by
improve security functionality, customer)
• Type of device
• Device operating system, upgrade and otherwise
device version, and other improve the services Ensure
device characteristics (e.g., if a secure devices and/or
device is “jailbroken” or has a applications
screen lock in place) • Issue certificates verifying
• IP address device is secure
• Time zone • Authenticate device
• Time and date of • Conduct statistical analysis with
authentication pseudonymized and/or
• Geolocation data aggregate usage data to
• Broad geographic area (country improve the services
or city-level location) • Prevent, detect, respond and
protect against potential or
• Application that device is
attempting to access actual claims, liabilities,
prohibited behavior, security
• The device’s fully qualified
risks, and criminal activity
domain name associated with
the end-user
• Snapshot of device location
represented by hash value
derived from visible SSID at
time of capture
End-User Device Metadata4 Non-Personal Data included in End • Deliver, support (including 1 year (unless deleted sooner by
User Device Metadata, such as: technical support), maintain, customer)
improve security functionality,
• Connection information - such upgrade and otherwise
as encryption protocol(s) being improve the services Ensure
used to access the Duo service secure devices and/or
• Browser type applications
• Issue certificates verifying
device is secure
4 Duo Passwordless does not record or collect user biometric data in any way. Where available, it can request use of device bio metric capabilities in a way that does
not involve any biometric data leaving the device.
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
• Whether a Public Key • Authenticate device
Infrastructure Certificate is • Conduct statistical analysis with
installed pseudonymized and/or
• Whether device is utilizing aggregate usage data to
certain plugins improve the services
• Device identifiers (e.g., device • Prevent, detect, respond and
name, processor ID, serial protect against potential or
numbers, UDIDs, UUIDs, DNS actual claims, liabilities,
Hostname) prohibited behavior, security
risks, and criminal activity
• Deliver, support (including
Events Data5 Personal Data: technical support), maintain, 1 year (unless deleted sooner by
improve security functionality, customer)3
• Dates and times of access
• IP address for determining upgrade and otherwise
where the services are improve the services
accessed • Conduct statistical analysis with
• Any personal data that may be pseudonymized and/or
included in device events (e.g., aggregate usage data to
crashes, system activity, improve the services
hardware settings) • Prevent, detect, respond and
protect against potential or
actual claims, liabilities,
prohibited behavior, security
risks, and criminal activity
• Deliver, support (including
Events Data5 Non-Personal Data included in technical support), maintain, 1 year (unless deleted sooner by
Events Data, such as: improve security functionality, customer)
• How end-users access the upgrade and otherwise
services improve the services
• Any non-personal data that • Conduct statistical analysis with
may be included in device pseudonymized and/or
events (e.g., crashes, system aggregate usage data to
activity, hardware settings) improve the services
• Success or failure of events • Prevent, detect, respond and
• Transaction identifiers linking protect against potential or
multiple events actual claims, liabilities,
• Anonymous system identifiers prohibited behavior, security
of users and devices involved risks, and criminal activity
• Provide and maintain the
Authentication and Activity Logs Personal Data: services 1 year (or less, depending on
• Improve user experience customer’s log retention settings)
• Which end-users access the
services • Improve security functionality
• Time when the end-user • Improve quality of the services
accesses the service • Conduct statistical analysis with
• End-user IP address when pseudonymized and/or
accessing the services aggregate usage data to
improve the services
• Prevent, detect, respond and
protect against potential or
actual claims, liabilities,
prohibited behavior, security
risks, and criminal activity
• Deliver, support (including
Authentication and Activity Logs Non-Personal Data included in technical support), maintain, 1 year (or less, depending on
activity logs, such as: improve security functionality, customer’s log retention settings)
• Which devices access the upgrade and otherwise
services improve the services
• Time when the devices access • Conduct statistical analysis with
the service pseudonymized and/or
5 Events data refers to records or logs of specific occurrences, actions, or incidents that take place within a system, application, network, or environment. Events
typically represent significant or noteworthy activities, such as user interactions, system events, errors, warnings, transactions, changes in state, or other noteworthy
occurrences.
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
• Applications protected by the aggregate usage data to
services improve the services
• Qualitative assessments of risk • Prevent, detect, respond and
(detections) protect against potential or
• Success or failure of actions actual claims, liabilities,
taken prohibited behavior, security
• Transaction identifiers linking risks, and criminal activity
multiple logs
• Anonymous system identifiers
of users and devices involved
Configuration Data6 Personal Data: Configuration data is typically used to 1 year (unless deleted sooner by
tailor the functionality of a system to customer)
▪ Configuration data is typically non-
specific requirements or preferences
personal data but may include
settings such as user preferences.
Configuration Data6 Non-Personal Data: Configuration data is typically used to 1 year (unless deleted sooner by
tailor the functionality of a system to customer)
• Configuration data may include specific requirements or preferences
non-personal data such as
hardware settings, software
configurations, network
settings, and other
customizable options.
• Localization settings (language,
timezone)
• Account-wide security settings
(password requirements,
lockout settings, etc.)
• Custom branding (customer
logos, colors)
Personal Data: ▪ Internal business and product
Business Analytics Data analytics and reporting to inform Deleted upon request
▪ Admin first and last name data-driven business and product
▪ Job title decisions and product
▪ Admin Email address improvements
▪ Product and feature usage analytics,
sales support, renewal support,
product adoption and deployment
assistance
▪ Email for product improvements or
enhancements
Non-Personal Data such as:
Business Analytics Data See Purposes immediately above for Deleted upon request
• Company name Business Analytics Data
• Admin role
Regardless of the default retention referenced above, service backups are generated daily, encrypted, and moved
into cold storage as a means of providing data integrity and resiliency for the services. Service backups are retained
for an additional 3 years in such cold storage. This retention period was selected because it is sufficient to cover
most scenarios wherein customers may request access to their historical data to serve their own legal discovery
or forensics needs.
Pseudonymized Data: Duo additionally may retain copies of the data above, including the Personal Data Categories
listed in the Cisco AI Assistant Offer Disclosure (if you use the Assistant through Duo), for the purpose of supporting
6 Configuration data refers to the settings or parameters that determine the behavior or operation of a system, application, device, or service.
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
the security, quality, and improved functionality of the service. In these copies, all personal data listed above is
pseudonymized (except for IP addresses, which are needed in the original form for threat detection and related
security reasons). In addition to the prompt data referenced in the Cisco AI Assistant Offer Disclosure, Duo may
retain queries, responses, and associated metadata for the stated retention period. After the retention periods
above have expired (or 1 year from collection in the case of IP Addresses), there will be no remaining production
data or account information allowing for re-identification. To the extent any of the data above is also processed by
the Cisco AI Assistant; it is retained in accordance with the Cisco AI Assistant Offer Disclosure.
A user may request deletion of personal data at any time by contacting their Organization/Controller. Duo Account
Administrators can reference the following article to process individual deletion requests:
https://help.duo.com/s/article/2162?language=en_US.
Duo only keeps personal data for as long as it has an ongoing legitimate business need to do so. As such, we retain
personal data associated with your account for as long as you have an active account using our services. This is
necessary to provide core service functionality. Personal data will remain in the account until a validated account
owner chooses to delete the data or requests an account closure. However, customers do have the ability to delete
user/administrator registration information and logs, as set forth below (note that it may take up to 30 days for
certain manually deleted data to fully purge from Duo’s systems).
The Duo multi-tenant service is designed to provide strong guarantees around data integrity and availability of
customer data. A core component of this architecture requires a balance between the need to purge data
associated with previously deleted customers while ensuring that data associated with remaining active customers
is properly maintained and protected.
2b. Storage and Processing
The Duo service is headquartered in the United States and operates internationally. Duo uses Amazon Web
Services (AWS) data centers in the United States, Canada, Ireland, France, Germany, Switzerland, Australia, Japan,
Singapore, Indonesia, the United Kingdom, India, and the UAE.
The Hosting region is automatically selected based on the country of the phone number during sign-up (or based
on the country selected during certain methods of provisioning). The countries that are selected for each hosting
region are listed in the table below. Customers may also request that their production hosting be in any region
listed below. If you use the CII functionality of Duo, your personal data from this functionality will be hosted in
accordance with the CII Addendum attached.
Duo maintains data within the customer's designated Hosting Region, though there are specific operational
circumstances under which data may be processed or transmitted outside of that region. Support-related data
may be transferred outside the hosting region to facilitate necessary debugging and maintenance activities. When
a user accesses Duo while traveling outside their hosting region, their data is encrypted and routed through the
closest physical network endpoint to the hosting region, unless the customer has specifically configured Duo to
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
restrict access to within the hosting region. Additionally, for purposes of service continuity and resilience, data
may be transferred outside the hosting region as part of the Duo Business Continuity and Disaster Recovery Plan.
In addition, if a customer selects voice or text for multi-factor authentication (MFA), then the user’s phone number
may leave its hosting region and get transmitted to the US to Duo’s telephony provider. Some limited data may
also leave the hosting region when processed by Duo’s non-telephony service providers, which act as sub-
processors (see Table 4 below).
Table 3: Data Centers
Region Infrastructure Automatically selected during sign-up Data Center Locations
Provider for phone numbers from these
countries
United States AWS California Multiple regions and availability zones in the United
Oregon States.
Canada AWS Canada Multiple regions and availability zones in Canada.
EU AWS Belgium, Bulgaria, Croatia, Cyprus, Czech Single regions and multiple availability zones in France
Republic (Czechia), Estonia, France, and Ireland.
Greece, Hungary, Ireland, Italy, Latvia,
Lithuania, Luxembourg, Malta,
Netherlands, Poland, Portugal, Romania,
Slovakia, Slovenia, Spain
Additionally, any other country in the
world, not listed in this table, will default
to the EU data center.
DACH AWS Germany, Austria, Switzerland, Denmark, Single regions and multiple availability zones in
Finland, Iceland, Norway, and Sweden Germany and Switzerland.
ANZ AWS Australia, Cook Islands, Fiji, French Multiple regions and availability zones in Australia.
Polynesia, Kiribati, Marshall Islands,
Federated States of Micronesia, Nauru,
New Caledonia,
New Zealand, Niue, Pitcairn, Samoa,
Solomon Islands, Tokelau, Tonga, Tuvalu,
Vanuatu, Wallis and Futana
Japan AWS Japan Multiple regions and availability zones in Japan.
ASEAN AWS Brunei, Cambodia, Indonesia, Laos, Single regions and multiple availability zones in
Malaysia, Myanmar, Philippines, Singapore and Indonesia.
Singapore, Thailand, and Vietnam
United Kingdom AWS United Kingdom, British Overseas A single region and multiple availability zones in the
Territories United Kingdom.
India AWS India Multiple regions and availability zones in India.
UAE AWS Bahrain, Iraq, Jordan, Kuwait, Lebanon, A single region and multiple availability zones in the
Oman, Palestine, Qatar, Saudi Arabia, UAE UAE
Service Providers. Cisco may share Customer Systems Information and Customer Content with a trusted
ecosystem of suppliers. In each instance, each participant has agreed to confidentiality terms, compliance with
applicable law, and adherence to information security, privacy, and other data processing requirements with
Cisco that are consistent with Cisco’s commitments to you.
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
Subcontractors assist with broader data processing services, while subprocessors specifically process Personal Data
on Cisco’s behalf to support the functionality of the Cisco Offer. Both are listed below. For updates, subscribe via
the “subscribe” link in the upper right corner of the
Trust Portal.
Table 4: Subprocessors and Subcontractors
Name Personal Data Service Type Cisco Data Center Location
AWS End-User Registration/Authentication Cloud based infrastructure and US (California, Oregon), Canada,
Information, End-User Device hosting, analytics, data storage Ireland, Germany, Australia,
Metadata, Account Registration Japan, Singapore, the United
Information, Events Data, Kingdom, India, and the UAE
Authentication & Activity Logs
Twilio, Inc. End-User Registration/Authentication Telephone and SMS for US (Oregon, Virginia)
Information authentication
Nexmo Inc. End-User Registration/Authentication Telephone and SMS for US (California, Oregon, Virginia)
Information authentication
Clickatell, Inc. End-User Registration/Authentication Telephone and SMS for US (California, Oregon, Virginia)
Information authentication
Bandwidth Inc. End-User Registration/Authentication Telephone and SMS for US (California, Oregon, Virginia)
Information authentication
Google End-User Registration/Authentication Push notifications for authentication US (California, Nevada, Ohio,
Information Virignia), Ireland
Salesforce Account Registration Information Deliver, support, and improve the US (Arizona, Texas)
services
Mulesoft Account Registration Information Assist with Salesforce integration US (California, Oregon, Virginia)
Marketo Account Registration Information Automated account management US (California, Virginia)
Amplitude Events Data Analyze feature usage and product US (Virginia, Ohio, Oregon,
functionality California)
Sentry Events Data Error Reporting US (Iowa)
Snowflake End-User Registration/Authentication Analytics and data storage US (Virginia)
Information, End-User Device
Metadata, Account Registration
Information, Events Data,
Authentication & Activity Logs,
Business Analytics Data
2c. Access and Sharing
Customers and their authorized third parties may directly access Data by using standard APIs, to the extent those
are described in the API documentation found here.
Duo APIs may support both structured and unstructured data sets depending on the particular data set requested
from Duo. Depending on the standard implemented by the API, structured data sets may use JSON, XML, or other
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
standardized data formats; while unstructured data sets may be in the form of text, PDF or other unstructured
data file formats. For more details, please consult the API documentation referenced above.
Customers may send requests for expanded API or data interface capabilities through their usual Cisco support or
account management channels.
3. Security
3a. Access Control and Encryption
Cisco has implemented reasonable and appropriate technical and organizational measures designed to protect
data from accidental loss, unavailability, and unauthorized access, use, alteration, and disclosure.
Table 5: Access & Controls
Data Category Who Has Access Purpose of Access Security Controls
End-User Registration / Customer administrator Modify and control access to the Encryption in transit over Transport
Authentication Information services and other administrator Layer Security (TLS). Encryption at
information rest for all customer accounts.
Cisco Support the services in accordance
with its data access and security
controls process
Account Registration Information Customer administrator Modify and control access to the Encryption in transit over Transport
services and other administrator Layer Security (TLS). Encryption at
information rest for all customer accounts.
Cisco Deliver, support, upgrade and
improve the services
End-User Device Metadata Customer administrator Set policies for customer network, Encryption in transit over Transport
monitor customer network, and limit Layer Security (TLS). Encryption at
or approve access to users and rest for all customer accounts.
applications
Cisco Deliver, support, upgrade and
improve the services
Events Data Customer administrator Set policies for customer network, Encryption in transit over Transport
monitor customer network, and limit Layer Security (TLS). Encryption at
or approve access to users and rest for all customer accounts.
applications
Cisco Deliver, support, upgrade and
improve the services
Authentication and Activity Logs Customer administrator Set policies for customer network, Encryption in transit over Transport
monitor customer network, and limit Layer Security (TLS). Encryption at
or approve access to users and rest for all customer accounts.
applications
Cisco Deliver, support, upgrade and
improve the services
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
Configuration Data Customer administrator Set policies for customer network, Encryption in transit over Transport
monitor customer network, and limit Layer Security (TLS). Encryption at
or approve access to users and rest for all customer accounts.
applications
Cisco Deliver, support, upgrade and
improve the services
Business Analytics Data Cisco Organize, analyze, and report on Encryption in transit over Transport
business and product usage data; Layer Security (TLS). Encryption at
improve the service rest for all customer accounts.
3b. Reports & Resources
In addition to complying with internal standards, Cisco maintains third-party validations and certifications to
demonstrate its commitment to robust information security and privacy. The General Disclosures describe Cisco’s
enterprise-wide certifications. The following additional resources and certifications apply specifically to this Offer:
• Trust Package
• ISO Documents
• SOC Documents
• C5 Documents
• CAIQ
• ENS Certification
• HIPAA Assessment
• CSA STAR Certification
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
Cisco Identity Intelligence Addendum
This Offer Disclosure Addendum for Cisco Identity Intelligence (CII) outlines Cisco’s overarching approach to
handling Customer Systems Information and Customer Content, and the Cisco Online Privacy Statement, which
offers a more in-depth explanation of how Cisco manages personal data. Together, these documents provide
transparency by addressing data handling at both a high level and an Offer specific level, helping you understand
how Cisco protects and processes information across its Offers.
1. Overview of Cisco Identity Intelligence
Cisco Identity Intelligence (CII) is an API-driven, cloud-native, and agentless platform that provides a unified view
of all the identities within, and interacting with, an organization and then helps remediate risks at scale.
This Addendum only addresses the CII feature. For information regarding the processing of personal data by Duo,
please see the Duo Offer Disclosure to which Addendum 1 is attached. CII is inclusive of data categories as
displayed in Table 1 and 2 above in the Duo Offer Disclosure. In addition to CII’s integrations with other
documented Cisco Offers, this Cisco Offer can integrate with Cisco Cloud Control and Cisco AI Canvas, part of Cisco’s
AI-native unified management experience. As part of this integration, the data from this Cisco Offer is transferred
and processed as outlined in the Cisco Cloud Control Offer Disclosure and the Cisco AI Canvas Offer Disclosure.
If You elect to use the OpenAI integration with Your CII license, the data attributes from that service will be sent to
CII. The data attributes may be found here: https://help.openai.com/en/articles/9261474-openai-compliance-
platform-for-enterprise-customers.
2. Data Handling
2a. Collection, Purpose & Retention
Cisco believes in transparency when it comes to how Cisco handles Customer Content and Customer Systems
Information. This disclosure provides details about the types of data Cisco collects, specific data elements involved,
the purposes for which they are used, and how long Cisco retains them for this Cisco Offer.
Table 1: Customer Content
Data Category Data Elements (Examples) Purposes Retention Period
• Account creation and activation
Admin Personal Data Personal Data: • Service authentication and Deleted upon customer request
• Username login
• Name • Sending communications to
• City you, including for marketing or
• Country customer satisfaction purposes,
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
either directly from Cisco or
from our partners
• Deliver, support, improve
security functionality, upgrade
and improve the service
• Account creation and activation
Subject Data Personal Data: • Service authentication and Deleted upon customer request
• Name login
• Username • Deliver, support, improve
• Telephone number security functionality, upgrade
• Email address and improve the services
• Login History (including city and
county)
Employment information (including
directory role, directory organization,
directory reporting structure,
directory title, directory department,
directory location)
Table 2: Customer Systems Information
Data Category Data Elements (Examples) Purposes Retention Period
Personal Data: • Service availability and support
Admin Audit Log • Name 1 year (unless deleted sooner by
• User Email customer)
• Login History
• Service availability and support
Admin Audit Log Non-Personal Data: 1 year (unless deleted sooner by
customer)
• Action History
2b. Storage and Processing
CII uses Amazon Web Services (AWS) data centers in the United States, Canada, UK, Germany, Australia, Singapore,
India, and Japan.
Hosting region is selected based on the country of the customer’s Duo deployment is located or where parties
mutually agree, except where customer is using CII through their XDR or Secure Access entitlements. In those
cases, the CII hosting region will default to the regions customer selected for XDR and Secure Access. The countries
that are selected for each hosting region are listed in the table below.
Table 3: Data Centers
Region Infrastructure Countries Supported Data Center Locations
Provider
United States AWS United States and all other countries not US (Ohio)
listed below
Canada AWS Canada CA (Montreal)
Europe AWS European Economic Area (EEA) EU (Frankfurt)
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
UK AWS UK EU (London)
ANZ AWS Australia AP (Sydney)
Japan AWS Japan AP (Tokyo)
India AWS India
AP (Mumbai)
Singapore AWS Singapore AP (Singapore)
Service Providers. Cisco may share Customer Systems Information and Customer Content with a trusted
ecosystem of suppliers. In each instance, each participant has agreed to confidentiality terms, compliance with
applicable law, and adherence to information security, privacy, and other data processing requirements with
Cisco that are consistent with Cisco’s commitments to you.
Subcontractors assist with broader data processing services, while subprocessors specifically process Personal Data
on Cisco’s behalf to support the functionality of the Cisco Offer. Both are listed below. For updates, subscribe via
the “subscribe” link in the upper right corner of the
Trust Portal.
Table 4: Subprocessors and Subcontractors
Sub-processor Data Processed Service Type Location of Data Center
AWS Subject Data and Admin Cloud based infrastructure and hosting, US (Ohio), Germany, UK,
Personal Data analytics, data storage Australia, and Japan
Snowflake Subject Data and Admin Data Storage and analytics Co-located with AWS account US
Personal Data (Virginia)
Datadog Subject Data and Admin Data Storage and analytics US (Virginia)
Personal Data
2c. Access and Sharing
Customers and their authorized third parties may directly access Data by using standard APIs, to the extent those
API’s are described in the API documentation found here.
APIs may support both structured and unstructured data sets depending on the particular data set requested.
Depending on the standard implemented by the API, structured data sets may use JSON, XML, or other
standardized data formats; while unstructured data sets may be in the form of text, PDF or other unstructured
data file formats. For more details, please consult the API documentation referenced above.
Customers may send requests for expanded API or data interface capabilities through their usual Cisco support or
account management channels.
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public
3. Security
3a. Access Control and Encryption
Cisco has implemented reasonable and appropriate technical and organizational measures designed to protect
data from accidental loss, unavailability, and unauthorized access, use, alteration, and disclosure.
Table 5: Access & Controls
The table below lists the personal data used by Cisco to carry out the service, who can access that data, and why.
Data Category Who Has Access Purpose of Access Security Controls
Admin Personal Data Customer administrator, Customer Deliver, support, upgrade and Encryption in transit over Transport
Support improve the services Layer Security (TLS). Encryption at
rest for all customer accounts (AES-
256)
Support the services in accordance
Cisco
with its data access and security
controls process
Deliver, support, upgrade and Encryption in transit over Transport
Admin Audit Log Customer administrator, Customer
improve the services Layer Security (TLS). Encryption at
Support
rest for all customer accounts (AES-
Support the services in accordance 256)
Cisco
with its data access and security
controls process
Deliver, support, upgrade and Encryption in transit over Transport
Subject Data Customer administrator, Customer
improve the services Layer Security (TLS). Encryption at
Support
rest for all customer accounts (AES-
Support the services in accordance 256)
Cisco
with its data access and security
controls process
3b. Reports & Resources
• Refer to 3b above in the Duo Offer Disclosure
©2025 Cisco and/or its affiliates. All rights reserved Version 1.3, June 2026. Cisco Public