Data Protection Policy
1. Data protection principles
AppHub is committed to processing data in accordance with the below responsibilities.
Personal Data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes subject to implementation of the appropriate technical and organisational measures in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2. General provisions
- This policy applies to all personal data processed by AppHub.
- The Responsible Person shall take responsibility for AppHub’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, AppHub shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal data and any such requests made to AppHub shall be dealt with in a timely manner.
4. Data storage
- AppHub shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- All data shall be encrypted using industry-accepted encryption methods and products to protect personal data and communications during transmissions between a customer’s network and the Service including encryption for data in transit over public networks and encryption for data at rest.
- Encryption in Transit
All data transferred over public networks is encrypted via Secure Sockets Layer (SSL) and HTTPS/Transport Layer Security (TLS).
- Encryption at Rest
Data at rest is encrypted using at least AES-256 or higher levels of encryption. AppHub shall not make copies of personal data save as reasonably necessary to provide the Service and for backup purposes.
- AppHub shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
6. Archiving / removal / deletion
- To ensure that personal data is kept for no longer than necessary, AppHub shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- Upon termination of the Service for which AppHub is processing personal data, AppHub shall, upon Client’s request and subject to the limitations described in the DPA or other governing Agreement, delete personal data in accordance with the procedures and timeframes specified in therein.
- AppHub shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorized sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
- AppHub requires industry best practices around password requirements and storage.
- We require Single Sign On (“SSO”) with multi-factor authentication requirements internally, as well as an option to our customers who wish to use SSO.
9. Business Continuity and Disaster Recovery
AppHub will ensure that the systems where personal data is stored have a disaster recovery plan that addresses geographic availability, multiple site availability, and replication of critical systems and data. AppHub will ensure that its third-party data center has adequate Disaster Recovery plans in place and that they are tested annually. All networking components, load balancers, web servers and application servers that are part of the AppHub platform are configured in a redundant configuration. All personal data is stored on a primary database server that is clustered with a backup database server for redundancy. All personal data is automatically backed up every six hours. AppHub performs regular recovery testing.
10. Incident Management and Breach Notification
AppHub will promptly notify Client in the event AppHub becomes aware of an actual or reasonably suspected unauthorized disclosure of personal data. In addition, in the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, AppHub shall promptly assess the risk of its Customer’s rights and freedoms and if appropriate report such breach to the proper authorities.
11. Risk Management
Our approach to enterprise risk management at AppHub has multiple layers, designed to focus on how we address risk as part of ongoing business operations throughout the year, not just as a point-in-time exercise on an annual basis. AppHub maintains enterprise and cybersecurity risk assessment procedures, including annual risk assessments.
12. Security Training
All new AppHub employees and contractors attend security training during the on-boarding process. Additionally, all employees and contractors are required to take annual information security awareness training. Training is tracked and monitored for compliance.
Employees shall also review and agree to company policies that include data security through an employee manual/handbook, Acceptable Use Policy and Non-Disclosure Agreement.
13. Third-Party Audit and Compliance
AppHub undergoes annual SOC 2 Type 2 audits, performed by an external third-party. A copy of the report is available under NDA (defined below) upon Customer request.
14. Threat and Vulnerability Management
AppHub uses several sources and tools for identifying, tracking, responding to, and remediating vulnerabilities. We subscribe to all relevant security mailing lists for our operating systems, datastores, load balancer, web frameworks, languages, as well as to industry and government mailing lists.
15. Vulnerability Management and Penetration Testing
We perform regular and continuous scans of our systems to identify vulnerabilities. AppHub performs annual penetration tests performed by a third-party. Reports are available under NDA upon Client request.
16. Patch Management
Patches and upgrades are automatically applied when a system is rebooted, or deployed fleet wide via our configuration management software. Patches are applied based on the severity level of the vulnerability according to our patch management guidelines.
17. General Controls
AppHub will implement, or be responsible for its Sub-Processors’ implementation of, measures designed to:
- deny unauthorized person’s access to data-processing equipment used for processing personal data (equipment access control);
- prevent the unauthorized reading, copying, modification or removal of data media containing personal data);
- prevent unauthorized inspection, modification or deletion of stored personal data;
- prevent the use of automated data-processing systems by unauthorized persons using data communication equipment used to process personal data (user control);
- limit access to personal data by persons authorized to use an automated data-processing system to the scope and duration of their access authorization;
- enable verification of the individuals to whom personal data has been transmitted or made available using data communication equipment;
- enable verification of which individuals input personal data into automated data-processing systems and when;
- prevent the unauthorized reading, copying, modification or deletion of personal data during transfers of that data or during transportation of data media;
- enable restoration of installed systems used to process personal data in case of interruption;
- ensure that the functions of the system used to process personal data perform, that the appearance of faults in the functions is reported and prevent stored personal data from corruption by means of a malfunctioning of the system.
18. Logging and Monitoring
AppHub shall ensure that all AppHub systems used to store personal data, including firewalls, routers, network switches and operating systems, log information to their respective system log facility or a centralized syslog server (for network systems).
19. Intrusion Detection
AppHub, or an authorized third party, will monitor the Service for unauthorized intrusions using network-based and log-based intrusion detection mechanisms.
20. Physical Security
AppHub’s third-party data centers have an access system that controls access to the data center. This system permits only authorized personnel to have access to secure areas. The facility is designed to withstand adverse weather and other reasonably predictable natural conditions, is secured by around-the-clock guards, biometric access screening and escort-controlled access, and is also supported by on-site back-up generators in the event of a power failure.