Data Processing Addendum

This Data Processing Addendum (“DPA”) shall be incorporated into iPaaS.com’ License Agreement (“Agreement”) entered into by and between iPaaS.com, Inc. (“iPaaS.com”) and the Licensee thereunder.  Any terms not defined in this DPA shall have the meaning set forth in the Agreement.  In the event of a conflict between the terms and conditions of this DPA and the Agreement, the terms and conditions of this DPA shall take precedence with regard to the subject matter of this DPA. 

1. Definitions 

“Anonymous Data” means Personal Data that has been processed in such a manner that it can no longer be attributed to an identified or identifiable Data Subject, including as applicable any “deidentified” Personal Data as defined under applicable Data Protection Law. 

(a) “Authorized Individual” means an employee of iPaaS.com who has a need to know or otherwise access Personal Data to enable iPaaS.com to perform its obligations under this DPA or the Agreement or an Authorized Sub-Processor. 

(b) Authorized Sub-Processor” means a Sub-Processor engaged by iPaaS.com who is either (1) listed as a Sub-Processor on iPaaS.com’ List (as defined in Section 4(b) [Authorized Sub-Processors] below) and/or (2) authorized by Licensee to do so under Section 4 (Authorized Sub-Processors) of this DPA. 

(c) “Controller” means the entity which determines the purposes and means of the Processing of Personal Data, including as applicable “business” as defined under the CCPA or “organizations” under the PDPA. 

(d) “Data Protection Laws” means (i) the California Consumer Privacy Act ("CCPA”) and the California Privacy Rights Act of 2020 ("CPRA”); (ii) the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and related data protection and privacy laws of the member states of the European Economic Area; (iii) the Data Protection Act 2018 of the United Kingdom (“UK GDPR”); and (iv) the Swiss Federal Act on Data Protection (1992) or the Swiss Federal Data Protection Act of 25 September 2020 when in full force and effect, as applicable, and its corresponding ordinances ("Swiss DPA”); and (v) the Singapore Personal Data Protection (Amendment) Act 2020 ("PDPA”); each as applicable and as amended, repealed, consolidated, implemented or replaced from time to time. 

(e) “Data Subject” means any identified or identifiable person to whom Personal Data relates, or as otherwise defined by Data Protection Laws. 

(f) “Instruct” or “Instruction” means a direction, either in writing, in textual form (e.g., by e-mail) or by using a software or online tool, issued by Licensee to iPaaS.com and which explicitly directs iPaaS.com to Process Personal Data. 

(g) “Personal Data” means any information relating to Data Subjects Processed through the Services by iPaaS.com on behalf of Licensee, as further defined as “personal data” or “personal information” under applicable Data Protection Laws. Personal Data does not include Anonymous Data. 

(h) “Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored, or otherwise Processed. 

(i) “Process” or “Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure, or destruction. 

(j) “Processor” means a natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller, including as applicable “service provider” as defined under the CCPA or “data intermediary” under the PDPA. 

(k) “Services” means the services provided by iPaaS.com pursuant to or in connection with the Agreement. 

(l) “Standard Contractual Clauses” means (i) where the GDPR or Swiss DPA applies, the standard contractual clauses for the transfer of Personal Data to third countries approved by the European Commission’s decision 2021/914/EC of June 4, 2021, as currently set out at https://eur- lex.europa.eu/eli/dec_impl/2021/914/oj (the “EU SCCs”); (ii) where the UK GDPR applies, the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses issued by the UK Information Commissioner, Version B1.0, as currently set out at https://ico.org.uk/media/for- organisations/documents/4019539/international-data-transfer-addendum.pdf, and as revised under Section 18 of the International Data Transfer Addendum (the “UK Addendum”). 

(m) “Sub-Processor” means another Processor who processes Personal Data on behalf of the Processor. 

(n) “Supervisory Authority” means an independent public authority which is established under applicable Data Protection Laws. 

2. Relationship of the Parties; Processing of Data 

(a) Licensee acknowledges and agrees that with respect to the Processing of Personal Data, Licensee may act either as a Controller or Processor and iPaaS.com acts as a Processor.  iPaaS.com has the right to Process Personal Data relating to or obtained in connection with the operation, support, or use of the Services for its legitimate internal business purposes, including, but not limited to: (i) billing, tax, and audit support, (ii) to provide, optimize, maintain, develop and improve the Services, (iii) to investigate fraud, wrongful or unlawful use of the Services, and (iv) as required by applicable law or regulation.  In such instances, this DPA shall not apply.  iPaaS.com will Process such Personal Data in compliance with applicable Data Protection Laws and Section 6(a)(i) as Controller. 

(b) The rights and obligations of the Licensee with respect to the Processing of Personal Data are described herein.  Licensee shall, in its use of the Services, always Process Personal Data, and provide Instructions for the Processing of Personal Data, in compliance with the Data Protection Laws.  Licensee shall ensure that its Instructions comply with all laws, rules, and regulations applicable in relation to Personal Data, and that the Processing of Personal Data in accordance with Licensee’s Instructions will not cause iPaaS.com to be in breach of the Data Protection Laws.  Licensee is solely responsible for the accuracy, quality, and legality of (i) Personal Data provided to iPaaS.com by or on behalf of Licensee, (ii) the means by which Licensee acquired any such Personal Data, and (iii) the Instructions it provides to iPaaS.com regarding the Processing of such Personal Data. Licensee shall not provide or make available to iPaaS.com any Personal Data in violation of the Agreement or otherwise inappropriate for the nature of the Services and shall indemnify iPaaS.com from all claims and losses in connection therewith. 

(c) iPaaS.com shall Process Personal Data only (i) for the purposes set forth in the Agreement and this DPA, including Schedule 1 (ii) in accordance with the terms and conditions set forth in this DPA and any other documented Instructions provided by Licensee, and (iii) in compliance with the Data Protection Laws. Licensee hereby Instructs iPaaS.com to Process Personal Data in accordance with the foregoing and as part of any Processing initiated by Licensee in its use of the Services.  If iPaaS.com is unable to Process Personal Data pursuant to the Instructions due to legal requirements under applicable laws, iPaaS.com shall inform the Licensee of that legal requirement before Processing, unless that law prohibits such information on important grounds of public interest.  iPaaS.com shall also promptly inform the Licensee if, in its opinion, an Instruction infringes the applicable laws, including the Data Protection Laws.  In such case, iPaaS.com will cease all Processing of the affected Personal Data (other than merely storing and maintaining the security of the affected Personal Data) until such time as the Licensee issues new Instructions with which iPaaS.com is able to comply.  If this provision is invoked, iPaaS.com will not be liable to Licensee under the Agreement for failure to perform the Services until such time as Licensee issues new Instructions. 

(d) The subject matter, nature, purpose, and duration of this Processing, as well as the types of Personal Data Processed and categories of Data Subjects, are described in Schedule 1 to this DPA. 

(e) Following completion of the Services, iPaaS.com shall delete Personal Data in accordance with the Agreement, except as required to be retained by the Data Protection Laws or other applicable laws, or for the limited scope and purposes specified in the Agreement.  If Licensee and iPaaS.com have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data), the parties agree that the certification of deletion of Personal Data that is described in Clause 8.5 and 16 of the EU SCCs shall be provided by iPaaS.com to Licensee only upon Licensee’s request. 

(f) iPaaS.com shall maintain and use Anonymous Data in a deidentified form and to not attempt to re-identify the Anonymous Data, except solely for the purpose of determining whether its de-identification processes satisfy the requirements of applicable law. 

3. Authorized Individuals 

(a) iPaaS.com shall take commercially reasonable steps to limit access to Personal Data to only Authorized Individuals. 

(b) iPaaS.com shall ensure that all Authorized Individuals are made aware of the confidential nature of Personal Data and have executed confidentiality agreements. 

4. Authorized Sub-Processors 

(a) Licensee acknowledges and agrees that iPaaS.com may (i) engage its Affiliates and other Authorized Sub-Processors to access and Process Personal Data in connection with the Services and (ii) from time to time engage additional third parties for the purpose of providing the Services, including without limitation the Processing of Personal Data. 

(b) iPaaS.com’ current Authorized Sub-Processors include the third-party Sub-Processors and the iPaaS.com Affiliates listed at www.iPaaS.com.com/sub-processors (such URL may be updated by iPaaS.com from time to time, the “List”), as updated from time to time.  At least thirty (30) days before enabling any third-party Sub-Processors other than Authorized Sub-Processors to access or participate in the Processing of Personal Data, iPaaS.com will add such third-party Sub-Processors and Affiliates to the List and notify Licensee of such updates via email. Licensee may object to such an engagement in writing within ten (10) days of receipt of such notice by Licensee. 

(i) If Licensee reasonably objects to an engagement in accordance with this Section 4(b), iPaaS.com may provide Licensee with a written description of commercially reasonable alternative(s), if any, to such engagement, including without limitation modification to the Services.  If iPaaS.com, in its sole discretion, does not provide any such alternative(s), or if Licensee does not agree to any such alternative(s) if provided, either party may terminate this DPA and the Agreement upon written notice.  Termination shall not relieve Licensee of any fees owed to iPaaS.com under the Agreement. 

(ii) If Licensee does not object to the engagement of a third-party Sub-Processor in accordance with this Section 4(b) within ten (10) days of notice by iPaaS.com, that third-party Sub-Processor will be deemed an Authorized Sub-Processor for the purposes of this DPA. 

(c) iPaaS.com shall, by way of contract or other legal act under Data Protection Laws (including Standard Contractual Clauses), ensure that every Authorized Sub-Processor is subject to obligations regarding the Processing of Personal Data that are no less protective than those to which iPaaS.com is subject under this DPA. 

(d) iPaaS.com shall be liable to Licensee for the acts and omissions of Authorized Sub-Processors to the same extent that iPaaS.com would itself be liable under this DPA had it conducted such acts or omissions.  If Licensee and iPaaS.com have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data), (i) the above authorizations in Section 4(b) (Authorized Sub-Processors) will constitute Licensee’s prior written consent to the subcontracting by iPaaS.com of the Processing of Personal Data if such consent is required under the Standard Contractual Clauses; and (ii) the parties agree that the copies of the agreements with Authorized Sub-Processors that must be provided by iPaaS.com to Licensee pursuant to Clause 9(c) of the EU SCCs may have commercial information, or information unrelated to the Standard Contractual Clauses or their equivalent, removed by the iPaaS.com beforehand, and that such copies will be provided by iPaaS.com only upon request by Licensee. 

5. Security and Confidentiality of Personal Data 

Considering the state of the art, the costs of implementation and the nature, scope, context, and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, iPaaS.com shall maintain appropriate technical and organizational measures to ensure a level of security appropriate to the risk of Processing Personal Data.  iPaaS.com shall, considering the nature of the Processing and the information available to iPaaS.com, provide Licensee with reasonable cooperation and assistance where necessary for Licensee to comply with Licensee’s obligations pursuant to Article 32 GDPR or equivalent provision of the Data Protection Laws.  More specific security and privacy measures implemented by iPaaS.com include, but are not limited to, those set forth in Schedule 2. 

6. Transfers of Personal Data 

(a) GDPR. Any transfer of Personal Data made from member states of the European Union, Iceland, Liechtenstein, or Norway to any countries which do not ensure an adequate level of data protection within the meaning of the laws and regulations of these countries shall, to the extent such transfer is subject to such laws and regulations, be undertaken by iPaaS.com through the EU SCCs, which are automatically incorporated by reference and form an integral part of the DPA, as follows: 

(i) iPaaS.com as Controller. The EU SCCs shall apply as follows: 

(1) Module One (Controller to Controller) will apply; 

(2) Clause 7, the optional docking clause will not apply; 

(3) Clause 11, the optional language will not apply; 

(4) Clause 13, the supervisory authority with responsibility for ensuring compliance by the Data Exporter with Regulation (EU) 2016/679 as regards the data transfers shall be the Data Protection Commission of Ireland; 

(5) Clause 17, Option 1 will apply, and the EU SCCs will be governed by Irish law; 

(6) Clause 18(b), disputes shall be resolved before the courts of Ireland; 

(7) Annex I of the EU SCCs shall be deemed completed with the information set out in Schedule 1 to this DPA; and 

(8) Annex II of the EU SCCs shall be deemed completed with the information set out in Schedule 2 to this DPA. 

(ii) iPaaS.com as Processor or Sub-Processor. The EU SCCs shall apply as follows: 

(1) where Licensee is a Controller and iPaaS.com is a Processor under the Agreement, Module Two (Controller to Processor) will apply; or where Licensee is a Processor and iPaaS.com is a sub-Processor under the Agreement, Module Three (Processor to Processor) will apply; 

(2) Clause 7, the optional docking clause will not apply; 

(3) Clause 9, Option 2 will apply, and the time period for prior notice is thirty (30) days; 

(4) Clause 11, the optional language will not apply; 

(5) Clause 13, the supervisory authority with responsibility for ensuring compliance by the Data Exporter with Regulation (EU) 2016/679 as regards the data transfers shall be the supervisory authority of Ireland; 

(6) Clause 17, Option 1 will apply, and the EU SCCs will be governed by Irish law; 

(7) Clause 18(b), disputes shall be resolved before the courts of Ireland; 

(8) Annex I of the EU SCCs shall be deemed completed with the information set out in Schedule 1 to this DPA; and 

(9) Annex II of the EU SCCs shall be deemed completed with the information set out in Schedule 2 to this DPA. 

(b) UK GDPR. With respect to transfer to which the UK GDPR applies, the parties agree to Process such Personal Data in compliance with the UK Amendment, which is automatically incorporated by reference and form an integral part of the DPA, as follows: 

(i) the EU SCCs as implemented under Sections 6(a)(i) (iPaaS.com as Controller) and 6(a)(ii) (iPaaS.com as Processor or Sub-Processor) of this DPA shall be deemed amended as specified by Part 2 of the UK Amendment; 

(ii) Tables 1 to 3 in Part 1 of the UK Addendum shall be deemed completed respectively with the information set out in Schedules 1 and 2 of this DPA (as applicable); and 

(ii) Table 4 in Part 1 of the UK Addendum shall be deemed completed by selecting “Importer” and “Exporter.” 

(c) Swiss DPA. With respect to transfer to which the Swiss DPA applies, the parties agree to Process such Personal Data in compliance with the EU SCCs as implemented under Sections 6(a)(i) (iPaaS.com as Controller) and 6(a)(ii) (iPaaS.com as Processor or Sub-Processor) of this DPA with the following modifications: 

(i) references to "Regulation (EU) 2016/679" shall be interpreted as reference to the Swiss DPA; 

(ii) references to "Regulation (EU) 2016/679" shall be replaced with the equivalent article or section of the Swiss DPA; 

(iii) references to the "competent supervisory authority" and "competent courts" shall be replaced with references to the "Swiss Federal Data Protection and Information Commissioner" and "applicable courts of Switzerland" for transfers from Switzerland; 

(iv) Clause 17, the EU SCCs shall be governed by the laws of Switzerland; and 

(v) Clause 18(b), disputes shall be resolved before the applicable courts of Switzerland. 

(d) CCPA and CPRA. To the extent the Processing of Personal Data is subject to CCPA or CPRA: 

(i) Licensee is a “business” and iPaaS.com is a “service provider”, each as defined under the CCPA and CPRA; 

(ii) iPaaS.com shall not (A) retain, use, disclose or otherwise Processing Personal Data other than as provided for in the Agreement or as needed to perform the Services, including to build or improve the quality of the Services, to detect security incidents, to protect against fraudulent or illegal activity, to retain Sub-Processors in compliance with the DPA, or as otherwise required or permitted by applicable law; (B) “sell” or “share” Personal Data, as defined under the CCPA and CPRA; and (C) Process Personal Data in any manner outside of the direct business relationship between Licensee and iPaaS.com. 

(iii) Licensee shall only disclose Personal Data in connection with the Agreement only for the limited and specified purposes of receiving the Services; and 

(iv) each party certifies that it understands the requirements under the CCPA and CPRA. 

7. Rights of Data Subjects 

(a) iPaaS.com shall, to the extent permitted by law, promptly notify Licensee upon receipt of a request by a Data Subject to exercise the Data Subject’s right of access, rectification, restriction of Processing, erasure, data portability, restriction of or objection to Processing, withdrawal of consent to Processing, and/or objection to being subject to Processing that involves automated decision-making (such requests individually and collectively “Data Subject Request(s)”).  If iPaaS.com receives a Data Subject Request in relation to Personal Data, iPaaS.com will advise the Data Subject to submit their request to Licensee and Licensee will be responsible for responding to such request, including, where necessary, by using the functionality of the Services. 

(b) iPaaS.com shall, at the request of the Licensee, and taking into account the nature of the Processing applicable to any Data Subject Request, apply appropriate technical and organizational measures to assist Licensee in complying with Licensee’s obligation to respond to such Data Subject Request, where possible, provided that (i) Licensee is itself unable to respond without iPaaS.com’ assistance and (ii) iPaaS.com is able to do so in accordance with all applicable laws, rules, and regulations. 

8. Actions and Access Requests 

iPaaS.com shall, taking into account the nature of the Processing and the information available to iPaaS.com, provide Licensee with reasonable cooperation and assistance (a) where necessary for Licensee to comply with obligations applicable to it under the Data Protection Laws to conduct a data protection impact assessment, provided that Licensee does not otherwise have access to the relevant information; and (b) with respect to Licensee’s cooperation and/or prior consultation with any Supervisory Authority, where necessary and/or where required by the Data Protection Laws. 

9. Audit Rights 

(a) Licensee may audit iPaaS.com’ compliance with the terms of this DPA (no more often than once a year). If a third-party is to conduct the audit, the third-party must be mutually agreed to by Licensee and iPaaS.com and such third-party must execute a confidentiality agreement with iPaaS.com before the audit is conducted. 

(b) To request an audit, Licensee must submit a detailed proposed audit plan to iPaaS.com at least thirty (30) days in advance of the proposed audit date. The proposed audit plan must describe the proposed scope, duration, and start date of the audit. iPaaS.com will review the proposed audit plan and communicate any concerns or questions to Licensee. iPaaS.com will cooperate with Licensee to agree on a final audit plan. 

(c) The audit must be conducted during iPaaS.com’ regular business hours and subject to applicable iPaaS.com policies.  The audit may not unreasonably interfere with iPaaS.com’ business operations.  If the information required for such an audit is not contained in iPaaS.com’ SOC 2 Type 2 audit or similar report, iPaaS.com will make reasonable efforts to provide the requested information to the auditor. 

(d) Licensee will provide iPaaS.com any audit reports generated in connection with any audit under this section, unless prohibited by law.  Licensee may use the audit reports only for the purposes of meeting its regulatory requirements and/or confirming compliance with the requirements of the Agreement and this DPA.  The audit report(s) and any information obtained by Licensee under this section are iPaaS.com’ Confidential Information under the terms of the Agreement.  If the parties have entered into Standard Contractual Clauses as described in Section 6 (Transfers of Personal Data), the parties agree that the audits described in Clause 8.9 of the EU SCCs shall be conducted in accordance with this section. 

(e) Any audits conducted shall be at Licensee’s expense.  Any request for iPaaS.com to assist with an audit is considered a separate service if such audit assistance requires the use of additional or different resources than those iPaaS.com would typically utilize when providing such audit assistance.  iPaaS.com will seek Licensee’s prior written approval and agreement to pay any related fees before performing such audit assistance. 

10. Incident Management and Breach Notification 

(a) iPaaS.com shall, within 72 hours after becoming aware of a confirmed Personal Data Breach, inform Licensee of Personal Data Breach and take such steps as iPaaS.com in its sole discretion deems necessary and reasonable to remediate such violation (to the extent that remediation is within iPaaS.com’ reasonable control). 

(b) In the event of a confirmed Personal Data Breach, iPaaS.com shall, considering the nature of the Processing and the information available to iPaaS.com, provide Licensee with reasonable cooperation and assistance necessary for Licensee to comply with its obligations under the applicable Data Protection Laws with respect to notifying (i) the relevant Supervisory Authority and (ii) Data Subjects affected by such Personal Data Breach without undue delay. 

(c) As information regarding the Personal Data Breach is collected or otherwise reasonably becomes available to iPaaS.com, iPaaS.com will also provide Licensee with (i) a description of the nature and reasonably anticipated consequences of the Personal Data Breach; (ii) the measures taken to mitigate any possible adverse effects and prevent a recurrence; and (iii) where possible, information about the types of Personal Data that were the subject of the Personal Data Breach.  Licensee agrees to coordinate with iPaaS.com on the content of Licensee’s intended public statements or required notices for the affected Data Subjects and/or notices to the relevant Supervisory Authority regarding the Personal Data Breach.  Further, Licensee understands and agrees that it shall bear sole responsibility for communicating any updates related to a confirmed Personal Data Breach to its impacted Controllers (where Licensee acts as the Processor pursuant to the Agreement, if applicable) and/or Data Subjects. 

(d) The obligations described in Sections 10(a) and 10(b) (Incident Management and Breach Notification) above shall not apply if a Personal Data Breach results from the actions or omissions of Licensee.  Notification of a Personal Data Breach does not constitute any acceptance of liability by iPaaS.com. 

11. Limitation of Liability; Expenses 

(a) The total liability of each of Licensee and iPaaS.com (and their respective employees, directors, officers, Affiliates, successors, and assigns), arising out of or related to this DPA, whether in contract, tort, or other theory of liability, shall not, when taken together in the aggregate, exceed the limitation of liability set forth in the Agreement. 

(b) iPaaS.com will be entitled to be reimbursed by Licensee, to the extent legally permitted, for reasonable costs and expenses arising from any assistance by iPaaS.com in Sections 7 (Rights of Data Subjects), 8 (Actions and Access Requests), and 9 (Audit Rights). 

12. Communications 

Licensee’s authorized users of the Services may issue Instructions to iPaaS.com via their use of the Services.  Outside of Instructions issued within the Services by authorized Personnel, any additional Instructions must be received only from designated individuals specified in the applicable Order Form.  If these contacts change or otherwise become permanently unavailable, the respective party shall communicate such change immediately in writing. 

13. Miscellaneous 

The parties' agreement to this DPA shall be considered as agreement to the Standard Contractual Clauses, including the EU SCCs and UK Addendum, as applicable. If there is any conflict between this DPA and the Standard Contractual Clauses, the Standard Contractual Clauses will prevail with respect to Personal Data that is subject to GDPR or UK GDPR. 

Schedule 1 – Details of Processing 

Section A: List of Parties 

Section B: Description of Processing/Transfer 

Categories of Data Subjects: Licensee may submit Personal Data to the Service, the extent to which is determined and controlled by the Licensee in its sole discretion, and which may include, but not limited to Personal Data relating to the following categories of Data Subjects: 

• Data Exporter employees, contractors, representatives, agents, and other individuals whom data exporter permits to use the Service, as well as Personal Information relating to the data exporter’s customers, partners, users, and vendors. 

Categories of Personal Data: The Personal Data included in the Licensee Data uploaded to the Services by Licensee for Processing under Licensee’s Accounts, the extent to which is determined and controlled by the Licensee in its sole discretion, which may include, but is not limited to the following categories of Personal Data: 

• Customer Information inclusive of name, email, phone number and address. 
• Order information inclusive of basic customer contact information (name, email, billing address and shipping address) and order details such as product information, taxes, shipping tracking information and payments (exclusive of any credit card or banking information). 
• Employee name, address, email and phone number. 

Sensitive data transferred (if applicable):  None. Data Exporter is contractually prohibited from transferring sensitive data for Processing. 

The frequency of the transfer (e.g., whether the data is transferred on a one-off or continuous basis):  Continuous 

Nature and Purpose of Processing: iPaaS.com provides a flexible business integration and automation service. iPaaS.com will Process Personal Data as necessary to perform the Services pursuant to the Agreement, and as further Instructed by Licensee and its authorized users in the use of the Services. 

Frequency and Duration of Processing: iPaaS.com will Process Personal Data for the duration of the Agreement. Personal Data submitted to iPaaS.com is retained for up to 90 days following termination of the Agreement. 

For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing: All customer configuration and integrated data is accepted only via SSL encrypted API access and is maintained on the http://iPaaS.com data hub (hosted on Microsoft Azure) for the duration of the contract unless removed by an integration or manual means. Integrated data is passed to customer systems via outbound API calls or scheduled push of flat files to FTPS/SFTP servers provided by customer.

Schedule 2 – Data Security Measures 

iPaaS.com shall: 

1. Maintain an information security program which is approved by its management and regularly reviewed and updated accordingly. 
2. Restrict access to Personal Data to Authorized Individuals who provide authentication that uniquely identifies them. 
3. Restrict Authorized Individuals’ rights to access or modify Personal Data based on business role and need. 
4. Review access and authorization rights for Authorized Individuals regularly. Access or authorization rights are withdrawn or modified, as appropriate, promptly upon termination or change of role for such Authorized Individuals. 
5. Ensure that physical access to systems storing or processing Personal Data is appropriately secured and monitored. 
6. Encrypt Personal Data both at rest and in transit, using industry standard protocols and encryption algorithms. 
7. Implement and maintain secure coding and development standards, incorporating security and privacy considerations. 
8. Ensure that its personnel receive regular security and privacy training so that they are aware of their roles and responsibilities regarding the treatment and protection of Personal Data. 
9. Segregate internal systems storing or processing Personal Data from public networks. 
10. Implement anti-malware on systems that do or may Process Personal Data. 
11. Implement monitoring and alerting capabilities on its systems. 
12. Evaluate its systems for vulnerabilities and deploy required security updates on a schedule based on risk and severity. 
13. Regularly test the security of its systems including an annual penetration test performed by a qualified third party. 
14. Evaluate the security and privacy practices of all Authorized Sub-Processors. All Authorized Sub-Processors are required to implement and maintain the same or substantially similar technical and organizational measures and assume the same responsibilities and obligations as those required of Processor under this DPA. 
15. Deploy redundant services and engage in practices including regular backups designed to provide continued availability and access to data despite disruptions to its infrastructure. 
16. Maintain an incident response plan and commit to providing required notifications in case of a confirmed Personal Data Breach without undue delay. 
17. Maintain systems and processes for complying with data privacy requirements including limited retention and processing of requests from Data Subjects.