Data Processing and Security Terms for SnapApp Services
Last modified: 6 February 2026
The customer agreeing to these terms (“Customer”), and BlueVector AI LLC (“BlueVector AI”) have entered into an agreement under which BlueVector AI has agreed to provide the Services and related technical support to Customer (as amended from time to time, the “Agreement”).
Commencement
Definitions
Duration
Scope of Data Protection Law
Processing of Data
Scope of Processing.
Data Deletion
Data Security
Data Incidents.
Customer’s Security Responsibilities and Assessment.
Reviews and Audits of Compliance.
Impact Assessments and Consultations
Access etc.; Data Subject Rights; Data Export
Data Subject Requests.
Data Transfers
Subprocessors
Processing Records
Interpretation
Appendix 1: Subject Matter and Details of the Data Processing
Appendix 2: Security Measures
Data Center and Network Security
Access and Site Controls
Data
Data Storage, Isolation and Logging. BlueVector AI stores data in a multi-tenant environment on Google Cloud servers. BlueVector AI replicates Customer Data between multiple geographically dispersed data centers. BlueVector AI also logically isolates the Customer’s data. Customer will be given control over specific data sharing policies. Those policies, in accordance with the functionality of the Services, will enable Customer to determine the product sharing settings applicable to Customer End Users for specific purposes. Customer may choose to make use of logging functionality that BlueVector AI makes available via the Services.
Personnel Security BlueVector AI personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. BlueVector AI conducts reasonably appropriate backgrounds checks to the extent legally permissible and in accordance with applicable local labor law and statutory regulations. Personnel are required to execute a confidentiality agreement and must acknowledge receipt of, and compliance with, BlueVector AI’s confidentiality and privacy policies. Personnel are provided with security training. Personnel handling Customer Data are required to complete additional requirements appropriate to their role (e.g., certifications). BlueVector AI’s personnel will not process Customer Data without authorization.
Subprocessor Security Before onboarding Subprocessors, BlueVector AI conducts an audit of the security and privacy practices of Subprocessors to ensure Subprocessors provide a level of security and privacy appropriate to their access to data and the scope of the services they are engaged to provide. Once BlueVector AI has assessed the risks presented by the Subprocessor, then subject to the requirements described in Section 11.3 (Requirements for Subprocessor Engagement) of these Terms, the Subprocessor is required to enter into appropriate security, confidentiality and privacy contract terms.
These Data Processing and Security Terms, including their appendices (the “Terms”) will be effective and replace any previously applicable data processing and security terms as from the Terms Effective Date (as defined below). These Terms supplement the Agreement.
Definitions
Capitalized terms defined in the Agreement apply to these Terms. In addition, in these Terms:
Additional Security Controls means security resources, features, functionality and/or controls that Customer may use at its option and/or as it determines, including the Admin Console, logging and monitoring, and access management.
Adequate Country means:
for data processed subject to the EU GDPR: the EEA, or a country or territory that is the subject of an adequacy decision by the Commission under Article 45(1) of the EU GDPR;
for data processed subject to the UK GDPR: the UK or a country or territory that is the subject of the adequacy regulations under Article 45(1) of the UK GDPR and Section 17A of the Data Protection Act 2018; and/or
for data processed subject to the Swiss FDPA: Switzerland, or a country or territory that (i) is included in the list of the states whose legislation ensures an adequate level of protection as published by the Swiss Federal Data Protection and Information Commissioner, or (ii) is the subject of an adequacy decision by the Swiss Federal Council under the Swiss FDPA.
Customer Data has the meaning given in the Agreement or, if no such meaning is given, means data provided to BlueVector AI by Customer or Customer End Users through the Services under the Account.
Customer End User has the meaning given in the Agreement or, if no such meaning is given, has the meaning given to “End User” in the Agreement.
Customer Personal Data means the personal data contained within the Customer Data.
Data Incident means a breach of BlueVector AI’s security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer Data on systems managed by or otherwise controlled by BlueVector AI.
EEA means the European Economic Area.
EMEA means Europe, the Middle East and Africa.
EU GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
European Data Protection Law means, as applicable: (a) the GDPR; and/or (b) the Federal Data Protection Act of 19 June 1992 (Switzerland).
European Law means, as applicable: (a) EU or EU Member State law (if the EU GDPR applies to the processing of Customer Personal Data); and/or (b) the law of the UK or a part of the UK (if the UK GDPR applies to the processing of Customer Personal Data).
GDPR means, as applicable: (a) the EU GDPR; and/or (b) the UK GDPR.
BlueVector AI’s Third Party Auditor means a BlueVector AI-appointed, qualified and independent third party auditor, whose then-current identity BlueVector AI will disclose to Customer.
Instructions has the meaning given in Section 5.2.1 (Customer’s Instructions).
Non-European Data Protection Law means data protection or privacy laws in force outside the European Economic Area, Switzerland and the UK.
Notification Email Address means the email address associated with Customer’s Account Customer is responsible for keeping its Notification Email Address current and valid.
Services mean the collection of services in the SnapApp Enterprise Application builder. These services allow organizations to build web-based applications with configuration not code.
Security Measures has the meaning given in Section 7.1.1 (BlueVector AI’s Security Measures).
Subprocessor means a third party authorized as another processor under these Terms to have logical access to and process Customer Data in order to provide parts of the Services and Technical Support.
Supervisory Authority means, as applicable: (a) a “supervisory authority” as defined in the EU GDPR; and/or (b) the “Commissioner” as defined in the UK GDPR.
Swiss FDPA means the Federal Data Protection Act of 19 June 1992 (Switzerland).
Technical Support means the then-current technical support service provided by BlueVector AI to Customer.
Term means the period from the Terms Effective Date until the end of BlueVector AI’s provision of the Services, including, if applicable, any period during which provision of the Services may be suspended and any post-termination period during which BlueVector AI may continue providing the Services for transitional purposes.
Terms Effective Date means the date on which Customer accepted, or the parties otherwise agreed to, these Terms.
UK GDPR means the EU GDPR as amended and incorporated into UK law under the UK European Union (Withdrawal) Act 2018, if in force.
The terms “personal data”, “data subject”, “processing”, “controller” and “processor” as used in these Terms have the meanings given in the GDPR irrespective of whether European Data Protection Law or Non-European Data Protection Law applies.
Additional Security Controls means security resources, features, functionality and/or controls that Customer may use at its option and/or as it determines, including the Admin Console, logging and monitoring, and access management.
Adequate Country means:
for data processed subject to the EU GDPR: the EEA, or a country or territory that is the subject of an adequacy decision by the Commission under Article 45(1) of the EU GDPR;
for data processed subject to the UK GDPR: the UK or a country or territory that is the subject of the adequacy regulations under Article 45(1) of the UK GDPR and Section 17A of the Data Protection Act 2018; and/or
for data processed subject to the Swiss FDPA: Switzerland, or a country or territory that (i) is included in the list of the states whose legislation ensures an adequate level of protection as published by the Swiss Federal Data Protection and Information Commissioner, or (ii) is the subject of an adequacy decision by the Swiss Federal Council under the Swiss FDPA.
Customer Data has the meaning given in the Agreement or, if no such meaning is given, means data provided to BlueVector AI by Customer or Customer End Users through the Services under the Account.
Customer End User has the meaning given in the Agreement or, if no such meaning is given, has the meaning given to “End User” in the Agreement.
Customer Personal Data means the personal data contained within the Customer Data.
Data Incident means a breach of BlueVector AI’s security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer Data on systems managed by or otherwise controlled by BlueVector AI.
EEA means the European Economic Area.
EMEA means Europe, the Middle East and Africa.
EU GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
European Data Protection Law means, as applicable: (a) the GDPR; and/or (b) the Federal Data Protection Act of 19 June 1992 (Switzerland).
European Law means, as applicable: (a) EU or EU Member State law (if the EU GDPR applies to the processing of Customer Personal Data); and/or (b) the law of the UK or a part of the UK (if the UK GDPR applies to the processing of Customer Personal Data).
GDPR means, as applicable: (a) the EU GDPR; and/or (b) the UK GDPR.
BlueVector AI’s Third Party Auditor means a BlueVector AI-appointed, qualified and independent third party auditor, whose then-current identity BlueVector AI will disclose to Customer.
Instructions has the meaning given in Section 5.2.1 (Customer’s Instructions).
Non-European Data Protection Law means data protection or privacy laws in force outside the European Economic Area, Switzerland and the UK.
Notification Email Address means the email address associated with Customer’s Account Customer is responsible for keeping its Notification Email Address current and valid.
Services mean the collection of services in the SnapApp Enterprise Application builder. These services allow organizations to build web-based applications with configuration not code.
Security Measures has the meaning given in Section 7.1.1 (BlueVector AI’s Security Measures).
Subprocessor means a third party authorized as another processor under these Terms to have logical access to and process Customer Data in order to provide parts of the Services and Technical Support.
Supervisory Authority means, as applicable: (a) a “supervisory authority” as defined in the EU GDPR; and/or (b) the “Commissioner” as defined in the UK GDPR.
Swiss FDPA means the Federal Data Protection Act of 19 June 1992 (Switzerland).
Technical Support means the then-current technical support service provided by BlueVector AI to Customer.
Term means the period from the Terms Effective Date until the end of BlueVector AI’s provision of the Services, including, if applicable, any period during which provision of the Services may be suspended and any post-termination period during which BlueVector AI may continue providing the Services for transitional purposes.
Terms Effective Date means the date on which Customer accepted, or the parties otherwise agreed to, these Terms.
UK GDPR means the EU GDPR as amended and incorporated into UK law under the UK European Union (Withdrawal) Act 2018, if in force.
The terms “personal data”, “data subject”, “processing”, “controller” and “processor” as used in these Terms have the meanings given in the GDPR irrespective of whether European Data Protection Law or Non-European Data Protection Law applies.
Duration
These Terms will notwithstanding expiry of the Term, remain in effect until, and automatically expire upon, deletion of all Customer Data by BlueVector AI as described in these Terms.
Scope of Data Protection Law
Application of European Law. The parties acknowledge that European Data Protection Law will apply to the processing of Customer Personal Data if, for example: a. the processing is carried out in the context of the activities of an establishment of Customer in the territory of the EEA or the UK; and/or b. the Customer Personal Data is personal data relating to data subjects who are in the EEA or the UK and the processing relates to the offering to them of goods or services in the EEA or the UK, or the monitoring of their behavior in the EEA or the UK.
Application of Non-European Law. The parties acknowledge that Non-European Data Protection Law may also apply to the processing of Customer Personal Data.
Application of Terms. Except to the extent these Terms state otherwise, these Terms will apply irrespective of whether European Data Protection Law or Non-European Data Protection Law applies to the processing of Customer Personal Data.
Application of Non-European Law. The parties acknowledge that Non-European Data Protection Law may also apply to the processing of Customer Personal Data.
Application of Terms. Except to the extent these Terms state otherwise, these Terms will apply irrespective of whether European Data Protection Law or Non-European Data Protection Law applies to the processing of Customer Personal Data.
Processing of Data
Roles and Regulatory Compliance; Authorization.
Processor and Controller Responsibilities. If European Data Protection Law applies to the processing of Customer Personal Data: a. the subject matter and details of the processing are described in Appendix 1; b. BlueVector AI is a processor of that Customer Personal Data under European Data Protection Law; c. Customer is a controller or processor, as applicable, of that Customer Personal Data under European Data Protection Law; and d. each party will comply with the obligations applicable to it under European Data Protection Law with respect to the processing of that Customer Personal Data.
Processor Customers. If European Data Protection Law applies to the processing of Customer Personal Data and Customer is a processor: a. Customer warrants on an ongoing basis that the relevant controller has authorized: (i) the Instructions, (ii) Customer’s appointment of BlueVector AI as another processor, and (iii) BlueVector AI’s engagement of Subprocessors as described in Section 11 (Subprocessors); b. Customer will immediately forward to the relevant controller any notice provided by BlueVector AI under Sections 5.2.3 (Instruction Notifications), 7.2.1 (Incident Notification), 9.2.1 (Responsibility for Requests), 11.4 (Opportunity to Object to Subprocessor Changes); and c. Customer may: i. request access for the relevant controller to the Security Reports in accordance with Section 7.5.3(a); and ii. make available to the relevant controller any other information made available by BlueVector AI under Sections 10.4 (Supplementary Measures and Information), 10.6 (Data Center Information) and 11.2 (Information about Subprocessors).
Responsibilities under Non-European Law. If Non-European Data Protection Law applies to either party’s processing of Customer Personal Data, the relevant party will comply with any obligations applicable to it under that law with respect to the processing of that Customer Personal Data.
Processor and Controller Responsibilities. If European Data Protection Law applies to the processing of Customer Personal Data: a. the subject matter and details of the processing are described in Appendix 1; b. BlueVector AI is a processor of that Customer Personal Data under European Data Protection Law; c. Customer is a controller or processor, as applicable, of that Customer Personal Data under European Data Protection Law; and d. each party will comply with the obligations applicable to it under European Data Protection Law with respect to the processing of that Customer Personal Data.
Processor Customers. If European Data Protection Law applies to the processing of Customer Personal Data and Customer is a processor: a. Customer warrants on an ongoing basis that the relevant controller has authorized: (i) the Instructions, (ii) Customer’s appointment of BlueVector AI as another processor, and (iii) BlueVector AI’s engagement of Subprocessors as described in Section 11 (Subprocessors); b. Customer will immediately forward to the relevant controller any notice provided by BlueVector AI under Sections 5.2.3 (Instruction Notifications), 7.2.1 (Incident Notification), 9.2.1 (Responsibility for Requests), 11.4 (Opportunity to Object to Subprocessor Changes); and c. Customer may: i. request access for the relevant controller to the Security Reports in accordance with Section 7.5.3(a); and ii. make available to the relevant controller any other information made available by BlueVector AI under Sections 10.4 (Supplementary Measures and Information), 10.6 (Data Center Information) and 11.2 (Information about Subprocessors).
Responsibilities under Non-European Law. If Non-European Data Protection Law applies to either party’s processing of Customer Personal Data, the relevant party will comply with any obligations applicable to it under that law with respect to the processing of that Customer Personal Data.
Scope of Processing.
Customer’s Instructions. Customer instructs BlueVector AI to process Customer Personal Data only in accordance with applicable law: (a) to provide the Services and Technical Support; (b) as further specified via Customer’s use of the Services (including the Admin Console and other functionality of the Services) and Technical Support; (c) as documented in the form of the Agreement, including these Terms; and (d) as further documented in any other written instructions given by Customer and acknowledged by BlueVector AI as constituting instructions for purposes of these Terms (collectively, the “Instructions”).
BlueVector AI’s Compliance with Instructions. BlueVector AI will comply with the Instructions unless prohibited by European Law.
Instruction Notifications. BlueVector AI will immediately notify Customer if, in BlueVector AI’s opinion: (a) European Law prohibits BlueVector AI from complying with an Instruction; (b) an Instruction does not comply with European Data Protection Law; or (c) BlueVector AI is otherwise unable to comply with an Instruction, in each case unless such notice is prohibited by European Law. This Section does not reduce either party’s rights and obligations elsewhere in the Agreement.
BlueVector AI’s Compliance with Instructions. BlueVector AI will comply with the Instructions unless prohibited by European Law.
Instruction Notifications. BlueVector AI will immediately notify Customer if, in BlueVector AI’s opinion: (a) European Law prohibits BlueVector AI from complying with an Instruction; (b) an Instruction does not comply with European Data Protection Law; or (c) BlueVector AI is otherwise unable to comply with an Instruction, in each case unless such notice is prohibited by European Law. This Section does not reduce either party’s rights and obligations elsewhere in the Agreement.
Data Deletion
Deletion by Customer. BlueVector AI will enable Customer to delete Customer Data during the Term in a manner consistent with the functionality of the Services. If Customer uses the Services to delete any Customer Data during the Term and that Customer Data cannot be recovered by Customer, this use will constitute an instruction to BlueVector AI to delete the relevant Customer Data from BlueVector AI’s systems in accordance with applicable law. BlueVector AI will comply with this instruction as soon as reasonably practicable and within a maximum period of 180 days, unless European Law requires storage.
Deletion on Termination. On expiry of the Term, Customer instructs BlueVector AI to delete all Customer Data (including existing copies) from BlueVector AI’s systems in accordance with applicable law. BlueVector AI will comply with this instruction as soon as reasonably practicable and within a maximum period of 180 days, unless European Law requires storage. Without prejudice to Section 9.1 (Access; Rectification; Restricted Processing; Portability), Customer is responsible for exporting, before the Term expires, any Customer Data it wishes to retain.
Deletion on Termination. On expiry of the Term, Customer instructs BlueVector AI to delete all Customer Data (including existing copies) from BlueVector AI’s systems in accordance with applicable law. BlueVector AI will comply with this instruction as soon as reasonably practicable and within a maximum period of 180 days, unless European Law requires storage. Without prejudice to Section 9.1 (Access; Rectification; Restricted Processing; Portability), Customer is responsible for exporting, before the Term expires, any Customer Data it wishes to retain.
Data Security
BlueVector AI’s Security Measures, Controls and Assistance.
BlueVector AI’s Security Measures. BlueVector AI will implement and maintain technical and organizational measures to protect Customer Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access as described in Appendix 2 (the “Security Measures”). The Security Measures include measures to encrypt personal data; to help ensure ongoing confidentiality, integrity, availability and resilience of BlueVector AI’s systems and services; to help restore timely access to personal data following an incident; and for regular testing of effectiveness. BlueVector AI may update the Security Measures from time to time provided that such updates do not result in the degradation of the overall security of the Services.
Access and Compliance. BlueVector AI will: (a) authorize its employees, contractors and Subprocessors to access Customer Personal Data only as strictly necessary to comply with Instructions; (b) take appropriate steps to ensure compliance with the Security Measures by its employees, contractors and Subprocessors to the extent applicable to their scope of performance, and (c) ensure that all persons authorized to process Customer Personal Data are under an obligation of confidentiality.
Additional Security Controls. BlueVector AI will make Additional Security Controls available to: (a) allow Customer to take steps to secure Customer Data; and (b) provide Customer with information about securing, accessing and using Customer Data.
BlueVector AI’s Security Assistance. BlueVector AI will (taking into account the nature of the processing of Customer Personal Data and the information available to BlueVector AI) assist Customer in ensuring compliance with its obligations pursuant to Articles 32 to 34 of the GDPR, by: a. implementing and maintaining the Security Measures in accordance with Section 7.1.1 (BlueVector AI’s Security Measures); b. making Additional Security Controls available to Customer in accordance with Section 7.1.3 (Additional Security Controls); c. complying with the terms of Section 7.2 (Data Incidents); d. providing Customer with the Security Documentation in accordance with Section 7.5.1 (Reviews of Security Documentation) and the information contained in the Agreement including these Terms; and e. if subsections (a)-(d) above are insufficient for Customer to comply with such obligations, upon Customer’s request, providing additional reasonable assistance.
BlueVector AI’s Security Measures. BlueVector AI will implement and maintain technical and organizational measures to protect Customer Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access as described in Appendix 2 (the “Security Measures”). The Security Measures include measures to encrypt personal data; to help ensure ongoing confidentiality, integrity, availability and resilience of BlueVector AI’s systems and services; to help restore timely access to personal data following an incident; and for regular testing of effectiveness. BlueVector AI may update the Security Measures from time to time provided that such updates do not result in the degradation of the overall security of the Services.
Access and Compliance. BlueVector AI will: (a) authorize its employees, contractors and Subprocessors to access Customer Personal Data only as strictly necessary to comply with Instructions; (b) take appropriate steps to ensure compliance with the Security Measures by its employees, contractors and Subprocessors to the extent applicable to their scope of performance, and (c) ensure that all persons authorized to process Customer Personal Data are under an obligation of confidentiality.
Additional Security Controls. BlueVector AI will make Additional Security Controls available to: (a) allow Customer to take steps to secure Customer Data; and (b) provide Customer with information about securing, accessing and using Customer Data.
BlueVector AI’s Security Assistance. BlueVector AI will (taking into account the nature of the processing of Customer Personal Data and the information available to BlueVector AI) assist Customer in ensuring compliance with its obligations pursuant to Articles 32 to 34 of the GDPR, by: a. implementing and maintaining the Security Measures in accordance with Section 7.1.1 (BlueVector AI’s Security Measures); b. making Additional Security Controls available to Customer in accordance with Section 7.1.3 (Additional Security Controls); c. complying with the terms of Section 7.2 (Data Incidents); d. providing Customer with the Security Documentation in accordance with Section 7.5.1 (Reviews of Security Documentation) and the information contained in the Agreement including these Terms; and e. if subsections (a)-(d) above are insufficient for Customer to comply with such obligations, upon Customer’s request, providing additional reasonable assistance.
Data Incidents.
Incident Notification. BlueVector AI will notify Customer promptly and without undue delay after becoming aware of a Data Incident, and promptly take reasonable steps to minimize harm and secure Customer Data.
Details of Data Incident. BlueVector AI’s notification of a Data Incident will describe, to the extent possible, the nature of the Data Incident, the measures taken to mitigate the potential risks and the measures BlueVector AI recommends Customer take to address the Data Incident.
Delivery of Notification. Notification(s) of any Data Incident(s) will be delivered to the Notification Email Address.
No Assessment of Customer Data by BlueVector AI. BlueVector AI has no obligation to assess Customer Data in order to identify information subject to any specific legal requirements.
No Acknowledgement of Fault by BlueVector AI. BlueVector AI’s notification of or response to a Data Incident under this Section 7.2 (Data Incidents) will not be construed as an acknowledgement by BlueVector AI of any fault or liability with respect to the Data Incident.
Details of Data Incident. BlueVector AI’s notification of a Data Incident will describe, to the extent possible, the nature of the Data Incident, the measures taken to mitigate the potential risks and the measures BlueVector AI recommends Customer take to address the Data Incident.
Delivery of Notification. Notification(s) of any Data Incident(s) will be delivered to the Notification Email Address.
No Assessment of Customer Data by BlueVector AI. BlueVector AI has no obligation to assess Customer Data in order to identify information subject to any specific legal requirements.
No Acknowledgement of Fault by BlueVector AI. BlueVector AI’s notification of or response to a Data Incident under this Section 7.2 (Data Incidents) will not be construed as an acknowledgement by BlueVector AI of any fault or liability with respect to the Data Incident.
Customer’s Security Responsibilities and Assessment.
Customer’s Security Responsibilities. Without prejudice to BlueVector AI’s obligations under Sections 7.1 (BlueVector AI’s Security Measures, Controls and Assistance) and 7.2 (Data Incidents), and elsewhere in the Agreement, Customer is responsible for its use of the Services and its storage of any copies of Customer Data outside BlueVector AI’s or Google’s systems, including: a. using the Services and Additional Security Controls to ensure a level of security appropriate to the risk in respect of the Customer Data; b. securing the account authentication credentials, systems and devices Customer uses to access the Services; and c. backing up its Customer Data as appropriate.
Customer’s Security Assessment. Customer agrees, based on its current and intended use of the Services, that the Services, Security Measures, Additional Security Controls and BlueVector AI’s commitments under this Section 7 (Data Security): (a) meet Customer’s needs, including with respect to any security obligations of Customer under European Data Protection Law and/or Non-European Data Protection Law, as applicable, and (b) provide a level of security appropriate to the risk in respect of the Customer Data.
Security Report. BlueVector AI will maintain an annual security report outlining the security status and any steps taken to remedy any known vulnerabilities.
Customer’s Security Assessment. Customer agrees, based on its current and intended use of the Services, that the Services, Security Measures, Additional Security Controls and BlueVector AI’s commitments under this Section 7 (Data Security): (a) meet Customer’s needs, including with respect to any security obligations of Customer under European Data Protection Law and/or Non-European Data Protection Law, as applicable, and (b) provide a level of security appropriate to the risk in respect of the Customer Data.
Security Report. BlueVector AI will maintain an annual security report outlining the security status and any steps taken to remedy any known vulnerabilities.
Reviews and Audits of Compliance.
Reviews of Security Documentation. BlueVector AI will make the Security Report available for review by Customer to demonstrate compliance by BlueVector AI with its obligations under these Terms.
Customer’s Audit Rights. a. If European Data Protection Law applies to the processing of Customer Personal Data, BlueVector AI will allow Customer or an independent auditor appointed by Customer to conduct audits (including inspections) to verify BlueVector AI’s compliance with its obligations under these Terms in accordance with Section 7.5.3 (Additional Business Terms for Reviews and Audits). BlueVector AI will contribute to such audits as described in Section 7.4 (Security Report) and this Section 7.5 (Reviews and Audits of Compliance). b. Customer may conduct an audit to verify BlueVector AI’s compliance with its obligations under these Terms by reviewing the Security Documentation (which reflects the outcome of audits conducted by BlueVector AI’s Third Party Auditor).
Additional Business Terms for Reviews and Audits. a. Customer must send any requests for reviews of the Security Report under Section 5.1.2(c)(i) or 7.5.1 or audits under Section 7.5.2(a) or 7.5.2(b) to BlueVector AI. b. Following receipt by BlueVector AI of a request under Section 7.5.3(a), BlueVector AI and Customer will discuss and agree in advance on: (i) the reasonable date(s) of and security and confidentiality controls applicable to any review of the Security Report under Section 5.1.2(c)(i) or 7.5.1; and (ii) the reasonable start date, scope and duration of and security and confidentiality controls applicable to any audit under Section 7.5.2(a) or 7.5.2(b). c. BlueVector AI may charge a fee (based on BlueVector AI’s reasonable costs) for any audit under Section 7.5.2(a) or 7.5.2(b). BlueVector AI will provide Customer with further details of any applicable fee, and the basis of its calculation, in advance of any such audit. Customer will be responsible for any fees charged by any auditor appointed by Customer to execute any such audit. d. BlueVector AI may object in writing to an auditor appointed by Customer to conduct any audit under Section 7.5.2(a) or 7.5.2(b) if the auditor is, in BlueVector AI’s reasonable opinion, not suitably qualified or independent, a competitor of BlueVector AI, or otherwise manifestly unsuitable. Any such objection by BlueVector AI will require Customer to appoint another auditor or conduct the audit itself.
Customer’s Audit Rights. a. If European Data Protection Law applies to the processing of Customer Personal Data, BlueVector AI will allow Customer or an independent auditor appointed by Customer to conduct audits (including inspections) to verify BlueVector AI’s compliance with its obligations under these Terms in accordance with Section 7.5.3 (Additional Business Terms for Reviews and Audits). BlueVector AI will contribute to such audits as described in Section 7.4 (Security Report) and this Section 7.5 (Reviews and Audits of Compliance). b. Customer may conduct an audit to verify BlueVector AI’s compliance with its obligations under these Terms by reviewing the Security Documentation (which reflects the outcome of audits conducted by BlueVector AI’s Third Party Auditor).
Additional Business Terms for Reviews and Audits. a. Customer must send any requests for reviews of the Security Report under Section 5.1.2(c)(i) or 7.5.1 or audits under Section 7.5.2(a) or 7.5.2(b) to BlueVector AI. b. Following receipt by BlueVector AI of a request under Section 7.5.3(a), BlueVector AI and Customer will discuss and agree in advance on: (i) the reasonable date(s) of and security and confidentiality controls applicable to any review of the Security Report under Section 5.1.2(c)(i) or 7.5.1; and (ii) the reasonable start date, scope and duration of and security and confidentiality controls applicable to any audit under Section 7.5.2(a) or 7.5.2(b). c. BlueVector AI may charge a fee (based on BlueVector AI’s reasonable costs) for any audit under Section 7.5.2(a) or 7.5.2(b). BlueVector AI will provide Customer with further details of any applicable fee, and the basis of its calculation, in advance of any such audit. Customer will be responsible for any fees charged by any auditor appointed by Customer to execute any such audit. d. BlueVector AI may object in writing to an auditor appointed by Customer to conduct any audit under Section 7.5.2(a) or 7.5.2(b) if the auditor is, in BlueVector AI’s reasonable opinion, not suitably qualified or independent, a competitor of BlueVector AI, or otherwise manifestly unsuitable. Any such objection by BlueVector AI will require Customer to appoint another auditor or conduct the audit itself.
Impact Assessments and Consultations
BlueVector AI will (taking into account the nature of the processing and the information available to BlueVector AI) assist Customer in ensuring compliance with its obligations pursuant to Articles 35 and 36 of the GDPR, by: a. providing Additional Security Controls in accordance with Section 7.1.3 (Additional Security Controls) and the Security Documentation in accordance with Section 7.5.1 (Reviews of Security Documentation); b. providing the information contained in the Agreement (including these Terms); and c. if subsections (a) and (b) above are insufficient for Customer to comply with such obligations, upon Customer’s request, providing additional reasonable assistance.
Access etc.; Data Subject Rights; Data Export
Access; Rectification; Restricted Processing; Portability. During the Term, BlueVector AI will enable Customer, in a manner consistent with the functionality of the Services, to access, rectify and restrict processing of Customer Data, including via the deletion functionality provided by BlueVector AI as described in Section 6.1 (Deletion by Customer), and to export Customer Data. If Customer becomes aware that any Customer Personal Data is inaccurate or outdated, Customer will be responsible for using such functionality to rectify or delete that data if required by applicable European Data Protection Law.
Data Subject Requests.
Responsibility for Requests. During the Term, if BlueVector AI receives a request from a data subject in relation to Customer Personal Data, and the request identifies Customer, BlueVector AI will: (a) advise the data subject to submit their request to Customer; (b) promptly notify Customer; and (c) not otherwise respond to that data subject’s request without authorization from Customer. Customer will be responsible for responding to any such request including, where necessary, by using the functionality of the Services.
BlueVector AI’s Data Subject Request Assistance. BlueVector AI will (taking into account the nature of the processing of Customer Personal Data) assist Customer in fulfilling its (or, where Customer is a processor, the relevant controller’s) obligations under Chapter III of the GDPR to respond to requests for exercising the data subject’s rights by: a. providing Additional Security Controls in accordance with Section 7.1.3 (Additional Security Controls); b. complying with Sections 9.1 (Access; Rectification; Restricted Processing; Portability) and 9.2.1 (Responsibility for Requests); and c. if subsections (a) and (b) above are insufficient for Customer to comply with such obligations, upon Customer’s request, providing additional reasonable assistance.
BlueVector AI’s Data Subject Request Assistance. BlueVector AI will (taking into account the nature of the processing of Customer Personal Data) assist Customer in fulfilling its (or, where Customer is a processor, the relevant controller’s) obligations under Chapter III of the GDPR to respond to requests for exercising the data subject’s rights by: a. providing Additional Security Controls in accordance with Section 7.1.3 (Additional Security Controls); b. complying with Sections 9.1 (Access; Rectification; Restricted Processing; Portability) and 9.2.1 (Responsibility for Requests); and c. if subsections (a) and (b) above are insufficient for Customer to comply with such obligations, upon Customer’s request, providing additional reasonable assistance.
Data Transfers
Data Transfer Compliance. It is the Customers responsibility to ensure data is transferred in a safe way in accordance with local laws and regulations.
Data Center Information. All data is stored and processed on the Google Cloud platform. Information about the locations of Google Cloud facilities is available at: https://cloud.google.com/about/locations/ (as may be updated by Google from time to time).
Data Center Information. All data is stored and processed on the Google Cloud platform. Information about the locations of Google Cloud facilities is available at: https://cloud.google.com/about/locations/ (as may be updated by Google from time to time).
Subprocessors
Consent to Subprocessor Engagement. Customer specifically authorizes the engagement as Subprocessors of: (a) those entities listed as of the Terms Effective Date at the URL specified in Section 11.2 (Information about Subprocessors); and (b) all other BlueVector AI Affiliates from time to time. In addition, without prejudice to Section 11.4 (Opportunity to Object to Subprocessor Changes), Customer generally authorizes the engagement as Subprocessors of any other third parties (“New Subprocessors”).
Information about Subprocessors. Information about Subprocessors, including their functions and locations, is available at: https://www.blueVector.ai/SnapApp/subprocessors (as may be updated by BlueVector AI from time to time in accordance with these Terms).
Requirements for Subprocessor Engagement. When engaging any Subprocessor, BlueVector AI will: a. ensure via a written contract that: i. the Subprocessor only accesses and uses Customer Data to the extent required to perform the obligations subcontracted to it, and does so in accordance with the Agreement (including these Terms) ; and ii. if the processing of Customer Personal Data is subject to European Data Protection Law, the data protection obligations described in these Terms (as referred to in Article 28(3) of the GDPR, if applicable), are imposed on the Subprocessor; and b. remain fully liable for all obligations subcontracted to, and all acts and omissions of, the Subprocessor.
Opportunity to Object to Subprocessor Changes. a. When any New Subprocessor is engaged during the Term, BlueVector AI will, at least 30 days before the New Subprocessor starts processing any Customer Data, notify Customer of the engagement (including the name and location of the relevant subprocessor and the activities it will perform). b. Customer may, within 90 days after being notified of the engagement of a New Subprocessor, object by terminating the Agreement immediately by notifying BlueVector AI.
Information about Subprocessors. Information about Subprocessors, including their functions and locations, is available at: https://www.blueVector.ai/SnapApp/subprocessors (as may be updated by BlueVector AI from time to time in accordance with these Terms).
Requirements for Subprocessor Engagement. When engaging any Subprocessor, BlueVector AI will: a. ensure via a written contract that: i. the Subprocessor only accesses and uses Customer Data to the extent required to perform the obligations subcontracted to it, and does so in accordance with the Agreement (including these Terms) ; and ii. if the processing of Customer Personal Data is subject to European Data Protection Law, the data protection obligations described in these Terms (as referred to in Article 28(3) of the GDPR, if applicable), are imposed on the Subprocessor; and b. remain fully liable for all obligations subcontracted to, and all acts and omissions of, the Subprocessor.
Opportunity to Object to Subprocessor Changes. a. When any New Subprocessor is engaged during the Term, BlueVector AI will, at least 30 days before the New Subprocessor starts processing any Customer Data, notify Customer of the engagement (including the name and location of the relevant subprocessor and the activities it will perform). b. Customer may, within 90 days after being notified of the engagement of a New Subprocessor, object by terminating the Agreement immediately by notifying BlueVector AI.
Processing Records
BlueVector AI’s will provide prompt and reasonable assistance with any Customer queries related to processing of Customer Personal Data under the Agreement and can be contacted at support@bluevector.ai (and/or via such other means as BlueVector AI may provide from time to time).
BlueVector AI’s Processing Records. BlueVector AI will keep appropriate documentation of its processing activities as required by the GDPR. To the extent the GDPR requires BlueVector AI to collect and maintain records of certain information relating to Customer, Customer will, where requested, supply such information and keep it accurate and up-to-date. BlueVector AI may make any such information available to the Supervisory Authorities if required by the GDPR.
Controller Requests. During the Term, if BlueVector AI receives a request or instruction from a third party purporting to be a controller of Customer Personal Data, BlueVector AI will advise the third party to contact Customer.
BlueVector AI’s Processing Records. BlueVector AI will keep appropriate documentation of its processing activities as required by the GDPR. To the extent the GDPR requires BlueVector AI to collect and maintain records of certain information relating to Customer, Customer will, where requested, supply such information and keep it accurate and up-to-date. BlueVector AI may make any such information available to the Supervisory Authorities if required by the GDPR.
Controller Requests. During the Term, if BlueVector AI receives a request or instruction from a third party purporting to be a controller of Customer Personal Data, BlueVector AI will advise the third party to contact Customer.
Interpretation
Precedence. To the extent of any conflict or inconsistency between: a. these Terms and the remainder of the Agreement, these Terms will prevail;
Appendix 1: Subject Matter and Details of the Data Processing
Subject Matter: BlueVector AI’s provision of the Services and Technical Support to Customer.
Duration of the Processing: The Term plus the period from the expiry of the Term until deletion of all Customer Data by BlueVector AI in accordance with the Terms.
Nature and Purpose of the Processing: BlueVector AI will process Customer Personal Data for the purposes of providing the Services and Technical Support to Customer in accordance with the Terms.
Categories of Data: Data relating to individuals provided to BlueVector AI via the Services, by (or at the direction of) Customer or by Customer End Users.
Data Subjects: Data subjects include the individuals about whom data is provided to BlueVector AI via the Services by (or at the direction of) Customer or by Customer End Users.
Duration of the Processing: The Term plus the period from the expiry of the Term until deletion of all Customer Data by BlueVector AI in accordance with the Terms.
Nature and Purpose of the Processing: BlueVector AI will process Customer Personal Data for the purposes of providing the Services and Technical Support to Customer in accordance with the Terms.
Categories of Data: Data relating to individuals provided to BlueVector AI via the Services, by (or at the direction of) Customer or by Customer End Users.
Data Subjects: Data subjects include the individuals about whom data is provided to BlueVector AI via the Services by (or at the direction of) Customer or by Customer End Users.
Appendix 2: Security Measures
As from the Terms Effective Date, BlueVector AI will implement and maintain the Security Measures described in this Appendix 2.
Data Center and Network Security
Data Centers.
Networks and Transmission.
Infrastructure. All infrastructure runs on the Google Cloud Platform. Google maintains geographically distributed data centers. Google stores all production data in physically secure data centers.
Redundancy. Google’s infrastructure systems have been designed to eliminate single points of failure and minimize the impact of anticipated environmental risks. Dual circuits, switches, networks or other necessary devices help provide this redundancy. The Services are designed to allow BlueVector AI to perform certain types of preventative and corrective maintenance without interruption. All environmental equipment and facilities have documented preventative maintenance procedures that detail the process for and frequency of performance in accordance with the manufacturer’s or internal specifications. Preventative and corrective maintenance of the data center equipment is scheduled through a standard change process according to documented procedures.
Power. The data center electrical power systems are designed to be redundant and maintainable without impact to continuous operations, 24 hours a day, 7 days a week. In most cases, a primary as well as an alternate power source, each with equal capacity, is provided for critical infrastructure components in the data center. Backup power is provided by various mechanisms such as uninterruptible power supplies (UPS) batteries, which supply consistently reliable power protection during utility brownouts, blackouts, over voltage, under voltage, and out-of-tolerance frequency conditions. If utility power is interrupted, backup power is designed to provide transitory power to the data center, at full capacity, for up to 10 minutes until the diesel generator systems take over. The diesel generators are capable of automatically starting up within seconds to provide enough emergency electrical power to run the data center at full capacity typically for a period of days.
Server Operating Systems. Google servers use a Linux based implementation customized for the application environment. Google employs a code review process to increase the security of the code used to provide the Services and enhance the security products in production environments.
Businesses Continuity. Google has designed and regularly plans and tests its business continuity planning/disaster recovery programs.
Redundancy. Google’s infrastructure systems have been designed to eliminate single points of failure and minimize the impact of anticipated environmental risks. Dual circuits, switches, networks or other necessary devices help provide this redundancy. The Services are designed to allow BlueVector AI to perform certain types of preventative and corrective maintenance without interruption. All environmental equipment and facilities have documented preventative maintenance procedures that detail the process for and frequency of performance in accordance with the manufacturer’s or internal specifications. Preventative and corrective maintenance of the data center equipment is scheduled through a standard change process according to documented procedures.
Power. The data center electrical power systems are designed to be redundant and maintainable without impact to continuous operations, 24 hours a day, 7 days a week. In most cases, a primary as well as an alternate power source, each with equal capacity, is provided for critical infrastructure components in the data center. Backup power is provided by various mechanisms such as uninterruptible power supplies (UPS) batteries, which supply consistently reliable power protection during utility brownouts, blackouts, over voltage, under voltage, and out-of-tolerance frequency conditions. If utility power is interrupted, backup power is designed to provide transitory power to the data center, at full capacity, for up to 10 minutes until the diesel generator systems take over. The diesel generators are capable of automatically starting up within seconds to provide enough emergency electrical power to run the data center at full capacity typically for a period of days.
Server Operating Systems. Google servers use a Linux based implementation customized for the application environment. Google employs a code review process to increase the security of the code used to provide the Services and enhance the security products in production environments.
Businesses Continuity. Google has designed and regularly plans and tests its business continuity planning/disaster recovery programs.
Networks and Transmission.
Data Transmission. Data centers are typically connected via high-speed private links to provide secure and fast data transfer between data centers. This is designed to prevent data from being read, copied, altered or removed without authorization during electronic transfer or transport or while being recorded onto data storage media. Google Cloud transfers data via Internet standard protocols.
External Attack Surface. Google Cloud employs multiple layers of network devices and intrusion detection to protect its external attack surface. BlueVector AI considers potential attack vectors and incorporates appropriate purpose built technologies into external facing systems.
Intrusion Detection. Intrusion detection is intended to provide insight into ongoing attack activities and provide adequate information to respond to incidents. Google Cloud intrusion detection involves:
tightly controlling the size and make-up of Google Cloud’s attack surface through preventative measures;
employing intelligent detection controls at data entry points; and
employing technologies that automatically remedy certain dangerous situations.
Incident Response. BlueVector AI monitors a variety of communication channels for security incidents, and BlueVector AI’s security personnel will react promptly to known incidents.
Encryption Technologies. All SnapApp network data is transferred on Google Cloud protected networks using HTTPS encryption (also referred to as SSL or TLS connection). Google Cloud servers support ephemeral elliptic curve Diffie-Hellman cryptographic key exchange signed with RSA and ECDSA. These perfect forward secrecy (PFS) methods help protect traffic and minimize the impact of a compromised key, or a cryptographic breakthrough.
External Attack Surface. Google Cloud employs multiple layers of network devices and intrusion detection to protect its external attack surface. BlueVector AI considers potential attack vectors and incorporates appropriate purpose built technologies into external facing systems.
Intrusion Detection. Intrusion detection is intended to provide insight into ongoing attack activities and provide adequate information to respond to incidents. Google Cloud intrusion detection involves:
tightly controlling the size and make-up of Google Cloud’s attack surface through preventative measures;
employing intelligent detection controls at data entry points; and
employing technologies that automatically remedy certain dangerous situations.
Incident Response. BlueVector AI monitors a variety of communication channels for security incidents, and BlueVector AI’s security personnel will react promptly to known incidents.
Encryption Technologies. All SnapApp network data is transferred on Google Cloud protected networks using HTTPS encryption (also referred to as SSL or TLS connection). Google Cloud servers support ephemeral elliptic curve Diffie-Hellman cryptographic key exchange signed with RSA and ECDSA. These perfect forward secrecy (PFS) methods help protect traffic and minimize the impact of a compromised key, or a cryptographic breakthrough.
Access and Site Controls
Site Controls.
Access Control.
On-site Data Center Security Operation. Google Cloud’s data centers maintain an on-site security operation responsible for all physical data center security functions 24 hours a day, 7 days a week. The on-site security operation personnel monitor closed circuit TV (CCTV) cameras and all alarm systems. On-site security operation personnel perform internal and external patrols of the data center regularly.
Data Center Access Procedures. Google Cloud maintains formal access procedures for allowing physical access to the data centers. The data centers are housed in facilities that require electronic card key access, with alarms that are linked to the on-site security operation. All entrants to the data center are required to identify themselves as well as show proof of identity to on-site security operations. Only authorized employees, contractors and visitors are allowed entry to the data centers. Only authorized employees and contractors are permitted to request electronic card key access to these facilities. Data center electronic card key access requests must be made through e-mail, and require the approval of the requestor’s manager and the data center director. All other entrants requiring temporary data center access must: (i) obtain approval in advance from the data center managers for the specific data center and internal areas they wish to visit; (ii) sign in at on-site security operations; and (iii) reference an approved data center access record identifying the individual as approved.
On-site Data Center Security Devices. Google Cloud’s data centers employ a dual authentication access control system that is linked to a system alarm. The access control system monitors and records each individual’s electronic card key and when they access perimeter doors, shipping and receiving, and other critical areas. Unauthorized activity and failed access attempts are logged by the access control system and investigated, as appropriate. Authorized access throughout the business operations and data centers is restricted based on zones and the individual’s job responsibilities. The fire doors at the data centers are alarmed. CCTV cameras are in operation both inside and outside the data centers. The positioning of the cameras has been designed to cover strategic areas including, among others, the perimeter, doors to the data center building, and shipping/receiving. On-site security operations personnel manage the CCTV monitoring, recording and control equipment. Secure cables throughout the data centers connect the CCTV equipment. Cameras record on site via digital video recorders 24 hours a day, 7 days a week. The surveillance records are retained for up to 30 days based on activity.
Data Center Access Procedures. Google Cloud maintains formal access procedures for allowing physical access to the data centers. The data centers are housed in facilities that require electronic card key access, with alarms that are linked to the on-site security operation. All entrants to the data center are required to identify themselves as well as show proof of identity to on-site security operations. Only authorized employees, contractors and visitors are allowed entry to the data centers. Only authorized employees and contractors are permitted to request electronic card key access to these facilities. Data center electronic card key access requests must be made through e-mail, and require the approval of the requestor’s manager and the data center director. All other entrants requiring temporary data center access must: (i) obtain approval in advance from the data center managers for the specific data center and internal areas they wish to visit; (ii) sign in at on-site security operations; and (iii) reference an approved data center access record identifying the individual as approved.
On-site Data Center Security Devices. Google Cloud’s data centers employ a dual authentication access control system that is linked to a system alarm. The access control system monitors and records each individual’s electronic card key and when they access perimeter doors, shipping and receiving, and other critical areas. Unauthorized activity and failed access attempts are logged by the access control system and investigated, as appropriate. Authorized access throughout the business operations and data centers is restricted based on zones and the individual’s job responsibilities. The fire doors at the data centers are alarmed. CCTV cameras are in operation both inside and outside the data centers. The positioning of the cameras has been designed to cover strategic areas including, among others, the perimeter, doors to the data center building, and shipping/receiving. On-site security operations personnel manage the CCTV monitoring, recording and control equipment. Secure cables throughout the data centers connect the CCTV equipment. Cameras record on site via digital video recorders 24 hours a day, 7 days a week. The surveillance records are retained for up to 30 days based on activity.
Access Control.
Infrastructure Security Personnel. Both Google and BlueVector AI have, and maintain, a security policy for their personnel, and require security training as part of the training package for their personnel. BlueVector AI’s infrastructure security personnel are responsible for the ongoing monitoring of SnapApp’s security infrastructure, while Google’s personnel review the under underlying Google Cloud infrastructure.
Access Control and Privilege Management. Customer’s administrators must authenticate themselves via a central authentication system or via a single sign on system in order to administer the Services.
Internal Data Access Processes and Policies – Access Policy. BlueVector AI’s internal data access processes and policies are designed to prevent unauthorized persons and/or systems from gaining access to systems used to process personal data. BlueVector AI designs its systems to:
only allow authorized persons to access data they are authorized to access; and
ensure that personal data cannot be read, copied, altered or removed without authorization during processing, use and after recording. The systems are designed to detect any inappropriate access. BlueVector AI employs a centralized access management system to control personnel access to production servers, and only provides access to a limited number of authorized personnel. BlueVector AI’s authentication and authorization systems utilize SSH certificates and security keys, and are designed to provide BlueVector AI with secure and flexible access mechanisms. These mechanisms are designed to grant only approved access rights to site hosts, logs, data and configuration information. BlueVector AI requires the use of unique user IDs, strong passwords, two factor authentication and carefully monitored access lists to minimize the potential for unauthorized account use. The granting or modification of access rights is based on: the authorized personnel’s job responsibilities; job duty requirements necessary to perform authorized tasks; and a need to know basis. The granting or modification of access rights must also be in accordance with BlueVector AI’s internal data access policies and training. Approvals are managed by workflow tools that maintain audit records of all changes. Access to systems is logged to create an audit trail for accountability. Where passwords are employed for authentication (e.g., login to workstations), password policies that follow at least industry standard practices are implemented. These standards include restrictions on password reuse and sufficient password strength.
Access Control and Privilege Management. Customer’s administrators must authenticate themselves via a central authentication system or via a single sign on system in order to administer the Services.
Internal Data Access Processes and Policies – Access Policy. BlueVector AI’s internal data access processes and policies are designed to prevent unauthorized persons and/or systems from gaining access to systems used to process personal data. BlueVector AI designs its systems to:
only allow authorized persons to access data they are authorized to access; and
ensure that personal data cannot be read, copied, altered or removed without authorization during processing, use and after recording. The systems are designed to detect any inappropriate access. BlueVector AI employs a centralized access management system to control personnel access to production servers, and only provides access to a limited number of authorized personnel. BlueVector AI’s authentication and authorization systems utilize SSH certificates and security keys, and are designed to provide BlueVector AI with secure and flexible access mechanisms. These mechanisms are designed to grant only approved access rights to site hosts, logs, data and configuration information. BlueVector AI requires the use of unique user IDs, strong passwords, two factor authentication and carefully monitored access lists to minimize the potential for unauthorized account use. The granting or modification of access rights is based on: the authorized personnel’s job responsibilities; job duty requirements necessary to perform authorized tasks; and a need to know basis. The granting or modification of access rights must also be in accordance with BlueVector AI’s internal data access policies and training. Approvals are managed by workflow tools that maintain audit records of all changes. Access to systems is logged to create an audit trail for accountability. Where passwords are employed for authentication (e.g., login to workstations), password policies that follow at least industry standard practices are implemented. These standards include restrictions on password reuse and sufficient password strength.
Data
Data Storage, Isolation and Logging. BlueVector AI stores data in a multi-tenant environment on Google Cloud servers. BlueVector AI replicates Customer Data between multiple geographically dispersed data centers. BlueVector AI also logically isolates the Customer’s data. Customer will be given control over specific data sharing policies. Those policies, in accordance with the functionality of the Services, will enable Customer to determine the product sharing settings applicable to Customer End Users for specific purposes. Customer may choose to make use of logging functionality that BlueVector AI makes available via the Services.
Personnel Security BlueVector AI personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. BlueVector AI conducts reasonably appropriate backgrounds checks to the extent legally permissible and in accordance with applicable local labor law and statutory regulations. Personnel are required to execute a confidentiality agreement and must acknowledge receipt of, and compliance with, BlueVector AI’s confidentiality and privacy policies. Personnel are provided with security training. Personnel handling Customer Data are required to complete additional requirements appropriate to their role (e.g., certifications). BlueVector AI’s personnel will not process Customer Data without authorization.
Subprocessor Security Before onboarding Subprocessors, BlueVector AI conducts an audit of the security and privacy practices of Subprocessors to ensure Subprocessors provide a level of security and privacy appropriate to their access to data and the scope of the services they are engaged to provide. Once BlueVector AI has assessed the risks presented by the Subprocessor, then subject to the requirements described in Section 11.3 (Requirements for Subprocessor Engagement) of these Terms, the Subprocessor is required to enter into appropriate security, confidentiality and privacy contract terms.
