HILO Cloud Marketplace EULA

1. Applicability; Provision of the Service

1.1 Access and Use. During the Term and subject to this Agreement and the applicable Order, Customer may access and use the Service solely for Customer’s internal business purposes.

1.2 Registration and Account. Customer will provide complete and accurate information required to create or administer its account and will keep such information current. Customer is responsible for maintaining the confidentiality and security of its credentials and for activities carried out through its account. Customer will notify Vendor promptly if it becomes aware of unauthorised access to or use of the Service.

1.3 Support. Vendor will provide support for the Service in accordance with Vendor’s applicable support policy and the support level, if any, specified in the applicable Order. Support requests may be submitted to [email protected]. Any applicable support policy will be made available through the Listing or Documentation.

1.4 Service Levels. If an applicable service level agreement is identified in the Listing or Order, Vendor will provide the Service in accordance with that service level agreement. If no service level agreement is identified, no separate service level commitment applies.

1.5 Subscription Entitlements. The applicable Order defines Customer’s Subscription Entitlements, including the permitted number of Connections, Production Message Flows, included monthly message capacity and any other applicable service or capacity limits. A public Marketplace plan or a customer-specific Private Offer may define different Subscription Entitlements.

1.6 Use Above Subscription Entitlements. The Service is provided on a subscription basis and is not subject to automatic per-message or usage overage charges unless expressly stated in the applicable Order. Temporary or incidental exceedance of an included capacity does not itself create an additional payment obligation. If Customer’s requirements materially or persistently exceed the applicable Subscription Entitlements, Vendor may notify Customer and require migration to an appropriate plan or customer-specific Private Offer. Vendor will use reasonable efforts to avoid unnecessary interruption while such adjustment is discussed, except where continued excess use materially affects the security, integrity or availability of the Service. If Customer fails to agree to an appropriate adjustment within 30 days after Vendor’s written notice, Vendor may restrict the affected excess use or, where reasonably necessary, suspend the affected Service until appropriate Subscription Entitlements are agreed through Google Cloud Marketplace.

2. Customer Obligations

2.1 Restrictions. Customer will not, and will not allow any third party to: (a) use the Service in violation of applicable law; (b) use the Service to violate third-party rights; (c) resell, sublicense or make the Service available to third parties except as expressly permitted in an Order; (d) disable, circumvent or interfere with security or access controls; (e) use the Service for malicious activity or to compromise the security or integrity of any network, system or application; (f) reverse engineer, decompile or attempt to derive source code from the Service except to the limited extent such restriction is prohibited by applicable law; (g) modify, adapt or create derivative works of the Service except as expressly authorised by Vendor; or (h) process data through the Service where such processing is prohibited by the Documentation or applicable law.

2.2 Applicable Law. Each party will comply with laws and regulations applicable to its performance or use of the Service.

2.3 Enforcement. Vendor may investigate suspected misuse of the Service and may suspend access to the extent reasonably necessary to protect the Service, Customer Data, other customers or third parties, or to comply with law. Where reasonably practicable, Vendor will provide advance notice of a suspension and cooperate with Customer to restore access promptly after the relevant issue is resolved.

2.4 Responsibility for Customer Data. Customer is responsible for the legality, accuracy and completeness of Customer Data and represents that it has all rights and permissions necessary to provide Customer Data to Vendor for processing in connection with the Service.

2.5 Security Responsibilities. Customer is responsible for securing its own systems, devices, credentials and connections used to access or connect to the Service and for using the Service in accordance with Vendor’s documented security requirements.

3. Data Processing

3.1 Performance Data. Vendor may collect and analyse technical and operational information concerning use and performance of the Service that does not include Customer Data or Customer Personal Data (“Performance Data”). Vendor may use Performance Data for its legitimate business purposes, including service operation, security, capacity planning, improvement and creation of aggregated or anonymised statistics. Customer Data and Customer Personal Data are processed only as set out in this Agreement and the DPA.

3.2 Data Processing Addendum. Where Vendor processes Customer Personal Data on behalf of Customer, the Data Processing Addendum attached as Attachment 1 applies and is incorporated into this Agreement. If the parties enter into a separate written data processing agreement that expressly supersedes Attachment 1, that separate agreement will govern the relevant processing.

3.3 Security. Vendor will implement and maintain appropriate technical and organisational measures designed to protect Customer Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Customer Data, as further described in Attachment 1 and its Security Measures.

3.4 Use of Customer Data. Vendor will access and use Customer Data only as necessary to provide, support, secure and operate the Service, to comply with documented Customer instructions, or as required by applicable law.

3.5 Data Hosting. The primary Service environment and Customer Data backups are hosted within the European Union. Customer environments are operated on a dedicated, single-tenant basis. Certain ancillary Subprocessors may process Customer Personal Data outside the European Economic Area where permitted under applicable Data Protection Law and subject to an appropriate transfer mechanism.

4. Payment

4.1 Marketplace Payment. Customer’s payment obligations for the Service are governed by the applicable Google Cloud Marketplace transaction, including the applicable public plan or Private Offer. Customer may not use the Service if it fails to comply with applicable Marketplace payment obligations.

5. Confidential Information

5.1 Obligations. The recipient of Confidential Information will use it only to exercise rights and fulfil obligations under this Agreement and will protect it using at least reasonable care. The recipient may disclose Confidential Information only to its Affiliates, employees, contractors, agents and professional advisers who need to know it and are bound by confidentiality obligations at least as protective as those in this Agreement.

5.2 Required Disclosure. A recipient may disclose Confidential Information to the extent required by applicable law or valid legal process. Where legally permitted, the recipient will use commercially reasonable efforts to give the disclosing party advance notice and reasonable assistance in seeking protective treatment.

6. Intellectual Property

6.1 Ownership. Except for rights expressly granted under this Agreement, neither party receives any right, title or interest in the other party’s Intellectual Property Rights. As between the parties, Customer owns Customer Data and materials supplied by Customer, and Vendor owns the Service, Documentation and all Intellectual Property Rights in technology, software, ontologies, schemas, reusable mappings, validation logic and other materials developed or provided by Vendor in connection with the Service, excluding Customer Data and materials supplied by Customer.

6.2 Feedback. Customer may provide suggestions or feedback regarding the Service. Vendor and its Affiliates may use such feedback without restriction or obligation, provided that Vendor does not publicly identify Customer as the source without Customer’s permission.

7. Warranties and Disclaimers

7.1 Mutual Authority. Each party represents that it has full power and authority to enter into this Agreement and perform its obligations under it.

7.2 Vendor Performance Warranty. Vendor warrants that the Service will perform materially in accordance with the Documentation and that any Support provided by Vendor will be performed with reasonable skill and care consistent with generally accepted industry practice.

7.3 Remedies. If the Service materially fails to conform to Section 7.2, Vendor will use commercially reasonable efforts to correct the non-conformity. If Vendor does not correct a material non-conformity within a reasonable period after written notice, Customer may terminate the affected Service and receive a refund of prepaid fees attributable to the unused portion of the applicable subscription period, to the extent such refund can be processed under the applicable Marketplace arrangements.

7.4 Disclaimer. Except as expressly stated in this Agreement, and to the maximum extent permitted by applicable law, the Service and Support are provided “as is”. Vendor disclaims implied warranties, including merchantability, fitness for a particular purpose and non-infringement. Vendor does not warrant that the Service will be uninterrupted, error-free or suitable for any use not described in the Documentation.

8. Suspension and Termination

8.1 Termination for Material Breach. Either party may terminate this Agreement if the other party materially breaches it and fails to cure the breach within 30 days after receipt of written notice describing the breach. Either party may terminate immediately if the other party ceases ordinary business operations, becomes insolvent or is subject to bankruptcy, liquidation or comparable proceedings, to the extent permitted by applicable law.

8.2 Suspension or Termination by Vendor. Vendor may suspend or terminate Customer’s access immediately where reasonably necessary because of unlawful use, a material security risk, a serious violation of Section 2.1, or an obligation imposed by law. Vendor will provide advance notice where reasonably practicable and otherwise will notify Customer promptly after taking action.

8.3 Effect of Termination. Upon expiry or termination, Customer’s right to use the Service ends. During the Term and during any applicable post-termination retention period agreed with Customer, Customer may request a reasonable export of Customer Data through Vendor’s support channel. Vendor will delete Customer Data in accordance with the retention and deletion period agreed with Customer for the applicable Service, which may be set out in the applicable Order, Private Offer or other written agreement between the parties. Where no specific period has been agreed, Vendor will delete Customer Data within a commercially reasonable period, subject to any retention required by applicable law. Vendor is not required to retain Customer Data solely to enable an export beyond the applicable retention period. Residual copies in backups may remain until deleted through Vendor’s standard backup retention cycle, during which time they will remain protected and will not be processed except for recovery, security or legal purposes. Sections that by their nature should survive termination, including confidentiality, intellectual property, payment obligations, indemnification, limitation of liability and general provisions, will survive.

9. Indemnification

9.1 By Customer. Customer will defend and indemnify Vendor and its Affiliates against third-party claims, damages and costs finally awarded or agreed in settlement, to the extent arising from (a) Customer Data that infringes a third party’s rights; (b) Customer’s unlawful use of the Service; or (c) Customer’s material violation of Section 2.1.

9.2 By Vendor. Vendor will defend and indemnify Customer and its Affiliates against third-party claims, damages and costs finally awarded or agreed in settlement, to the extent arising solely from an unaffiliated third-party allegation that Customer’s authorised use of Vendor technology forming part of the Service infringes that third party’s Intellectual Property Rights.

9.3 Exclusions. A party’s indemnification obligation does not apply to the extent a claim results from (a) the indemnified party’s breach of this Agreement; (b) modifications not made or authorised by the indemnifying party; (c) combination with products, services or materials not supplied or approved by the indemnifying party where the claim would not otherwise have arisen; or (d) use outside the scope of the Documentation or applicable Order.

9.4 Infringement Remedies. If the Service becomes, or Vendor reasonably believes is likely to become, subject to an infringement claim, Vendor may at its option: (a) obtain the right for Customer to continue using the Service; (b) modify or replace the affected Service so that it is non-infringing without materially reducing core functionality; or (c) terminate the affected Service and refund prepaid fees attributable to the unused portion of the applicable subscription period, to the extent such refund can be processed under the applicable Marketplace arrangements.

9.5 Procedure. Indemnification is conditioned on the indemnified party providing prompt written notice of the claim, reasonable cooperation at the indemnifying party’s expense, and control of the defence and settlement to the indemnifying party. The indemnified party may participate with its own counsel at its own expense. No settlement may require the indemnified party to admit wrongdoing, pay amounts not covered by the indemnity, or accept ongoing obligations without its prior written consent, not to be unreasonably withheld.

10. Limitation of Liability

10.1 Excluded Damages. To the maximum extent permitted by applicable law, neither party will be liable to the other for indirect, consequential, special, incidental or punitive damages, or for loss of profits, revenues, savings, goodwill, anticipated business, or loss or corruption of data, arising out of or relating to this Agreement, even if advised of the possibility of such damages.

10.2 Aggregate Liability Cap. Except as stated in Section 10.3, each party’s total aggregate liability arising out of or relating to this Agreement, the Service, Support, the Data Processing Addendum, confidentiality obligations and indemnification obligations, whether in contract, tort (including negligence), statute or otherwise, will not exceed the fees paid or payable by Customer for the Service during the 12 months immediately preceding the event giving rise to the claim. If the event giving rise to liability occurs during the first 12 months of the Term, the cap will be calculated by reference to the fees paid or payable for the period from the Effective Date to the date of that event, unless applicable law requires otherwise.

10.3 Exceptions. Sections 10.1 and 10.2 do not limit or exclude liability for (a) fraud or fraudulent misrepresentation; (b) wilful misconduct or intentional wrongdoing; (c) death or personal injury to the extent liability cannot lawfully be limited; (d) Customer’s payment obligations; or (e) any other liability that cannot lawfully be limited or excluded under applicable law.

11. General

11.1 Notices. Notices under this Agreement must be in writing and sent to the other party’s legal or primary business contact. Notices to Vendor must be sent to [email protected] or to Hilo Semantics B.V., Pieter van der Doesstraat 67-2, 1056 VD Amsterdam, The Netherlands. Notice is effective on confirmed receipt or, for email, when delivery is evidenced by an electronic delivery record, unless the sender receives a failure notice.

11.2 Assignment. Neither party may assign this Agreement without the other party’s prior written consent, except to an Affiliate or in connection with a merger, reorganisation, sale of substantially all relevant assets or change of control, provided the assignee agrees to be bound by this Agreement. Any prohibited assignment is void.

11.3 Force Majeure. Neither party will be liable for delay or failure to perform caused by events beyond its reasonable control, except for payment obligations already due.

11.4 No Agency. This Agreement does not create an agency, partnership, joint venture or employment relationship between the parties.

11.5 No Waiver; Severability. Failure or delay in exercising a right is not a waiver. If any provision is held invalid or unenforceable, the remaining provisions remain in effect and the invalid provision will be interpreted or replaced to the minimum extent necessary to make it enforceable while preserving its intended effect.

11.6 No Third-Party Beneficiaries. Except for Affiliates entitled to the benefit of an indemnity or limitation expressly stated in this Agreement, this Agreement does not confer rights on third parties.

11.7 Export Control and Sanctions. Each party will comply with applicable export control and sanctions laws in connection with the Service. Customer will not use the Service in a manner that would cause Vendor to violate such laws.

11.8 Governing Law and Jurisdiction. This Agreement and any non-contractual obligations arising out of or in connection with it are governed by the laws of the Netherlands, without regard to conflict-of-laws principles. Subject to any mandatory jurisdiction requirements, the competent courts of Amsterdam, the Netherlands will have exclusive jurisdiction over disputes arising out of or relating to this Agreement. The United Nations Convention on Contracts for the International Sale of Goods does not apply.

11.9 Entire Agreement; Order of Precedence. This Agreement, the applicable Order and Attachment 1 constitute the entire agreement concerning the Service and supersede prior agreements concerning the same subject matter. The Documentation, applicable support policy and any service level agreement apply to the extent expressly referenced in this Agreement or the applicable Order. In case of conflict: (a) a customer-specific Private Offer or other Order term expressly stated to override this Agreement prevails for commercial entitlements and pricing; (b) Attachment 1 prevails for data processing matters; and (c) this Agreement prevails over the Documentation and general support materials.

11.10 Amendments. Any bilateral amendment to this Agreement must be in writing and agreed by authorised representatives of both parties. Vendor may update operational policies or Documentation that are incorporated by reference where the update does not materially reduce Customer’s contractual rights during the then-current subscription period.

11.11 Language. If this Agreement is translated, the English version governs in case of conflict unless the parties expressly agree otherwise in writing.

12. Definitions

“Account”

means the account or access credentials used by Customer to access or administer the Service.

“Affiliate”

means an entity that directly or indirectly controls, is controlled by, or is under common control with a party.

“Confidential Information”

means information disclosed by or on behalf of a party that is marked confidential or should reasonably be understood as confidential given its nature and the circumstances of disclosure. Customer Data is Customer Confidential Information. Confidential Information excludes information independently developed without use of the other party’s Confidential Information, lawfully received without confidentiality duty, or publicly available through no breach of this Agreement.

“Connection”

means a configured interface between two systems or endpoints through which data may be exchanged using the Service. For clarity, two Connections may connect three systems in a chain such as System A to HILO to System B.

“Customer Data”

means data, including message payloads and other information, submitted to or processed by the Service by or on behalf of Customer. Customer Data does not include Performance Data.

“Customer Personal Data”

means personal data contained in Customer Data and processed by Vendor on behalf of Customer.

“Data Protection Law”

means applicable laws relating to privacy, data protection and the processing of personal data, including the EU General Data Protection Regulation 2016/679 and applicable national implementing laws.

“Documentation”

means Vendor’s then-current technical documentation describing the material features and operation of the Service.

“Included Monthly Message Capacity”

means the number of messages included in the applicable subscription plan or Private Offer for a calendar or billing month, as specified in the applicable Order.

“Intellectual Property Rights”

means rights under patent, copyright, database right, trade secret, trademark and similar intellectual property laws.

“Listing”

means the Google Cloud Marketplace page that describes the Service.

“Marketplace”

means Google Cloud Marketplace.

“Order”

means Customer’s applicable procurement of the Service through Google Cloud Marketplace, including a public plan subscription or Private Offer, together with the applicable commercial terms and Subscription Entitlements.

“Production Message Flow”

means one message type transmitted in one direction between connected systems or endpoints.

“Service”

means the HILO interoperability service procured by Customer through Google Cloud Marketplace and identified in the Listing or applicable Order.

“Subprocessor”

means a third party engaged by Vendor that processes Customer Personal Data on behalf of Vendor in connection with the Service.

“Subscription Entitlements”

means the Connections, Production Message Flows, Included Monthly Message Capacity and other service or capacity limits specified in the applicable Order.

“Term”

means the applicable subscription term purchased for the Service, together with any renewal period, unless terminated earlier in accordance with this Agreement.

Attachment 1 — Data Processing Addendum

1. Scope and Application. This Data Processing Addendum (“DPA”) forms part of the Agreement and applies where and to the extent Vendor processes Customer Personal Data on behalf of Customer in connection with the Service. It does not apply to processing for which Vendor independently determines the purposes and means of processing.

2. Roles and Instructions

2.1 Roles. Where the GDPR applies, Customer is a controller or processor, as applicable, and Vendor is a processor or subprocessor, as applicable, with respect to Customer Personal Data.

2.2 Instructions. Customer instructs Vendor to process Customer Personal Data only as necessary to provide, support, secure and operate the Service; as configured or requested through Customer’s use of the Service; as documented in the Agreement and applicable Order; and as further documented in written instructions acknowledged by Vendor. Vendor will inform Customer if, in Vendor’s reasonable opinion, an instruction infringes applicable Data Protection Law, unless prohibited by law.

2.3 Compliance. Each party will comply with the obligations applicable to it under Data Protection Law. If Customer is a processor, Customer warrants that it is authorised by the relevant controller to appoint Vendor as a subprocessor.

3. Nature and Purpose of Processing

3.1 Processing Details. The subject matter, duration, nature and purpose of processing, categories of Customer Personal Data and categories of data subjects are described in Appendix 1 to this DPA and may be further specified in the applicable Order or Customer’s documented instructions.

4. Confidentiality and Personnel

4.1 Confidentiality. Vendor will ensure that persons authorised to process Customer Personal Data are subject to appropriate confidentiality obligations and are instructed to process Customer Personal Data only as necessary for their authorised role.

5. Data Retention, Deletion and Export

5.1 Message Payload Retention. Unless otherwise agreed with Customer, Customer message payloads that are successfully processed and transmitted through the Service are deleted promptly after successful delivery and are not retained as part of the normal operation of the Service. Vendor and Customer may agree different retention settings for message payloads where supported by the Service. Message payloads that cannot be successfully processed or delivered may be retained for troubleshooting, analysis and resolution for a retention period agreed with Customer for the applicable Service, after which they will be deleted, unless retention is required by applicable law. The applicable retention period may be set out in the applicable Order, Private Offer or other written agreement between the parties. Operational metadata and logs may be retained separately in accordance with Vendor’s applicable retention practices and need not include the full message payload.

5.2 Deletion on Request. Customer may request deletion of Customer Data by contacting Vendor at [email protected] or through the support channel at [email protected]. Vendor will carry out documented deletion requests in accordance with Customer’s instructions and applicable law. Where supported by the Service, the parties may agree an automated retention period for specified categories of Customer Data.

5.3 Export. During the Term and during any applicable post-termination retention period agreed with Customer, Customer may request a reasonable export of Customer Data. Export may be provided through a manual process and in a format reasonably selected by Vendor taking into account the nature of the data and the functionality of the Service.

5.4 Deletion on Termination. Upon expiry or termination of the Service, Vendor will delete Customer Data in accordance with the retention and deletion period agreed with Customer for the applicable Service. The applicable retention and deletion period may be set out in the applicable Order, Private Offer or other written agreement between the parties. Where no specific period has been agreed, Vendor will delete Customer Data within a commercially reasonable period, subject to any retention required by applicable law. Customer Data remaining in backup systems may persist until deleted through Vendor’s standard backup retention cycle, provided such data remains protected and is not further processed except for recovery, security or legal purposes.

6. Data Security

6.1 Security Measures. Vendor will implement and maintain appropriate technical and organisational measures designed to protect Customer Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Customer Personal Data. The current categories of measures are described in Appendix 2.

6.2 Security Incidents. Vendor maintains an incident response process designed to identify, assess, contain and remediate security incidents affecting Customer Data. Vendor will notify Customer without undue delay after becoming aware of a personal data breach affecting Customer Personal Data and will provide information reasonably available to Vendor regarding the nature and likely impact of the incident and the remediation measures taken or proposed.

6.3 Customer Responsibilities. Customer is responsible for the security of systems, devices, credentials and copies of Customer Data outside Vendor’s or its Subprocessors’ systems, including secure transmission to and from the Service where Customer controls the relevant endpoint or integration.

7. Assistance and Data Subject Rights

7.1 Assistance. Taking into account the nature of processing and information available to Vendor, Vendor will provide reasonable assistance to Customer with obligations under applicable Data Protection Law concerning security, personal data breaches, data protection impact assessments and consultations with supervisory authorities.

7.2 Data Subject Requests. If Vendor receives a data subject request relating to Customer Personal Data and can identify the relevant Customer, Vendor will refer the requester to Customer unless prohibited by law. On Customer’s documented instruction, Vendor will provide reasonable assistance with access, correction, restriction or deletion requests, which may be handled through Vendor’s support process rather than self-service functionality.

8. Audits and Compliance Information

8.1 Compliance Information. On reasonable request and subject to confidentiality and security restrictions, Vendor will make available information reasonably necessary to demonstrate compliance with its obligations under this DPA.

8.2 Audit. Where required by applicable Data Protection Law and the information provided under Section 8.1 is insufficient, Customer may request a reasonable audit of Vendor’s processing of Customer Personal Data. The parties will agree the scope, timing, confidentiality and security arrangements in advance. Audits will be conducted during normal business hours, in a manner that minimises disruption, and no more than once per 12-month period unless a supervisory authority requires otherwise or there is a material personal data breach reasonably justifying an additional audit. Customer will bear its own audit costs and Vendor’s reasonable costs to the extent permitted by applicable law.

9. Data Location and International Transfers

9.1 EU Hosting. Vendor hosts the primary Service environment and Customer Data backups within the European Union. Vendor may use Subprocessors that process Customer Personal Data outside the European Economic Area where permitted under applicable Data Protection Law.

9.2 Transfer Mechanisms. Where a transfer of Customer Personal Data outside the European Economic Area requires a transfer mechanism under applicable Data Protection Law, Vendor will ensure that an appropriate lawful mechanism is in place, such as an applicable adequacy decision, the European Commission’s Standard Contractual Clauses, or another valid transfer mechanism. Vendor will provide reasonable information about the applicable mechanism on request.

10. Subprocessors

10.1 Authorisation. Customer gives Vendor general written authorisation to engage Subprocessors to provide the Service. Vendor’s current Subprocessor list is available at https://hilosemantics.com/legal/subprocessors/.

10.2 Requirements. Vendor will impose data protection obligations on each Subprocessor that are appropriate to the nature of the services and no less protective in substance than Vendor’s relevant obligations under this DPA, as required by applicable Data Protection Law. Vendor remains responsible for the performance of its Subprocessors to the extent required by applicable law.

10.3 Changes. Vendor will provide at least 30 days’ prior notice before a new Subprocessor begins processing Customer Personal Data, for example by email to Customer’s designated contact or through another notification mechanism made available by Vendor. Customer may object during that period on reasonable data protection grounds. The parties will work in good faith to resolve the objection. If no reasonable solution is available, Customer may terminate the affected Service as its sole remedy in relation to the proposed Subprocessor, and Vendor will refund any prepaid fees attributable to the unused portion of the applicable subscription period, to the extent such refund can be processed under the applicable Marketplace arrangements.

11. Liability and Effect

11.1 Liability. Liability arising under or in connection with this DPA is subject to Section 10 of the Agreement, including the aggregate liability cap and its stated exceptions.

11.2 Priority. If this DPA conflicts with the remainder of the Agreement on matters concerning processing of Customer Personal Data, this DPA prevails to the extent of the conflict.

Appendix 1 — Subject Matter and Details of Processing

Appendix 2 — Security Measures

Vendor maintains security measures appropriate to the nature of the Service and the risks presented by the processing. The measures may evolve over time, provided the overall level of protection is not materially reduced during the Term. Current categories of measures include:

• Single-tenant customer environments designed to isolate Customer Data from other customers.
• Hosting of the primary Service environment and backups within the European Union.
• Encryption of Customer-facing communications in transit using industry-standard transport security and encryption of stored data using cloud-platform encryption controls.
• Private-network and perimeter security controls designed to limit unnecessary exposure of internal service components.
• Identity and access controls restricting production infrastructure access to authorised personnel based on role and need to know.
• Security, administrative and application logging appropriate to the Service, together with monitoring and alerting for material security events.
• Backup and recovery measures appropriate to the Service.
• An incident response process designed to identify, assess, contain and remediate security incidents affecting Customer Data.
• Confidentiality obligations applicable to personnel authorised to process Customer Data.
• Data retention and deletion practices designed to limit retention of message payloads and Customer Data to periods reasonably necessary for service delivery, troubleshooting, security and legal compliance.
• Risk-based assessment of Subprocessors that process Customer Personal Data and contractual data protection obligations appropriate to their role.