August 15, 2018
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, PayPerse shall maintain appropriate technical and organizational measures for the Service to ensure a level of security appropriate to that risk, including, the measures described in this Appendix (the "Security Measures"). PayPerse may update or modify the Security Measures from time to time provided that such updates and modifications do not result in the degradation of the overall security of the Service.
“Customer Data” means electronic data and content provided to PayPerse by Customer (or at its direction) via the Service.
“Service” means the PayPerse proprietary big data service platform specified in the applicable order.
“Security Incident” means any unauthorized access to the Service that results in unauthorized transmission, copy, disclosure, alteration or loss of Customer Data.
PayPerse will maintain an information security program (including the adoption and enforcement of internal policies and procedures), designed to (a) satisfy these Security Measures, (b) identify reasonably foreseeable and internal security risks and unauthorized access to the Service, and (c) minimize security risks, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
(a) Data Center Security.
(b) Logical and Data Access Controls.
(a) Data Transmission. PayPerse makes HTTPS encryption (also referred to as SSL/TLS connection) available for data in motion. Clear text HTTP connections to the Service are disabled by default.
(b) Intrusion Detection. Intrusion detection is intended to provide insight into ongoing attack activities and provide adequate information to respond to incidents. PayPerse intrusion detection involves:
(a) Software Development. All development for the Service is based on Secure Development Lifecycle (SDLC) model.
(b) Standards Compliance. PayPerse follows OWASP Top 10 best practices and Cloud Security Alliance (CSA) standards.
(a) Redundancy. Infrastructure systems are designed to eliminate single points of failure and minimize the impact of anticipated environmental risks. Dual circuits, switches, networks and other necessary components help provide this redundancy.
(b) Server Operating Systems. PayPerse servers use a Linux based implementation customized for the application environment. Industry best practice hardening standards are used. Data in the production environment is stored using proprietary algorithms to augment data security and redundancy.
(c) Businesses Continuity. PayPerse replicates data over multiple systems and locations to help protect against accidental destruction or loss of data in the Service. PayPerse backs up the Service at least on a daily basis to a separate geographic location from the production servers for the Service. PayPerse has designed and regularly plans and tests its business continuity planning/disaster recovery programs.
(a) Data Storage and Isolation. PayPerse stores Customer Data in a multi-tenant environment on public cloud servers. PayPerse also logically isolates Customer Data in the Service. PayPerse conducts tests on a regular basis to confirm logical isolation.
(b) Data Deletion. After 90 days following termination of Customer’s contract for the Service, PayPerse will delete all Customer Data in the production servers of the Service. In addition, certain Customer Data will be deleted on an ongoing basis in accordance with the PayPerse data retention schedule.
(c) Location. Data centers used for the Service are located in the each country where the Service is serviced, and all Customer Data is stored in the Data centers of each country. By using the Service, Customer consents to storage of Customer Data in the Data centers of each country, which may include transfer of Customer Data to the Data centers of each country.
If PayPerse becomes aware of a Security Incident, PayPerse will notify Customer without undue delay of the Security Incident, and take reasonable steps to minimize harm and secure Customer Data. Notification(s) of any Security Incident will be delivered to the email address provided by Customer in the Agreement or in the admin console of the Service. Customer acknowledges that it is solely responsible for ensuring that the contact information set forth in the Agreement (or in the admin console of the Service) is current and valid. Customer agrees that “Security Incidents” do not include: (i) unsuccessful access attempts or similar events that do not compromise the security or privacy of Customer Data, including pings, port scans, denial of service attacks, and other network attacks on firewalls or networked systems; or (ii) accidental loss or disclosure of Customer Data caused by Customer’s use of the Service or Customer’s loss of account authentication credentials.
(a) Background Checks. PayPerse conducts appropriate backgrounds checks to the extent legally permissible and in accordance with applicable local labor law and statutory regulations.
(b) Employee Training. PayPerse employees are required to (a) execute a confidentiality agreement; (b) undergo annual security training, and (c) if handling Customer Data, complete additional requirements appropriate to their role.
(c) Employee Code of Conduct. PayPerse employees are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards.
PayPerse employs Privacy by Design and Privacy by Default principles in its development and operations processes.
(a) Subprocessor Security. Prior to onboarding subprocessors, PayPerse conducts a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of subprocessors to assess that 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. Subprocessors are re-authorized upon contract renewal or on an annual basis.
(b) Subprocessor List. List of subprocessors will be provides when it is available.