Data Processing Agreement
This Data Processing Agreement ("DPA") is an integral part of the master Terms and Conditions ("Agreement") between Zintlr and the Customer. Zintlr and the Customer shall hereafter be collectively referred to as the "Parties," and each individually as a "Party."
The Parties seek to implement this DPA to comply with the requirements of EU GDPR (defined hereunder) about the Processor’s processing of Personal Data (as defined under the EU GDPR) as part of its obligations under the Agreement.
This DPA supersedes and replaces any existing data processing terms between the Parties related to the processing of personal data. In case of any contradiction or conflict between the terms of this DPA and the Agreement, the terms of this DPA shall take precedence.
Definitions
For the purposes of this Data Processing Agreement ("DPA"), the following terms have the meanings set forth below. Capitalized terms used but not defined in this DPA shall have the meanings given in EU GDPR or the Agreement.
Agreement:
The contractual arrangement between Zintlr and the Customer, governing the Customer's subscription to the Services; here the Terms & Conditions Agreement between the Licensee and End-User and Zintlr.
Applicable Data Protection Laws:
The data protection laws and regulations applicable to the processing of Personal Data under this DPA, including the relevant U.S. Data Protection Law, EU Data Protection Laws, and Indian Data Protection Laws.
Controller:
The entity that determines how and why personal data is processed and holds the ultimate responsibility for data protection; in this case, the Licensee and End-user of Zintlr.
Customer:
The entity or individual that has entered into the Agreement with Zintlr for the provision of services; here Zintlr’s Licensee and End-user.
Data Exporter:
The data exporter is typically the party that transfers personal data to another party for processing. They are the entity that holds the responsibility for the personal data and determines the purposes and means of its processing. In the context of Zintlr, the data exporter would be Zintlr itself, as it transfers personal data to a third-party data processor or service provider for processing.
Data Importer:
The data importer is the party that receives and processes the personal data on behalf of the data exporter. They act as a data processor and handle personal data according to the instructions provided by the data exporter. In the context of Zintlr, the data importer could be a third-party service provider or subprocessor that assists Zintlr in processing the personal data collected through its services.
Data Subject:
an identified or identifiable natural person whose personal data is being processed.
Data Transfer:
a transfer of the Personal Data from the Controller to the Processor, or between two establishments of the Processor, or with a Sub-processor by the Processor.
EU GDPR:
the 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 (General Data Protection Regulation).
Personal Data:
information that can be linked to an individual and helps to identify or distinguish them from others.
Processing
(and "Process"): any operation or action that is taken with personal data, ranging from its collection to its eventual deletion or destruction.
Processor:
a party that processes personal data on behalf of the controller, following their instructions and under their authority; here Zintlr Private Limited.
Services:
the provision of the Zintlr Platform (and any other hosted solutions or cloud products) by Zintlr to the Customer as specified in the Agreement.
Standard Contractual Clauses:
the contractual clauses attached hereto as Schedule 1 pursuant to the European Commission’s Implementing Decision (EU) 2021/914 of 4 June 2021 on Standard Contractual Clauses for the transfer of Personal Data to processors established in third countries which do not ensure an adequate level of data protection.
Sub-processor:
a processor/ sub-contractor appointed by the Processor for the provision of all or parts of the Services and Processes the Personal Data as provided by the Controller.
Supervisory Authority:
an independent public authority responsible for monitoring and enforcing the application of the data protection laws within its jurisdiction.
Scope
Sections 3 to 8 of this DPA are applicable if and to the extent that Zintlr acts as a Data Processor for processing Personal Data received from the Customer, where the Customer is a Data Controller subject to: (a) GDPR; (b) the GDPR as it forms part of the laws of the United Kingdom ("UK") as retained EU law, including the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 and any further UK laws addressing data transfers from the UK (collectively referred to as "UK GDPR") concerning the Personal Data processed by Zintlr; and (c) IT ACT 2000 as part of the Indian data protection laws.
Section 9 of this DPA applies only if and to the extent that Zintlr acts as a "service provider" for processing Personal Information received from the Customer, where the Customer is a Business subject to the CCPA.
Standard Contractual Clauses
These Standard Contractual Clauses ("SCCs") form an integral part of the agreement between the Data Exporter and the Data Importer. These SCCs apply to the transfer of personal data from the Data Exporter to the Data Importer, in compliance with the GDPR, CCPA, and the Information Technology Act 2000.
Obligations of the Parties
The Data Importer shall inform the Data Exporter in writing of any intended changes to its list of sub-processors at least 10 days in advance. The Data Exporter shall have the right to object to such changes, and if legitimate objections are raised, the Data Importer shall either refrain from using the objected sub-processor or provide notice of its intention to continue using the sub-processor. The Data Exporter may terminate the agreement by providing written notice if it chooses to do so.
The Parties agree that any legal disputes or proceedings arising from the Standard Contractual Clauses (SCCs) will be handled by the courts of Bangalore.
The Parties agree that the laws of Bengaluru courts, India shall prevail, irrespective of the location where the Data Exporter is established.
Description of Transfer
Data Exporter: Customer
Activities: Organization using Zintlr's services involving the processing of personal data received from the Customer.
Role: Controller.
Data Importer: Zintlr Inc.
Activities: Developer, operator, and provider of Zintlr's services involving the processing of personal data received from the Customer.
Role: Processor.
Description of Transfer
Categories of data subjects: Business professionals and Companies
Categories of personal data transferred: Name, contact information, employment information, online identifiers, and geographic information.
Sensitive data transferred: None.
Frequency of the transfer: Continuous basis.
Nature of the processing: Recording, storage, consultation, use, disclosure by transmission, and erasure.
Purpose(s) of the data transfer and further processing: Provision of Zintlr's services.
Period for which the personal data will be retained: The period of the agreement. Zintlr may retain personal data on an aggregated basis or after removing personally identifiable attributes for statistical, and financial purposes, and as required by the IT Act 2000.
Technical and Organizational Measures
Please refer to Section 7 below for the technical and organizational measures implemented by Zintlr to ensure the security of the transferred data.
Assistance Fees
If Zintlr's assistance to the Customer under these SCCs entails material costs, expenses, or resources, the Parties shall discuss and agree upon the fees payable to Zintlr for such assistance.
Data Controller’s Obligations
The Data Controller shall warrant that it has all necessary rights to provide the Personal Data to the Data Processor for the Processing to be performed in relation to the agreed services. To the extent required by Data Privacy Laws, Data Controller is responsible for ensuring that it provides such Personal Data to Data Processor based on an appropriate legal basis allowing lawful processing activities, including any necessary Data Subject consents to this Processing are obtained, and for ensuring that a record of such consents is maintained. Should such consent be revoked by the Data Subject, the Data Controller is responsible for communicating the fact of such revocation to the Data Processor.
The Data Controller shall provide all natural persons from whom it collects Personal Data with the relevant privacy notice.
The Data Controller shall request the Data Processor to purge Personal Data when required by the Data Controller or any Data Subject whom it collects Personal Data unless the Data Processor is otherwise required to retain the Personal Data by applicable law.
The Data Controller shall immediately advise the Data Processor in writing if it receives or learns of any:
Complaint or allegation indicating a violation of Data Privacy Laws regarding Personal Data;
Request from one or more individuals seeking to access, correct, or delete Personal Data;
Inquiry or complaint from one or more individuals relating to the collection, processing, use, or transfer of Personal Data; and
Any regulatory request, search warrant, or other legal, regulatory, administrative, or governmental process seeking Personal Data.
Data Processor’s Obligations
The Processor will follow written and documented instructions received, including email, from the Controller, its affiliate, agents, or personnel, with respect to the Processing of Personal Data (each, an “Instruction”).
The Processing described in the Agreement and the related documentation shall be considered as Instruction from the Controller.
At the Data Controller’s request, the Data Processor will provide reasonable assistance to the Data Controller in responding to/ complying with requests/ directions by the Data Subject in exercising their rights or of the applicable regulatory authorities regarding the Data Processor’s Processing of Personal Data.
In relation to the Personal Data, the Data Processor shall obtain consent (where necessary) and/or provide notice to the Data Subject in accordance with Data Protection Laws to enable shared Personal Data to be provided to, and used by, the other Party as contemplated by this Agreement.
Where shared Personal Data is transferred outside the Data Processor’s territorial boundaries, the transferor shall ensure that the recipient of such data is under contractual obligations to protect such Personal Data to the same or higher standards as those imposed under this Addendum and the Data Protection Laws.
Audits
Upon Controller’s reasonable request, the Processor will make available to the Controller, information as is reasonably necessary to demonstrate Processor’s compliance with its obligations under the EU GDPR or other applicable laws in respect of its Processing of the Personal Data.
When the Controller wishes to conduct the audit (by itself or through a representative) at Processor’s site, it shall provide at least thirty (30) days’ prior written notice to the Processor; the Processor will provide reasonable cooperation and assistance in relation to audits, including inspections, conducted by the Controller or its representative.
The Controller shall bear the expense of such an audit.
Data Secrecy
To Process the Personal Data, the Processor will use personnel who are
Informed of the confidential nature of the Personal Data, and
Perform the Services in accordance with the Agreement.
The Processor will regularly train individuals having access to Personal Data in data security and data privacy in accordance with accepted industry practice and shall ensure that all the Personal Data is kept strictly confidential.
The Processor will maintain appropriate technical and organizational measures for protection of the security, confidentiality, and integrity of the Personal Data as per the specifications as per the standards mutually agreed in writing by the Parties.
Mechanism of Data Transfers
Any Data Transfer for the purpose of Processing by the Processor in a country outside the European Economic Area (the “EEA”) shall only take place in compliance as detailed in Schedule 1 to the DPA. Where such model clauses have not been executed at the same time as this DPA, the Processor shall not unduly withhold the execution of such template model clauses, where the transfer of Personal Data outside of the EEA is required for the performance of the Agreement.
Sub-processors
The Controller acknowledges and agrees that the Processor, may engage a third-party Sub-processor(s) in connection with the performance of the Services, provided such Sub-processor(s) take technical and organizational measures to ensure confidentiality of Personal Data shared with them; The current Sub-processors engaged by the Processors and approved by the Controller are listed in Annex III of Schedule 1 hereto. In accordance with Article 28(4) of the GDPR, the Processor shall remain liable to Controller for any failure on behalf of a Sub-processor to fulfil its data protection obligations under the DPA in connection with the performance of the Services.
If the Controller has a concern that the Sub-processor(s) Processing of Personal Data is reasonably likely to cause the Controller to breach its data protection obligations under the GDPR, the Controller may object to Processor’s use of such Sub-processor and the Processor and Controller shall confer in good faith to address such concern.
Personal Data Breach Notification
The Processor shall maintain defined procedures in case of a Personal Data Breach (as defined under the GDPR) and shall without undue delay notify Controller if it becomes aware of any Personal Data Breach unless such Data Breach is unlikely to result in a risk to the rights and freedoms of natural persons.
The Processor shall provide the Controller with all reasonable assistance to comply with the notification of Personal Data Breach to Supervisory Authority and/or the Data Subject, to identify the cause of such Data Breach and take such commercially reasonable steps as reasonably required to mitigate and remedy such Data Breach.
No Acknowledgement of Fault by Processor. Processor’s notification of or response to a Personal Data Breach under this DPA will not be construed as an acknowledgement by Processor of any fault or liability with respect to the data incident.
Return and Deletion of Personal Data
The Processor shall at least thirty (30) days from the end of the Agreement or cessation of the Processor’s Services under the Agreement, whichever occurs earlier, shall return to the Controller all the Personal Data, or if the Controller so instructs, the Processor shall have the Personal Data deleted. The Processor shall return such Personal Data in a commonly used format or in the current format in which it was stored at discretion of the Controller, soon as reasonably practicable following receipt of Controller’s notification.
In any case, the Processor shall delete Personal Data including all the copies of it as soon as reasonably practicable following the end of the Agreement.
Technical and Organizational Measures
Having regard to the state of technological development and the cost of implementing any measures, the Processor will take appropriate technical and organizational measures against the unauthorized or unlawful processing of Personal Data and against the accidental loss or destruction of, or damage to, Personal Data to ensure a level of security appropriate to: (a) the harm that might result from unauthorized or unlawful processing or accidental loss, destruction or damage; and (b) the nature of the data to be protected [including the measures stated in Annex II of Schedule 1].
Legal Basis
The Customer shall ensure that all Personal Data processed through the Zintlr Service is done so in accordance with a valid and recognized lawful basis as required by the GDPR, CCPA, and the IT Act 2000. The Customer is responsible for providing Zintlr with lawful instructions that comply with the provisions of these regulations and do not impose any obligation on Zintlr that would result in a breach of the GDPR, CCPA, or the IT Act 2000.
Additional Safeguards
Zintlr acknowledges and assures the implementation and maintenance of a comprehensive procedure to review and respond to any requests, orders, or demands from non-EEA and non-Indian government authorities or regulatory bodies (including law enforcement or intelligence agencies) seeking access to or disclosure of personal data ("Government Authority Requests"). This procedure includes the following commitments by Zintlr:
Promptly notifying the Customer in writing, within the bounds of applicable law, upon receipt of a Government Authority Request, enabling the Customer to contest, limit, or seek appropriate legal remedies. Zintlr will make reasonable efforts to redirect the requesting authority to obtain the requested personal data directly from the Customer, where permitted by applicable law.
Providing reasonable assistance as required by the Customer in responding to the Government Authority Request, subject to applicable law.
Promptly notifying the Data Subject (if their identity is known) of the Government Authority Request, in compliance with applicable law.
If prohibited by applicable law from notifying the Customer, making reasonable efforts to obtain permission to allow the Customer to intervene in the proceedings, assess the validity and lawfulness of the Government Authority Request, and challenge any request that is not legally binding or lawful. No information will be disclosed until a competent court has issued an unchallengeable legal order.
If contesting or seeking limitations on the Government Authority Request is unsuccessful, taking reasonable steps to ensure that any disclosed personal data or granted access is proportionate and limited to the minimum necessary to comply with the Government Authority Request.
Promptly informing the Customer if any Government Authority Request or subsequent actions prevent Zintlr from complying with the obligations outlined in this agreement or the Customer's instructions.
Zintlr commits to maintaining written records, to the extent permitted by applicable law, that includes details of the authority making the Government Authority Request, the number of requests received, Zintlr's response to each request, the types of personal data provided, and the number of data subjects affected. Upon request, and subject to applicable law, Zintlr will provide aggregated information from these records to the Customer.
Security Measures
Security Measures in this section refer to reasonable and appropriate security-related policies, standards, and practices implemented by Zintlr. These measures are based on the size and complexity of Zintlr's business, the sensitivity of the collected data, and the nature of its operations.
Zintlr guarantees and commits to implementing Security Measures to safeguard the availability, confidentiality, and integrity of any Personal Data collected, accessed, or processed in connection with this agreement. These measures aim to prevent Personal Data Breach incidents and are detailed in Schedule 2 (Technical and Organizational Security Measures).
The Security Measures may be subject to updates and modifications by Zintlr to reflect technological advancements and industry developments. However, such changes will not compromise the overall security of the services provided to the Customer.
Zintlr will take reasonable measures to ensure the trustworthiness of its staff and any individuals under its supervision who have access to and process Personal Data. Zintlr will ensure that authorized personnel handling Personal Data have committed to maintaining the confidentiality or are bound by relevant legal obligations of confidentiality.
CCPA
As a Service Provider, Zintlr is strictly prohibited from retaining, using, or disclosing the Customer's Personal Information for purposes other than those defined in the Agreement. Zintlr's permitted use of Personal Information is limited to searching the Zintlr database for information about a Contact as requested by the Customer, or as otherwise allowed under applicable regulations.
Zintlr is explicitly prohibited from Selling Customer's Personal Information or using or disclosing it outside of the direct business relationship between the Parties, except as permitted under the relevant provisions of the IT Act 2000. Zintlr acknowledges and understands this restriction, and commits to comply with it in all aspects of its operations.
Changes
Zintlr reserves the right to modify this Data Protection Agreement (DPA) if necessary to comply with Data Protection Laws, court orders, or guidance provided by governmental regulators or agencies. However, any changes made by Zintlr shall not:
alter the classification of Zintlr as the Data Processor;
expand the scope of either Party's rights to process Personal Data or remove any existing restrictions; or
have a significant adverse impact on the Customer, as reasonably determined by Zintlr.
In the event that Zintlr intends to make changes to this DPA under this provision, and such changes are expected to have a material adverse impact on the Customer, as reasonably determined by Zintlr, Zintlr will make commercially reasonable efforts to notify the Customer at least 30 days in advance. In certain cases, where compliance with applicable laws, regulations, court orders, or guidance from governmental regulators or agencies necessitates a shorter notice period, Zintlr will adhere to the required timeframe before implementing the changes.
SCHEDULE 1
ANNEX I
A. LIST OF PARTIES
Data exporter(s):
Name: Customer (as defined in Agreement) Address: As set forth in the relevant Order Form. Contact person’s name, position, and contact details: As set forth in the relevant Order Form. Activities relevant to the data transferred under these Clauses: Recipient of the Services provided by Scrut Automation in accordance with the Agreement. Signature and date Signature and date are set out in the Agreement. Role (Controller/ Processor): Controller Data importer(s):
Name: Zintlr Private Limited Address: 3rd Floor, No. 38, GKR Vaishtadhama, 12th Cross, CBI Rd., Ganganagar, Bengaluru - 32 Contact person’s name, position, and contact details: Pranay Khariwal, [email protected] Activities relevant to the data transferred under these Clauses: Provision of the Services to the Customer in accordance with the Agreement. Signature and date Signature and date are set out in the Agreement. Role (Controller/ Processor): Processor B. DESCRIPTION OF TRANSFER
Categories of data subjects whose personal data is transferred Customer’s authorized users of the Services Categories of personal data transferred Processed automatically by the Services:
- Names
- Email IDs
Processed where and to the extent provided by Customer or its authorized users in connection with audit services provided by Scrut.
Automation:
- Address
- Date of birth
- Past employment details
Sensitive personal data transferred None Frequency of the transfer Continuous Nature of the processing The nature of the processing is more fully described in the Agreement and accompanying order forms but will include the following basic processing activities: The provision of Services to Customer. In order to provide people data, Scrut Automation receives identifying Customer Personal Data to permit Scrut Automation to query, cleanse, standardize, enrich, (when required) send to additional data to feed providers, and to store the query information. Purpose(s) of the data transfer and further processing The purpose of the transfer is to facilitate the performance of the Services more fully described in the Agreement and accompanying order forms. Period for which the personal data will be retained or criteria used to determine that period The period for which the Customer's Personal Data will be retained is more fully described in the Agreement, Addendum, and accompanying order forms. Subprocessor transfers – subject matter, nature, and duration of processing The subject matter, nature, and duration of the Processing more fully described in the Agreement, Addendum, and accompanying order forms. C. COMPETENT SUPERVISORY AUTHORITY
Identify the competent supervisory authority/ies in accordance (e.g. in accordance with Clause 13 SCCs) As determined by application of Clause 13 of the EU SCCs. ANNEX II
TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA
Description of the technical and organizational security measures implemented by Zintlr Private Limited as the data processor/data importer to ensure an appropriate level of security, taking into account the nature, scope, context, and purpose of the processing, and the risks for the rights and freedoms of natural persons.
Security
Security Management System:
Organization:
Zintlr Private Limited designates qualified security personnel whose responsibilities include development, implementation, and ongoing maintenance of the Information Security Program.
Policies:
Management reviews and supports all security related policies to ensure the security, availability, integrity and confidentiality of Customer Personal Data. These policies are updated at least once annually.
Assessments:
Zintlr Private Limited engages a reputable independent third-party to perform risk assessments of all systems containing Customer Personal Data at least once annually.
Risk Treatment:
Zintlr Private Limited maintains a formal and effective risk treatment program that includes penetration testing, vulnerability management and patch management to identify and protect against potential threats to the security, integrity or confidentiality of Customer Personal Data.
Vendor Management:
Zintlr Private Limited maintains an effective vendor management program.
Incident Management:
Zintlr Private Limited reviews security incidents regularly, including effective determination of root cause and corrective action.
Standards:
Zintlr Private Limited operates an information security management system that complies with the requirements of ISO/IEC 27001:2022 standard.
Personnel Security:
Zintlr Private Limited personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. Zintlr Private Limited conducts reasonably appropriate background checks on any employees who will have access to client data under this Agreement, including in relation to employment history and criminal records, to the extent legally permissible and in accordance with applicable local labor law, customary practice and statutory regulations.
Personnel are required to execute a confidentiality agreement in writing at the time of hire and to protect Customer Personal Data at all times. Personnel must acknowledge receipt of, and compliance with, Zintlr Private Limited’s confidentiality, privacy and security policies. Personnel are provided with privacy and security training on how to implement and comply with the Information Security Program. Personnel handling Customer Personal Data are required to complete additional requirements appropriate to their role (e.g., certifications). Zintlr Private Limited’s personnel will not process Customer Personal Data without authorization.
Access Controls:
Access Management:
Zintlr Private Limited maintains a formal access management process for the request, review, approval and provisioning of all personnel with access to Customer Personal Data to limit access to Customer Personal Data and systems storing, accessing or transmitting Customer Personal Data to properly authorized persons having a need for such access. Access reviews are conducted periodically to ensure that only those personnel with access to Customer Personal Data still require it.
Infrastructure Security Personnel:
Zintlr Private Limited has, and maintains, a security policy for its personnel, and requires security training as part of the training package for its personnel. Zintlr Private Limited’s infrastructure security personnel are responsible for the ongoing monitoring of Zintlr Private Limited’s security infrastructure, the review of the Services, and for responding to security incidents.
Access Control and Privilege Management:
Zintlr Private Limited’s and Customer’s administrators and end users must authenticate themselves via a Multi-Factor authentication system or via a single sign on system in order to use the Services.
Internal Data Access Processes and Policies – Access Policy:
Zintlr Private Limited’s internal data access processes and policies are designed to protect against unauthorized access, use, disclosure, alteration or destruction of Customer Personal Data. Zintlr Private Limited designs its systems to only allow authorized persons to access data they are authorized to access based on principles of “least privileged” and “need to know”, and to prevent others who should not have access from obtaining access. Zintlr Private Limited 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; a need to know basis; and must be in accordance with Zintlr Private Limited’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 follow industry standard practices. These standards include password complexity, password expiry, password lockout, restrictions on password reuse and re-prompt for password after a period of inactivity.
Data Center:
Infrastructure:
Zintlr Private Limited has GCP as its data center.
Resiliency:
Multi Availability Zones are enabled on GCP and Zintlr Private Limited conducts Backup Restoration Testing on regular basis to ensure resiliency.
Server Operating Systems:
Zintlr Private Limited’s servers are customized for the application environment and the servers have been hardened for the security of the Services. Zintlr Private Limited 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.
Disaster Recovery:
Zintlr Private Limited replicates data over multiple systems to help to protect against accidental destruction or loss. Zintlr Private Limited has designed and regularly plans and tests its disaster recovery programs.
Security Logs:
Zintlr Private Limited’s systems have logging enabled to their respective system log facility in order to support the security audits, and monitor and detect actual and attempted attacks on, or intrusions into, Zintlr Private Limited’s systems.
Vulnerability Management:
Zintlr Private Limited performs regular vulnerability scans on all infrastructure components of its production and development environment. Vulnerabilities are remediated on a risk basis, with Critical, High and Medium security patches for all components installed as soon as commercially possible.
Networks and Transmission:
Data Transmission:
Transmissions on production environment are transmitted via Internet standard protocols.
External Attack Surface:
GCP Security Group which is equivalent to virtual firewall is in place for Production environment on GCP.
Incident Response:
Zintlr Private Limited maintains incident management policies and procedures, including detailed security incident escalation procedures. Zintlr Private Limited monitors a variety of communication channels for security incidents, and Zintlr Private Limited security personnel will react promptly to suspected or known incidents, mitigate harmful effects of such security incidents, and document such security incidents and their outcomes.
Encryption Technologies
Zintlr Private Limited makes HTTPS encryption (also referred to as SSL or TLS) available for data in transit.
Networks and Transmission:
Data Transmission:
Transmissions on production environment are transmitted via Internet standard protocols.
External Attack Surface:
GCP Security Group which is equivalent to virtual firewall is in place for Production environment on GCP.
Incident Response:
Zintlr Private Limited maintains incident management policies and procedures, including detailed security incident escalation procedures. Zintlr Private Limited monitors a variety of communication channels for security incidents, and Zintlr Private Limited security personnel will react promptly to suspected or known incidents, mitigate harmful effects of such security incidents, and document such security incidents and their outcomes.
Encryption Technologies
Zintlr Private Limited makes HTTPS encryption (also referred to as SSL or TLS) available for data in transit.
Data Storage, Isolation, Authentication, and Destruction:
Zintlr Private Limited stores data in a multi-tenant environment on GCP servers. Data, the Services database and file system architecture are replicated between multiple availability zones on GCP. Zintlr Private Limited logically isolates the data of different customers. A central authentication system is used across all Services to increase uniform security of data. Zintlr Private Limited ensures secure disposal of Client Data through the use of a series of data destruction processes.
ANNEX III
LIST OF SUB-PROCESSORS
The controller has authorized the use of the following sub-processors:
Name of Sub-Processor Description of Processing Location of Sub-Processor Stripe Payment Gateway USA Razorpay Payment Gateway India Stripe Payment Gateway USA Microsoft Clarity Product analytics USA Google Analytics Product analytics USA MixPanel Product analytics USA Hubspot CRM solution USA Google Ads Advertisements USA Facebook Pixel Advertisements USA Google Tag manager Insights USA Partenero Affiliate Commission Tracking Switzerland Google recaptcha Risk Analysis USA Cloudflare Risk Analysis USA Google Firebase User Authentication USA Brevo Email Services USA Gmail Email Services USA