1.Identity of AreaBFE
Our customers may submit inquiries regarding personal data protection, privacy and security matters to CEO Richard Berger, AreaBFE, firstname.lastname@example.org.
2. What information do we collect?
You may visit our site anonymously.
If you choose to fill out a form on our website, four categories of data to and on behalf of you will be processed:
When you register for an account on our site, i.e. fill out a form or contact us, basic contact details are collected such as the e-mail address and name of your contact person, phone number, etc.
“Configuration data” We collect your direct input to our cloud service (the “Service”) after form submission, like your name, company, email, phone etc. (“end user data”).
“System Generated Data” The Service automatically creates and stores meta data on basis of the other types of data, e.g.: You will be informed by AreaBFE about relevant changes concerning the Service, such as the implementation of additional functions, by e-mail, if you subscribe to AreaBFE’s newsletter.
3. What do we use your information for?
Any of the information we collect from you may be used for one or more of the following purposes:
3.1.To personalize your experience (the information will help AreaBFE better respond to your individual needs);
3.2.To enable you to control the user experience towards End Users and enable the Service to automatically apply the End User’s consent to other websites of yours;
3.3.To improve our website (AreaBFE continually strives to improve our website offerings based on the information and feedback we receive from our customers);
3.4.To identify you as a contracting party;
3.5.To establish a primary channel of communication with you;
3.6.To enable automated handling of the subscriptions;
3.7.To produce and display cookie declarations to End Users and store and display scan report(s) to you;
3.8.To provide you with aggregated information on the choices of the End Users regarding accepted cookie types and generate a graphical representation in the Service Manager; and/or 3.11.To send periodic e-mails (The e-mail address you provide when filling out a form, may be used to send you information and updates pertaining to your inquiry, in addition to receiving occasional company news (if accepted), updates, related product or service information, etc.)
If at any time you would like to unsubscribe from receiving future e-mails, you can cancel your account after login by clicking on “Cancel my account”
4. Legal basis
4.1. EU General Data Protection Regulation (GDPR)
The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, cf. GDPR art. 6(1)(a)-(b).
If the processing is based on your consent, you may at any time withdraw your consent by contacting us using the contact information in clause 1.
4.2. California Online Privacy Protection Act Compliance
Because AreaBFE values your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute any personal information to outside parties without your consent except as stated in clause 7.
As part of the California Online Privacy Protection Act, all users of our website may make any changes to their information at any time by logging into their account and navigating to the “profile page”.
4.3. Children’s Online Privacy Protection Act Compliance
AreaBFE is in compliance with the requirements of the Children’s Online Privacy Protection Act. We will not intentionally collect any information from anyone under 13 years of age. Our website, products and services are all directed at people who are at least 13 years old or older.
5. How do we protect your information?
AreaBFE implements the following technical, physical and organizational measures to maintain the safety of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized use, unauthorized modification, disclosure or access and against all other unlawful forms of processing.
The Service utilizes the extensive features of the cloud environment to ensure high availability, like full redundancy, load balancing, automatic capacity scaling, continuous data backup and geo-replication along with a traffic manager for automatic geographical failover on datacenter level disasters. All failover mechanisms are fully automated.
No personal data is stored permanently outside AreaBFE’s cloud platforms. The physical security is thereby maintained by AreaBFE’s subcontractors, see clause 7. Microsoft’s datacenters comply with industry standards such as ISO 27001 for physical security and availability, e.g. by using security staff around the clock, two-factor access control using biometric and card readers, barriers, fencing, security cameras and other measures.
To ensure integrity, all data transits are encrypted to align with best practices for protecting confidentiality and data integrity. E.g. all supplied credit card information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those who are authorized to access such systems and who are required to keep the information confidential.
For data in transit, the Service uses industry-standard transport protocols between devices and Microsoft datacenters and within datacenters themselves.
All personnel are subject to full confidentiality and any subcontractors and subprocessors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties.
Whenever personal data is accessed by authorized personnel the access is only possible over an encrypted connection. When accessing the data in a database, the IP number of the person accessing the data must also be pre-authorized to obtain access.
Any device being used to access personal data is login protected by AreaBFE’s Azure Active Directory (AAD), Microsoft’s cloud based identity and access management service, and has AreaBFE’s corporate antivirus solution installed. If any personal data are temporarily stored on a device, the storage unit on the device must also be strongly encrypted.
On premise devices storing personal data temporarily is at all times, except when not being actively used or relocated under uninterrupted supervision, locked in a safe. Personal data are never stored on mobile media like USB sticks and DVD’s.
AreaBFE will at all times keep you informed about changes to the processes to protect data privacy and security, including practices and policies. You may at any time request information on where and how data is stored, secured and used. AreaBFE will also provide the summaries of any independent audits of the Service.
All access to personal data is blocked by default, using a zero privileges policy. Access to personal data is restricted to individually authorized personnel. AreaBFE’s Security and Privacy Officer issues authorizations and maintains a log of granted authorizations. Authorized personnel are granted a minimum access on a need-to-have basis through our AAD.
5.6. The ability to intervene
AreaBFE enables your rights of access, rectification, erasure, blocking and objection mainly by providing built-in functions for data handling in the Service Manager, by offering the option to send instructions through AreaBFE’s helpdesk and also by informing about and offering the customer the possibility of objection when AreaBFE is planning to implement changes to relevant practices and policies.
AreaBFE uses security reports to monitor access patterns and to proactively identify and mitigate potential threats. Administrative operations, including system access, are logged to provide an audit trail if unauthorized or accidental changes are made.
System performance and availability is monitored from both internal and external monitoring services.
5.8. Personal Data breach notification
In the event that your data is compromised, AreaBFE will notify you and competent Supervisory Authority(ies) within 72 hours by e-mail with information about the extent of the breach, affected data, any impact on the Service and AreaBFE’s action plan for measures to secure the data and limit any possible detrimental effect on the data subjects.
“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of the Service.
6. Do we disclose any information to outside parties?
AreaBFE does not sell, trade or otherwise transfer to outside parties any personally identifiable information.
This does not include trusted third parties or subcontractors who assist us in operating our website, conducting our business, or servicing you. Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential.
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety. Furthermore, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
AreaBFE will monitor subcontractors’ and subprocessors’ maintenance of these standards and audits to ensure that data protection requirements are fulfilled.
Any intended changes concerning the addition or replacement of subcontractors or subprocessors handling personal data will be announced to you with at least 3 months’ notice. You retain at all times the possibility to object to such changes or to terminate the contract with AreaBFE.
Legally required disclosure:
AreaBFE will not disclose the customer’s data to law enforcement except when instructed by you or where it is required by law. When governments make a lawful demand for customer data from AreaBFE, AreaBFE strives to limit the disclosure. AreaBFE will only release specific data mandated by the relevant legal demand.
If compelled to disclose your data, AreaBFE will promptly notify you and provide a copy of the demand unless legally prohibited from doing so.
7. Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our website and welcome any feedback about these websites.
8. Where do we store the information?
All data are stored in databases and file repositories hosted in a data center at AreaBFE’s cloud vendor, Bluehost. All data are automatically replicated in real time to secondary hot failover databases and file repositories in Bluehost’s data center in Provo, Utah, USA.
Databases are continuously backed up to enable restore to any point in time within a retention period of 15 days. Backups are stored on file storage at the same geographical location as the database.
9. Access, data portability, migration, and transfer back assistance
You may at any time obtain confirmation from AreaBFE as to whether or not personal data concerning you are being processed.
You may at any time order a complete data copy, which you may transmit to another controller of the data. Your data will be delivered within 10 working days by AreaBFE as spreadsheet files in Microsoft Excel-format. Logical relations between datasets will be preserved in form of unique identifiers. You are required to pay $1,000 + any applicable taxes on delivery for each data copy order.
10. Request for rectification, restriction or erasure of the personal data
You may at any time obtain without undue delay rectification of inaccurate personal data concerning you, cf. clause 5.6.
10.2. Restriction of processing personal data
You may at any time request AreaBFE to restrict the processing of personal data when one of the following applies:
a. if you contest the accuracy of the personal data, for a period enabling AreaBFE to verify the accuracy of the personal data;
b. if the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; or
c. if AreaBFE no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims.
d. if the personal data have been unlawfully processed; or
e. if the personal data have to be erased for compliance with a legal obligation in EU or national law.
11. Data retention
11.1. Data retention policy
Account Data will due to tax regulations be retained for up to five full fiscal years from your cancellation of your Service account. Configuration Data and System Generated Data will be erased immediately when you cancel the Service account.
End User Data will be erased on an ongoing basis after 12 months from registration, and immediately when you cancel the Service account.
11.2. Data retention for compliance with legal requirements
You cannot require AreaBFE to change any of the default retention periods, except for the reasons for erasure pursuant to clause 11.3, but may suggest changes for compliance with specific sector laws and regulations.
11.3. Data restitution and/or deletion
No data except Account Data will be retained after the termination of the contract. You may request a data copy before termination. You must not cancel the Service account until the data copy has been delivered, as AreaBFE otherwise will not be able to deliver the data copy.
AreaBFE uses the extensive range of built-in features and audits trails provided by Bluehost cloud platform. AreaBFE also logs all system updates, configuration changes and access to provide an audit-trail if unauthorized or accidental changes are made.
AreaBFE will cooperate with you in order to ensure compliance with applicable data protection provisions, e.g. to enable you to effectively guarantee the exercise of data subjects’ rights (right of access, rectification, erasure, blocking, opposition), to manage incidents including forensic analysis in case of security breach.
14. Your consent
You may at any time lodge a complaint with a supervisory authority regarding AreaBFE’s collection and processing of your personal data.