Data processing agreement

This document lays out the responsibilities of Priice SARL (French company registration: 751361627), hereafter referred to as Priice, to its customers with regards to data protection in general and the European Union’s General Data Protection Regulation (GDPR) specifically.

1. Priice as Data Processor, Definitions

• Priice is a Data Processor operating on behalf of its customers.
• Customers are individuals or organizations paying money to use the Priice service. Free trial users of the Priice Service are not Customers and should not send Priice personal data.
• Priice's Customers are Data Controllers.
• “Personal data” means any information relating to an identified or identifiable person.
• “Data Protection Laws” means EU Directive 95/46/EC, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR.
• "Services" means the Priice's APIs (Commercial name: Strackr) (application program interface) and the professional services provided by Priice.
• “Sub-processor” means any Data Processor engaged by Priice.
• “Data Subject” means the individual to whom Personal Data relates.

2. Processing of Personal Data

• Use of the service implies that Priice may process personal data on behalf of the Data Controller in accordance with the requirements of Data Protection Laws. The Data Controller will ensure that instructions to Priice for the processing of personal data comply with Data Protection Laws. The Data Controller is solely responsibility for the accuracy, quality, and legality of Personal Data and the means by which it acquires personal data.
• The inputs to the Priice Service provided by the Data Controller are URLs and optionnal parameters. No other data should be sent to Priice. The Data Controller bears sole responsibility for transmission of URls that can include personnal data.
• Priice lays out a full and accurate description of its data protection practices on its website at https://strackr.com/legal/gdpr . This description is updated from time to time as and when practices change.

3. Rights of Data Subjects

• The Data Controller is solely responsible for the collecting of all necessary consent from Data Subjects to allow Priice to process personal data on its behalf.
• Priice will, to the extent legally permitted, promptly notify the Data Controller if it receives a request from a Data Subject for access to, or deletion of, that person’s personal data. Priice will not respond to a Data Subject request without the Data Controllers prior written consent except to confirm that the request relates to the Data Controller. The Data Controller is solely responsible for completing such request as required by law.

4. Personnel

• Priice ensures that its personnel engaged in the processing of personal data are informed of the confidential nature of the personal data, have received appropriate training on their responsibilities and have agreed to confidentiality obligations that survive the termination of that persons’ employment or engagement by Priice.
• Priice shall take commercially reasonable steps to ensure the reliability of any Priice personnel engaged in the processing of personal data and that access to personal data by Priice is limited to those Priice personnel who require such access to perform the Services.
• Priice’s data protection officer can be reached by email at contact@strackr.com

5. Sub-Processors

• The Data Controller agrees Priice may engage third-party Sub-processors to provide the Services and such Sub-processors may access personal data, and appoint additional levels of Sub-processors, only for purposes of providing the services Priice retained them to provide and not for any other purpose.

6. Security Measures

• Priice agrees to implement and maintain the administrative, technical, and physical safeguards of personal data stored using the Services.
• Access control: Servers are only accessible through SSH keys.
• Integrity & Confidentiality: User authorisation is heavily restricted. Only members of Priice SARL (currently the Lead developer Julien Hany) have access to the production database.
• Anonymisation: Personal data such as IP addresses are by standard, if tracked at all, anonymised.
• Encryption: The Cloud database solution is cerified ISO/IEC 27001, 27017, 27018, 27701 and in transit with TLS/SSL.
  On top of that, sensitive user data such as login information, network API credentials are all encrypted using AES-256.
• Transmission Control: All requests and responses get transmitted through SSL.
• Recoverability: Recoverability is managed by a Cloud solution. Backups are performed with 2 different providers in 2 different physical locations with a history over the last 30 days.
• Evaluation: Regular check-ups on data registration, user capacities and database scalability requirements.

7. Security Breach Management and Notification

• If Priice becomes aware of unlawful access to the Data Controller's personal data stored through the Services, or unauthorized access to the Services resulting in loss, disclosure, or alteration of the Data Controller's personal data (“Security Breach”), Priice will promptly: (a) notify the Data Controller of the Security Breach; (b) investigate the Security Breach and provide the Data Controller with information known to Priice about the Security Breach; and (c) follow its policies and procedures to mitigate the effects and to minimize any damage resulting from the Security Breach.
• The Data Controller agrees that an unsuccessful Security Breach attempt will not be subject to Section 7.1 above. An unsuccessful Security Breach attempt is one that results in no unauthorized access to the Data Controller's personal data or to the Services storing your Personal Data, and may include, without limitation, pings and other broadcast attacks on firewalls or edge servers, port scans, unsuccessful log-on attempts, denial of service attacks, packet sniffing (or other unauthorized access to traffic data that does not result in access beyond IP addresses or headers) or similar incidents.
• Notification(s) of Security Breaches, if any, will be delivered to one or more of the Customer’s business, technical or administrative contacts by any means Priice selects, including via email. It is Customer’s sole responsibility to ensure it maintains accurate contact information on Priice’s support systems at all times.
• Priice’s report of and/or response to a Security Breach under this Section will not be construed as an admission by Priice to fault or liability with respect to the Security Breach.

8. Deletion of Customer Data

• Priice agrees to delete Customer personal data in accordance with Priice’s procedures and Data Protection Laws.
• At a Customer's request, Priice will provide the Customer with a certification of deletion of personal data.

9. Governing Laws

• This Agreement is governed by the laws of France

10. Legal Effect

• This agreement comes into effect from the time of purchase of an Priice subscription. It expires with cessation of the Customer's Priice subscription.