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If you require a signed copy of this DPA for your records, please contact your Aventri Account Manager.
This Data Processing Addendum and its Annexes (“DPA”) reflect the mutual agreement of Aventri and any Aventri client (“Client”) regarding the ways in which Aventri can Process Personal Data on behalf of Client, in connection with Aventri’s provision of Services. This DPA is supplemental to, and forms an integral part of the Terms of Service (including any form of master services agreement entered by the parties, the “Agreement”) that govern Client’s use of Aventri’s Services. Any capitalized terms used but not defined in this DPA shall have the meaning given to them in the Agreement. In the event of a conflict between the terms of this DPA and the of the Agreement, the terms of this DPA will govern.
By signing an order form or purchase order for Aventri Services, Client enters into this DPA on behalf of itself and, to the extent required under applicable Data Protection Laws, those of its Affiliates who are authorized to use the Services under the Agreement (“Permitted Affiliates”). For purposes of this DPA, and except where indicated otherwise, the terms “Client”, “you” and “your” will include Client and its Permitted Affiliates.
Unless otherwise defined in this DPA, all capitalized terms have the meaning given to them in the Agreement.
“Data Controller” means the entity which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data, and includes a Business as such term is defined under the CCPA.
“Data Processor” means the entity which Processes Personal Data on behalf of the Data Controller.
“Data Protection Laws” means all local, state, national and/or foreign data protection and privacy laws, treaties and/or regulations applicable to the collection, use, transfer, storage, processing, correction, disclosure, and deletion of Personal Data under this DPA, including but not limited to EU Data Protection Laws, and the California Consumer Privacy Act of 2018 Cal. Civil Code § 1798.100 et seq. (“CCPA”).
“EEA” means the European Economic Area, which constitutes the member states of the European Union and Norway, Iceland and Liechtenstein.
“EU Data Protection Laws” means the General Data Protection Regulation (EU) 2016/679 (“GDPR”), implementations of GDPR into national law, and other applicable data protection laws of EEA member states, Switzerland and the United Kingdom (as amended, replaced or superseded).
“European Data” means Personal Data that is subject to the protection of EU Data Protection Laws.
“Instructions” means those written, documented instructions issued by the Data Controller to the Data Processor, directing the latter to perform a specific or general action with regard to Personal Data (including but not limited to deleting, making available, and anonymizing).
“Personal Data” means any information collected, uploaded, transferred, stored, or otherwise Processed in connection with the Services provided to Client under the Agreement that relates to an identifiable natural person (each such person, a “Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. Personal Data includes names, contact information and other information defined as personal data under applicable Data Protection Laws.
“Personal Data Breach” means any actual or reasonably suspected breach of security leading to, or likely to result in, the unlawful or unauthorized use, loss, access, misappropriation, alteration, or disclosure of Personal Data.
“Privacy Policy” shall mean the Aventri privacy policy, as updated from time to time, located at https://www.Aventri.com/privacy-policy/.
“Processing” or “Process” means any operation or set of operations performed on Personal Data or sets of Personal Data, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying.
“Standard Contractual Clauses” means the 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, pursuant to Commission Implementing Decision (EU) (2021/915), available on the European Commission’s website at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914&from=EN.
“Sub-Processor” means a Data Processor engaged by Aventri or an Aventri Affiliate to assist Aventri or such Affiliate in its provision of Services to Client under the Agreement. The Data Processor may be an Aventri Affiliate or a third-party entity.
“Valid Transfer Mechanism” means a data transfer mechanism permitted by EU Data Protection Laws as a lawful basis for transferring European Personal Data to a recipient outside the EEA, including but not limited to the Standard Contractual Clauses.
2.1: Scope and Role of the Parties.This DPA applies to the Processing of Personal Data by Aventri in the course of providing the Services. As between the parties, Client (together with its Permitted Affiliates) is the Data Controller and Aventri is the Data Processor of Personal Data. Aventri shall Process the Personal Data as a Data Processor only for the purpose of providing the Services described in the Agreement. In no event will Aventri Process the Personal Data for its own purposes or those of any third party.
2.2: Instructions for Processing.Aventri shall Process Personal Data in accordance with the Privacy Policy and Client’s Instructions. Client hereby instructs Aventri to Process Personal Data as necessary to provide the Services in accordance with the Agreement (including this DPA). Client may provide additional Instructions to Aventri to Process Personal Data, however Aventri shall be obligated to perform such additional Instructions only if they are consistent with the terms and scope of the Agreement and this DPA.
2.3: Compliance with Laws.Aventri shall comply with all Data Protection Laws applicable to Aventri in its role as a Data Processor Processing Personal Data.
2.4: Client Authority.Client represents and warrants to Aventri that Client has obtained the Personal Data in accordance with the requirements of applicable Data Protection Laws, and that Client is and will at all time remain duly and effectively authorized to give the instruction set out in Section 2.2.
3.1: Use of Subprocessors.Client agrees that Aventri and Aventri Affiliates may engage Sub-Processors to Process Personal Data when necessary to provide the Services. Aventri or the relevant Aventri Affiliate shall ensure that each such Sub-Processor abides by data processing terms no less protective of Personal Data than those provided in this DPA (including, where appropriate, the Standard Contractual Clauses). Aventri agrees that it will remain responsible to Client for each Sub-Processor’s compliance with the obligations of this DPA, and shall be liable to Client for the acts and omissions of any Sub-Processors with respect to Personal Data, to the same extent as if the acts or omissions were performed by Aventri.
3.2: Notification of New Subprocessors. Aventri has currently appointed, as Sub-Processors, those Aventri Affiliates and third parties listed in Annex III attached hereto (the “Authorized Sub-Processsors”), and shall provide written notice to Client as provided in the Agreement (or in any event at least 30 days in advance) if Aventri adds any new Sub-Processor to Annex III.
4.1: Location of Processing Personal Data.Client acknowledges and agrees that Aventri may access and Process Personal Data on a global basis as necessary to provide the Services in accordance with the Agreement, and that Personal Data will be transferred to and Processed by Aventri, LLC in the United States and to other jurisdictions where Aventri Affiliates and other Sub-Processors have operations. Upon Client request, Aventri will make available to Client a list of the locations where it Processes Personal Data.
The provisions of this Section 5 shall apply only with respect to European Data, if any, Processed by Aventri.
5.1: Scope.Aventri will Process European Data only as necessary to provide the Services.
5.2: Roles. When Processing European Data, as between Aventri and Client for the purposes of the descriptions in the Standard Contractual Clauses, the parties agree that Aventri is the Data Processor and the "data importer" (as defined in the Standard Contractual Clauses), and that Client is the Data Controller and the “data exporter” (as defined in the Standard Contractual Clauses), notwithstanding that Client may be located outside the EEA and may itself be a Data Processor acting on behalf of third party Data Controllers.
5.3 Transfers of European Data. Aventri will not transfer European Data to any country or recipient not formally recognized by the European Commission as providing an adequate level of data protection unless Aventri has (i) implemented a Valid Transfer Mechanism for the European Data, or (ii) received prior written consent from Client. Client hereby consents to the transfer by Aventri of Personal Data to its Sub-Processors identified on Annex III hereto, as necessary to provide Client with Services pursuant to the Agreement, and subject to a Valid Transfer Mechanism.
5.4 Transfers to Aventri. Client acknowledges that in its provision of the Services, Aventri, LLC is likely to receive European Data in the United States. The parties therefore acknowledge and agree the following:
5.4.1 Aventri, LLC agrees to abide by and Process European Data in compliance with the Standard Contractual Clauses, and such Standard Contractual Clauses are incorporated by reference into and form an integral part of this DPA.
5.4.2 If and to the extent the Standard Contractual Clauses conflict with any provision of this DPA, the Standard Contractual Clauses shall prevail. In no event does this DPA restrict or limit the rights of any Data Subject or of any competent supervisory authority.
5.4.3 Although Aventri, LLC does not rely on the EU-US Privacy Shield as a legal basis for transfers of European Data in light of the judgment of the EU Court of Justice in Case C-311/18, for as long as Aventri, LLC is self-certified to the Privacy Shield, Aventri, LLC will Process European Data in compliance with Privacy Shield principles.
5.4.4 To the extent Client requires Aventri assistance to meet its obligations under Article 35 and 36 of the GDPR to carry out a data protection impact assessment and prior consultation with the competent supervisory authority related to Client’s use of the Service, Aventri will, taking into account the nature of Processing and the information available to Aventri, provide reasonable assistance to Client.
5.5 Sub-Processors of European Data.
5.5.1 Sub-Processor Objection Right. Aventri will notify Client of any changes to Sub-Processors of European Data by updating Annex III to this DPA, and will provide Client the opportunity to object to the engagement of the new Sub-Processor on reasonable grounds relating to Personal Data protection within thirty (30) days of the update to Annex III. If Client notifies Aventri of such an objection within thirty (30) days, the parties will discuss the Client’s concerns in good faith and use commercially reasonable efforts to achieve a resolution. Should no resolution be reached, and should Aventri choose to retain the objected-to Sub-Processor, Client may elect to suspend or discontinue using the relevant portion(s) of the Service and may terminate the relevant portion(s) of the Service. Upon any such termination by Client of the Service Agreement, in whole or in part, pursuant to this Section, Aventri shall refund Client any prepaid fees for the terminated portion(s) of the Service that were to be provided after the effective date of termination.
5.5.2 Sub-Processor Agreements. For purposes of clause 9(c) of the Standard Contractual Clauses, Client acknowledges that Aventri may be restricted from disclosing Sub-Processor agreements to Client, but Aventri agrees to use reasonable efforts to request any Sub-Processor to disclose the Sub-Processor agreement to Client and will provide (on a confidential basis) all Sub-Processor information reasonably possible without breaching any obligations of confidentiality Aventri may have to the Sub-Processor.
5.6 Access by Government Authorities. In accordance with Article 46 of the GDPR and the Standard Contractual Clauses, and without prejudice to any provisions of this DPA, Aventri undertakes the following additional safeguards to secure European Data transferred pursuant to the Standard Contractual Clauses:
5.6.1 For the purposes of safeguarding European Data when any government or regulatory authority requests access to such data, and unless required by a valid court order or if otherwise Aventri may face criminal charges for failing to comply with orders or demands to disclose or otherwise provide access to European Data, or where the access is requested in the event of imminent threat to lives, Aventri will:
5.6.1.1 not provide the source code or encryption keys to any government agency for the purpose of accessing European Data; and
5.6.1.2 upon Client’s written request, provide reasonable available information about the requests of access to European Data by government agencies Aventri has received in the 6 months prior to Client’s request.
5.6.2 If Aventri receives a request by a government agency to access European Data, Aventri will notify Client of such request to enable the Client to take necessary actions, to communicate directly with the relevant authority and to respond to the request. If Aventri is prohibited by law to notify the Client of such request, Aventri will make reasonable efforts to challenge such prohibition through judicial action or other means at Client’s expense and, to the extent possible, will provide only the minimum amount of information necessary.
5.7 Standard Contractual Clauses. For purposes of the Standard Contractual Clauses, the parties agree to the following (provided, if and to the extent a Permitted Affiliate relies on the Standard Contractual Clauses for the transfer of European Data, any references to “Client” in this Section 5 include such Affiliate):
5.7.1 The relevant provisions contained in the Standard Contractual Clauses are incorporated by reference and are an integral part of this DPA.
5.7.2 With respect to the transfer of European Data, the parties shall abide by the terms of the Standard Contractual Clauses as set out in MODULE 2 (Controller to Processor).
5.7.3 The Docking Clause option under clause 7 shall apply.
5.7.4 The DPA and the Service Agreement are Client’s complete and final documented Instructions at the time of signature of the Service Agreement for the Processing of Personal Data.
5.7.5 The parties agree that the audits described in clause 8.9 of the Standard Contractual Clauses shall be carried out in accordance with the audit provisions detailed in Section 12 of this DPA.
5.7.6 Option 2 under clause 9 of the Standard Contractual Clauses will apply with respect to any Sub-Processor. For purposes of clause 9(a), Aventri has Client’s general authorization to engage Sub-Processors in accordance with Section 3 and Section 5.5 of this DPA.
5.7.7 The option under clause 11 (Redress) shall not apply.
5.7.8 The information required for purposes of the Appendix to the Standard Contractual Clauses will be completed as follows:
5.7.8.1 The contents of Part A of Annex I of this DPA will form Annex I.A. to the Standard Contractual Clauses.
5.7.8.2 The contents of Part B of Annex I of this DPA will form Annex I.B. to the Standard Contractual Clauses.
5.7.8.3 The contents of Part C of Annex I of this DPA will form Annex I.C. to the Standard Contractual Clauses.
5.7.8.4 The contents of Annex II of this DPA will form Annex II to the Standard Contractual Clauses.
5.7.8.5 The contents of Annex III of this DPA will form Annex III to the Standard Contractual Clauses.
6.1 Cooperation. Aventri will, as necessary to enable Client to meet its obligations under applicable Data Protection Laws, provide reasonable and timely assistance to Client to (i) maintain up-to-date and accurate records regarding Personal Data, (ii) respond to any Data Subject Request (as defined in Section 6.4 below); and (iii) respond to any other correspondence, enquiry or complaint received from a Data Subject, regulator, court or other supervisory authority in connection with the Processing of Personal Data. In the event that any such request, correspondence, enquiry or complaint is made directly to Aventri, Aventri shall promptly inform Client and shall not respond to the communication unless required by law or authorized by Client.
6.2 Deletion or Restriction. Aventri will either (i) provide Client the ability within the Service to correct or delete Personal Data or restrict its Processing; or (ii) make such corrections, deletions, or restrictions on Client’s behalf if such functionality is not available within the Service. Aventri shall comply with Client’s reasonable Instructions in relation to the correction, deletion and blocking of Personal Data.
6.3 Access to Personal Data. To the extent a Data Subject’s Personal Data is not accessible to Client through the Service, Aventri will, as necessary to enable Client to meet its obligations under applicable Data Protection Laws, provide reasonable assistance to make such Personal Data available to Client.
6.4 Handling of Data Subject Requests. Client is responsible for responding to a Data Subject’s request to exercise any of its rights under relevant Data Protection Laws (including such Data Subject’s rights of access, correction, objection, deletion, restriction of Processing and data portability of its Personal Data) (“Data Subject Request”). If Aventri receives a Data Subject Request, Aventri shall promptly redirect the Data Subject to Client.
6.5 Data Portability. During the term of the Agreement, Aventri shall ensure that Client can extract Personal Data from the Service in a structured, commonly used and machine-readable format such that Client can provide the Personal Data to an individual who makes a data portability request under EU Data Protection Laws.
Unless prohibited by applicable law or a legally-binding request of law enforcement, Aventri shall promptly notify Client of any request by government agency, judicial body or law enforcement authority for access to or disclosure of Personal Data.
Aventri shall take reasonable steps to require screening of its personnel who may have access to Personal Data, and shall ensure such personnel (i) Processes Personal Data in accordance with Client’s Instructions as set forth in this DPA; (ii) receives appropriate training on its responsibilities regarding the handling and safeguarding of Personal Data; and, (iii) is subject to confidentiality obligations designed to safeguard Personal Data from unauthorized access, use or disclosure.
In the event Aventri becomes aware of a Personal Data Breach, it shall, without undue delay (but in any event within forty-eight (48) hours), notify Client. Aventri’s notification shall include, to the extent known at the time of notification (i) a description of the Personal Data Breach, including, where possible, the categories and approximate number of Data Subjects concerned and the categories and approximate number of Personal Data records concerned, (ii) a description of the likely consequences of the Personal Data Breach, and (iii) a description of the measures taken or proposed to be taken by Aventri to address the Personal Data Breach, including, where appropriate, measures to mitigate its possible adverse effects. If Aventri is unable to provide all of the information listed above as part of the initial notification, Aventri will provide this information to Client as soon as reasonably practicable. To the extent Client requires additional information from Aventri to meet its Personal Data Breach notification obligations under applicable Data Protection Laws, Aventri shall provide reasonable assistance to provide such information to Client taking into account the nature of Processing and the information available to Aventri.
Aventri shall implement appropriate technical and organizational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data as set forth in the Agreement, including the implementation of appropriate Aventri security policies, which are available to Client upon request.
In the event Aventri Processes credit or debit card payment information, it does so in compliance with all applicable Payment Card Industry Security Standard (PCI DSS) requirements, and is PCI DSS Level 1 certified.
Aventri shall make available to Client, upon Client’s written request, copies of any relevant summaries of external security certifications, security audit reports, penetration tests or other information reasonably necessary to demonstrate compliance with this DPA. Client shall be entitled to audit Aventri’s compliance with this DPA; provided, such audit shall occur not more than once a year, save for in the event of a Personal Data Breach where an additional audit may be conducted by Client. An audit shall be conducted following reasonable prior written notice and may include, but not be limited to, a site visit (during normal office hours and with reasonable prior notice), and a review of Aventri’s policies, procedures and other documentary evidence as reasonably required by Client.
Upon Client’s request at any time during the term of the Agreement or upon termination of the Agreement, Aventri shall immediately cease Processing the Personal Data and, at Client’s option or direction, delete, destroy or render unusable all Personal Data in its possession or control, unless instructed by Client (within 60 days following such request or termination) to also return a copy of such Personal Data. This requirement shall not apply to the extent that Aventri is required by any applicable law to retain some or all of the Personal Data, in which event Aventri shall isolate and protect such Personal Data from any further Processing except to the extent required by such law. If requested by Client, Aventri shall provide written certification of its compliance with this section.
The provisions of this Section 14 will apply only with respect to Personal Data that is subject to California Civil Code Sec. 1798.100 et seq., also known as the California Consumer Privacy Act of 2018, or “CCPA” (such Personal Data, “California Personal Information”).
14.1:14.1 In connection with the Processing of California Personal Information pursuant to Client’s Instructions, Aventri is a “Service Provider,” Client is a “Business,” and the term Data Subject includes “Consumer” as such terms are defined under the CCPA.
14.2:14.2 The parties acknowledge and agree that Aventri will Process California Personal Information strictly for the purpose of performing the Services under the Agreement or as otherwise permitted by the CCPA. In particular, Aventri will not: (i) sell Client’s California Personal Information; (ii) retain, use or disclose Client’s California Personal Information for a commercial purpose other than providing the Services in accordance with the Agreement; or (iii) retain, use or disclose California Personal Information outside of the direct business relationship between Aventri and Client.
15.1: Disclosure of DPA Terms.Client or its Permitted Affiliates may disclose the terms of this DPA to a data protection regulatory authority to the extent required by law or regulatory authority.
15.2: Termination.The term of this DPA will end simultaneously and automatically at the later of (i) the termination of the Agreement, or (ii) when all Personal Data is deleted from, or rendered unusable within, Aventri’s systems.
15.3: Conflict.This DPA is subject to the non-conflicting terms of the Agreement. With regard to the subject matter of this DPA, in the event of inconsistencies between the provisions of this DPA and the Agreement, the provisions of this DPA shall prevail with regard to the parties’ data protection obligations.
15.4: Headings.The section headings contained in this DPA are for reference purposes only and shall not in any way affect the meaning or interpretation of this DPA.
15.5: Updates.Aventri may update this DPA from time to time, and will provide Client with written notice of any such updates in accordance with the Agreement.
15.6: Miscellaneous.The legal entity agreeing to this DPA as Client represents that it is authorized to agree to and enter into this DPA for and on behalf of itself and each of its Permitted Affiliates. Except where applicable Data Protection Laws require a Permitted Affiliate to exercise a right or seek any remedy under this DPA against Aventri directly by itself, the parties agree that (i) solely the Client entity that is the contracting party to the Agreement will exercise any right or seek any remedy a Permitted Affiliate may have under this DPA on behalf of its Affiliates, and (ii) the Client entity that is the contracting party to the Agreement will exercise any such rights under this DPA in a combined manner for itself and all of its Permitted Affiliates together.
PART A – LIST OF PARTIES
Data Exporter:
Name: The Client, as defined in the Agreement, on behalf of itself and its Permitted Affiliates
Address: Client’s address, as set out in the Order Form
Contact person’s name, position and contact details: Client’s contact details, as set out in the Order Form and/or as submitted by Client for Client’s Aventri account.
Activities relevant to the data transferred under these Clauses: The Processing of Personal Data in connection with Client’s use of Aventri Services pursuant to the Agreement.
Role: Controller
Data Importer:
Name: Aventri, LLC.
Address: 13 Marshall Street, Norwalk, Connecticut 06854, USA
Contact person’s name, position and contact details: Joe Coffie, Information Security Officer, Aventri, LLC, 13 Marshall Street, Norwalk, Connecticut 06854, USA
Activities relevant to the data transferred under these Clauses: The Processing of Personal Data in connection with Aventri’s provision of Aventri Services to Client pursuant to the Agreement
Role: Processor
PART B – DESCRIPTION OF PROCESSING AND TRANSFER
Categories of Data Subjects whose Personal Data is Processed/Transferred
Client may submit personal data to Aventri, the extent of which is determined and controlled by the by the Client in its sole discretion, and which may include, but is not limited to, personal data relating to the following categories of data subjects:
1. Security Program and Standards
Aventri, as a Data Processor and data importer, maintains appropriate administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Personal Data provided to Aventri in the course of performing the Services pursuant to the Agreement in effect between the parties, including but not limited to documented data and information security policies, secure coding practices, encryption policies, data storage and deletion protocols, anti-virus protections, password policies, system and facility access controls, service monitoring and management procedures, disaster recovery and business continuity plans, and personnel security training. Specific measures and safeguards are detailed below.
2. Access Controls
A. Preventing Unauthorized Product Access and Use
Outsourced processing: We host our Service with outsourced cloud infrastructure providers (Amazon Web Services, Microsoft). Additionally, we maintain carefully structured contractual relationships with vendors and contractors in order to provide the Services in accordance with our DPA. We rely on contractual agreements, privacy policies, and vendor due diligence and compliance programs in order to protect any data Processed or stored by 3rd parties.
Physical/environmental security: Our product infrastructure is hosted with multi-tenant, outsourced cloud service providers. The physical and environmental security controls are audited for SOC 2 Type II and ISO 27001 compliance annually, among other certifications.
Authentication: Multi Factor Authentication (MFA) is implemented and required for access to all our customer products in addition to all other environments.
Authorization: We enforce a least-privilege model and as such only appropriately assigned individuals can access relevant application features as assigned by their administrator. Customers are not allowed access to the underlying application infrastructure.
Storage: Data is stored in multi-tenant storage systems which is encrypted at rest. Access to the data storage repositories is also controlled by Multi Factor Authentication (MFA), in addition to signing an NDA for access to the customer data.
Internal Network: We have implemented industry standard technical access and detection capabilities to protect the internal network infrastructure that supports our products.
Logging and alerting: We log all system activity including system behavior, all communication, all levels of authentication and APE calls. Any abnormalities or malicious activities are alerted and investigated by our security operations team. For any confirmed incidents we take appropriate steps to minimize product and customer disruptions. Notifications are in accordance with the terms of the agreement.
We implement a Virtual Private Network (VPC) with all our Cloud Service Providers (CSPs) giving us the ability to customize access controls and firewall rules at a granular level.
Penetration testing: We engage with industry recognized penetration testing service providers for annual penetration tests to identify and remediate any potential attack vectors.
Code testing: We perform static and dynamic code analysis: We perform security reviews of all code within our repositories against OWASP best practices and other vulnerabilities.
B. Limiting Internal Privileges and Authorization Requirements
Personnel Screening: All of our personnel are subject to a third-party background check prior to being extended an employment offer, subject to applicable laws.
Control Environment: Employees enter into written obligations of confidentiality, and are required to conduct themselves in a manner consistent with company privacy policies, non-disclosure requirements, and ethical standards. Access to data is provided to that subset of employees who have a “need to know” in order to provide the Services, including to provide customer support, mitigate potential problems, and detect and respond to security incidents. Employees are granted access based on role, and access products and data via controlled, password protected, interfaces.
Security Training and Awareness. Aventri maintains a security awareness program that includes annual training of personnel on Aventri’s security policies and data privacy best practices.
3. Data Transmission Controls
In-transit: We implement encryption on all data communication (logins, customer sites) using NIST based cryptographic algorithms. All web traffic is via https with TLS.
At-rest: We store user passwords following policies that follow industry standard practices for security. We have implemented technologies to ensure that stored data is encrypted at rest.
4. Availability Controls
Infrastructure availability: The infrastructure providers use commercially reasonable efforts to ensure a minimum of 99.95% uptime. The providers maintain a minimum of N+1 redundancy to power, network, and HVAC services.
Fault tolerance: Our products are designed to ensure redundancy and seamless failover. The server instances that support the products are also architected with a goal to prevent single points of failure. This design assists our operations in maintaining and updating the product applications and backend while limiting downtime. Customer data is backed up to multiple durable data stores and replicated across multiple availability zones.
Backup replication: Our production databases are designed to replicate data between a primary and backup database using industry standard backup methods to create resiliency.
LIST OF SUBPROCESSORS
* The marked Sub-Processors are Aventri Affiliates and Aventri wholly-owned subsidiaries.
If you require a signed copy of these Standard Contractual Clauses for your records, please contact your Aventri Account Manager.
Version Updated 15 February 2022
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