Data Processing Addendum
In order that you as a service user (both candidate or employer) and data controller (referred to as “Controller” or “User”) may use or continue to use our expert SaaS recruitment services (“Services”) offered by us, Fully Ramped Consulting Ltd, business address 2913 Pilatus run, Victoria, BC, Canada, V9B 0R4 and data processor (referred to as “Fully Ramped” or “Processor”), you agree that certain Personal Data you submit as part of your use of our Services and these data processing terms (“Terms”) shall apply (notwithstanding any other terms and conditions applicable to the delivery of the Services to the contrary) in order to address the compliance obligations imposed upon Fully Ramped and its Users pursuant to Applicable Law.

DEFINITIONS

“Affiliate” means an entity that, directly or indirectly, controls, is controlled by, or is under common control with a Party. As used herein, “control” means the power to direct the management or affairs of an entity and the beneficial ownership of fifty percent (50%) or more of the voting equity securities or other equivalent voting interests of an entity.
“Applicable Law(s)” means all US, UK, and EU laws, regulations, and other legal or regulatory requirements relating to privacy, data protection/security, or the Processing of Personal Data applicable to Fully Ramped's performance of its services under the Agreement, including without limitation the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”), including any implementing regulations, the United Kingdom Data Protection Act 2018, and the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), and Canada's Personal Information Protection and Electronic Documents Act (“PIPEDA”).
“User Contact Data” means the User’s contact information.
“User Personal Data” means User Data, as defined in the Agreement, consisting of Personal Data, except for User Contact Data.
“EEA” means, for purposes of this DPA, the European Economic Area (which is composed of the member states of the European Union), Norway, Iceland, Liechtenstein, and Switzerland.
“EU SCCs” means the Standard Contractual Clauses issued pursuant to the EU Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, available at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj and completed as described in Section 9.
“Personal Data Breach” means the accidental or unlawful destruction, loss, alteration, or unauthorised disclosure of or access to User Personal Data.
“Personal Data” includes “personal data,” “personal information,” and “personally identifiable information,” each as defined by Applicable Law.
“Process” and “Processing” mean any operation or set of operations performed on Personal Data, or on sets of Personal Data, whether or not by automated means, such as collecting, recording, organising, creating, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing (by transmission, dissemination or otherwise making such data available), aligning or combining, restricting, erasing, or destroying such Personal Data.
“Standard Contractual Clauses” means the EU SCCs or the UK SCCs, as applicable.
“UK SCCs” means the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses, available as of the Effective Date at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-data-transfer-agreement-and-guidance/ and completed as described in Section 9.

RELATIONSHIP OF THE PARTIES

User is the Controller as defined under Applicable Laws, and User determines the means and purposes for which User Personal Data is Processed by Fully Ramped. To the extent Fully Ramped Processes User Personal Data subject to Applicable Laws, Fully Ramped is a Processor and Service Provider as defined under Applicable Laws, and Fully Ramped will Process the User Personal Data according to the instructions set forth in this DPA, the Agreement, and as required under Applicable Laws. User and Fully Ramped are independent Controllers, as defined under Applicable Laws, with respect to User Contact Data. Either Party may Process User Contact Data as necessary for the purpose of (i) carrying out its obligations under the Agreement, (ii) applicable legal or regulatory requirements, (iii) requests and communications with the other Party, (iv) administrative, business, and marketing purposes, and (v) to protect its respective rights in accordance with applicable law and, in the case of Fully Ramped, maintaining the security and integrity of the Services.
Fully Ramped hereby certifies that it understands the restrictions and obligations set forth in this DPA in relation to its role as a Processor and Service Provider, and that it will comply with them.

USER’S INSTRUCTIONS TO FULLY RAMPED

Purpose Limitation. Fully Ramped will not

3.1.1.sell or share (as defined by CCPA) User Personal Data,
3.1.2.Process User Personal Data for any purpose other than for the specific purposes set forth in the Agreement,
3.1.3.retain, use, or disclose any such data outside of the direct business relationship between the Parties,
3.1.4.combine any User Personal Data with personal information that it receives from, or on behalf of, another person or persons, or collects from its own interaction with a consumer, except as otherwise permitted by Applicable Law, or
3.1.5.otherwise engage in any Processing of User Personal Data beyond that in which a Processor may engage under the Applicable Law or in which a Service Provider may engage under the Applicable Law, unless obligated to do otherwise by Applicable Law. In such a case, Fully Ramped will inform User of the applicable legal obligation before engaging in the Processing, unless legally prohibited from doing so. Further details regarding Fully Ramped's Processing operations are set forth in Schedule 1. To the extent User discloses or makes available deidentified data (as such term is defined under Applicable Law) within the User Data to Fully Ramped, Fully Ramped shall not attempt to re-identify such data.

Lawful Instructions. User will not instruct Fully Ramped to Process User Personal Data in violation of Applicable Law. Fully Ramped will without undue delay inform User if, in Fully Ramped's opinion, an instruction from User infringes Applicable Law. The Agreement, including this DPA, constitutes User’s complete and final instructions to Fully Ramped regarding the Processing of User Personal Data, including for purposes of the Standard Contractual Clauses. User shall also have the right to take reasonable and appropriate steps to stop or remediate any unauthorised Processing of User Personal Data by Fully Ramped.

LIMITATIONS ON DISCLOSURE

Fully Ramped will not disclose User Personal Data to any third party without first obtaining User’s written consent, except as provided in Section 5, Section 7 or Section 9, except as required by law. Fully Ramped will require all employees, contractors, and agents who Process User Personal Data on Fully Ramped's behalf to protect the confidentiality of the User Personal Data and to comply with the other relevant requirements of this DPA.

SUBCONTRACTING

Sub-Processors. Fully Ramped may subcontract the collection or other Processing of User Personal Data only in compliance with Applicable Law and any additional conditions for subcontracting set forth in the Agreement. User acknowledges and agrees that Fully Ramped's Affiliates and certain third parties may be retained as sub-processors to Process User Personal Data on Fully Ramped's behalf (under this DPA as well as under the Standard Contractual Clauses, if they apply) in order to provide the Services.
Prior to a sub-processor’s Processing of User Personal Data, Fully Ramped will impose contractual obligations on the sub-processor substantially the same as those imposed on Fully Ramped under this DPA to the extent applicable to the nature of the services provided by such sub-processor. Fully Ramped remains liable for its sub-processors’ performance under this DPA to the same extent Fully Ramped is liable for its own performance.
Notification. Fully Ramped will provide Users with at least ten (10) days’ written notice of new sub-processors before authorising such sub-processor(s) to Process User Personal Data in connection with the provision of the Services. Fully Ramped will notify User at the email address provided in the signature block of this DPA for purposes of this notification. The sub-processor agreements to be provided under Section 5(j) of the EU SCCs may have all commercial information, or provisions unrelated to the EU SCCs, redacted prior to sharing with User, and User agrees that such copies will be provided only upon written request.
Right to Object. User may object to Fully Ramped's use of a new sub-processor on reasonable grounds relating to the protection of User Personal Data by notifying Fully Ramped promptly in writing at support@Fully Ramped.com within ten (10) business days after receipt of Fully Ramped's notice in accordance with the mechanism set out in Section 5.2. In its notification, User will explain its reasonable grounds for objection. In the event User objects to a new sub-processor, Fully Ramped will use commercially reasonable efforts to make available to User a change in the Services or recommend a commercially reasonable change to User’s configuration or use of the Services to avoid Processing of User Personal Data by the objected-to new sub-processor without unreasonably burdening User. If Fully Ramped is unable to make available such change within a reasonable period of time, which will not exceed thirty (30) days, either Party may terminate without penalty the Processing of User Personal Data and/or the Agreement with respect only to those services which cannot be provided by Fully Ramped without the use of the objected-to new sub-processor by providing written notice to the other Party.

ASSISTANCE AND COOPERATION

Security. Fully Ramped will provide reasonable assistance to User regarding User’s compliance with its security obligations under Applicable Law relevant to Fully Ramped's role in Processing User Personal Data, taking into account the nature of Processing and the information available to Fully Ramped, by implementing the technical and organisational measures set forth in Schedule 2, without prejudice to Fully Ramped's right to make future replacements or updates to the measures that do not materially lower the level of protection of User Personal Data. Fully Ramped will ensure that the persons Fully Ramped authorises to Process the User Personal Data are subject to written confidentiality agreements or are under an appropriate statutory obligation of confidentiality no less protective than the confidentiality obligations set forth in the Agreement.
Personal Data Breach Notification & Response. Fully Ramped will comply with the Personal Data Breach-related obligations directly applicable to it under Applicable Law. Taking into account the nature of Processing and the information available to Fully Ramped, Fully Ramped will inform User of a substantiated Personal Data Breach without undue delay or within the time period required under Applicable Law, and in any event no later than seventy-two (72) hours following such substantiation. Fully Ramped will notify User at the email address provided in the signature block of this DPA for purposes of Personal Data Breach notifications. Any such notification is not an acknowledgement of fault or responsibility. This notification will include Fully Ramped's then-current assessment of the following information, to the extent available, which may be based on incomplete information:

6.2.1.the nature of the Personal Data Breach, including, where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of User Personal Data records concerned;
6.2.2.the likely consequences of the Personal Data Breach; and
6.2.3.measures taken or proposed to be taken by Fully Ramped to address the Personal Data Breach, including, where applicable, measures to mitigate its possible adverse effects.

Fully Ramped will provide timely and periodic updates to User as additional information regarding the Personal Data Breach becomes available. User is solely responsible for complying with legal requirements for incident notification applicable to User and fulfilling any third-party notification obligations related to any Personal Data Breach. Nothing in this DPA or in the Standard Contractual Clauses will be construed to require Fully Ramped to violate, or delay compliance with, any legal obligation it may have with respect to a Personal Data Breach or other security incidents generally.

DATA SUBJECT REQUESTS

To the extent legally permitted, Fully Ramped will without undue delay notify User if Fully Ramped receives any request from an individual seeking to exercise any right afforded to them under Applicable Law regarding their Personal Data (a “Data Subject Request”). To the extent User, in its use of the Services, does not have the ability to address a Data Subject Request, Fully Ramped will, upon User’s request, take commercially reasonable efforts to assist User in responding to such Data Subject Request, to the extent Fully Ramped is legally permitted to do so and the response to such Data Subject Request is required under Applicable Law.

DPIAS AND CONSULTATION WITH AUTHORITIES

Upon User’s written request, Fully Ramped will provide User with reasonable cooperation and assistance as needed and appropriate to fulfil User’s obligations under Applicable Law to carry out a data protection impact assessment related to User’s use of the Services. Fully Ramped will provide reasonable assistance to User in the cooperation or prior consultation with the Supervisory Authority (as defined under the GDPR) in the performance of its tasks relating to the data protection impact assessment, and to the extent required under the Applicable Law.

INTERNATIONAL DATA TRANSFERS

User authorises Fully Ramped and its sub-processors to make international transfers of the User Personal Data in accordance with this DPA so long as Applicable Law for such transfers is respected.
With respect to User Personal Data transferred from the EEA, the EU SCCs will apply and form part of this DPA, unless the European Commission issues updates to the EU SCCs, in which case the updated EU SCCs will control. Undefined capitalised terms used in this provision will have the meanings given to them (or their functional equivalents) in the definitions in the EU SCCs. For purposes of the EU SCCs, they will be deemed completed as follows:

9.2.1.Where User acts as a Controller and Fully Ramped acts as User's Processor with respect to User Personal Data subject to the EU SCCs, Module 2 applies.
9.2.2.Where User acts as a Processor and Fully Ramped acts as User's sub-processor with respect to User Personal Data subject to the EU SCCs, Module 3 applies.
9.2.3.Section 7 (the optional docking Section) is not included.
9.2.4.Under Section 9 (Use of sub-processors), the Parties select Option 2 (General written authorization). The initial list of sub-processors is set forth at Section 5. Fully Ramped will provide notice of updates to that list at least ten (10) business days in advance of any intended additions or replacements of sub-processors, in accordance with Section 5 of this DPA.
9.2.5.Under Section 11 (Redress), the optional requirement that data subjects be permitted to lodge a complaint with an independent dispute resolution body is inapplicable.
9.2.6.Under Section 17 (Governing law), the Parties select Option 1 (the law of an EU Member State that allows for third-party beneficiary rights). The Parties select the law of Ireland.
9.2.7.Under Section 18 (Choice of forum and jurisdiction), the Parties select the courts of Ireland.
9.2.8.Annexes I and II of the EU SCCs are set forth in Schedule 1 below.
9.2.9.Annex III of the EU SCCs (List of sub-processors) is inapplicable.
9.2.10.By entering into this DPA, the Parties are deemed to be signing the EU SCCs.

With respect to User Personal Data transferred from the United Kingdom for which the law of the United Kingdom (and not the law in any European Economic Area jurisdiction) governs the international nature of the transfer, the UK SCCs form part of this DPA and take precedence over the rest of this DPA as set forth in the UK SCCs, unless the United Kingdom issues updates to the UK SCCs, in which case the updated UK SCCs will control. Undefined capitalised terms used in this provision will have the meanings given to them (or their functional equivalents) in the definitions in the UK SCCs. For purposes of the UK SCCs, they will be deemed completed as follows:

9.3.1.Table 1 of the UK SCCs:

9.3.1.1.The Parties’ details are the Parties and their affiliates to the extent any of them is involved in such transfer, including those set forth in Schedule 1.
9.3.1.2.The Key Contacts are the contacts set forth in Schedule 1.

9.3.2.Table 2 of the UK SCCs: The Approved EU SCCs referenced are the EU SCCs as executed by the Parties pursuant to this Addendum.
9.3.3.Table 3 of the UK SCCs: Annex 1A, 1B, and II are set forth in Schedule 1.
9.3.4.Table 4 of the UK SCCs: Either Party may terminate this Addendum as set forth in Section 19 of the UK SCCs.

By entering into this DPA, the Parties are deemed to be signing the UK SCCs and their applicable Tables and Appendix Information.
With respect to User Personal Data transferred from Switzerland for which Swiss law (and not the law in any European Economic Area jurisdiction) governs the international nature of the transfer, the EU SCCs will apply and will be deemed to have the following differences to the extent required by the Swiss Federal Act on Data Protection (“FADP”):
References to the GDPR in the EU SCCs are to be understood as references to the FADP insofar as the data transfers are subject exclusively to the FADP and not to the GDPR.
The term “member state” in the EU SCCs will not be interpreted in such a way as to exclude data subjects in Switzerland from the possibility of suing for their rights in their place of habitual residence (Switzerland) in accordance with Section 18(c) of the EU SCCs.
References to Personal Data in the EU SCCs also refer to data about identifiable legal entities until the entry into force of revisions to the FADP that eliminate this broader scope.
Under Annex I(C) of the EU SCCs (Competent supervisory authority): where the transfer is subject exclusively to the FADP and not the GDPR, the supervisory authority is the Swiss Federal Data Protection and Information Commissioner, and where the transfer is subject to both the FADP and the GDPR, the supervisory authority is the Swiss Federal Data Protection and Information Commissioner insofar as the transfer is governed by the FADP, and the supervisory authority is as set forth in the EU SCCs insofar as the transfer is governed by the GDPR.

AUDITS

Fully Ramped will allow for and contribute to audits, including inspections, conducted by User or another auditor mandated by User subject to the following conditions: so long as the Agreement remains in effect, User may request that Fully Ramped provide it with Fully Ramped's most recent information security reports (“Records”) no more than once annually relating to Fully Ramped's compliance with this DPA (an “Audit”). To the extent User uses a third-party representative at User’s sole expense to conduct the Audit, User will ensure that such third-party representative is bound by obligations of confidentiality no less protective than those contained in the Agreement. User will provide Fully Ramped with ninety (90) business days prior written notice of its intention to conduct an Audit. User will conduct the Audit in a manner that will result in minimal disruption to Fully Ramped's business operations and such Audit will take no longer than two (2) business days. Further, User will not be entitled to receive data or information of other Users of Fully Ramped or any other Confidential Information of Fully Ramped that is not directly relevant for the authorised purposes of the Audit.

LEGAL PROCESS

If Fully Ramped is legally compelled by a court or other government authority to disclose User Personal Data, then to the extent permitted by law, Fully Ramped will promptly provide User with sufficient notice of all available details of the legal requirement and reasonably cooperate with User’s efforts to challenge the disclosure, seek an appropriate protective order, or pursue such other legal action, as Fully Ramped deems appropriate.

DESTRUCTION OF PERSONAL DATA

Upon termination of the Agreement and written request from User, Fully Ramped will delete or anonymize User Personal Data, unless prohibited by Applicable Law. Notwithstanding the foregoing, nothing will oblige Fully Ramped to delete or anonymize User Personal Data from files created for security, backup and business continuity purposes sooner than required by Fully Ramped's data retention processes. Any User Personal Data that may be retained beyond the duration of the Agreement will still be protected in accordance with this DPA and Fully Ramped shall not process such User Personal Data except as strictly permitted under Applicable Law.

APPLICABILITY AND ORDER OF PRECEDENCE

This DPA replaces any existing data processing addendum the Parties may have previously entered into in connection with the Agreement. In the event of a conflict between the terms of the Agreement and this DPA, the terms of the DPA will apply. In the event of a conflict between this DPA and the applicable Standard Contractual Clauses, the Standard Contractual Clauses will apply.

SCHEDULE 1

Annexes I and II of the SCCs

List of Parties

Module Two: Transfer Controller to Processor
Module Three: Transfer Processor to Processor

Data exporter(s):

1.2.1.Name: The exporter is the User specified in the Agreement.
1.2.2.Address: specified in the Agreement.
1.2.3.Contact person’s name, position and contact details: specified in the Agreement.
1.2.4.Activities relevant to the data transferred under these Sections: Obtaining the Services from data importer.
1.2.5.Role (Controller/Processor): Controller

Data importer(s):

1.3.1.Name: Fully Ramped Consulting Ltd, 2913 Pilatus Run, Victoria, British Columbia, Canada, V9B 0R4;
1.3.2.Address: specified in the Agreement.
1.3.3.Contact person’s name, position and contact details: specified in the Agreement.
1.3.4.Activities relevant to the data transferred under these Sections: Providing the Services to data exporter.
1.3.5.Role (Controller/Processor): Processor

Description of Transfer

Module Two: Transfer Controller to Processor
Module Three: Transfer Processor to Processor

Categories of data subjects whose personal data is transferred

Data subjects whose Personal Data is uploaded by data exporter to, or otherwise received directly or indirectly from data exporter by or through, the Services, or provided by data exporter to Fully Ramped to input into the Services.

Categories of personal data transferred

The data exporter may transfer Personal Data to Fully Ramped, the extent of which is determined and controlled by the data exporter in its sole discretion. Such Personal Data may include any category of Personal Data the data exporter may enter into the Services.
Sensitive data transferred and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.
In particular,

4.3.1.Personal contact details
4.3.2.Information relating to suitability
4.3.3.Where applicable sensitive personal information
4.3.4.Feedback and opinion related to an individual
4.3.5.Information relevant to referees
4.3.6.Business contact details
4.3.7.Tax and National Insurance information
4.3.8.Time worked records
4.3.9.Payroll records
4.3.10.Employment or engagement records
4.3.11.Online Identifier
4.3.12.Location Data
4.3.13.Education
4.3.14.Qualifications
4.3.15.Document CV
4.3.16.Next of Kin
4.3.17.Identifier Information
4.3.18.Right to work Identifier
4.3.19.Document ID
4.3.20.Referee Details

The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis)

Continuously, for the length of the Agreement between the Parties.

Nature of the processing

User Personal Data transferred will be processed to (i) provide the Services to the data exporter and fulfil the data importer’s obligations under the Agreement; and (ii) comply with applicable law.

Purpose(s) of the data transfer and further processing

User Personal Data transferred will be processed to (i) provide the Services to the data exporter and fulfil the data importer’s obligations under the Agreement; and (ii) comply with applicable law.

The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period

User Personal Data will be retained for the length of time necessary to provide Services under the Agreement and in accordance with Fully Ramped's data retention processes and as otherwise required by applicable law.

For transfers to (sub-)processors, also specify subject matter, nature and duration of the processing

Fully Ramped's sub-processors will process User Personal Data to assist Fully Ramped in providing the Services pursuant to the Agreement, for as long as needed for Fully Ramped to provide the Services.

Competent Supervisory Authority

Module Two: Transfer Controller to Processor
Module Three: Transfer Processor to Processor

Identify the competent supervisory authority/ies in accordance with Section 13.

The Parties will follow the rules for identifying such authority under Section 13 and, to the extent legally permissible, select the Irish Office of the Information Commissioner (OIC).

SCHEDULE 2

TECHNICAL AND ORGANISATIONAL MEASURES

Technical and Organisational Measures Including Technical and Organisational Measures to Ensure the Security of the Data

Module Two: Transfer Controller to Processor
Module Three: Transfer Processor to Processor

Description of the technical and organisational measures implemented by the data importer(s) (including any relevant certifications) 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.

ACCESS CONTROLS

Control Measures

1.1.1.Fully Ramped has implemented reasonable system access controls and physical access controls designed to limit access based on authorization and prevent personnel and others who should not have access from obtaining access to Fully Ramped systems housing User Data.

System Access Controls

1.2.1.Fully Ramped's system access control measures include the following:

1.2.1.1.restricting unauthorised users from accessing information not needed for their roles through role-based user access, and using "least privileged" principles;
1.2.1.2.unique user accounts identifiable to individual users, password requirements, and Auth0 authentication;
1.2.1.3.provisioning and removal of employee access to User Data when access is no longer required; and
1.2.1.4.periodic access reviews to ensure that only Fully Ramped personnel who still require access to User Data have such access.

Physical Access Controls

1.3.1.Fully Ramped utilises cloud hosting infrastructure for the Services. All physical security controls are managed by the cloud hosting provider. Annually, Fully Ramped reviews the applicable security and compliance reports of its cloud hosting provider to ensure appropriate physical security controls, which include:

1.3.1.1.use of data centres with physical and environmental controls appropriate to the risk for User Data and for the equipment, assets, or facilities used to hold and process such User Data (e.g., use of key card access controls and security guard monitoring); and
1.3.1.2.use of data centres with 24/7 security protection, automatic fire detection and suppression, fully redundant power systems, and other reasonable environmental controls.

OPERATIONS MANAGEMENT AND NETWORK SECURITY

Fully Ramped establishes and maintains reasonable operations management and network security measures, including:

2.1.1.network segmentation based on the label or classification level of the information stored;
2.1.2.protection of servers and web applications using restrictive firewalls; and
2.1.3.regular review, testing, and installation of security updates and patches to servers.

CHANGE MANAGEMENT

Change and Release Management

3.1.1.Fully Ramped maintains a formal change and release management policy and procedure for software, system, and configuration changes. Such policies and procedures include:

3.1.1.1.a process for testing and approving promotion of changes into production; and
3.1.1.2.a process for performing security assessments of changes into production.

Secure Application Development

3.2.1.Fully Ramped follows secure application development policies, procedures, and standards that are aligned to industry-standard practices, such as the OWASP Top 10.

Development Training

3.3.1.Fully Ramped provides secure code development training based on role for secure application development, configuration, testing, and deployment.

DATA ENCRYPTION AND DELETION

Fully Ramped establishes and maintains reasonable data encryption and deletion practices, including:

4.1.1.encryption of User Data while at rest using industry best practice encryption standards and methods;
4.1.2.encryption of User Data while in transit using industry standard encryption methods designed to encrypt communications between its server(s) and User browser(s);
4.1.3.use of cryptographic controls and approved algorithms for information protection within the service environment based on Fully Ramped's company policies and standards;
4.1.4.encryption of employee workstations with full disk encryption, strong passwords, and screen lockout; and
4.1.5.maintenance of policies and procedures regarding the deletion of User Data in accordance with applicable laws and NIST guidance (User Data is deleted upon User request and removed off Fully Ramped's cloud hosting provider servers).

SUB-PROCESSORS

Fully Ramped uses certain sub-processors to assist Fully Ramped in providing the Services. Prior to engaging any sub-processor who has access to, potentially will have access to, or processes User Data, Fully Ramped conducts an assessment of the security and privacy practices of the sub-processor to ensure they are commensurate with the level of data access the sub-processor will have and the scope of the services it will provide. Fully Ramped then enters into a written agreement with the sub-processor containing privacy, data protection, and data security obligations that ensure a level of protection appropriate to the sub-processor’s processing activities. Fully Ramped performs annual reviews of its sub-processors to ensure that compliance and security standards are maintained and material changes to processes are reviewed.

SYSTEM MONITORING AND VULNERABILITY MANAGEMENT

Fully Ramped regularly monitors its production environment for unauthorised intrusions, vulnerabilities, and the like. Fully Ramped's system monitoring measures include the following:

6.1.1.use of intrusion detection methods to prevent and identify potential security attacks from users outside the boundaries of the system;
6.1.2.performance of automated application and infrastructure vulnerability scans to identify vulnerabilities, classification of vulnerabilities using industry standards, and remediation of vulnerabilities based on severity level;
6.1.3.annual third-party penetration testing (an executive summary can be provided upon request);
6.1.4.annual risk assessments and continuous monitoring of Fully Ramped's risk register;
6.1.5.periodic third-party security audits;
6.1.6.monitoring, logging, and reporting on critical or suspicious activities with regard to network devices, including retention of logs for forensic-related analysis, maintenance of audit logs that record and examine activity within Fully Ramped's production environment, back-up of logs in real-time, and implementation of controls to prevent modification or tampering of logs;
6.1.7.operation of a “bug bounty” program to identify potential security vulnerabilities; and
6.1.8.deployment of anti-virus and malware tools to detect and remediate harmful code or programs that can negatively impact the Services.

PERSONNEL CONTROLS

Fully Ramped uses reasonable efforts to ensure the continued reliability of Fully Ramped employees who have access to User Data by implementing the following measures:

7.1.1.conducting background checks, subject to applicable laws, on all employees who may access User Data;
7.1.2.requiring employees to complete new-hire security training and acknowledge Fully Ramped's information security policies, including but not limited to Fully Ramped's Code of Conduct and Acceptable Use of Technology Resources Policy, upon hire;
7.1.3.requiring employees to complete annual privacy and security training covering topics that address their obligations to protect User Data as well as privacy and security best practices;
7.1.4.instructing employees to report potential personal data breaches to the Security team; and
7.1.5.imposing discipline for material violations of Fully Ramped's information security policies.

BACKUPS, BUSINESS CONTINUITY, AND DISASTER RECOVERY

Backups

8.1.1.Fully Ramped maintains a policy and procedure for performing backups of User Data.

Business Continuity Program

8.2.1.Fully Ramped maintains a reasonable business continuity program, including a disaster recovery plan, designed to minimise disruption to the Services. The plans are tested annually and the process is amended, as needed.

AUDIT REVIEW

Upon User’s written request (email to suffice), Fully Ramped will provide to User for review a copy of Fully Ramped's most recent annual audit results.

Location

Contact