Соглашение об обработке данных

This agreement applies where Infinity Curve processes personal data on your behalf through Schemahaus. It forms part of the terms of service. Where the terms and this agreement disagree about processing personal data, this agreement wins.

Under this agreement you are the controller and we are the processor.

1. What we process, and why

Subject matter. Providing Schemahaus to you.

Duration. For as long as your organisation exists, plus the thirty-day deletion window.

Nature and purpose. Storing, organising, retrieving, transmitting and deleting the content and records you put into the service, and doing whatever a feature you switch on requires.

Categories of data subject. The people you invite as members; the authors you record; any person described in the content you write; and, if you use the newsletter or contact features, the people who give you their details.

Categories of personal data. Names, email addresses, roles, biographies, and whatever else appears in content you choose to store. We do not require special-category data and ask that you do not put it here without telling us.

2. Our obligations

We will:

• process personal data only on your documented instructions, which the terms and your use of the product constitute, unless a law we are subject to requires otherwise — in which case we will tell you before processing, unless that law forbids it;

• ensure the people who handle it are bound by confidentiality;

• take the technical and organisational measures in section 5;

• not engage a subprocessor without notice, and remain responsible for what ours do;

• help you respond to a data subject's request, and to your obligations on security, breach notification and impact assessments, taking into account what we know and what the product can do;

• at your choice, delete or return the personal data when we stop providing the service.

3. Your obligations

You will make sure you have a lawful basis for putting personal data into Schemahaus, that you have told the people concerned what they need to be told, and that your instructions to us do not require us to break the law. You are responsible for the roles you grant and for what your members do with them.

4. Subprocessors

The subprocessor list is published and forms part of this agreement. We will give at least thirty days' notice before adding one, and you may object on reasonable grounds; if we cannot resolve the objection you may cancel and we will refund the unused part of what you have paid.

5. Security

We will keep measures appropriate to the risk, including:

• encryption in transit everywhere, and at rest for backups and for stored secrets;

• tenancy enforced in the software, so that a query cannot reach another organisation's rows, and cross-tenant references answer "not found" rather than "forbidden";

• role-based access control, with the least role that does the job as the default;

• an audit log of actions that change something;

• backups taken nightly, encrypted, held in a different country from the primary data, and restored as a test rather than assumed to work;

• separation of the delivery path from the draft path, so that unpublished content cannot be served by an endpoint meant for published content.

6. Breaches

If we become aware of a personal data breach affecting your data we will tell you without undue delay, and in any event within seventy-two hours of becoming aware, with what we know and what we are doing. We will not wait until we understand it fully before telling you.

7. Audits

We will make available the information needed to show we are meeting this agreement, and will allow an audit by you or an auditor you appoint, on reasonable notice, no more than once a year unless a regulator or a breach requires otherwise, and subject to confidentiality.

8. Transfers

Personal data stays in the European Union except for machine translation, which is optional and can be disabled per site; where it is used, the transfer relies on the standard contractual clauses. The subprocessor list says which subprocessor is involved and what it receives.

9. Deletion

When your organisation is closed we mark it deleted and purge it after thirty days. You may export everything before then. We will not keep a copy afterwards except where a law requires it, in which case we keep only what that law requires, for only as long as it requires.