Data Processing Agreement

1. Parties and Scope

This agreement is between your company (the customer) and Modul4r Solutions, Edmonton, Alberta, Canada. It covers the personal data we process for you when you use Vigilance.

2. Roles

You are the controller. We are the processor for the data from your computers. For your company's account details and billing, and for the verdict library, we are a controller, as our Privacy Policy says.

3. What We Process

We process this data for you:

• The name and email address you give us for readouts and receipts.
• For each joined computer: a random device id, a two-word name, the operating system, the join date, the hash of the device credential, and the counts for that computer.
• Count codes, which let us count different packages without naming them. We make them with a secret for your company.
• Flagged package versions and swap outcomes, linked to your company.
• The IP addresses of your computers, in memory only, for 5 minutes, to stop abuse.

We process no staff names, no code and no files. Annex 1 lists every field.

4. Purpose

We use the data only to run Vigilance for you, and as you tell us in writing. We also add counts into totals across many companies, where no company can be picked out.

5. Our Staff

Everyone who can reach your data is bound to keep it confidential.

6. Security

Annex 2 is the Security page, sections 4 to 7. We keep to what it says.

7. Sub-processors

Annex 3 lists the companies that process data for us. We tell you 30 days before we add one. You can object. If we cannot meet your objection, you can cancel and get a pro-rata refund.

8. Breach Notice

We tell you within 72 hours after we confirm a breach of your data.

9. Help With Requests

We help you answer requests from people about their data. We hold a random id and a two-word name for each computer, and counts. We cannot link an id to a person. Your company can.

10. Transfers

We store your data in Canada, in AWS Canada (Central). Requests pass through servers in other countries, mostly the United States, on the way. Where a sub-processor is outside Canada, we use the safeguards our Privacy Policy names. If your law needs more for transfers, tell us at support@vigihq.com.

11. Deletion at the End

When you stop being a customer:

• We delete your company secret for count codes on the day you leave.
• We keep each device record for 90 days after its computer leaves, then delete it.
• We remove the link to your company from flagged package versions 90 days after you leave.
• We keep your counts, readouts and receipts for 2 years, then delete them.

Ask and we delete your data sooner, except payment records that tax law makes us keep.

12. Audit

Once a year, you can send us a security questionnaire. We answer it in writing within 30 days. An on-site audit needs a separate written agreement.

13. Term and Order

This agreement runs while you use Vigilance. If it conflicts with our Terms, this agreement wins on data.

14. Alberta Organizations

If you are an organization in Alberta, we act as your service provider. We use the data only for the purpose in clause 4. We keep it secure as clause 6 says. We tell you of a breach as clause 8 says. We return or delete it as clause 11 says. We store it in Canada, as clause 10 says.

15. Governing Law

The laws of Alberta, Canada.

Annexes

Annex 1. The data page. Every field that leaves a computer, where it goes and how long we keep it: What Leaves the Computer. The signed copy holds a dated copy of that page.

Annex 2. The Security page. How we protect the data: Security. The signed copy holds a dated copy of that page.