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EU DPA

Overview

Platform.sh has adopted the European Commission’s June 2021 official, standardized DPA Clauses for controllers and processors in the EU or adequate countries, located at:https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021D0915&locale-en. The Clauses are not to be modified, except for adding or updating information in the Annexes, selecting between different options, or adding other clauses or additional safeguards that do not directly or indirectly contradict the Clauses.

As permitted, Platform.sh has made the following customizations:

  • Selected applicable regulation, Regulation (EU) 2016/679 (GDPR) - (Clause 1(a): Option 1)
  • Removed Optional Docking Clause - (Clause 5)
  • Added audit notice clause - (7.6 (f))
  • Selected Option 2: General Written Authorisation for use of sub-processors - (7.7 (a))
  • Specified time is 15 days to object to new sub-processors - (7.7 (a))
  • Selected applicable article and regulation, Regulation (EU) 2016/679 (GDPR) - (8(c)(4): Option 1)
  • Selected applicable article and regulation, Article 33(3) of Regulation (EU) 2016/679 (GDPR) - (9.1 (b): Option 1)
  • Selected applicable article and regulation, Article 34 of Regulation (EU) 2016/679 (GDPR) - (9.1(c): Option 1)
  • Selected applicable articles and regulation, Articles 33 and 34 of Regulation (EU) 2016/679 (GDPR) - (9.2 last paragraph: Option 1)
  • Removed Annex IV, list of sub-processors for specific authorisation, based on Clause 7.7 (a) selection of General Written Authorisation - (Annex IV)

Applicability

If you are an European Economic Area (EEA) customer, and you have agreed to our online Terms of Service, our EU DPA is automatically part of your agreement. If the details of this EU DPA are not acceptable to you, you need to make changes, or you are strictly bound by paper terms, please Contact Us. For existing customers, please create a support ticket to allow for identity verification.

Effective Date: September 1, 2022

Article 28 Data Processing Agreement (DPA)

SECTION I

Clause 1

Purpose and scope

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.

(c) These Clauses apply to the processing of personal data as specified in Annex II.

(d) Annexes I to III are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2

Invariability of the Clauses

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3

Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4

Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

SECTION II – OBLIGATIONS OF THE PARTIES

Clause 6

Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7

Obligations of the Parties

7.1. Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6 Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

(f) The audits shall in no event be less than thirty (30) days’ notice unless required by a Supervisory Authority. Controller shall use its best efforts (and ensure that each of its mandated auditors uses its best efforts) to avoid causing, and hereby indemnifies processor in respect of, any damage, injury or disruption to processor’s premises, equipment, personnel, data, and business (including any interference with the confidentiality or security of the data of processor’s other customers or the availability of the processor services to such other customers) while its personnel are on those premises in the course of such an audit or inspection.

7.7. Use of sub-processors

(a) GENERAL WRITTEN AUTHORISATION: The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least fifteen (15) days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) At the controller’s request, the processor shall provide a copy of such a subprocessor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secrets or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e) The processor shall agree to a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the subprocessor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8

Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions.

(c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

(1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;
(2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;
(3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;
(4) the obligations in Article 32 Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9

Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 Regulation (EU) 2016/679 or under Articles 34 and 35 Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b) in obtaining the following information which, pursuant to Article 33(3) Regulation (EU) 2016/679, shall be stated in the controller’s notification, and must at least include:

(1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
(2) the likely consequences of the personal data breach;
(3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III – FINAL PROVISIONS

Clause 10

Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;
(2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;
(3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.


Signature not required as this DPA is incorporated into the PSH Customer Agreement

ANNEX I: LIST OF PARTIES

Controller(s): [Identity and contact details of the controller(s), and, where applicable, of the controller’s data protection officer]

Name:

Address:

Contact person’s name, position and contact details:

Signature and accession date:

Processor(s): [Identity and contact details of the processor(s) and, where applicable, of the processor’s data protection officer].

Note: With respect to the GDPR, Platform.sh is both a Controller and a Processor.
Platform.sh is a Controller for the overall PaaS service and our Infrastructure Control Plane. Platform.sh is a Processor for the customer’s project environment which may contain personal data. Please see our Controller vs. Processor page for detailed information on how Platform.sh defines its roles under the GDPR and more specifically, how Platform.sh processes personal data as a Controller.

Name: Platform.sh SAS

Contact person’s name, position and contact details:

Address: 131 boulevard de Sébastopol 75002 Paris

Joey Stanford VP, Privacy & Security dpo@platform.sh

Signature and accession date:


ANNEX II: DESCRIPTION OF THE PROCESSING

Note: This Annex contains a description of the processing Platform.sh does as a Processor only. For an explanation of how Platform.sh may process personal data as a Controller, please see our Controller vs. Processor documentation.

Categories of data subjects whose personal data is processed

  • The data subject can be any person whose personal data is being collected by the controller and contained in the customer’s project environment.

Categories of personal data processed

  • Personal data that may be contained in the controller’s project environment.
  • Note: While Platform.sh provides the project environment and stores the data within as part of our service offering, Platform.sh does not know whether the environment includes personal data as defined by the GDPR, nor is Platform.sh responsible for the controller’s obligations as it relates to the collection of such personal data. However, Platform.sh operates under the assumption that the controller’s project environment includes personal information and potentially even sensitive personal data, and we treat the environment accordingly, such as applying the appropriate security and data protection safeguards which are audited by third-party auditors.

Sensitive data processed (if applicable) 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.

  • If a Platform.sh customer chooses to store sensitive personal data in their project environment.
  • Note: Platform.sh does not know what types of personal data, if any, are contained in the customer’s project environment. However, Platform.sh operates under the assumption that the customer’s environment includes personal data and potentially even sensitive personal data. Thus, Platform.sh applies appropriate technical, organizational, and security measures to the environment, as described in Annex III (see below).

Nature of the processing

  • Storing of personal data
  • Access of personal data
  • Erasure of personal data
  • Destruction of personal data

Purpose(s) for which the personal data is processed on behalf of the controller

  • To fulfill Platform.sh’s contractual terms related to project hosting (e.g. storage, code execution, backups, network traversal)
  • To access the customer’s project environment for the following reasons:
    • When requested to do so by the customer to fix a problem
    • To prevent an outage
    • To fix an outage
  • To comply with applicable legal obligations.

Duration of the processing

  • Until expressly stopped by customer, or
  • Until deletion of all customer data pursuant to termination of the Customer’s subscription, whichever event occurs first.

ANNEX III: TECHNICAL AND ORGANISATIONAL MEASURES

Technical and Organizational Security MeasureEvidence of Technical and Organizational Security Measure
Measures of pseudonymisation and encryption of personal data
  • We do not have a use case for anonymizing or pseudonymizing personal data. We only use personal data for the purposes of providing our service.
  • Data, including backups, is encrypted at rest and in transit.
Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services
  • We have an internal governance program that oversees compliance with external standards that include confidentiality, integrity, availability and resilience of processing systems and services. This program, along with the technical implementation, is audited annually by a third-party assessor.
  • We implement configuration standards in an automation manner whenever possible.
  • We internally and externally audit technical measures to ensure compliance.
Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident:
  • Backups on Platform.sh Professional are retained for at least 7 days. They will be purged between 7 days and 6 months, at Platform.sh’s discretion.
  • Platform.sh takes a byte-for-byte snapshot of Dedicated production environments every six (6) hours.
  • We regularly restore data in the course of normal business operations.
  • We perform an annual disaster recovery exercise that tests our ability to restore data
Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures in order to ensure the security of the processing
  • Testing: We have regular quality assurance testing and annual disaster recovery testing.
  • Assessing and Evaluating: We have weekly & monthly review meetings that cover our technical and organisational measures. Annually, we engage with third-party auditors to formally audit us against multiple industry standards. We also have an internal audit program that assesses our compliance with our internal and external requirements.
Measures for user identification and authorisation
  • We maintain a separate authorization system for customers which utilizes MFA.
  • Internally, we use a centralized identity provider that handles authentication and authorization which utilizes MFA
  • All of our sites adhere to our cryptographic controls policy, which mandates the use of strong, industry-standard cryptographic measures.
  • Customers have control and governance over user access via fine-grained, per-environment permissions
Measures for the protection of data during transmission
  • Data is encrypted in transit.
Measures for the protection of data during storage
  • Application data is encrypted at rest by default using encrypted ephemeral storage (typically using an AES-256 block cipher).
Measures for ensuring physical security of locations at which personal data are processed
  • We have no physical locations, and thus transfer this requirement to our IAAS providers.
Measures for ensuring events logging
  • Infrastructure: We implement a variety of logging methods. Logs are sent to separate, protected, locations. We regularly look at logs in the course of business. We are annually audited by a third party against our logging and monitoring implementation.
  • Customer environment: Logs for various tasks on an application container are available in the /var/log directory. They can be accessed on the normal shell after logging in with platform ssh. Application logs are the responsibility of the customer.
Measures for ensuring system configuration, including default configuration
  • We have implemented a configuration management system that automates standard configuration items. We also have CI/CD processes to ensure consistent configuration. These systems are audited annually by a third-party.
Measures for internal IT and IT security governance and management
  • Platform.sh has dedicated Security and Privacy Teams to implement and manage security strategy and IT governance. Various activities such as regular meetings and reporting, internal auditing, and third-party audits have been implemented.
  • We have a company-wide security strategy.
Measures for certification/assurance of processes and products
  • Platform.sh undergoes multiple third-party audits resulting in certification. Please see our website for a list of our industry certifications
Measures for ensuring data minimisation
  • Platform.sh collects only the personal information which is necessary for the purposes identified at the time of collection (e.g. to provide you with technical support, and to improve your services).
  • Platform.sh does not use or disclose personal information for purposes other than those which it has identified and received consent for in line with these Clauses and only retains personal information for as long as is necessary to fulfill such purposes.
Measures for ensuring data quality
  • Customers directly input their data into our systems.
  • Customers have direct access to their data with the ability to modify that data.
Measures for ensuring limited data retention
  • Platform.sh’s Privacy Team mandates a company-wide Data Retention Policy and audits this information internally.
  • Where feasible, we programmatically implement a data retention lifecycle.
  • Our data retention standards and implementation are audited by a third-party annually.
Measures for ensuring accountability
  • We have a designated Data Protection Officer that reports to the highest level of executive management.
  • We have Security and Privacy Teams who are accountable for the stewardship of personal information, including collection, usage, disclosure, retention, and transfer of personal information to third parties for processing.
  • We produce an internal report on Privacy and Security activities and metrics annually which is distributed to the entire company and our board of directors.
Measures for allowing data portability and ensuring erasure
  • Customers have direct access to their own data and can export it at will.
  • Data deletion is handled via our backend providers. When a volume is released back to the provider, the provider will perform a wipe on the data utilizing either NIST 800-88 or DoD 5220.22-M depending upon the offering. This wipe is done immediately before reuse. Additionally, the encryption key is destroyed when we release the volume back to the provider, adding another layer of protection.
  • Data subject deletion requests where Platform is the controller are handled via a support ticket. For contracts designating Platform as the processor, deletion requests should be sent to the controller and we will forward any that we receive.
For transfers to sub-processors, also describe the specific technical and organisational measures to be taken by the sub-processor to be able to provide assistance to the controller
  • There are no additional measures in place at this time.
Description of the specific technical and organisational measures to be taken by the processor to be able to provide assistance to the controller
  • We have a DPO email address of dpo@platform.sh for general queries.
  • We have a ticketing system for customers to ask specific questions about their account including data protection and security topics.
  • We have user documentation that includes security and privacy topics.
VersionDateChanges
1.02021-09-27
  • Original version
1.12022-08-29
  • Added a note to Annex I describing when Platform.sh is a Controller and when PSH is a Processor.
  • Removed language from Annex II that refers to Platform.sh acting as a Controller.
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