GDPR

GDPR Introduction

The European Union General Data Protection Regulation (GDPR) is a regulation that aims at unifying EU member state data privacy regulations into a single regulation, enforced on the EU single market. This article describes the GDPR compliance status of Upvoty.

If your company needs to ensure it is GDPR-compliant, it also needs to ensure its providers (ie. Upvoty) are also GDPR compliant. Upvoty is GDPR-compliant, and strictly enforces the regulation as to protect the user data we store.

 

Upvoty and GDPR

The GDPR regulation can be reduced to 11 important points. For each point, we explain how Upvoty handles its compliance. If we did not answer your questions in this article, you can still drop us a chat or email.

Also, please note that all Upvoty data processor providers have been checked to be all GDPR-compliant (Stripe). 

 

1. Awareness

All employees responsible for software development & infrastructure maintenance of Upvoty are fully aware of the GDPR requirements.

Also, code reviews are performed by the Data Protection Officers (as listed in this article), before any code deployment to the platform. This ensures security breaches and bad practices are not implemented by eg. a third party temporary contractor or a Upvoty employee, even if aware of GDPR requirements (this plays as a double human safety check).

 

2. Information we hold

Upvoty stores data on 2 kinds of parties:

  • Our customers

  • Our customers end-users (ie. the users of our customers)

2.1. Information held on our users

Upvoty collects account information for each user (we refer to them as customers in this article), including:

  • User first and last name, email, and profile picture

  • User payment details (includes invoicing information, eg. company address and country — the credit card number is stored by Stripe)

  • Browsed pages on the Controller’s website and referring URL
    b) date and time of visits to the Controller’s website
    c) technical information as screen resolution, operating system, browser type and device type
    d) geolocation data (country and city)
    e) IP address

2.2. Information held on our users’ end-users

Information held on our users’ end-users include:

  • End-user email address (if provided by end-user, thus involving a consent)

  • End-user message exchanges on the Upvoty platform (feedback boards)

  • End-user last activity date and time

  • End-user profile information (resolved from public data shared by end-user on the Internet, see notice below)

  • Browsed pages on the Controller’s website and referring URL
    b) date and time of visits to the Controller’s website
    c) technical information as screen resolution, operating system, browser type and device type
    d) geolocation data (country and city)
    e) IP address

Upvoty resolves end-user identity information (first and last name, avatar, company) from external APIs. Those external APIs sources from public information that the end-user consented to share on a third-party service (eg. on social networks such as LinkedIn or Twitter). This end-user identity information is stored on Upvoty services, for as long as the Upvoty customer wishes them to be stored in their Upvoty CRM database.

The information help on our users’ end-users is solely the responsibility of our users (ie. the individual websites using Upvoty). It is the responsibility of our users to manage the data they hold in their personal Upvoty Inbox and CRM, ie. to remove sensitive data if someone may happen to share it with them (eg. Social Security Numbers, etc.). It is our responsibility to secure access to this data (ie. only website operators can access it and have a right to rectification and deletion).

 

3. Communicating privacy information

Upvoty customers end-users privacy terms are the sole responsibility of Upvoty customers. They should be announced on Upvoty customers website.

 

4. Individuals’ right

  • Right to be informed

  • Right of access: our users can access all their data

  • Right of rectification

  • Right of erasure

  • Right to restrict processing

  • Right to data portability

  • Right to object

  • Right not to be subject to automated decision-making including profiling

 

5. Subject access requests

Upvoty replies to all access requests (positively or negatively) under 1 week (the legal limit from GDPR is 1 month).

We offer this free of charge for our customers (paid and free).

 

6. Lawful basis for processing personal data

Upvoty stores user data involving a consent (ie. a conversation both parties entered by will, and exchanged eg. emails).

It is the Upvoty customers responsibility to ensure user data is lawfully collected in the event they use our CRM features. For instance, if the emails that get collected from the Upvoty feedback boards get re-used for marketing campaign purposes either on Upvoty or an external system, the Upvoty customer has to ask for user consent upon collecting this email.

 

7. Consent

Consent is provided by our users explicitly when proceeding an action or task (eg. when they provide user data).

Upvoty allows its customers to submit user data in an automated way, via a frontend JavaScript API and backend REST API. This data must have been provided by the customer user in a consensual way, as it will get propagated to Upvoty in an automatic way (if the customer implemented such API in their source code).

 

8. Children

Upvoty does not offer online services to children, due to the nature of the service provided (business-to-business). Thus, we did not identified it as relevant to control the age of users signing up for services.

Children might still be able to use the Upvoty services, from the website or apps of a customer. To this extent, the Upvoty customer is responsible for checking against their own users and activities regarding children regulations.

 

9. Data breaches

Our team closely monitors any unauthorized system access, and has put in place multiple preventive measures to reduce the attack surface on our systems and services. From the start in 2018, Upvoty has had 0 major security issues.

Here are a few measures we took to reduce any attack surface:

  • Aggressive use of firewalls and network isolation in our infrastructure

  • No access to our server systems is allowed from the public Internet, trusted administrators from the Upvoty team need to connect via a trusted VPN network

  • We monitor any security flaw in any library we may use in our running backends, and patch them as soon as an update is issued

  • Use of 2-Factor-Authentication on all our sensitive accounts (eg. hosting provider, etc.)

  • Isolate data stores and sensitive backends on different servers

  • All platform backups are GPG/PGP-encrypted and stored privately, retained for a maximum of 1 week

The points listed above help reduce the probability of a major data breach occurring.

 

10. Data Protection by Design and Data Protection Impact Assessments

Whenever Upvoty develops a new system, security comes as a first when designing the architecture of such a system. Our first goal is to protect the integrity of the new production system, and the second goal to protect the user data that’s being stored and used by that system.

 

11. Contact Us

If you have any questions about these Terms, please contact us at hi@upvoty.com.

These Terms were published on 12.01.2019.