Data Processing Addendum

Scope

The Customer instructs Visitly to Process the following Personal Data for the purpose of the Agreement and pursuant to the DPA:

Definitions in this Addendum:

Visitly, we, us, our, Data Importer, or Processor refers to the provider of Visitly website and services, (collectively referred to as Visitly Service).

‍You, Customer, Data Exported, or Controller refers to the company or organization that signs up to use Visitly Service to manage the relationships with your consumers or service users.

‍Party or Parties refers to Visitly and/or the Customer depending on the context.

‍Personnel refers to those individuals who are employed by or are under contract to perform a service on behalf of one of the parties. Personnel may have rights to their personal data (including business contact information) if they reside in the EU. It is important to be clear about how personnel’s rights are protected.

‍Sub-processor is a Third-party, independent contractor, vendor, and suppliers who provide specific services and products related to Visitly’s website and our services, such as hosting, credit card processing, fraud screening, and mailing list hosting (“third-party” or “outside contractor” shall have similar meanings).

‍Incident means (a) a complaint or a request with respect to the exercise of an individual’s rights under the GDPR; (b) an investigation into or seizure of the personal data by government officials, or a specific indication that such an investigation or seizure is imminent; or (c) any breach of the security and/or confidentiality as set out in this DPA leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the personal data, or any indication of such breach having taken place or being about to take place.

‍Data Subject, Personal Data, Member State, Controller, Processor, and Processing shall have the same meaning as in the GDPR and applicable Data Protection Laws from time to time, and their cognate terms shall be construed accordingly.

‍Data Protection Laws means, as binding on either party or the services:

• The Directive 95/46/EC (Data Protection Directive) and/or Data Protection Act 1998 or the GDPR;
• Any laws which implement any such laws or regulations; and
• Any laws that replace, extend, re-enact, consolidate, or amend any of the foregoing.

‍Data Subject has the meaning given in applicable Data Protection Laws from time to time.GDPR means the General Data Protection Regulation (EU) 2016/679.

‍International Organization has the meaning in the GDPR.

‍Personal Data Has the meaning given in applicable Data Protection Laws from time to time.
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‍Personal Data Breach has the meaning given in applicable Data Protection Laws from time to time.

‍Processing has the meaning given in applicable Data Protection Laws from time to time (and related expressions, including process, processed, processing, and processes shall be construed accordingly).

‍Protected Data means Personal Data received from or on your behalf of and in connection with the performance of our obligations under the applicable Terms of Service.

Standard Contractual Clauses (SCCs) are the contractual clauses developed by the European Commission to ensure that any personal data leaving the European Economic Area (EEA) will be transferred in compliance with EU data protection laws and as may be amended by the European Commission from time to time.

‍Supervisory Authority means the relevant supervisory authority with responsibilities for privacy or data protection matters in the jurisdiction of the Controller.

Undertakings regarding personal data

1. Each party agrees that personal data shall be treated as confidential information under this DPA. In addition, each party shall at all times comply with applicable laws relating to data protection in the relevant jurisdiction with respect to each other’s personal data.
2. Personal Data shall remain the property of the disclosing party. Visitly acknowledges that the Customer is the controller and maintains control over the data subject’s personal data.
3. Visitly will process Customer’s personal data only to the extent strictly necessary for the purpose of providing the services in accordance with the ToS and any further written instructions from the Customer that are mutually agreed upon in writing and in accordance with applicable laws. Visitly agrees that:

• it will implement and maintain a reasonable and appropriate security program comprising adequate security, technical, and organizational measures (link to Technical and Organizational Measures) to protect against unauthorized, unlawful, or accidental processing, use, erasure, loss or destruction of, or damage to, Customer personal data;
• it will not modify, alter, delete, publish, or disclose any Customer personal data to any third party, nor allow any third party to process such personal data on Visitly’s behalf unless the third party is bound to similar confidentiality and data handling provisions;
• it shall ensure that access to personal data is limited to those personnel who require such access to perform its obligations under the ToS, and its personnel engaged in the processing of personal data are informed of the confidential nature of the personal data, have received appropriate training on their responsibilities and have executed written confidentiality agreements. Visitly shall ensure that such confidentiality obligations survive the termination of the personnel engagement; and

1. Upon termination of your account Visitly will delete, destroy, or anonymize the personal data in accordance with our standard backup and retention policy per the ToS, normally, no later than 60 days, unless we are required to retain personal data due to Union, Member State or United States laws; in which case Visitly reserves the right to retain personal data.
2. The parties acknowledge that Customer may from time to time be in possession of personal data relating to Visitly’s personnel. Visitly warrants that it has provided all necessary notifications and obtained all necessary consents, authorizations, approvals, and/or agreements as required under any applicable law to enable: (i) the disclosure of Visitly’s personal data to Customer; and (ii) further processing of such Visitly personal data by Customer.

Undertakings regarding sub-processors

1. The parties acknowledge that Visitly may engage third-party sub-processors in connection with the obligations of the ToS. For any sub-processor with which Visitly engages, we will enter into a written agreement containing data protection obligations no less protective than those in this amendment and as required to protect Customer’s personal data to the standard required by the GDPR
2. Visitly shall maintain the list of current Sub-Processors online. Visitly shall update the list with details of any addition or replacement of sub-processors at least 10 days prior to any change. If Customer has a reasonable basis to object to Visitly’s change in sub-processors, Customer shall notify Visitly promptly within 10 business days after receipt of Visitly’s notice regarding sub-processor changes. Customer may object to a new sub-processor appointment or replacement, provided such objection is based on reasonable grounds related to data protection. Visitly will use reasonable efforts to work in good faith with Customer to find an acceptable, reasonable, alternate solution. If the parties are not able to agree to an alternate solution, Customer may suspend or terminate their account.

Customer undertakings and Visitly’s assistance

1. Customer warrants that it has all necessary rights to provide to Visitly the personal data for processing in connection with the provision of Visitly Services.
2. To the extent required by applicable law, Customer is responsible for ensuring that any data subject consents that may be necessary to this processing are obtained, and for ensuring that a record of such consents is maintained, including any consent to use personal data that is obtained from third parties. Should such consent be revoked by a data subject, Customer is responsible for communicating the fact of such revocation to Visitly, and Visitly remains responsible for implementing any Customer instruction with respect to the further processing of that personal data, or, as may be in accordance with any of Visitly’s legal obligations.
3. Customer understands, as a controller, that it is responsible (as between Customer and Visitly) for:

• determining the lawfulness of any processing, performing any required data protection impact assessments, and accounting to regulators and individuals, as may be needed;
• making reasonable efforts to verify parental consent when data is collected on a data subject under 16 years of age;
• providing relevant privacy notices to data subjects as may be required in your jurisdiction, including notice of their rights and providing the mechanisms for individuals to exercise those rights;
• responding to requests from individuals about their data and the processing of the same, including requests to have personal data altered, corrected, or erased, and providing copies of the actual data processed;
• implementing your own appropriate technical and organizational measures to ensure and demonstrate processing in accordance with this DPA;
• notifying individuals and any relevant regulators or authorities of any incident as may be required by law in your jurisdiction.

1. Visitly shall assist the Customer by implementing appropriate technical and organizational measures, insofar as this is reasonably and commercially possible, in fulfilling Customer’s obligations to respond to individuals’ requests to exercise rights under the GDPR.
2. On an annual basis, Visitly will procure an independent audit of its code base and systems by independent third parties to demonstrate compliance with its obligations under this DPA. Upon Customer request, and subject to confidentiality obligations, Visitly shall make available to Customer information reasonably necessary to demonstrate compliance with Visitly’s obligations under this DPA. At a minimum, upon written request, Visitly will produce to Customer an executive summary of any third-party audit reports concerning the adequacy of Visitly’s technical security measures as described in the Security Policy.
3. Customer may contact Visitly in writing to schedule an audit of the procedures relevant to the protection of personal data. Customer shall reimburse Visitly for any time or resources expended for any such on-site audit at Visitly’s then-current professional services rates, which shall be made available to Customer upon request. Before the commencement of any such on-site audit, Customer and Visitly shall mutually agree upon the scope, timing, and duration of the audit. Customer shall promptly notify Visitly with information regarding any non-compliance discovered during the course of an audit.

Incident Management

• When either party becomes aware of an incident that impacts the processing of personal data, it shall promptly notify the other about the incident and shall reasonably cooperate in order to enable the other party to perform a thorough investigation into the incident, to formulate a correct response, and to take suitable further steps in respect of the incident.
• Both parties shall at all times have in place written procedures that enable them to promptly respond to the other about an incident. Where the incident is reasonably likely to require a data breach notification under applicable laws, the party responsible for the incident shall notify the other without undue delay of having become aware of such an incident.
• Any notifications made under this section shall be made to privacy@www.visitly.io (when made to Visitly) and to our point of contact with you (when made to the Customer) and shall contain: (i) a description of the nature of the incident, including, where possible, the categories and approximate number of individuals concerned and the categories and approximate number of records concerned; (ii) the name and contact details of the point of contact where more information can be obtained; (iii) a description of the likely consequences of the incident; and (iv) a description of the measures taken or proposed to be taken to address the incident including, where appropriate, measures to mitigate its possible adverse effects.

Data Transfer Requirements

The Standard Contractual Clauses will apply to all processing of Personal Data by Customer where the Personal Data is transferred from the EEA or the United Kingdom to outside the EEA or United Kingdom, from a Data Exporter acting as Controller to a Data Importer acting as Processor to any country or recipient: (i) not recognized by the European Commission as providing an adequate level of protection for Personal Data (as described in the Data Protection Legislation), and (ii) not covered by a suitable framework recognized by the relevant authorities or courts as providing an adequate level of protection for Personal Data.

All transfers of Personal Data to a third country or an international organization will be subject to appropriate safeguards and such transfers and safeguards will be documented according to Articles 46 and 30(2) described in the GDPR.

In addition to the obligations under this section, the parties agree to the following additional safeguards:

1. All Personal Data on the Products shall be encrypted both in transit and at rest using state of the art encryption technology that is robust against the performance of cryptanalysis;
2. If, for any reason, the transfer of Personal Data under the Standard Contractual Clauses or other lawful data transfer mechanism, approved by the relevant data protection authority, ceases to be lawful or the additional safeguards are no longer effective, Customer may, at its discretion, require Processor to: (i) cease transfers of the Personal Data to, or access to such Personal Data from, the relevant jurisdictions; or (ii) promptly cooperate with Customer to facilitate the use of an alternative lawful data transfer mechanism and any additional safeguards that will permit Customer to continue to benefit from the Products in compliance with applicable Data Protection Legislation. If Customer and Processor are unable to implement such alternate data transfer mechanism promptly, then Customer may, at its option, upon written notice to Processor terminate the Agreement, suspend the transfer, or reduce the scope of Products to exclude Personal Data, without liability or penalty of any kind.

To the extent any new or further measures are legally required by relevant Data Protection Legislation to be implemented by Processor to ensure ongoing compliance with the Standard Contractual Clauses, Processor shall implement such measures within a reasonable time.

 Indemnification

You agree to indemnify and hold Visitly, its officers, employees, agents, and representatives harmless, including costs and attorneys’ fees, from any claim or demand made by any third party arising directly or indirectly out of (i) your access to or use of Visitly’s platform, (ii) your violation of the Terms of Service or this Addendum, (iii) your infringement, or the infringement by any third party using your registration information, of any intellectual property, or other right of any person or entity, including but not limited to any third party claims relating to your use, disclosure, or transfer of Personal Data to Visitly, and (iv) the Data or any other materials provided to Visitly.

 Duration and Termination

1. This DPA shall come into effect on the commencement of the ToS and shall be in force and effect until it is changed or terminated in accordance with the ToS agreement. If after the termination of the ToS, further Processing of Personal Data by Visitly is necessary for the winding-up of the Agreement or provided by law, e.g., regarding the return of Personal Data, this DPA shall continue to apply until the completion of the winding-up or return, as applicable.
2. Termination or expiration of this DPA shall not discharge the parties from the confidentiality obligations herein. The Parties agree that on the termination of the ToS, Visitly shall, at the choice of Customer, return or delete all (copies of) the Personal Data Processed on the Customer’s behalf unless legislation imposed upon Visitly prevents it from returning or destroying all or part of the Personal Data transferred.

 Obligations

Definitions
Terms not otherwise defined herein shall have the meaning given to them in the EU GDPR or the Agreement. The following terms shall have the corresponding meanings assigned to them below:

1. “Data Transfer” means a transfer of the Personal Data from the Controller to the Processor, or between two establishments of the Processor, or with a Sub-processor by the Processor.
2. “EU GDPR” means the 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).
3. “Standard Contractual Clauses” means the contractual clauses attached hereto as Schedule 1 pursuant to the European Commission’s Implementing Decision (EU) 2021/914 of 4 June 2021 on Standard Contractual Clauses for the transfer of Personal Data to processors established in third countries which do not ensure an adequate level of data protection.
4. “Processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
5. “Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
6. “Sub-processor” means a processor/ sub-contractor appointed by the Processor for the provision of all or parts of the Services and Processes the Personal Data as provided by the Controller.

Purpose of this Agreement
This DPA sets out various obligations of the Processor in relation to the Processing of Personal Data and shall be limited to the Processor’s obligations under the Agreement. If there is a conflict between the provisions of the Agreement and this DPA, the provisions of this DPA shall prevail.

Categories of Personal Data and Data Subjects
The Controller authorizes permission to the Processor to process the Personal Data to the extent of which is determined and regulated by the Controller. The current nature of the Personal Data is specified in Annex I to Schedule 1 to this DPA.

Purpose of Processing
The objective of Processing of Personal Data by the Processor shall be limited to the Processor’s provision of the Services to the Controller and or its Client, pursuant to the Agreement.

Duration of Processing
The Processor will Process Personal Data for the duration of the Agreement, unless otherwise agreed upon in writing by the Controller.

Data Controller’s Obligations

1. The Data Controller shall warrant that it has all necessary rights to provide the Personal Data to the Data Processor for the Processing to be performed in relation to the agreed services. To the extent required by Data Privacy Laws, Data Controller is responsible for ensuring that it provides such Personal Data to Data Processor based on an appropriate legal basis allowing lawful processing activities, including any necessary Data Subject consents to this Processing are obtained, and for ensuring that a record of such consents is maintained. Should such consent be revoked by the Data Subject, the Data Controller is responsible for communicating the fact of such revocation to the Data Processor.
2. The Data Controller shall provide all natural persons from whom it collects Personal Data with the relevant privacy notice.
3. The Data Controller shall request the Data Processor to purge Personal Data when required by the Data Controller or any Data Subject whom it collects Personal Data unless the Data Processor is otherwise required to retain the Personal Data by applicable law.
4. The Data Controller shall immediately advise the Data Processor in writing if it receives or learns of any:
   Complaint or allegation indicating a violation of Data Privacy Laws regarding Personal Data;
   Request from one or more individuals seeking to access, correct, or delete Personal Data;
   Inquiry or complaint from one or more individuals relating to the collection, processing, use, or transfer of Personal Data;
   and  Any regulatory request, search warrant, or other legal, regulatory, administrative, or governmental process seeking Personal Data

Data Processor’s Obligations

1. The Processor will follow written and documented instructions received, including email, from the Controller, its affiliate, agents, or personnel, with respect to the Processing of Personal Data (each, an “Instruction”).
2. The Processing described in the Agreement and the relating documentation shall be considered as Instruction from the Controller.
3. At the Data Controller’s request, the Data Processor will provide reasonable assistance to the Data Controller in responding to/ complying with requests/ directions by Data Subject in exercising their rights or of the applicable regulatory authorities regarding Data Processor’s Processing of Personal Data.
4. In relation to the Personal Data, Data Processor shall obtain consent (where necessary) and/or provide notice to the Data Subject in accordance with Data Protection Laws to enable shared Personal Data to be provided to, and used by, the other Party as contemplated by this Agreement.
5. Where shared Personal Data is transferred outside the Data Processor’s territorial boundaries, the transferor shall ensure that the recipient of such data is under contractual obligations to protect such Personal Data to the same or higher standards as those imposed under this Addendum and the Data Protection Laws.

Data Secrecy

1. To Process the Personal Data, the Processor will use personnel who are Informed of the confidential nature of the Personal Data, and  Perform the Services in accordance with the Agreement.
2. The Processor will regularly train individuals having access to Personal Data in data security and data privacy in accordance with accepted industry practice and shall ensure that all the Personal Data is kept strictly confidential.
3. The Processor will maintain appropriate technical and organizational measures for protection of the security, confidentiality, and integrity of the Personal Data as per the specifications as per the standards mutually agreed in writing by the Parties.

Audit Rights

1. Upon Controller’s reasonable request, the Processor will make available to the Controller, information as is reasonably necessary to demonstrate Processor’s compliance with its obligations under the EU GDPR or other applicable laws in respect of its Processing of the Personal Data.
2. When the Controller wishes to conduct the audit (by itself or through a representative) at Processor’s site, it shall provide at least fifteen (15) days’ prior written notice to the Processor; the Processor will provide reasonable cooperation and assistance in relation to audits, including inspections, conducted by the Controller or its representative.
3. The Controller shall bear the expense of such an audit.

Mechanism of Data Transfers
Any Data Transfer for the purpose of Processing by the Processor in a country outside the European Economic Area (the “EEA”) shall only take place in compliance as detailed in Schedule 1 to the DPA. Where such model clauses have not been executed at the same time as this DPA, the Processor shall not unduly withhold the execution of such template model clauses, where the transfer of Personal Data outside of the EEA is required for the performance of the Agreement.

Sub-processors

1. The Controller acknowledges and agrees that the Processor, may engage a third-party Sub-processor(s) in connection with the performance of the Services, provided such Sub-processor(s) take technical and organizational measures to ensure confidentiality of Personal Data shared with them; The current Sub-processors engaged by the Processors and approved by the Controller are listed in Annex III of Schedule 1 hereto. In accordance with Article 28(4) of the GDPR, the Processor shall remain liable to Controller for any failure on behalf of a Sub-processor to fulfil its data protection obligations under the DPA in connection with the performance of the Services.
2. If the Controller has a concern that the Sub-processor(s) Processing of Personal Data is reasonably likely to cause the Controller to breach its data protection obligations under the GDPR, the Controller may object to Processor’s use of such Sub-processor and the Processor and Controller shall confer in good faith to address such concern.

Here are a list of processors:

Personal Data Breach Notification

1. The Processor shall maintain defined procedures in case of a Personal Data Breach (as defined under the GDPR) and shall without undue delay notify Controller if it becomes aware of any Personal Data Breach unless such Data Breach is unlikely to result in a risk to the rights and freedoms of natural persons.
2. The Processor shall provide the Controller with all reasonable assistance to comply with the notification of Personal Data Breach to Supervisory Authority and/or the Data Subject, to identify the cause of such Data Breach and take such commercially reasonable steps as reasonably required to mitigate and remedy such Data Breach.
3. No Acknowledgement of Fault by Processor. Processor’s notification of or response to a Personal Data Breach under this DPA will not be construed as an acknowledgement by Processor of any fault or liability with respect to the data incident.

Return and Deletion of Personal Data

1. The Processor shall at least thirty (30) days from the end of the Agreement or cessation of the Processor’s Services under the Agreement, whichever occurs earlier, shall return to the Controller all the Personal Data, or if the Controller so instructs, the Processor shall have the Personal Data deleted. The Processor shall return such Personal Data in a commonly used format or in the current format in which it was stored at discretion of the Controller, soon as reasonably practicable following receipt of Controller’s notification.
2. In any case, the Processor shall delete Personal Data including all the copies of it as soon as reasonably practicable following the end of the Agreement.

Technical and Organizational Measures
Having regard to the state of technological development and the cost of implementing any measures, the Processor will take appropriate technical and organizational measures against the unauthorized or unlawful processing of Personal Data and against the accidental loss or destruction of, or damage to, Personal Data to ensure a level of security appropriate to: (a) the harm that might result from unauthorized or unlawful processing or accidental loss, destruction or damage; and (b) the nature of the data to be protected.

SCHEDULE 1

ANNEX I

TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA

Description of the  technical and organisational security measures implemented by Visitly LLC as the data processor/data importer 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.

Security Management System

1. Organization. Visitly LLC designates qualified security personnel whose responsibilities include development, implementation, and ongoing maintenance of the Information Security Program.
2. Policies. Management reviews and supports all security related policies to ensure the security, availability, integrity and confidentiality of Customer Personal Data.  These policies are updated at least once annually.
3. Assessments. Visitly LLC engages a reputable independent third-party to perform risk assessments of all systems containing Customer Personal Data at least once annually.
4. Risk Treatment. Visitly LLC maintains a formal and effective risk treatment program that includes penetration testing, vulnerability management and patch management to identify and protect against potential threats to the security, integrity or confidentiality of Customer Personal Data.
5. Vendor Management. Visitly LLC maintains an effective vendor management program.
6. Incident Management. Visitly LLC reviews security incidents regularly, including effective determination of root cause and corrective action.
7. Standards. Visitly LLC operates an information security management system that complies with the requirements of ISO/IEC 27001:2022 standard.

Personnel Security.
Visitly LLC personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. Visitly LLC conducts reasonably appropriate background checks on any employees who will have access to client data under this Agreement, including in relation to employment history and criminal records, to the extent legally permissible and in accordance with applicable local labor law, customary practice and statutory regulations.

Personnel are required to execute a confidentiality agreement in writing at the time of hire and to protect Customer Personal Data at all times. Personnel must acknowledge receipt of, and compliance with, Visitly LLC’s confidentiality, privacy and security policies. Personnel are provided with privacy and security training on how to implement and comply with the Information Security Program. Personnel handling Customer Personal Data are required to complete additional requirements appropriate to their role (e.g., certifications). Visitly LLC’s personnel will not process Customer Personal Data without authorization.

Access Controls

1. Access Management. Visitly LLC maintains a formal access management process for the request, review, approval and provisioning of all personnel with access to Customer Personal Data to limit access to Customer Personal Data and systems storing, accessing or transmitting Customer Personal Data to properly authorized persons having a need for such access. Access reviews are conducted periodically to ensure that only those personnel with access to Customer Personal Data still require it.
2. Infrastructure Security Personnel. Visitly LLC has, and maintains, a security policy for its personnel, and requires security training as part of the training package for its personnel. Visitly LLC’s infrastructure security personnel are responsible for the ongoing monitoring of Visitly LLC’s security infrastructure, the review of the Services, and for responding to security incidents.
3. Access Control and Privilege Management. Visitly LLC’s and Customer’s administrators and end users must authenticate themselves via a Multi-Factor authentication system or via a single sign on system in order to use the Services.
4. Internal Data Access Processes and Policies – Access Policy. Visitly LLC’s internal data access processes and policies are designed to protect against unauthorized access, use, disclosure, alteration or destruction of Customer Personal Data. Visitly LLC designs its systems to only allow authorized persons to access data they are authorized to access based on principles of “least privileged” and “need to know”, and to prevent others who should not have access from obtaining access.  Visitly LLC requires the use of unique user IDs, strong passwords, two factor authentication and carefully monitored access lists to minimize the potential for unauthorized account use. The granting or modification of access rights is based on: the authorized personnel’s job responsibilities; job duty requirements necessary to perform authorized tasks; a need to know basis; and must be in accordance with Visitly LLC’s internal data access policies and training. Approvals are managed by workflow tools that maintain audit records of all changes. Access to systems is logged to create an audit trail for accountability. Where passwords are employed for authentication (e.g., login to workstations), password policies follow industry standard practices. These standards include password complexity, password expiry, password lockout, restrictions on password reuse and re-prompt for password after a period of inactivity

Data Center and Network Security

1. Infrastructure. Visitly LLC has AWS as its data center.
2. Resiliency. Multi Availability Zones are enabled on AWS and Visitly LLC conducts Backup Restoration Testing on regular basis to ensure resiliency.
3. Server Operating Systems. Visitly LLC’s servers are customized for the application environment and the servers have been hardened for the security of the Services. Visitly LLC employs a code review process to increase the security of the code used to provide the Services and enhance the security products in production environments.
4. Disaster Recovery. Visitly LLC replicates data over multiple systems to help to protect against accidental destruction or loss. Visitly LLC has designed and regularly plans and tests its disaster recovery programs.
5. Security Logs. Visitly LLC’s systems have logging enabled to their respective system log facility in order to support the security audits, and monitor and detect actual and attempted attacks on, or intrusions into, Visitly LLC’s systems.
6. Vulnerability Management. Visitly LLC performs regular vulnerability scans on all infrastructure components of its production and development environment.  Vulnerabilities are remediated on a risk basis, with Critical, High and Medium security patches for all components installed as soon as commercially possible.

Networks and Transmission

1. Data Transmission. Transmissions on production environment are transmitted via Internet standard protocols.
2. External Attack Surface. AWS Security Group which is equivalent to virtual firewall is in place for Production environment on AWS.
3. Incident Response. Visitly LLC maintains incident management policies and procedures, including detailed security incident escalation procedures. Visitly LLC monitors a variety of communication channels for security incidents, and Visitly LLC’s security personnel will react promptly to suspected or known incidents, mitigate harmful effects of such security incidents, and document such security incidents and their outcomes.
4. Encryption Technologies. Visitly LLC makes HTTPS encryption (also referred to as SSL or TLS) available for data in transit.

Data Storage, Isolation, Authentication, and Destruction.
Visitly LLC stores data in a multi-tenant environment on AWS servers. Data, the Services database and file system architecture are replicated between multiple availability zones on AWS. Visitly LLC logically isolates the data of different customers. A central authentication system is used across all Services to increase uniform security of data. Visitly LLC ensures secure disposal of Client Data through the use of a series of data destruction processes.

Data Processing Officer: Luv Bedi
Address: 2261 Market St #5206 San Francisco, California 94114, US
Contact emailt: support@visitly.io