Last Updated: September 2026
This Data Processing Agreement (“DPA”) is entered into between Vendavo, Inc., located at 1200 17th Street, Suite 1000, Denver, Colorado, USA (“Vendavo”), and the Customer defined in the associated Agreement (defined below). This DPA is effective on the date that the applicable Agreement has been duly executed by both parties. In signing the Agreement, Customer enters into this DPA on behalf of itself and, to the extent required by Data Protection Law, its affiliates.
This DPA is only valid and legally binding if the Customer entity signing the Agreement is: (a) a party to an Agreement subject to which Vendavo is a data processor for the purposes of GDPR or a service provider for the purposes of CCPA; and (b) a data controller to which Article 3 of the GDPR applies or a business to which the CCPA applies. This DPA forms part of such Agreement. If multiple Agreements exist between the parties, a separate instance of this DPA shall apply with respect to each Agreement.
This DPA consists of the main body of the DPA and Exhibit A (which contains three annexes).
By signing this DPA, or by signing the Agreement, the parties hereby agree and affirm that the signatures constitute full and unconditional acceptance of the terms and conditions contained in the Standard Contractual Clauses and their respective annexes, as incorporated by reference into this DPA. The parties acknowledge that the Standard Contractual Clauses form an integral part of this DPA and agree to execute all obligations as set forth therein.
“Agreement” means any agreement between Vendavo and the Customer, or between the Customer and a Vendavo-authorized partner, under which Products are provided by Vendavo and/or a Vendavo-authorized partner to that Customer to the extent Vendavo is processing Personal Data under such agreement between Customer and Vendavo-authorized partner. Such an Agreement may include various counterparts.
“controller”, “data subject”, “personal data”, “personal data breach,” “process”, “processing”, “processor”, and “supervisory authority” have the same meanings as in GDPR. “Business” and “Service Provider” have the meanings ascribed to them in CCPA.
“CCPA” means the California Consumer Privacy Act of 2018, as amended by the CPRA or otherwise, or as replaced.
“CPRA” means the California Privacy Rights Act of 2020, effective on January 1, 2023, as may be amended from time to time.
“Customer” means the customer that is identified on the Agreement, and that is a party to, the Agreement and this DPA, and any Customer affiliates.
“Data Privacy Framework” or “DPF” means, where applicable, the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, or the Swiss-U.S. Data Privacy Framework, each as administered by the U.S. Department of Commerce.
“Data Protection Law” means, as applicable: (i) the General Data Protection Regulation (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 (“EU GDPR“); (ii) the EU GDPR as saved into United Kingdom law by virtue of section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018 (the “UK GDPR“); (iii) the Swiss Federal Act on Data Protection of 25 September 2020 (“FADP“); (iv) any and all applicable national data protection laws and regulations made under, pursuant to or that apply in conjunction with any of (i), (ii) or (iii); in each case as amended or replaced from time to time.
“GDPR” means (i) the EU GDPR, and/or (ii) the UK GDPR, as may be applicable.
“Personal Data” means personal data that is submitted to Vendavo by Customer and processed by Vendavo for the purposes of providing the Products to Customer.
“Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer Personal Data processed by Vendavo under this DPA.
“Products” means the Vendavo services and products ordered, subscribed to, or licensed by Customer in an Agreement, including software, technical support and professional services as set out in the applicable Agreement.
“Restricted Transfer” means: (i) where the EU GDPR applies, a transfer of Personal Data from the European Economic Area to a country outside of the European Economic Area which is not subject to an adequacy determination by the European Commission; (ii) where the UK GDPR applies, a transfer of Personal Data from the United Kingdom to any other country which is not based on adequacy regulations pursuant to Section 17A of the United Kingdom Data Protection Act 2018; and (iii) where the FADP applies, a transfer of Personal Data from Switzerland to any other country which is not subject to an adequacy determination by the Swiss Federal Council.
“Standard Contractual Clauses” or “Clauses” means (i) where the EU GDPR applies, the contractual clauses annexed to the European Commission’s Implementing Decision 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council (“EU SCCs“), as annexed to this Agreement; and (ii) where the UK GDPR applies, the “International Data Transfer Addendum to the EU Commission Standard Contractual Clauses” issued by the Information Commissioner under s.119A(1) of the Data Protection Act 2018 (“UK Addendum“).
“US Data Privacy Laws” means the CCPA and any other applicable US state or federal comprehensive data privacy or data protection law or regulation, in each case as amended or replaced from time to time.
2.1 Roles of the Parties. The parties acknowledge and agree that with regard to the processing of Personal Data, Customer is the controller and Vendavo is the processor and that Vendavo will engage Sub-processors pursuant to the requirements set forth in Section 5 below. The parties agree that they shall comply with Data Protection Law as applicable to them in such roles.
2.2 Customer Processing of Personal Data. Customer shall, in its use of the Products and provision of instructions, process Personal Data in accordance with the requirements of applicable Data Protection Law. Customer shall have sole responsibility for the accuracy, quality and legality of Personal Data and the means by which Customer acquired Personal Data and transferred such Personal Data to Vendavo.
2.3 Vendavo Processing of Personal Data. As Customer’s processor, Vendavo shall only process Personal Data for the following purposes: (a) processing in accordance with the Agreement; (b) processing initiated by Customer or its authorized users in their use of the Products; and (c) processing to comply with other reasonable documented instructions of Customer (e.g. in email, in Jira, or via the support portal) that are consistent with the terms of the Agreement (individually and collectively the “Purpose”). Vendavo shall inform Customer immediately upon becoming aware that, in Vendavo’s opinion, an instruction provided by Customer violates applicable Data Protection Law.
2.4 Details of the Processing. The subject matter of processing of Personal Data by Vendavo is described in the Purpose set out in Section 2.3. The duration of the processing, the nature and purpose of the processing, the types of Personal Data and the categories of data subjects processed under this DPA are further specified in Annex I to Exhibit A (Description of Transfer) of this DPA.
Vendavo shall, to the extent legally permitted, promptly notify Customer if Vendavo receives any requests from a data subject to exercise the following individual rights under Data Protection Law in relation to the Personal Data: right of access, right to rectification, restriction of processing, erasure, data portability, objection to the processing, right not to be subject to an automated individual decision making (each a “Data Subject Request”). Taking into account the nature of the processing, Vendavo will assist Customer insofar as this is possible, for the fulfilment of Customer’s obligation to respond to a Data Subject Request. To the extent that Customer, in its use of the Products, does not have the ability to adequately address a Data Subject Request, Vendavo shall, upon Customer’s request, provide commercially reasonable efforts to assist Customer in responding to such Data Subject Request, to the extent Vendavo is legally permitted to do so and the response to such Data Subject Request is required by applicable Data Protection Law. To the extent legally permitted, Customer shall be responsible for any cost arising from Vendavo’s provision of such assistance including costs or fees associated with provision of additional functionality.
4.1 Use of Sub-processors. Customer acknowledges and agrees that Vendavo shall use third party sub-contractors to process Personal Data in some circumstances, which may include Vendavo’s affiliates (“Sub-processors”). Customer consents to Vendavo’s use of the Sub-processors set out in Annex III to Exhibit A, being the Sub-processors in use at the date of this DPA. Customer acknowledges that Vendavo is located in the USA and is involved in the provision of the Products to Customer either directly or through the provision of support to Vendavo’s affiliates. In either case, Customer agrees to enter into the Standard Contractual Clauses set out in Exhibit A and acknowledges that Sub-processors may be appointed by Vendavo in accordance with Exhibit A.
4.2 Notification of New Sub-processors. In the event that a new Sub-processor is to be used, Vendavo will provide prior written notice of the proposed new Sub-processor, including general details of its location and the processing it will perform. Customer may reasonably object to Vendavo’s use of a new Sub-processor (e.g. if making Personal Data available to the new Sub-processor may violate applicable Data Protection Law) in writing within fifteen (15) business days after receipt of Vendavo’s notice, stating the grounds for the objection. If the Customer objects in writing to the appointment of a new Sub-processor as permitted in the preceding sentence, Vendavo shall make commercially reasonable efforts to offer Customer a change in the Products, recommend a change to the Customer’s configuration or use of the Products to avoid the processing of Personal Data by the objected-to new Sub-processor without unreasonably burdening Customer. If Customer does not provide a written objection as provided in this Section, Customer agrees that it will be deemed to have consented to the new Sub-processor for the purposes of applicable Data Protection Law. The foregoing shall not limit Customer’s existing payment obligations under the Agreement.
4.3 Liability. Vendavo will: (a) enter into a written agreement with any Sub-processor containing terms that are no less protective of Personal Data than those contained in this DPA; and (b) be liable for the acts and omissions of its Sub-processors to the same extent Vendavo would be liable if performing the services of each of those Sub-processors directly under the terms of this DPA.
Vendavo shall maintain appropriate technical and organizational measures to protect the security, confidentiality and integrity of Personal Data against a Personal Data Breach as set forth in Annex II to Exhibit A. Such measures will take into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing, as well as the risk to the rights and freedoms of natural persons so as to ensure a level of security that is appropriate to the risk. Vendavo regularly monitors compliance with these technical and organizational measures and may amend them from time to time provided that Vendavo maintains at least an equivalent level of protection. Upon request from Customer, Vendavo will provide an updated description of the technical and organizational measures in the form presented in Annex II to Exhibit A. All Vendavo personnel who process Personal Data shall be adequately trained with respect to their data protection, security and confidentiality obligations, and shall be subject to written obligations to maintain confidentiality.
Vendavo shall notify the Customer without undue delay upon confirming the occurrence of a breach relating to Personal Data (within the meaning of applicable Data Protection Law) which may require a notification to be made to any supervisory authority or data subject under applicable Data Protection Law or which Vendavo is required to notify to Customer under applicable Data Protection Law (a “Personal Data Incident”). Vendavo shall provide commercially reasonable cooperation and assistance in identifying the cause of the Personal Data Incident and take commercially reasonable actions to mitigate the effects of the Personal Data Incident and remediate the cause, to the extent such remediation is within Vendavo’s control. Except as required by applicable Data Protection Law, this shall not apply to incidents that are caused by Customer, Customer’s authorized users, and/or any products or services not provided by Vendavo.
7.1 Third Party Certifications. The Customer acknowledges that Vendavo is regularly audited by independent third-party auditors against SSAE 18 SOC 2 standards, and against ISO 27001 standards. Upon request, and subject to the confidentiality provisions of the Agreement, Vendavo shall make available to Customer (or Customer’s independent third-party auditor) a copy of such third-party audit reports, which reports shall be subject to the confidentiality provisions of the Agreement. The Customer acknowledges that the third-party author of such report does not accept any responsibility to Customer or the Customer’s auditors unless and until Customer enters into a separate duty of care agreement with such author.
7.2 Customer’s Right to Audit. In addition to the above, not more than once per year and only to the extent explicitly required under applicable Data Protection Law, Customer may request to perform an audit of Vendavo’s processing of Personal Data in compliance with this DPA. Customer must provide Vendavo with at least thirty (30) days’ notice of such audit, confirming whether the audit will be conducted by the Customer or an independent third party who must be identified in the notice. Vendavo shall have the right to refuse audit by any third party which is or may be a competitor of Vendavo, in Vendavo’s sole opinion. The parties will mutually agree upon the timing, duration, place, any applicable conditions for the audit and the reimbursement rate for which Customer shall be responsible. All reimbursement rates shall be reasonable taking into account the resources expended by Vendavo. Customer shall be fully responsible for all its own costs and expenses in relation to such audit. Customer shall promptly notify Vendavo of any areas of non-compliance identified in such audit and Vendavo shall use commercially reasonable efforts to address any such confirmed non-compliance.
Upon termination of the Agreement, Vendavo shall delete the Personal Data from its systems in accordance with the terms of that Agreement and at all times subject to applicable Data Protection Law.
9.1 GDPR. Vendavo will process Personal Data in accordance with GDPR requirements directly applicable to Vendavo’s provision of the Products sold, licensed or provided to Customer. Upon request, Vendavo shall provide Customer with reasonable cooperation and assistance needed to fulfil Customer’s obligation under the GDPR to carry out a data protection impact assessment related to Customer’s use of the Products, to the extent that Customer does not already have access to the relevant information, Vendavo does have access to the relevant information, and the data protection impact assessment is required by Data Protection Law.
9.2 International Data Transfers. The parties acknowledge that Vendavo participates in the Data Privacy Framework and maintains an active self-certification with the U.S. Department of Commerce. To the extent that the transfer of Personal Data to Vendavo constitutes a Restricted Transfer, such transfer shall be made in reliance on the European Commission’s adequacy decision for the EU-U.S. Data Privacy Framework (Commission Implementing Decision (EU) 2023/1795 of 10 July 2023) and, where applicable, the UK adequacy regulations for the UK Extension to the EU-U.S. Data Privacy Framework (The Data Protection (Adequacy) (United States of America) Regulations 2023) and, where applicable, the Swiss-U.S. Data Privacy Framework as recognized under the FADP. In the event that Vendavo’s Data Privacy Framework certification lapses or is invalidated, or the applicable adequacy decision or adequacy regulations are suspended, amended, repealed, or invalidated, the transfer of Personal Data shall instead be subject to the appropriate Standard Contractual Clauses as set out in Exhibit A.
10.1 Scope. This Section 10 applies to Vendavo’s processing of Customer’s Personal Data that is subject to US Data Privacy Laws. For purposes of this Section 10, “Personal Information” means personal data that constitutes “personal information,” “personal data,” or an equivalent term as defined under the applicable US Data Privacy Laws.
10.2 Selling Prohibited. Vendavo shall not “sell,” “share,” or otherwise make available (as such terms are defined under applicable US Data Privacy Laws) Personal Information under any circumstances.
10.3 Additional Prohibitions. To the extent Vendavo acts as a “Service Provider,” “Processor,” or equivalent role under applicable US Data Privacy Laws and receives from Customer Personal Information, Vendavo is prohibited from and agrees not to: (i) retain, use, or disclose such Personal Information for any purpose, including a commercial purpose, other than performing the business purpose and Services under the Agreement or as otherwise permitted under applicable US Data Privacy Laws, or (ii) retain, use, or disclose such Personal Information outside of the direct business relationship between Customer and Vendavo unless otherwise permitted under the Agreement or applicable US Data Privacy Laws, or (iii) combine such Personal Information Vendavo receives from or on behalf of Customer with Personal Information it receives from or on behalf of another person or persons, or collects from its own interactions with a consumer, provided that Vendavo may combine Personal Information to perform any business purpose as defined and permitted under applicable US Data Privacy Laws.
10.4 Remediation. Customer shall have the right to take reasonable and appropriate steps to ensure that Vendavo uses Personal Information in a manner consistent with Customer’s obligations under applicable US Data Privacy Laws. Customer shall have the right, upon notice, to take reasonable and appropriate steps to stop and remediate unauthorized use of Personal Information.
10.5 Certification. Vendavo certifies that it understands these Section 10 restrictions and will comply with them and applicable US Data Privacy Laws. Vendavo agrees it will notify Customer if it determines it can no longer comply with applicable US Data Privacy Laws.
10.6 General Compliance. To the extent any applicable US Data Privacy Laws impose obligations on Vendavo as a processor, service provider, or equivalent role that are not expressly addressed in this Section 10, Vendavo shall comply with such obligations as applicable to its processing of Personal Information on behalf of Customer.
11.1 Term and Termination. This DPA will remain in force until (i) it is replaced or repealed by mutual agreement of Customer and Vendavo, or (ii) the Agreement is terminated or expires.
11.2 Modification. Any modification to this DPA shall be invalid unless made in writing and signed by both parties.
11.3 Liability. Any claims brought under this DPA will be subject to the same terms and conditions, including the exclusions and limitations of liability, as are set out in the Agreement. The total liability of Vendavo and its affiliates for all claims by Customer arising out of or related to the Agreement and this DPA shall apply in aggregate for all claims under both the Agreement and this DPA.
11.4 Governing Law. Without prejudice to clause 17 (Governing law) and clause 18 (Choice of forum and jurisdiction) of the Standard Contractual Clauses: (i) the parties to this DPA hereby submit to the choice of jurisdiction stipulated in the Agreement with respect to any disputes or claims howsoever arising under this DPA, including disputes regarding its existence, validity or termination or the consequences of its nullity; and
(ii) this DPA and all non-contractual or other obligations arising out of or in connection with it are governed by the laws of the country or territory stipulated for this purpose in the Agreement.
11.5 Counterparts. This DPA may be executed in any number of counterparts, each of which will be deemed to be an original and all of which taken together will comprise a single instrument. This DPA may be delivered in electronic document format (e.g. PDF), and electronic copies of executed signature pages will be binding as originals.
11.6 Entire Agreement. This DPA, together with the Agreement, constitutes the entire agreement between the parties and supersedes any other prior or contemporaneous agreements or terms and conditions, written or oral, concerning the processing of Personal Data by Vendavo on behalf of Customer. In case of conflict or inconsistency between this DPA, the Agreement, and the Standard Contractual Clauses, the following order of precedence shall govern to the extent of the conflict or inconsistency: (i) the Standard Contractual Clauses; (ii) this DPA; and (iii) the Agreement.
11.7 Severability. If any provision of this DPA is determined to be unenforceable by a court of competent jurisdiction, that provision will be severed, and the remainder of terms will remain in full effect.
1. EU Standard Contractual Clauses. The parties agree that the standard contractual clauses set out in the Annex to Commission Implementing Decision (EU) 2021/914 of 4 June 2021 (available at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj) are hereby incorporated by reference into this DPA and shall apply to Restricted Transfers of Personal Data protected by the EU GDPR, completed as follows:
2. UK International Data Transfer Addendum. For Restricted Transfers of Personal Data protected by the UK GDPR, the “International Data Transfer Addendum to the EU Commission Standard Contractual Clauses” issued by the Information Commissioner under s.119A(1) of the Data Protection Act 2018, Version B1.0, in force 21 March 2022 (available at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/appropriate-safeguards/what-are-standard-data-protection-clauses-the-uk-idta-and-the-addendum) (the “UK Addendum“), is hereby incorporated by reference into this DPA and shall apply as follows:
3. Swiss Data Transfers. For transfers of Personal Data protected by the Swiss Federal Act on Data Protection (“FADP”), the EU SCCs as incorporated above shall also apply, with the following modifications:
4. Interpretation. In the event of any conflict between this Exhibit A and the main body of the DPA, this Exhibit A shall prevail to the extent required by the applicable Standard Contractual Clauses or UK Addendum. Capitalized terms used but not defined in this Exhibit A shall have the meanings given to them in the main body of the DPA or, where applicable, in the EU SCCs or the UK Addendum.
A. LIST OF PARTIES
Data exporter(s):
Name: | Data Exporter is (i) the legal entity that has executed the Standard Contractual Clauses as a Data Exporter (by its signature to the DPA or Agreement) and, (ii) all affiliates of such legal entity established within the European Economic Area (EEA) and Switzerland that have ordered or subscribed to license Vendavo’s software through one or more agreement(s) (“agreement”) as a “Customer.” |
Address: | The address for the legal entity named above, as stated in the Agreement. |
Contact person’s name, position and contact details: | The contact details provided in the Agreement. |
Activities relevant to the data transferred under these Clauses: | Vendavo is a provider of cloud-based pricing solutions which processes personal data upon the instruction of the Data Exporter in accordance with the terms of the agreement between Vendavo and Data Exporter under which software is licensed by Vendavo for use by Data Exporter. |
Signature and date: | Deemed signed on date of signature of the DPA (or Agreement). |
Role (controller/processor): | Controller. |
Data importer(s):
Name: | Vendavo, Inc. |
Address: | 1200 17th Street, Suite 1000, Denver CO 80202, USA |
Contact person’s name, position and contact details: | Sian Story, General Counsel |
Activities relevant to the data transferred under these Clauses: | Vendavo is a provider of cloud-based pricing solutions which processes personal data upon the instruction of the Data Exporter in accordance with the terms of the agreement between Vendavo and Data Exporter under which software is licensed by Vendavo for use by Data Exporter.
|
Signature and date: | Deemed signed on date of signature of the DPA (or Agreement). |
Role (controller/processor): | Processor. |
Name: | Vendavo AB |
Address: | Sveavägen 9, 111 57, Stockholm, Sweden |
Contact person’s name, position and contact details: | Sian Story, General Counsel |
Activities relevant to the data transferred under these Clauses: | Vendavo is a provider of cloud-based pricing solutions which processes personal data upon the instruction of the Data Exporter in accordance with the terms of the agreement between Vendavo and Data Exporter under which software is licensed by Vendavo for use by Data Exporter.
|
Signature and date: | Deemed signed on date of signature of the DPA (or Agreement). |
Role (controller/processor): | Processor. |
B. DESCRIPTION OF TRANSFER
Categories of data subjects whose personal data is transferred | Employees and third-party contractors of the Data Exporter and its affiliates who are authorized users of the Data Importer’s software. |
Categories of personal data transferred
| First name, last name, username, business email address, IP address, business telephone number |
Sensitive data transferred (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.
| None. |
The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis).
| Continuous. |
Nature of the processing
| To facilitate user account administration and audit logs, and to provide technical support. |
Purpose(s) of the data transfer and further processing
| To enable use of Data Importer’s software by Data Exporter. |
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period
| The duration of the term stated in the contract by way of which software is licensed to the Data Exporter by the Data Importer. |
For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing
| To provide web application hosting and support throughout the term as stated above. |
C. COMPETENT SUPERVISORY AUTHORITY
Identify the competent supervisory authority/ies in accordance with Clause 13 | The supervisory authority applicable to the Data Exporter, its representative, or if neither are applicable, the relevant data subject. |
Measures of pseudonymisation and encryption of personal data | – Storage encryption services used provide encryption at rest. All Personal Data is encrypted automatically when written to disk using (at minimum) 256-bit AES encryption. – Personal Data are encrypted during transmission using up-to-date versions of TLS and other security protocols (HTTPS) with strong encryption algorithms and keys. -Access to systems processing Personal Data is made via secure VPN channels and networks are protected by securely configured firewalls/application gateways |
Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services | -Vendavo users have unique login credentials, Multi factor authentication is required, and complex passwords and lock-out session settings are enforced. -Access to systems is made via secured VPN channels and perimeter networks are protected by securely configured firewalls/application gateways. -IP whitelisting is used to ensure only customer IP’s can access the subscribed Vendavo services. -Controlling access to customer Personal Data via role-based access controls (RBAC) in line with the security principle of “least privilege”. Only authorised Administrators have access to systems processing personal data in line with their job responsibilities. -Authorization of access rights by system owner as well as monitoring and logging. -Ongoing review of user accounts and assigned privileges. -Use of integrity checks to monitor the completeness and correctness of the transfer of data (e.g. SFTP) & Web application interface input validation checks and error handling. -Vendavo maintains full capacity disaster recovery (DR) sites and annually tests its DR plan. -Global and redundant service infrastructure that is set up with full disaster recovery sites leveraging leading cloud providers. -Constantly evaluating data center providers to optimize performance, in regard to bandwidth, latency and disaster recovery isolation. |
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 | -Geographic-Redundant attached storage is used for daily backups. Full Database Backups are currently being taken daily, with the inclusion of archive/incremental logs every 15min to reduce the time it takes to restore the database in the event of a failure -Vendavo maintains full capacity disaster recovery (DR) sites and annually tests its DR plan where RTO’s and RPO’s are specified. -Global and redundant service infrastructure that is set up with full disaster recovery sites leveraging leading cloud providers. |
Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures in order to ensure the security of the processing | Vendavo does not access Customer Personal Data, except to provide services to the Customer which Vendavo is obligated to perform in support of the Customer experience as required by law, or on request by Customer. Vendavo has implemented suitable measures to monitor access restrictions of Vendavo’s system administrators and to ensure that they act in accordance with instructions received. Annual independent third-party attestations are done to validate the operating effectiveness of technical organisational measures implemented by Vendavo Cloud. Attestation standards Vendavo Cloud is assessed against and has achieved includes SOC I Type II, SOC II Type II and ISO 27001/2). Vendavo is also GDPR compliant. |
Measures for user identification and authorisation | -Vendavo users have unique login credentials, Multi factor authentication is required, and complex passwords and lock-out session settings are enforced. -Controlling access to customer Personal Data via role-based access controls (RBAC) in line with the security principle of “least privilege”. Only authorised Administrators have access to systems processing customer Personal Data in line with their job responsibilities. -Authorization of access rights by system owner(s) as well as monitoring and logging. -Ongoing review of user accounts and assigned privileges. |
Measures for the protection of data during transmission | – Personal Data is encrypted during transmission using up-to-date versions of TLS e.g. TLS v 1.2 or higher, and other security protocols (HTTPS) with strong encryption algorithms and keys. -Access to systems is made via secured VPN channels and networks are protected by securely configured firewalls/application gateways. |
Measures for the protection of data during storage | – Storage encryption services used provide encryption at rest. All personal data and sensitive business data are encrypted automatically when written to disk using (at minimum) 256-bit AES encryption. With HTTPS used for Client to Server Communication and Storage service encryption used for data at rest, effectively, end-to-end encryption in-transit and at-rest is exercised. |
Measures for ensuring physical security of locations at which personal data are processed | Vendavo leverages leading cloud providers data centres which manage all aspects of physical security on behalf of Vendavo. The audit for Cloud services covers controls for data security, availability, processing integrity, and confidentiality as applicable to in-scope trust principles for each service. [Azure/AWS] has ISO27001/2, SOC 1 Type II, SOC 2 Type II, and SOC 3 certifications and reports available. |
Measures for ensuring events logging | Vendavo Cloud Operations leverage log aggregation tool which also provides the engine for monitoring, searching, analyzing, visualizing and acting on streams of real-time data. -All Vendavo Application server logs are shipped to the aggregation tools and presented via a Web Interface for visualizing, reporting and alerting. -Modules included are Logs, Application Performance Monitoring (APM), Security Information & Event Management (SIEM), and Infrastructure Monitoring. -Cloud native monitoring tools such as Azure Microsoft Security Center, AWS CloudTrail, CloudWatch, Config, Security Hub, Inspector & Guard Duty are also leveraged for log aggregation with the aim to detect and respond to security threats. |
Measures for ensuring system configuration, including default configuration | All Operating System hardening, Vendavo Security Policies and Security benchmarks from the Center of Internet Standards, industry best practices and recommendations are baked into the pipeline to ensure servers and environments are secure during the provisioning process from the onset. |
Measures for internal IT and IT security governance and management | Vendavo has an Information Security Council which is overall accountable for information security across Vendavo. The Committee must meet no less than once per quarter to review the current status of information security within the organization, review and monitor material security incidents, approve material information security policy changes, and perform other necessary information security stewardship activities. The Vendavo Information Security Council is responsible for the review and approval of information security policy, standards, assessments, procedures, oversight and other guidance developed by the Information Security Office. The Committee/Council represents business, finance, legal, Information Technology, Information Security, Human Resources and management interests of Vendavo, and provides a forum for the cross-functional identification and resolution of security issues, endorsement of security strategies and review of significant exceptions to information security policy. Organisational structures are in place. |
Measures for certification/assurance of processes and products | Annual independent third-party attestations are done to validate the operating effectiveness of technical organisational measures implemented by Vendavo Cloud. Attestation standards Vendavo Cloud is assessed against and has achieved include SOC I Type II, SOC 2 Type II and ISO 27001/2). Vendavo is also GDPR compliant. |
Measures for ensuring data minimisation | Vendavo does not access Customer Personal Data, except to provide services to the Customer which Vendavo is obligated to perform in support of the Customer experience as required by law, or on request by Customer. Customer data obtained is very minimal and is very limited and not sensitive in nature. Information collected for setting up customer applications by authorised Vendavo Administrators is limited to business contact information, username and business IP address. |
Measures for ensuring data quality | -Use of integrity checks to monitor the completeness and correctness of the transfer of data (e.g. SFTP) -OWASP and CLASP Secure development methodologies are used in the internal development of Vendavo web applications and ensures that input & validation checks and error handling mechanisms are in place to ensure the quality of data entered into systems and secure operation of applications. |
Measures for ensuring limited data retention | All DB backups are configured to a minimum of 30-days retention policy. In the event of Termination of services and Disposal of Data automated and secure erasure of data is in place and is utilized 60days from contract termination (Note: Data deletion period can be adjusted per customer requirement). |
Measures for ensuring accountability | See “Measures for internal IT and IT security governance and management” above. |
Measures for allowing data portability and ensuring erasure | Vendavo does not access Customer Personal Data, except to provide services to the Customer which Vendavo is obligated to perform in support of the Customer experience as required by law, or on request by Customer. Vendavo leverages leading cloud providers who have implemented portable data mechanisms. In the event of Termination of services and Disposal of Data automated and secure erasure of data is in place and is utilized 60days from contract termination (Note: Data deletion period can be adjusted per customer requirement). |
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 and, for transfers from a processor to a sub-processor, to the data exporter:
Amazon Web Services (AWS) | Both the same technical and organizational measures set forth in Annex II above and AWS’ |
Anthropic | Both the same technical and organizational measures set forth in Annex II above and |
Atlassian | Both the same technical and organizational measures set forth in Annex II above and |
Microsoft Azure | Both the same technical and organizational measures set forth in Annex II above and MS |
Pendo.io, Inc. | Both the same technical and organizational measures set forth in Annex II above and |
Salesforce | Both the same technical and organizational measures set forth in Annex II above and |
The Rocket Science Group LLC d/b/a Mailchimp | Both the same technical and organizational measures set forth in Annex II above and |
Twilio Inc. (SendGrid) | Both the same technical and organizational measures set forth in Annex II above and |
The controller has authorized the use of the following sub-processors:
Name: | Amazon Web Services (AWS) |
Address: | Site determined by agreement with data exporter |
Description of processing (including a clear delimitation of responsibilities in case several sub-processors are authorised): | Data ingestion and access management integration; data hosting |
Applicable Vendavo products | All products |
Name: | Anthropic, Inc. |
Address: | 548 Market Street, PMB 90375, San Francisco, CA 94104 |
Description of processing (including a clear delimitation of responsibilities in case several sub-processors are authorised): | Large language AI processing model |
Applicable Vendavo products | Agentic AI Services |
Name: | Atlassian |
Address: | Level 6, 341 George Street, Sydney NSW 2000 Australia |
Description of processing (including a clear delimitation of responsibilities in case several sub-processors are authorised): | Customer Support Process |
Applicable Vendavo products | All products |
Name: | Microsoft Azure |
Address: | Site determined by agreement with data exporter |
Description of processing (including a clear delimitation of responsibilities in case several sub-processors are authorised): | Web application hosting |
Applicable Vendavo products | VPP, EPS, CPQ |
Name: | Pendo.io, Inc. |
Address: | 301 Hillsborough Street, Suite 1900, Raleigh, North Carolina 27603 |
Description of processing (including a clear delimitation of responsibilities in case several sub-processors are authorised): | Product analytics and in-app guidance |
Applicable Vendavo products | High-Tech Revenue Cloud, Channel Management, Rebate Management, Channel Data Management (CDM) |
Name: | SalesForce |
Address: | The Landmark @ One Market Street, Suite 300, San Francisco, CA 94105 |
Description of processing (including a clear delimitation of responsibilities in case several sub-processors are authorised): | Customer Support process |
Applicable Vendavo products | All products |
Name: | The Rocket Science Group LLC d/b/a Mailchimp |
Address: | 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 |
Description of processing (including a clear delimitation of responsibilities in case several sub-processors are authorised): | Email hosting for system messages |
Applicable Vendavo products | CPQ |
Name: | Twilio Inc. (SendGrid) |
Address: | 101 Spear Street, Suite 500, San Francisco, CA 94105 |
Description of processing (including a clear delimitation of responsibilities in case several sub-processors are authorised): | Transactional email delivery for system messages |
Applicable Vendavo products | All products |
