ANNEX 2 - DATA PROCESSING AND SECURITY DETAILS

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Last updated: Jul 11, 2024
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The processing of Protected Data by the Data Controller under this DPA shall have as its object, duration, nature and purpose and shall cover the types of Personal Data and categories of Data Subjects outlined in Annex 2.

1. OBJECT AND SUBJECT MATTER OF DATA PROCESSING:

The Data Processor shall have access to the Personal Data of the Customer, the Customer's Named Users and the specific information that the Customer adds to the XCALLY Service.

 

2. DURATION OF PROCESSING:

2.1 The Data Processor may process Personal Data for as long as the Data Controller subscribes to the Service as defined in the EULA.

2.2 The Data Processor may delete the Personal Data upon the termination of the Service and shall delete the Personal Data no later than 12 months after termination unless the Data Processor is required to retain the Personal Data for a longer period based on legal requirements.

 

3. NATURE AND PURPOSE OF PROCESSING

The Data Processor will process data, including Personal Data, for the performance of the Service as described in the EULA in case of direct sales and, therefore, in case of a direct contractual relationship between XCALLY and the user/end user. In the remaining cases, XCALLY is the Data Processor only and exclusively for the support and maintenance activities of the Service, if any.

Lastly, it is understood that XCALLY is the Data Processor for System Administrator activities in compliance with current legislation, cf. provision of the Guarantor for the Protection of Personal Data of November 27, 2008, as amended according to the provision of June 25, 2009

 

4. TYPE OF PERSONAL DATA

The personal data that may be handled by XCALLY are, for example: name, address, e-mail, date of birth, telephone numbers, company, address, IP address, and country.

 

5. CATEGORIES OF DATA SUBJECTS

Employees of the Data Controller, any external consultants who process personal data on behalf of the Data Controller.

 

6. SPECIFIC PROCESSING INSTRUCTIONS

The Service is automated and processing will only take place at the command of the Data Controller.

Support services by the Data Controller will take place only upon the specific request of the appropriate person of the Data Controller.

 

7. SUB-PROCESSORS

The current and updated list of Sub-processors is available at www.xcally.com/list-of-subprocessors-2.pdf