This Selz Data Processing Addendum (“Addendum”) amends the Selz Terms of Service (the “Agreement”) by and between you (“Customer”) and Selz Pty Ltd., an Australian company with offices at Suite 1D, Level 23, 1 Farrer Place, Sydney NSW 2000, AUSTRALIA (“Selz”).

This Addendum will be effective as of the day Selz receives a complete executed Addendum from Customer in accordance with the instructions under paragraphs 1 and 2 below (the “Addendum Effective Date”).

If you do not agree to this Addendum, you may discontinue the use of the Selz service and close your account.

1. Instructions

  1. Complete the executable version of the Addendum by signing and providing the customer full legal entity name, address and signatory information; and
  2. Submit the completed and signed Addendum to Selz via email to privacy@selz.com

2. Effectiveness

  1. This Addendum will be effective only if it is executed and submitted to Selz in accordance with paragraph 1 above and this paragraph 2, and all items identified as “Required” in the table on the signature page are completed accurately and in full. If Customer makes any deletions or other revisions to this Addendum, then this Addendum will be null and void.
  2. Customer signatory represents to Selz that he or she has the legal authority to bind Customer and is lawfully able to enter into contracts (e.g., is not a minor).
  3. This Addendum will terminate automatically upon termination of the Agreement, or as earlier terminated pursuant to the terms of this Addendum.

3. Definitions

  1. Data Protection Legislation” means European Directives 95/46/EC and 2002/58/EC, and any legislation and/or regulation implementing or made pursuant to them, or which amends or replaces any of them (including the General Data Protection Regulation, Regulation (EU) 2016/679);
  2. Data Processor”, “Data Subject”, “Data Controller”, “Processing”, “Subprocessor”, and “Supervisory Authority” shall be interpreted in accordance with applicable Data Protection Legislation;
  3. Incident” means: (a) a complaint or a request with respect to the exercise of an individual’s rights under Data Protection Legislation; (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 Addendum 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.
  4. Personal Data” as used in this Addendum means information relating to an identifiable or identified Data Subject who visits or engages in transactions through your store, which Selz Processes as a Data Processor in the course of providing you with the Services.
  5. Merchant”, “You” refers to the individual, company or organization that signs up to use the Selz Service to manage the relationships with your Merchants;
  6. Standard Contractual Clauses” means Annex 1 attached to and forming part of this Addendum pursuant to the European Commission Decision of 5 February 2010 on standard contractual clauses for the transfer of personal data to processors established in third countries under the Directive.
  7. All other capitalized terms in this Addendum shall have the same definition as in the Agreement.

4. Undertakings regarding Personal Data

  1. Each party agrees that Personal Data shall be treated as confidential information under this Addendum. 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 Data Controller. Selz acknowledges that the Merchant is the Data Controller and maintains control over the Data Subject’s Personal Data.
  3. When Selz Processes Personal Data in the course of providing the Services, Selz will:
    1. process the Personal Data as a Data Processor, only for the purpose of providing the Services in accordance with documented instructions from you (provided that such instructions are commensurate with the functionalities of the Services), and as may subsequently be agreed to by you. If Selz is required by law to Process the Personal Data for any other purpose, Selz will provide you with prior notice of this requirement, unless Selz is prohibited by law from providing such notice;
    2. notify you if, in Selz’s opinion, your instruction for the processing of Personal Data infringes applicable Data Protection Legislation;
    3. notify you promptly, to the extent permitted by law, upon receiving an inquiry or complaint from a Data Subject or Supervisory Authority relating to Selz’s Processing of the Personal Data;
    4. implement and maintain appropriate technical and organizational measures to protect the Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, damage, theft, alteration or disclosure. These measures shall be appropriate to the harm which might result from any unauthorized or unlawful processing, accidental loss, destruction, damage or theft of Personal Data and appropriate to the nature of the Personal Data which is to be protected;
    5. make available to the customer information reasonably necessary to demonstrate compliance with Selz’s obligations under this Addendum. At a minimum, upon written request, Selz will produce to Customer a copy of any internal or external audit reports concerning the adequacy of Selz’s technical security measures. Customer does not have any independent right to audit Selz’s technical and/or organizational measures;
    6. notify you promptly upon becoming aware of and confirming any accidental, unauthorized, or unlawful processing of, disclosure of, or access to the Personal Data;
    7. ensure that its personnel who access the Personal Data are subject to confidentiality obligations that restrict their ability to disclose the Personal Data; and
    8. upon termination of the Agreement, Selz will promptly initiate its purge process to delete or anonymize the Personal Data. If you request a copy of such Personal Data within 90 days of termination, Selz will provide you with a copy of such Personal Data.
  4. In the course of providing the Services, you acknowledge and agree that Selz may use Subprocessors to Process the Personal Data. Selz’s use of any specific Subprocessor to process the Personal Data must be in compliance with Data Protection Legislation and must be governed by a contract between Selz and the Subprocessor.

5. Merchant undertakings and Selz’s assistance

  1. The Merchant warrants that it has all necessary rights to provide to Selz the Personal Data for processing in connection with the provision of the Selz Services.
  2. To the extent required by applicable law, the Merchant 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, the Merchant is responsible for communicating the fact of such revocation to Selz, and Selz remains responsible for implementing any Merchant instruction with respect to the further processing of that Personal Data, or, as may be in accordance with any of Selz’s legal obligations.
  3. The Merchant understands, as a Data Controller, that it is responsible for:
    1. determining the lawfulness of any processing, performing any required data protection impact assessments, and accounting to regulators and individuals, as may be needed;
    2. making reasonable efforts to verify parental consent when data is collected on a data subject under 16 years of age;
    3. providing relevant privacy notices to data subjects as may be required in your jurisdiction, including notice of their rights and provide the mechanisms for individuals to exercise those rights;
    4. 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;
    5. implementing your own appropriate technical and organizational measures to ensure and demonstrate processing in accord with this Addendum;
    6. notifying individuals and any relevant regulators or authorities of any incident as may be required by law in your jurisdiction.
  4. Selz shall assist the Merchant by implementing appropriate technical and organizational measures, insofar as this is reasonably and commercially possible (in Selz’s sole determination and discretion), in fulfilling Merchant’s obligations to respond to individuals’ requests to exercise rights under the GDPR.

6. Incident Management

  1. 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.
  2. Both parties shall at all times have in place written procedures which 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 no later than 24 hours of having become aware of such an Incident.
  3. Any notifications made under this section shall be made to privacy@selz.com (when made to Selz) and to our point of contact with you (when made to the Merchant), 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.
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7. Transfer of Personal Data

As part of providing the Selz Service, Selz processes Personal Data in the United States, Australia and in other countries outside of the EEA. The Standard Contractual Clauses found at Annex 1 of this Addendum will apply to Personal Data that is transferred outside the EEA, either directly or via onward transfers, to any country not recognized by the European Commission as providing an adequate level of protection for personal data.

8. Liability and Indemnity

Each party indemnifies the other and holds them harmless against all claims, actions, third party claims, losses, damages and expenses incurred by the indemnified party and arising directly or indirectly out of or in connection with a breach of this Addendum.

9. Duration and Termination

  1. This Addendum shall come into effect on May 25, 2018 and shall continue until it is changed or terminated in accordance with the Agreement.
  2. Termination or expiration of this Addendum shall not discharge the parties from the confidentiality obligations herein.

ANNEX 1 - Standard Contractual Clauses

For the purposes of Article 26(2) of Directive 95/46/EC for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection

The entity identified as “Customer” in the Addendum
(the “data exporter”)

And

Selz Pty Ltd.
Suite 1D, Level 23, 1 Farrer Place, Sydney NSW 2000, AUSTRALIA
(the “data importer”)

Each a “party”; together “the parties”,

HAVE AGREED on the following Contractual Clauses (the Clauses) in order to adduce adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of individuals for the transfer by the data exporter to the data importer of the personal data specified in Appendix 1.

Clause 1 - Definitions

For the purposes of the Clauses:

  1. 'personal data', 'special categories of data', 'process/processing', 'controller', 'processor', 'data subject' and 'supervisory authority' shall have the same meaning as in Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data;
  2. 'the data exporter' means the controller who transfers the personal data;
  3. 'the data importer' means the processor who agrees to receive from the data exporter personal data intended for processing on his behalf after the transfer in accordance with his instructions and the terms of the Clauses and who is not subject to a third country's system ensuring adequate protection within the meaning of Article 25(1) of Directive 95/46/EC;
  4. 'the subprocessor' means any processor engaged by the data importer or by any other subprocessor of the data importer who agrees to receive from the data importer or from any other subprocessor of the data importer personal data exclusively intended for processing activities to be carried out on behalf of the data exporter after the transfer in accordance with his instructions, the terms of the Clauses and the terms of the written subcontract;
  5. 'the applicable data protection law' means the legislation protecting the fundamental rights and freedoms of individuals and, in particular, their right to privacy with respect to the processing of personal data applicable to a data controller in the Member State in which the data exporter is established;
  6. 'technical and organisational security measures' means those measures aimed at protecting personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.

Clause 2 - Details of the transfer

The details of the transfer and in particular the special categories of personal data where applicable are specified in Appendix 1 which forms an integral part of the Clauses.

Clause 3 - Third-party beneficiary clause

The details of the transfer and in particular the special categories of personal data where applicable are specified in Appendix 1 which forms an integral part of the Clauses.

  1. The data subject can enforce against the data exporter this Clause, Clause 4(b) to (i), Clause 5(a) to (e), and (g) to (j), Clause 6(1) and (2), Clause 7, Clause 8(2), and Clauses 9 to 12 as third-party beneficiary.
  2. The data subject can enforce against the data importer this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where the data exporter has factually disappeared or has ceased to exist in law unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law, as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity.
  3. The data subject can enforce against the subprocessor this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent, unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity. Such third-party liability of the subprocessor shall be limited to its own processing operations under the Clauses.
  4. The parties do not object to a data subject being represented by an association or other body if the data subject so expressly wishes and if permitted by national law.

Clause 4 - Obligations of the data exporter

The data exporter agrees and warrants:

  1. that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;
  2. that it has instructed and throughout the duration of the personal data processing services will instruct the data importer to process the personal data transferred only on the data exporter's behalf and in accordance with the applicable data protection law and the Clauses;
  3. that the data importer will provide sufficient guarantees in respect of the technical and organisational security measures specified in Appendix 2 to this contract;
  4. that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;
  5. that it will ensure compliance with the security measures;
  6. that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC; [If these Clauses are not governed by the law of a Member State, the words "within the meaning of Directive 95/46/EC" are deleted.]
  7. to forward any notification received from the data importer or any subprocessor pursuant to Clause 5(b) and Clause 8(3) to the data protection supervisory authority if the data exporter decides to continue the transfer or to lift the suspension;
  8. to make available to the data subjects upon request a copy of the Clauses, with the exception of Appendix 2, and a summary description of the security measures, as well as a copy of any contract for subprocessing services which has to be made in accordance with the Clauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information;
  9. that, in the event of subprocessing, the processing activity is carried out in accordance with Clause 11 by a subprocessor providing at least the same level of protection for the personal data and the rights of data subject as the data importer under the Clauses; and
  10. that it will ensure compliance with Clause 4(a) to (i).

Clause 5 - Obligations of the data importer

The data importer agrees and warrants:

  1. to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
  2. that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the Clauses, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
  3. that it has implemented the technical and organisational security measures specified in Appendix 2 before processing the personal data transferred;
  4. that it will promptly notify the data exporter about:
    1. any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation,
    2. any accidental or unauthorised access, and
    3. any request received directly from the data subjects without responding to that request, unless it has been otherwise authorised to do so;
  5. to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with regard to the processing of the data transferred;
  6. at the request of the data exporter to submit its data processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;
  7. to make available to the data subject upon request a copy of the Clauses, or any existing contract for subprocessing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;
  8. that, in the event of subprocessing, it has previously informed the data exporter and obtained its prior written consent;
  9. that the processing services by the subprocessor will be carried out in accordance with Clause 11;
  10. to send promptly a copy of any subprocessor agreement it concludes under the Clauses to the data exporter.

Clause 6 - Liability

  1. The parties agree that any data subject, who has suffered damage as a result of any breach of the obligations referred to in Clause 3 or in Clause 11 by any party or subprocessor is entitled to receive compensation from the data exporter for the damage suffered.
  2. If a data subject is not able to bring a claim for compensation in accordance with paragraph 1 against the data exporter, arising out of a breach by the data importer or his subprocessor of any of their obligations referred to in Clause 3 or in Clause 11, because the data exporter has factually disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract of by operation of law, in which case the data subject can enforce its rights against such entity. The data importer may not rely on a breach by a subprocessor of its obligations in order to avoid its own liabilities.
  3. If a data subject is not able to bring a claim against the data exporter or the data importer referred to in paragraphs 1 and 2, arising out of a breach by the subprocessor of any of their obligations referred to in Clause 3 or in Clause 11 because both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent, the subprocessor agrees that the data subject may issue a claim against the data subprocessor with regard to its own processing operations under the Clauses as if it were the data exporter or the data importer, unless any successor entity has assumed the entire legal obligations of the data exporter or data importer by contract or by operation of law, in which case the data subject can enforce its rights against such entity. The liability of the subprocessor shall be limited to its own processing operations under the Clauses.

Clause 7 - Mediation and Jurisdiction

  1. The data importer agrees that if the data subject invokes against it third-party beneficiary rights and/or claims compensation for damages under the Clauses, the data importer will accept the decision of the data subject:
    1. to refer the dispute to mediation, by an independent person or, where applicable, by the supervisory authority;
    2. to refer the dispute to the courts in the Member State in which the data exporter is established.
  2. The parties agree that the choice made by the data subject will not prejudice its substantive or procedural rights to seek remedies in accordance with other provisions of national or international law.

Clause 8 - Cooperation with supervisory authorities

  1. The data exporter agrees to deposit a copy of this contract with the supervisory authority if it so requests or if such deposit is required under the applicable data protection law.
  2. The parties agree that the supervisory authority has the right to conduct an audit of the data importer, and of any subprocessor, which has the same scope and is subject to the same conditions as would apply to an audit of the data exporter under the applicable data protection law.
  3. The data importer shall promptly inform the data exporter about the existence of legislation applicable to it or any subprocessor preventing the conduct of an audit of the data importer, or any subprocessor, pursuant to paragraph 2. In such a case the data exporter shall be entitled to take the measures foreseen in Clause 5 (b).

Clause 9 - Governing Law

The Clauses shall be governed by the law of the Member State in which the data exporter is established.

Clause 10 - Variation of the contract

The parties undertake not to vary or modify the Clauses. This does not preclude the parties from adding clauses on business related issues where required as long as they do not contradict the Clause.

Clause 11 - Subprocessing

  1. The data importer shall not subcontract any of its processing operations performed on behalf of the data exporter under the Clauses without the prior written consent of the data exporter. Where the data importer subcontracts its obligations under the Clauses, with the consent of the data exporter, it shall do so only by way of a written agreement with the subprocessor which imposes the same obligations on the subprocessor as are imposed on the data importer under the Clauses. Where the subprocessor fails to fulfil its data protection obligations under such written agreement the data importer shall remain fully liable to the data exporter for the performance of the subprocessor's obligations under such agreement.
  2. The prior written contract between the data importer and the subprocessor shall also provide for a third-party beneficiary clause as laid down in Clause 3 for cases where the data subject is not able to bring the claim for compensation referred to in paragraph 1 of Clause 6 against the data exporter or the data importer because they have factually disappeared or have ceased to exist in law or have become insolvent and no successor entity has assumed the entire legal obligations of the data exporter or data importer by contract or by operation of law. Such third-party liability of the subprocessor shall be limited to its own processing operations under the Clauses.
  3. The provisions relating to data protection aspects for subprocessing of the contract referred to in paragraph 1 shall be governed by the law of the Member State in which the data exporter is established.
  4. The data exporter shall keep a list of subprocessing agreements concluded under the Clauses and notified by the data importer pursuant to Clause 5 (j), which shall be updated at least once a year. The list shall be available to the data exporter's data protection supervisory authority.

Clause 12 - Obligation after the termination of personal data processing services

  1. The parties agree that on the termination of the provision of data processing services, the data importer and the subprocessor shall, at the choice of the data exporter, return all the personal data transferred and the copies thereof to the data exporter or shall destroy all the personal data and certify to the data exporter that it has done so, unless legislation imposed upon the data importer prevents it from returning or destroying all or part of the personal data transferred. In that case, the data importer warrants that it will guarantee the confidentiality of the personal data transferred and will not actively process the personal data transferred anymore.
  2. The data importer and the subprocessor warrant that upon request of the data exporter and/or of the supervisory authority, it will submit its data processing facilities for an audit of the measures referred to in paragraph 1.

APPENDIX 1 TO THE STANDARD CONTRACTUAL CLAUSES

Data exporter
The data exporter is the entity identified as “Customer” in the Addendum.

Data importer
The data importer is Selz Pty Ltd., a provider of e-commerce services.

Data subjects
Data Subjects include the data exporter’s customers and visitors.

Categories of data
The personal data relating to individuals who visit the stores and/or checkout modals operated by the Customer through Selz Services.

Processing operations
The objective of Processing the Personal Data by the importer is the provision of the importer's ecommerce platform services to the exporter's customers.

APPENDIX 2 TO THE STANDARD CONTRACTUAL CLAUSES

This Appendix forms part of the Clauses and must be completed and signed by the parties. By signing the signature page of this Addendum, the parties will be deemed to have signed this Appendix 2.

Description of the technical and organisational security measures implemented by the data importer in accordance with Clauses 4(d) and 5(c) (or document/legislation attached):

  1. Access Control

    Selz hosts data and applications in industry leading, multi-tenant data centers with comprehensive physical security precautions, including access control systems, ID checking, visit logging and surveillance facilities. The physical and environmental security controls are audited for SOC 2 Type II and ISO 27001 compliance, among other certifications.

    1. Preventing Unauthorized Product Access

      Outsourced processing: Selz maintains contractual relationships with vendors in order to provide its service. Selz relies on contractual agreements, privacy policies, and vendor compliance programs in order to assure the protection of data processed or stored by these vendors.

      Authentication: Selz implemented a uniform password policy for its customer products. Customers who interact with the products via the user interface must authenticate before accessing non-public customer data.

      Authorization: Customer data is stored in multi-tenant storage systems accessible to Selz’s customers via only application user interfaces and application programming interfaces. Customers are not allowed direct access to the underlying application infrastructure. The authorization model in each of Selz’s products is designed to ensure that only the appropriately assigned individuals can access relevant features, views, and customization options. Authorization to data sets is performed through validating the user’s permissions against the attributes associated with each data set.

      Application Programming Interface (API) access: Public product APIs may be accessed using an API key or through Oauth authorization.

    2. Preventing Unauthorized Product Use

      Selz implements industry standard access controls and detection capabilities for the internal networks that support its products.

      Access controls: Network access control mechanisms are designed to prevent network traffic using unauthorized protocols from reaching the product infrastructure. The technical measures implemented include security group assignment and enterprise firewall installations.

      Intrusion detection and prevention: Selz implemented a Web Application Firewall (WAF) solution to protect all hosted sites as well as Selz Service access. The WAF is designed to identify and prevent attacks against publicly available network services.

      Static code analysis: Security reviews of code stored in Selz’s source code repositories is performed, checking for coding best practices and identifiable software flaws.

      Bug bounty: Selz has implemented a bug bounty program that invites and incentivizes independent security researchers to ethically discover and disclose security flaws.

    3. Limitations of Privilege & Authorization Requirements

      Product access: A subset of Selz’s employees have access to the products and to customer data via controlled interfaces. The intent of providing access to a subset of employees is to provide effective customer support, to troubleshoot potential problems, and to detect and respond to security incidents. Employees are granted access by role.

      Background checks: All Selz employees undergo appropriate background checks prior to being extended an employment offer. All employees are required to conduct themselves in a manner consistent with company guidelines, non-disclosure requirements, and ethical standards.

  2. Transmission Control

    In-transit: Selz makes HTTPS encryption (also referred to as SSL or TLS) available on every one of its login interfaces and for free on every customer site hosted on the Selz products. Selz’s HTTPS implementation uses industry standard algorithms and certificates.

    At-rest: Selz stores user passwords following policies that follow at least industry standard practices for security.

  3. Input Control

    Detection: Selz designed its infrastructure to log extensive information about the system behavior, traffic received, system authentication, and other application requests. Internal systems aggregated log data and alert appropriate employees of malicious, unintended, or anomalous activities. Selz personnel, including security, operations, and support personnel, are responsive to known incidents.

    Response and tracking: Selz maintains a record of known security incidents that includes description, dates and times of relevant activities, and incident disposition. Suspected and confirmed security incidents are investigated by security, operations, or support personnel; and appropriate resolution steps are identified and documented. For any confirmed incidents, Selz will take appropriate steps to minimize product and Customer damage or unauthorized disclosure.

  4. Job Control

    Selz uses industry standard and unambiguous wording in its contracts with third parties. Selz regularly reviews its contracts with third parties to monitor contract performance.

  5. Availability Control

    Infrastructure availability: Selz uses industry leading cloud hosting providers to store data. Backup and replication strategies are designed to ensure redundancy and fail-over protections during a significant processing failure. Customer data is backed up to storage media across multiple virtual instances and availability zones.

    Online replicas and backups: All databases containing data and applications are backed up and maintained using at least industry standard methods.

    Selz uses industry leading anti-virus and firewall systems to protect data and applications.

  6. Segregation Control

    Selz restricts access to data stored for different purposes according to staff duties. Selz testing and application environments are securely separated.