Data Protection Agreement

1. Definitions

• Data Controller: TribeZ, responsible for determining data processing purposes
• Data Processor: Third-party services processing data on our behalf
• Data Subject: Individuals whose personal data is processed
• Personal Data: Any information relating to an identified or identifiable person
• Processing: Any operation performed on personal data

2. Processing Activities

• Purpose: Platform operation, user management, payment processing
• Duration: For the duration of account activity plus retention period
• Categories: Account data, payment information, communication logs
• Recipients: Authorized personnel and approved third-party services

3. Security Measures

• Encryption: AES-256 encryption for data at rest and in transit
• Access Controls: Role-based access with least privilege principle
• Audit Logging: Comprehensive logging of all data access
• Regular Assessments: Quarterly security assessments and penetration testing
• Incident Response: 24/7 monitoring and rapid response procedures

Data Subject Rights

• Right to Access: Request confirmation of data processing and copies
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of personal data ("right to be forgotten")
• Right to Restriction: Limit processing under certain conditions
• Right to Portability: Receive data in structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests

Response Procedures

• All requests acknowledged within 24 hours
• Full response provided within 30 days
• No fees charged for standard requests
• Identity verification required for sensitive requests
• Appeal process available for denied requests

Technical Security

• Infrastructure: AWS/GCP with SOC 2 Type II compliance
• Network Security: Firewalls, DDoS protection, VPN access
• Application Security: OWASP Top 10 compliance, regular security testing
• Database Security: Encrypted connections, access logging, backup encryption
• API Security: Rate limiting, authentication, input validation

Organizational Security

• Employee Training: Annual security awareness training
• Background Checks: Pre-employment screening for all staff
• Access Management: Regular access reviews and privilege audits
• Incident Response: Documented procedures and escalation matrix
• Business Continuity: Disaster recovery and backup procedures

Certifications and Standards

• ISO 27001: Information security management system
• SOC 2 Type II: Security, availability, and confidentiality controls
• GDPR: Full compliance with European data protection regulations
• CCPA: California consumer privacy rights compliance
• PCI DSS: Payment card industry data security standards

Regular Audits

• Annual third-party security assessments
• Quarterly internal security reviews
• Monthly vulnerability scanning and penetration testing
• Continuous monitoring and threat detection
• Regular compliance gap analysis

Breach Detection and Response

• 24/7 Monitoring: Automated threat detection and alerting
• Incident Classification: Risk-based assessment of security incidents
• Containment Procedures: Immediate isolation and mitigation steps
• Forensic Analysis: Detailed investigation and root cause analysis
• Recovery Planning: Business continuity and system restoration

Notification Requirements

• 72-Hour Rule: GDPR notification within 72 hours of discovery
• Data Subject Notification: Individual notification for high-risk breaches
• Regulatory Reporting: Required notifications to data protection authorities
• Transparency: Public disclosure when required by law
• Documentation: Comprehensive breach documentation and lessons learned

Approved Subprocessors

• Cloud Infrastructure: AWS, Google Cloud Platform
• Payment Processing: Stripe, PayPal
• Communication: SendGrid, Twilio
• Analytics: Google Analytics (anonymized data only)
• Support: Zendesk, Intercom

Subprocessor Requirements

• All subprocessors must sign data processing agreements
• Regular security assessments of subprocessors
• Notification of any subprocessor changes
• Right to audit subprocessor security practices
• Subprocessors must meet same security standards

Data Protection Officer

Additional Resources