Data Processing Agreement

v3.0 published on 1 September 2023

INTRODUCTION

Licensee (hereinafter referred to as the “controller”) controls certain personal data, which it wishes to provide to Scrive (hereinafter referred to as the “processor”) (each a “Party”; together the “Parties”) in accordance with the Agreement and, in particular, with the terms set out herein.

For the purposes of Article 28(3) of Regulation 2016/679 (the “GDPR”) between controller and processor, the Parties hereby agree to the following Data Processing Agreement (the “Clauses”) with one or several applicable sets of annexes (each set referred to as an “Enclosure”) for each of the Scrive Services respectively, per the specifications in the Agreement, in order to meet the requirements of the GDPR and to ensure the protection of the rights of data subjects, upon which the controller will provide the processor with the personal data and the processor shall process the personal data.

SECTION I

Clause 1

Purpose and scope

(a) The purpose of these Clauses is to ensure compliance with Article 28(3) and (4) of 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.

(b) The Parties have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679.

(d) Annexes I to III are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679.

Clause 2

Modifications of these Clauses

The Terms & Conditions for Online Agreement Documents, as stated on https://www.scrive.com/terms/oad/ (follow link to view) shall apply without limitation to these Clauses and its Enclosures. Notwithstanding the above, Clause 7.7 (a) shall apply without limitation to Annex II to each respective Enclosure.

Clause 3

Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

(d) Any reference in these Clauses to the “Agreement” shall be deemed to refer to the valid license agreement (or similar) between the Parties that covers the processor’s provision and licensing of Scrive Services to the controller. Any reference to “Scrive Services” shall be deemed to refer to such services provided to controller by processor under the Agreement as per the further specifications in the Agreement. The Parties agree and acknowledge that within the Scrive Services portfolio, there are some main services with specific characteristics in terms of data processing. This necessitates the use of a separate Enclosure per main service, including individual details. The specific Enclosure(s) as relevant and reflecting the current agreed scope under the Agreement shall be included and form a part of these Clauses.

Clause 4

Hierarchy

In the event of a contradiction between these Clauses and the other Agreement documents the order of precedence as specified in the Agreement shall apply.

Clause 5

Limitation of liability

The Parties agree that each Party is liable in accordance with the GDPR, subject to the general limitation of liability as set out in the Agreement. Each Party acknowledges that the Parties are individually liable for any penalties or administrative fines imposed pursuant to the GDPR. Thus, the Parties agree to refrain from making any claims for compensation, through recourse proceedings (or otherwise), against the other Party on the basis of such penalties or administrative fines.

SECTION II – OBLIGATIONS OF THE PARTIES

Clause 6

Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex I.

Clause7

Obligations of the Parties

7.1. Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex I, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex I.

7.4. Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

Processor has taken organisational and technical safeguards, as described in Annex III, to protect controller’s data, including sensitive data. Notwithstanding the above, the Parties acknowledge that processor does not control, nor does processor monitor the types of data that processor processes on behalf of controller. Thus, processor has no way of knowing what types of personal data controller uploads to the Scrive Services. It is up to controller to determine whether it is appropriate and sufficient or not to make use of a certain Scrive Services for each specific category of personal data. Furthermore, processor may within the Scrive Services offer controller mitigating measures such as customisable retention tools, offboarding of documents, and multiple choices of hosting providers, subject to service specific limitations.

7.6 Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

(f) The controller accepts and acknowledges that; restrictions for on-site audits may apply for the processor’s third party hosting environments; processor shall have the right to require reasonable compensation for its actual costs, and for its assistance, in connection with any inspections performed at the premises or physical facilities of processor; an audit shall not grant the controller access to processor’s, or any third-party’s, trade secrets or proprietary information unless such access is required to comply with Regulation (EU) 2016/679; the controller shall ensure that any personnel conducting an audit are subject to adequate secrecy obligations; an audit must be performed without causing interruptions to the processor’s regular service operations, and; the processor shall be entitled to receive a copy of any audit report, whereby confidential information of the controller may be redacted.

7.7. Use of sub-processors

(a) The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 60 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679.

(c) At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

7.8. International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8

Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions

(c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

(1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;

(2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;

(3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;

(4) the obligations in Article 32 Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9

Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 Regulation (EU) 2016/679, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b) in obtaining the following information which, pursuant to Article 33(3) Regulation (EU) 2016/679:

(1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;

(2) the likely consequences of the personal data breach;

(3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III – FINAL PROVISIONS

Clause 10

Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

(2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679;

(3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

– – –

v1.1 published on 1 September 2023

DPA ENCLOSURE – esignatur by Scrive

Annex I – Processing Activities

1 Purposes of Processing

The processor shall, in accordance with the Agreement, provide the controller with:

(i) esignatur by Scrive, i.e., a cloud-based software as a service solution used by controller for the main purposes of performing and/or enabling; electronic signatures of documents provided by the controller; various methods for authentication of a signatory’s identity;

(ii) the optional logging of documents signed, including related evidence materials within the solution, and;

(iii) associated support/maintenance/statistical/security services, including problem report handling services.

All of the above is hereinafter referred to as the “Services”.

2 Instructions

a. The processor shall only be entitled to process the personal data for the purposes set out in section 1 above, and in accordance with the controller’s reasonable written instructions, and in any event in compliance with applicable laws and legal obligations. In this context, the processor’s provision of the Services in accordance with the controller’s configurations of, and data input into, esignatur by Scrive shall be deemed as following the instructions from the controller. If, by following any additional reasonable instructions from the controller, the processor would incur additional costs (other than such costs that the processor incurs as a result to amend necessary operations in order for it to comply with the GDPR), the Parties shall agree in good faith on the apportionment of such costs.

b. Controller acknowledges and agrees that a Processed Document can be sent/made available through the Services via email or touch device to such third party recipient(s) as designated by controller and that the recipient may thus access the Processed Document from whatever country where the recipient may be located.

3 Specific Definitions

“External Initiator”	means a third party that initiates a signing process via the Services for a specific Processed Document. N.b. a third party can only initiate a signing process via the Services if the controller has enabled such access via an integration with the esignatur by Scrive service (typically as a web-form integration).
“External User“	means a third party that has an active account of their own within esignatur by Scrive. To avoid doubt; also an employee of the controller could, in their capacity of a private person with a private account in esignatur by Scrive, be deemed as an External User.
“Initiator”	means an individual employee/representative of the controller that initiates a signing process via the Services for a specific Processed Document.
“Processed Document”	means a document that has been uploaded to esignatur by Scrive by the controller by any available means (e.g. esignatur by Scrive web-interface, API or printer-driver) and including any and all personal data that is (i) included in such document and (ii) associated therewith as metadata.

4 Categories of data subjects

a) Any data subject that acts as the Initiator in relation to a Processed Document;

b) Any data subject as may be designated by the Initiator as a signatory, reviewer or other party, in relation to a Processed Document;

c) Any data subject that acts as an External Initiator in relation to a Processed Document, and;

d) Any other data subject (if any) whose personal data was originally included in the contents of a Processed Document – or as may be added to a Processed Document by a signatory thereto – without such data subject belonging to either of the above categories with regards to that same Processed Document.

e) Employees of the controller that have an account in the Services and/or that contact the processor’s support/helpdesk resources.

5 Categories of personal data

(i) Always

Audit trail / evidence collected to ensure the validity of electronic signatures, including time of reviewing and signing, and IP-addresses of the parties involved in the individual signing process.

(ii) Typically

Name and contact details (e.g., email address, home address, mobile phone number etc.) of the data subject that shall be the signatory or reviewer of a Processed Document. Handwritten signature (optional). In case eID is used (optional); any such categories of personal data as processed by the selected eID Provider, as further detailed in Annex II.

(iii) Additionally

Any other personal data that may be added by an Initiator/External Initiator of a Processed Document and/or originally included in the Processed Document, and/or added or attached to the Processed Document by a signatory to the document.

6 Processing Operations

The Processing of personal data in accordance with the Agreement includes the following main events:

1. Personal data of category (i) Always is collected by the Services throughout all events and gathered in an event log (audit trail) that is appended to the Processed Document when signed by all parties thereto.

2. Personal data may already be included in a document to be Processed when uploaded to the Services by the Initiator, or when already made available to the Initiator (or External Initiator, as the case may be) as a template stored in the Services.

3.
a) Personal data is added as metadata in the Services by the Initiator and may be used to populate fields in the Processed Documentb) In case of use via an integration to the esignatur by Scrive API: personal data as entered by an Initiator (or External Initiator, as the case may be) is automatically transferred as metadata from the controller’s system to the Services and may be used to populate fields in the Processed Document.c) Additional personal data may be added, or attached, by a signatory to the Processed Document

4. The Processed Document is made available to the signatories, reviewers or other parties thereto via the means as configured by the controller, i.e. through either a) an invitation message sent via the services (including a hyperlink to the Processed Document) distributed to the designated recipients via email, b) through email services outside of the services or c) without any invitation message in case of e.g. a web-form integration.

5. When the Processed Document has been signed by all the signatories thereto, personal data is embedded in the final PDF, as well as in the attached evidence package. The final PDF, including the evidence package, is sealed with a digital signature.

6. Unless configured otherwise by the controller in the Services, the final PDF is distributed and made available (downloadable) via web-link included in confirmation message to such parties. The final PDF may also/alternatively be distributed as an attachment via confirmation email to the Initiator, the signatories, and reviewers (if any) of the Processed Document.

7 Data Retention

Retention and deletion of personal data in the e-archive of the Services:

1. Personal data is retained in the Services in two types of instances; (i) as data included in a Processed Document and (ii) as metadata related to the Initiator (or External Initiator, as the case may be), each signatory and any reviewer to the Processed Document.

2. The processor will only store documents for a given period unless otherwise agreed upon. When a signing order is completed, the Processed Document will be stored for 90 days after which they will be deleted.

(i) Deletion of documents takes place as follows.

– Expiration: At expiration, the documents are deleted immediately. This is done automatically via an application on the Data Processor’s server.

– Cancelled: If cancelled, the documents are deleted when reaching the set expiration date. This is done automatically via an application on the Data Processor’s server.

– Signed: When signed, the document is stored for 90 days after which it is deleted. This is done automatically via an application on the Data Processor’s server.

– Awaiting: As long as a signing order has the status “awaiting”, the Data Processor stores the documents associated with the order.

The Data Processor keeps documentation from the CPR-check service, until the Data Controller

requests them to be deleted/alternatively after 5 years from termination of the Agreement.

(ii) Deletion of documents takes place as follows.

– Expiration: Upon expiration, the order will be deleted immediately. This is done automatically via an application on the Data Processor’s server.

– Cancelled: If cancelled, the order will be deleted when reaching the set expiration date. This is done automatically via an application on the Data Processor’s server.

– Completed: Upon completion, the documentation from the CPR-check service is kept until the Data Controller requests to have it deleted.

– Awaiting: As long as a CPR-check has the status awaiting, the Data Processor stores the order.

esignatur ”Forms” stores the signed forms until the Customer deletes the signed forms for themselves.

3. Metadata associated to Processed Documents will be retained in the Services until deleted by controller or as described in section 4 below.

Retention and deletion of data upon termination of the Agreement:

4. Upon the termination of the Agreement, the processor will delete all of the controller’s personal data. The controller may in writing request the processor to return to the controller any retained personal data prior to deleting any remaining copies in accordance with the above. Such request must however be done within ten (10) days after the termination of the Agreement.

Annex II – Sub-processor list

Approved sub-processors

On commencement of these Clauses, the controller authorises the engagement of the sub-processors listed at:

https://www.esignatur.dk/underdatabehandlere/ (follow link to view)

Optional usage

The controller accepts and acknowledges that the controller is entrusted with selecting to use such sub-processors that are subject to “optional usage” as per the current sub-processor list. The selection of usage may either be made directly within the Services through controller’s own configurations/settings, or – when specific activation is required – by ordering access to the services provided by a specific sub-processor from the processor.

Prior notice for the authorisation of sub-processors

With reference to clause 7.7 (a) the controller may object to such notified change in the event of its reasonable concerns with regards to the appropriate protection of personal data. Such objection shall be detailed in writing within fifteen (15) working days from the processor’s original notice where after the Parties shall in good faith endeavour to settle the situation. In the event that the controller’s reasonable concerns still remain after conclusion of such good faith effort, then the controller shall have the right to terminate the Agreement forthwith by written notice without liability for either Party.

Annex III – Technical and organisational measures

Information Security Approach

An ISMS based on ISO/IEC 27001 using a continual improvement model is used to enhance information security over the time it is operated on an ongoing basis. To measure success testing, monitoring, and measuring effectiveness of controls is carried out internally as part of ISMS management and externally as part of yearly auditing.

Continual, systematic risk assessment considers threats, vulnerabilities and impacts affecting confidentiality, availability and integrity of assets and devises treatment plans based on risk scoring to address risks that are not acceptable via technical and organisational controls.

Responsibility and therefore accountability is assigned to policies, procedures and controls designed to meet organisational and customer information security requirements.

Business Continuity

A business continuity policy backed by procedures is maintained, aimed at mitigating disaster scenarios that may impact operations targeting various situations, including:

Loss of facilities (e.g., via a pandemic, estate issues, natural disaster etc.)
Impairment of facilities (e.g., loss of supporting utilities, internet connectivity, etc.)
Loss or corruption of information assets including production systems data.

The policy and procedures detail requirements (RTO, RPO etc) and resolutions for each scenario and mitigating controls (e.g., defining a backup regime and requirements for periodic backup testing) so that normal operations may resume as rapidly as possible.

Data Protection Controls

Baseline configuration and ongoing management of employee devices is carried out via MDM, and servers using infrastructure-as-code, including installation of security software relevant to the platform in question which may include EDR/Antivirus and/or intrusion detection software.

Cryptography policies cover requirements such as strong, unbroken encryption ciphers or hashing algorithms and key management. Data at rest (including documents in object storage, databases, employee devices, backups etc.) and transport over public networks is encrypted.

Identity and Access Management systems are integrated with internal systems where possible, with a requirement for auditable management of access rights assignment and operated using the principle of minimum-privilege and role-based access.

Log management is centralised and heavily restricted to allow troubleshooting and performance & security monitoring of systems. Where systems do not support centralised logging, secure log shipping measures are utilised to enable this.

Passwords are governed by a password policy defining requirements such as complexity, multi-factor authentication and usage of an enterprise password management utility.

Retention controls are applied to different systems containing applicable data governed by a retention policy designed by our Legal Department and DPO to meet legal and regulatory requirements.

Supplier management procedures govern the onboarding and ongoing relationship with third party suppliers, considering legal, physical, and technical security controls utilised in the delivery of services at locations where data is processed.

Data minimisation and quality

Scrive does not require or retain any personal data that is not needed for a signing process to be completed and/or such data that the customer has defined to be a part of their signing process(es), and then only until the customer deletes the signing process from the system.

Regardless of input method, input data is escaped to avoid injection attacks. The controller may, if so desired and when feasible, define the format of permitted input by means of regular expressions on a case-by-case basis. Input of data of known format (e.g. personal identification numbers) is validated automatically by the Scrive Services used.

Data portability

Scrive Services that feature document export offer the output of documents in ISO 32000 PDF format and of metadata in JSON and/or CSV format.

Other transactional data can be exported in JSON format for the duration of the retention period for transaction history of the relevant service.

Data erasure

Scrive will retain personal data within the Services in accordance with the processing operations for data retention as set forth for the relevant Scrive Services as subscribed to by the controller. When a transaction is deleted from the Scrive Services, Scrive will retain an internal transaction identifier (which cannot be used to identify any individual) and the date and time of that transaction, for billing and statistics purposes. Data that has been captured by the daily backups will, in accordance with the processor’s data retention policy, be retained in AES-256 encrypted format until it is automatically deleted after a period defined in said policy (i.e. no longer than six months).

– – –