Updated: April 27, 2022
Obligations as a xBOT customer
xBOT’s clients generally act as controllers for the personal data registers and data they are processing in xBOT. The aim of the controller (client) is to define the purpose of the register, and the processor (xBOT) is responsible for helping the client in the processing of information in an intended manner. Simply put, this means that the customer uses xBOT for their intended purpose and xBOT assists the customer in implementing this purpose. This means that we are also doing updates to the software so that this is going to be fast and easy. The controller (customer) is responsible for ensuring that data is processed technically and administratively in accordance with the requirements of the regulation. The regulation includes significant changes to how and when registers can be maintained. In addition, the controller must ensure that their own activities are transparent towards the data subject, the data is valid, and correct restrictions are applied to the use of personal data. It is particularly important to remove unnecessary information and to safeguard the data subject’s legislative rights. According to the regulation, the data subject has the right to ask for their registered data, to update it and, in certain circumstances, to demand it’s deleted. If you are a controller, we encourage you to review the content of the regulation. The European Data Protection Supervisor provides vast resources and up-to-date information on its website. We also encourage you to analyse your situation with the assistance of a lawyer, as the services or training they provide may give you instructions directed specifically at your organisation. The responsibility to take care of this is on the controller (client) so we strongly advise to put some effort in.
xBOT compliance with GDPR
We are proud to say that we have put a tremendous amount of work into making sure that everything is in order in respect to the European Union’s General Data Protection Regulation (GDPR). We have put in enterprise-level effort to look after our data protection and privacy as we understand the importance of this matter. This way also our enterprise customers can rely on us to do our part in the data protection chain. xBOT’s data protection mechanisms have been entrusted to the management of the entire company, as well as to a DPO (Christian da Costa) who is responsible for operations as part of the management team. The tech team has set up and implemented the changes required by the regulation. Their task is to implement the data protection processes and changes and make them part of the company’s overall functions and services.
GDPR in the xBOT software
Automatic expiration of personal data
In order to avoid storing old and unnecessary data, xBOT will set an expiration date for personal data by default. Our customers can change the expiration date by request according to their business needs and regulatory requirements.
Stricter requirements for consent
The GDPR enforces even stricter requirements for consent when collecting the data. By using xBOT and strictly required fields, everyone can be sure that the data that enters the system is collected with proper permissions.
Ability to manage personal data
The GDPR gives more rights to individuals over their personal data. We at xBOT provide the possibility for our customers to find out what personal data is stored in their account and therefore fulfil requests coming from individuals. This includes the ability to by request print out a report on personal data by the individual, delete all related personal data etc.
Access to customer data
While we have always accessed customer data only purposefully and with the agreement of our customers, we have developed stricter controls on who can access the data inside the company.
Storing relevant backups is crucial to us for disaster recovery purposes. However, backups tend to hold information even after it is deleted from production systems. This is why we periodically run our backups through certain filters to ensure they contain only information we and our customers have permissions to store.
Data processing and subcontractors
Our objective is to provide the safest and highest quality service to our customers. Like many other SaaS services, we also use subcontractors and partners to provide our service. This means that our subcontractors also take part in the processing of personal data on a case-by-case basis. All our subcontractors go through an audit process, which ensures that they share our own tight security and privacy requirements. For more detailed answers, please contact our Data Protection Officer ([email protected]). Here are the partners used today:
|Name of controller||Categories of processing||Third countries data is transferred to||Safeguards||Agreements|
|Amazon Web Services, Linode, Upcloud||Storage and processing of all customer data||Servers in EU / US based company (except Upcloud)||Privacy shield and automatic wiping of data after customer defined time delay.||DPA|
|Clearbit||OPTIONAL:Gathering company information from IP addresses to enrich the customer’s lead data||US||Only IP address, not considered as personal data, is sent over the wire to acquire company name||Signed SCC|
|Twilio||OPTIONAL: Handling of sending of messages through WhatsApp and Sendgrid Emails||US||Messages and emails in society in general are sent over unencrypted channels. As such as little as possible is included in these channels, but at the end the customer is able to send whatever they want to through these channels and are responsible for their own communication.||DPA|
|Zapier||OPTIONAL:Integrations to the customer’s own 3rd party systems such as CRMs, ATSs etc.||US||Only implemented on the request of the customer in order to integrate with their 3rd party system, in which case the customer is in charge of fulfilling their privacy and GDPR related duties for transferring data into a 3rd party system and xBOT only works as a proxy.||DPA|
As part of a data processing agreement, our customers must accept our subcontractors’ use of personal data.
Data processing agreements
We fully understand our important role as a processor of valuable and confidential personal data and are serious about the responsibility that our customers give us. We have built a processing agreement with our customers in accordance with the Data Protection Regulation, which identifies the customer’s processing instructions for the registry. These guidelines are the foundation for all our processing operations. We require all our customers to accept our data processing agreement so that we can ensure safe and lawful processing of personal data. We will process personal information you provide to xBOT only and solely in accordance with the regulation. These terms you can find at the upper part of this page. xBOT employees undertake to participate in data protection and processing training to ensure that your data is reliably managed. All our employees are also subject to the duty of confidentiality with respect to our customers’ data when they start working at xBOT.
Retrieving and removing data
xBOT provides a possibility for retrieving and removing individual data subject’s items. Also, if your customer relationship with us will nevertheless end, or if you want to retrieve or remove any personal information, we will provide you with the possibility to do this. Retrieving events, data subject, and other personal information is done by request. You can submit a request for this to support(at)xBOT.com. In addition, on request, we can ensure that your personal data is removed on our own and on our subcontractors’ data bases upon termination of your customer relationship. We will permanently remove your information within the stated deadline unless we have a legitimate reason in public interest to maintain the data.
Data transmission internationally
xBOT reserves the right to process information covered by its own registers in countries outside the European Union or the European Economic Area, provided that adequate security and data protection of these services is appropriately undertaken. We also try to minimise the amount of data that is being processed outside the EU, but because of the open nature of the Internet, we cannot completely restrict the processing.
Our support to you
xBOT’s team provides assistance in questions to do with the data protection regulation. In addition, our customer success managers and customer service personnel provide user support and help with xBOT’s data protection features.