Buddy's GDPR compliance

The EU General Data Protection Regulation (GDPR) sets a new standard for how companies use and protect EU citizens’ data. The regulation has been in force since May 25, 2018. You can find all information about GDPR at https://www.eugdpr.org/.

Over the last few months, we’ve been receiving questions about compliance with the General Data Protection Regulation (GDPR). We have worked hard to ensure that we fulfill its obligations and maintain our transparency about personal data processing. As a result, we can officially confirm that Buddy is compliant with the GDPR.

This post outlines what we have done to make sure that Buddy meets GDPR obligations.

GDPR overview

The purpose of GDPR is to protect the private information of EU citizens and give them more control over their personal data. Under GDPR, private information is defined as any information that is directly or indirectly identifiable to an individual. This includes information such as social security numbers, location data, online identifiers, pseudonymous data, and genetic or biometric data, such as fingerprints and facial recognition.

Specifically, GDPR grants EU citizens the following means of controls over their personal data:

Transparent information about data processing

Every company that hold and/or process data of any person in the EU is obligated to provide any information relating to processing this data subject

Right of access

Data controllers will be required to fulfill requests from individuals seeking access to their private data or information on how it is being used. Data collectors and processors will have to detail how the personal information was obtained, how and why it is being used, as well as with whom the company is sharing the information. Companies will also be mandated to provide the individual with a copy of their personal records.

Right to be Forgotten

Individuals can decide they no longer want their personal data to be processed and request all of their information to be deleted.

Notice of security breaches

Individuals must be alerted within 72 hours if their personal data has been hacked or otherwise compromised.

Privacy by design

The idea has existed as a concept for years now, but it is only just becoming part of a legal requirement with the GDPR. At its core, privacy by design calls for the inclusion of data protection from the onset of the designing of systems, rather than an addition.

Data portability

Individuals will be permitted to move their personal data from one company to another upon request, without opposition from the data controller.

Buddy and GDPR

Over the last few months, we’ve gotten questions asking about our General Data Protection Regulation (GDPR) compliance. In October 2017 we have made thoroughly research the areas of our product and our business impacted by GDPR. Here are all important points regarding Buddy and GDPR

Transparent information about data processing

The Article 4 of GDPR defines data controllers and data processors as below:

Controller – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor – a natural or legal person, public authority, agency or another body which processes personal data on behalf of the controller.

For example, if Acme Co. sells widgets to consumers and uses Email Automation Co. to email consumers on their behalf and track their engagement activity, then, with regard to such email activity data, Acme Co. is the data controller, and Email Automation Co. is the data processor.

This distinction is important for compliance. Generally speaking, the GDPR treats the data controller as the principal party for responsibilities such as collecting consent, managing consent-revoking, enabling the right to access, etc. A data subject who wishes to revoke consent for his or her personal data therefore will contact the data controller to initiate the request, even if such data lives on servers belonging to the data processor. The data controller, upon receiving this request, would then proceed to request the data processor remove the revoked data from their servers.

Buddy as a Data Controller

In the meaning of Data Controller stated above, Buddy stores the following private data:

1. User email address
2. User name (option)
3. User phone number (option)
4. User avatar (option)

If you create an account in Buddy, we will ask you for a valid email address. The email address will be used as your ID in the service. You also have the option to give us more information if you want to, including real name, additional email address, phone number and a photograph (avatar). This type of information will be shared in the workspace (account) with other workspace members for identification purposes, with the phone number required for two-factor identification and notifications to your mobile about events in the workspace.

Why we collect this

• We need your Personal Information to create your account, and to provide the services you request.
• We show your Personal Information on your profile page. This profile is only accessible by users with whom you share a workspace.
• We use your Personal Information, specifically your email address, to identify you on Buddy.
• We will use your email address to communicate with you (newsletters, notifications). You can change your email and unsubscribe from those messages any time. We are using AWS SES to send our email messages to our clients (all information about our Vendors and their GDPR commitments is listed below)

We limit our use of your Personal Information to the purposes listed in our Privacy Statement. We do not share, sell, rent, or trade Personal Information with third parties.

Buddy as a Data Processor

All private data stored in Buddy's Git repositories, pipelines and sandboxes are defined by our users. What data is stored, how it is processed and how it is used by our users. In this case, Buddy operates as a Data Processor. User as the controller of the information must ensure that the collection of personal data is GDPR compliant as well as other processors in his pipeline.

If require, Buddy customers can ask for a signed Data Processing Agreement, which defines our responsibilities regarding the data stored on our servers.

Right of access and Right to be Forgotten

Buddy doesn’t ask for more personal data from our users than we need to provide our services to you. We provide you the ability to access and delete the data you have given us (e.g. you can remove your profile information at any time).

We have gone through our Privacy Statement to provide more context and transparency, though, so our users understand exactly why we ask for information and what we’ll do with it.

Notice of security breaches

Buddy takes all measures reasonably necessary to protect Personal Information from unauthorized access, alteration, or destruction, maintain data accuracy, and help ensure the appropriate use of Personal Information. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We are committed to announcing any security breaches within 72 hours after we notice this kind of issue.

Privacy by design

Since the very beginning, the application's architecture and server infrastructure have been designed and chosen specifically to ensure that all user data is safe.

The application and user data are hosted Amazon Web Services servers. You can see how AWS secures data here. Amazon's GDPR commitment is available here.

Buddy’s system installation is using a hardened, patched OS with dedicated firewall and VPN services that help block unauthorized access. We also employ industry-leading solutions to mitigate DDoS attacks. Our servers are under constant surveillance by SecurityMetrics with security audits performed every quarter in accordance to AWS Security Audit Guidelines.

The application is continually updated on weekly basis with the most recent and secure solutions. Critical security patches are provided as needed outside of the regular release cycle and specifically announced with email notifications and via our Twitter channel. We also have a bug bounty program that lets users report vulnerabilities to our dedicated address security@buddy.works. All reported issues and security holes are fixed with the highest priority.

Data portability

As described it Transparent information about data processing Buddy, as a private Data Controler, has only access to data that provided during registration with optional Personal Information provided by the user. All this information can be found in My-ID. The data can be changed, removed or copied at any time.

Tracking

If you do not want online services to collect and share certain kinds of information about your online activity from third-party tracking services, you can set the Do Not Track privacy preference in your browser.

We do not track your online browsing activity on other online services over time and we do not permit third-party services to track your activity on our site with the exception of basic Google Analytics tracking and occasional user behavior tracking performed with Hotjar analytics tool. The tracking data is collected exclusively to improve the UX and performance of the Service and website. Buddy does not record any personal data with Hotjar as all text entered to the Service during tracking is suppressed before the data is sent back to Hotjar servers.

Because we do not share this kind of data with third-party services or permit this kind of third party data collection on Buddy for any of our users, and we do not track our users on third-party websites ourselves, we do not need to respond differently to an individual browser's Do Not Track setting. If you wish, you can opt out from Google Analytics tracking here, and from Hotjar here.

Our emails might contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email. If you prefer not to receive pixel tags, please opt out of marketing emails.

Our Vendors

We also use the services that already confirmed they met GDPR conditions or are in the final stage of preparations:

• Amazon Web Services – hosting infrastructure for the Service and SES for email and SMS notifications (United States)
• Braintree – payment processing (United States)
• Digital Ocean – hosting infrastructure for Buddy's website (United States)
• Google G Suite – email communication with clients (United States)
• Intercom – helpdesk and customer messaging platform (United States)
• Hotjar – UX analytics (Europe/Malta)
• Singlehop – parts of hosting infrastructure for the Service (until May 2018) (United States)

Updates to our ToS and other policies

To achieve compliance with the GDPR we're very focused on bringing our policies into alignment with the new law. This includes updates to Terms of Service, Privacy Policy, and Safety & Security.

We also offer a GDPR-compliant Data Processing Addendum (DPA), enabling you to comply with GDPR contractual obligations. If you need a Data Protection Agreement with us, please contact us at support@buddy.works.