New Sub-Processor assessment
Idloom respects its Customer’s privacy and is committed to protecting your Personal Information (any information that relates to an identified or identifiable individual) in compliance with the European Regulation 2016/679 (hereinafter: “GDPR”).
While Google continues to review the impact of the Court of Justice of the European Union (CJEU) case C-311/18, he takes appropriate steps to maintain a high level of privacy protection for idloom Customers and all EU citizens.
Idloom is bound with Google's Cloud Data Processing Addendum (Customers) and Google's EU Standard Contractual Clauses (SCCs module 3: Processor-to-Processor) deemed to apply regardless of the location of the data.
Nevertheless, idloom takes advantage of Google Cloud’s Data Residency capabilities pursuant to the 'Data Location' Section of the General Terms that allows us to store our Customer’s data at rest exclusively in the European Union (Belgium and another EU region).
In addition, idloom uses its own cryptographic keys to protect Customer’s data within Google Cloud.
Please read the complete set of information on Google Cloud & the General Data Protection Regulation (GDPR).
Google is certified against recognized international standards such as ISO/IEC 27001, ISO/IEC 27018 and ISO/IEC 27017. The complete listing of Google’s compliance offerings can be found on the compliance resource center.
For the time being, nothing! Idloom continues to host all its applications and data on its own infrastructure in its data center in Brussels, and only previously accepted sub-processors are used. We have recently invested heavily in improving the security and processing capabilities of our data center and there are no plans to migrate key applications in the next 18 months.
The first major project using Google Cloud will be the implementation of the "Disaster Recovery Plan". We will be putting in place a fully redundant infrastructure that, in the event of a major data center failure, will allow us to return to an operational state quickly enough to fully meet our service level agreement.
The second plan is to use Goggle Cloud to store encrypted backups in a frozen state to prevent modification by a system, a user or, in extreme cases, by ransomware.
We may also decide to host some of idloom's future applications or modules in Google Cloud, if that would be attractive in terms of reliability or performance.
Finally, we may decide at some point to migrate all applications when we decide to dismantle our data center. As mentioned earlier, this will not happen in the next 18 months anyway.
We emphasize that we have taken all legal, technical and security measures to integrate Google Cloud into our list of sub-processors in full compliance with RGPD rules. We would be happy to assist you in the process of evaluating and validating these measures if you have not yet accepted Google Cloud as a sub-processor.
In the meantime, even if the main services related to idloom applications remain valid and work perfectly without the use of Google Cloud as a sub-processor, some services and related guarantees may no longer be available to you.
By June 2023, our new “Disaster Recovery Plan” will be in place at Google Cloud. In the event of a major datacenter failure, even though this risk is extremely limited, we would not be able to guarantee that we would be able to meet our Service Level Agreement in terms of service recovery for the service we offer you.
Starting in October 2023, we may decide to host some new services or modules exclusively on Google Cloud. These services or modules, while ancillary to the main services you currently use, will not be available to you if you have not accepted Google Cloud as a sub-processor by that time.
Finally, we may decide within the next 24 months not to replace components in our datacenter that would become obsolete. This would force us to move all or part of our core services to Google Cloud.
Should you need any assistance with this sub-processor assessment, please reach out to us at privacy@idloom.com and we will be glad to assist you with your request.
14-Mar-2023, Brussels, Belgium.
I herely accept the Google Cloud.
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