Annex II — Technical and Organisational Measures

Technical and Organisational Measures Including Technical and Organisational Measures to Ensure the Security of the Data

Description of the technical and organisational security measures implemented by Grubtech as the data processor/data importer to ensure an appropriate level of security, taking into account the nature, scope, context, and purpose of the processing, and the risks for the rights and freedoms of natural persons.

Security

Security Management System

Organization. Grubtech designates qualified security personnel whose responsibilities include development, implementation, and ongoing maintenance of the Information Security Program.

Policies. Management reviews and supports all security related policies to ensure the security, availability, integrity and confidentiality of Customer Personal Data. These policies are updated at least once annually.

Assessments. Grubtech engages a reputable independent third-party to perform risk assessments of all systems containing Customer Personal Data at least once annually.

Risk Treatment. Grubtech maintains a formal and effective risk treatment program that includes penetration testing, vulnerability management and patch management to identify and protect against potential threats to the security, integrity or confidentiality of Customer Personal Data.

Vendor Management. Grubtech maintains an effective vendor management program.

Incident Management. Grubtech reviews security incidents regularly, including effective determination of root cause and corrective action.

Standards. Grubtech operates an information security management system that complies with the requirements of ISO/IEC 27001:2022 standard.

Personnel Security

Grubtech personnel are required to conduct themselves in a manner consistent with the company's guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. Grubtech conducts reasonably appropriate background checks on any employees who will have access to client data under this Agreement, including in relation to employment history and criminal records, to the extent legally permissible and in accordance with applicable local labor law, customary practice and statutory regulations.

Personnel are required to execute a confidentiality agreement in writing at the time of hire and to protect Customer Personal Data at all times. Personnel must acknowledge receipt of, and compliance with, Grubtech's confidentiality, privacy and security policies. Personnel are provided with privacy and security training on how to implement and comply with the Information Security Program. Personnel handling Customer Personal Data are required to complete additional requirements appropriate to their role (e.g., certifications). Grubtech's personnel will not process Customer Personal Data without authorization.

Access Controls

Access Management. Grubtech maintains a formal access management process for the request, review, approval and provisioning of all personnel with access to Customer Personal Data to limit access to Customer Personal Data and systems storing, accessing or transmitting Customer Personal Data to properly authorized persons having a need for such access. Access reviews are conducted periodically to ensure that only those personnel with access to Customer Personal Data still require it.

Infrastructure Security Personnel. Grubtech has, and maintains, a security policy for its personnel, and requires security training as part of the training package for its personnel. Grubtech's infrastructure security personnel are responsible for the ongoing monitoring of Grubtech's security infrastructure, the review of the Services, and for responding to security incidents.

Access Control and Privilege Management. Grubtech's and Customer's administrators and end users must authenticate themselves via a Multi-Factor authentication system or via a single sign on system in order to use the Services.

Internal Data Access Processes and Policies – Access Policy. Grubtech's internal data access processes and policies are designed to protect against unauthorized access, use, disclosure, alteration or destruction of Customer Personal Data. Grubtech designs its systems to only allow authorized persons to access data they are authorized to access based on principles of "least privileged" and "need to know", and to prevent others who should not have access from obtaining access. Grubtech requires the use of unique user IDs, strong passwords, two factor authentication and carefully monitored access lists to minimize the potential for unauthorized account use. The granting or modification of access rights is based on: the authorized personnel's job responsibilities; job duty requirements necessary to perform authorized tasks; a need to know basis; and must be in accordance with Grubtech's internal data access policies and training. Approvals are managed by workflow tools that maintain audit records of all changes. Access to systems is logged to create an audit trail for accountability. Where passwords are employed for authentication (e.g., login to workstations), password policies follow industry standard practices. These standards include password complexity, password expiry, password lockout, restrictions on password reuse and re-prompt for password after a period of inactivity.

Data Center and Network Security

Data Centers.

Infrastructure. Grubtech has AWS as its data center.

Resiliency. Multi Availability Zones are enabled on AWS and Grubtech conducts Backup Restoration Testing on regular basis to ensure resiliency.

Server Operating Systems. Grubtech's servers are customized for the application environment and the servers have been hardened for the security of the Services. Grubtech employs a code review process to increase the security of the code used to provide the Services and enhance the security products in production environments.

Disaster Recovery. Grubtech replicates data over multiple systems to help to protect against accidental destruction or loss. Grubtech has designed and regularly plans and tests its disaster recovery programs.

Security Logs. Grubtech's systems have logging enabled to their respective system log facility in order to support the security audits, and monitor and detect actual and attempted attacks on, or intrusions into, Grubtech's systems.

Vulnerability Management. Grubtech performs regular vulnerability scans on all infrastructure components of its production and development environment. Vulnerabilities are remediated on a risk basis, with Critical, High and Medium security patches for all components installed as soon as commercially possible.

Networks and Transmission

Data Transmission. Transmissions on production environment are transmitted via Internet standard protocols.

External Attack Surface. AWS Security Group which is equivalent to virtual firewall is in place for Production environment on AWS.

Incident Response. Grubtech maintains incident management policies and procedures, including detailed security incident escalation procedures. Grubtech monitors a variety of communication channels for security incidents, and Grubtech's security personnel will react promptly to suspected or known incidents, mitigate harmful effects of such security incidents, and document such security incidents and their outcomes.

Encryption Technologies. Grubtech makes HTTPS encryption (also referred to as SSL or TLS) available for data in transit.

Data Storage, Isolation, Authentication, and Destruction. Grubtech stores data in a multi-tenant environment on AWS servers. Data, the Services database and file system architecture are replicated between multiple availability zones on AWS. Grubtech logically isolates the data of different customers. A central authentication system is used across all Services to increase uniform security of data. Grubtech ensures secure disposal of Client Data through the use of a series of data destruction processes.

Annex III — List of Sub-processors

Please refer to https://security.grubtech.com/