EU Data Protection

Overview

Practical Cloud Ltd, A United Arab Emirates registered company that abides by UAE laws, prioritizes customer trust. We know that customer data is important to our customers’ values and operations. That is why we keep it private and safe.

Our customers entrust us with large amounts of sensitive information, stemming from a wide range of industries including healthcare, financial services, government, and technology.

Practical Cloud helps customers maintain control of their privacy and data security in a myriad of ways:

Data Security: We provide our customers compliance with high security standards, such as encryption of data in motion over public networks, auditing standards (SOC 2, ISO 27001, ISO 27018), Distributed Denial of Service (“DDoS”) mitigations, and a Support team that is on-call 24/7.
Disclosure of Customer Service Data: Practical Cloud only discloses Service Data to third parties where disclosure is necessary to provide the services or as required to respond to lawful requests from public authorities.
Trust: Practical Cloud, through its providers (Rackspace, NameSilo, Enom, Amazon, Hetzner Online AG, has developed security protections and control processes to help our customers ensure a secure environment for their information.
Access Management: Practical Cloud provides an advanced set of access and encryption features to help customers effectively protect their information. We do not access or use customer content for any purpose other than providing, maintaining and improving Practical Cloud services and as otherwise required by law.

What is Service Data?

Service Data is any information, including personal data, which is stored in or transmitted via Practical Cloud services, by, or on behalf of, our customers and their end-users.

Who owns and controls Service Data?

From a privacy perspective, the customer is the controller of Service Data, and Practical Cloud and its suppliers are a processor. This means that throughout the time that a customer subscribes to services with Practical Cloud, the customer retains ownership of and control over Service Data in its account.

Who are Practical Cloud’s sub-processors?

Entity Name	Entity Type	Entity Country
Rackspace	Cloud Service Provider	United States
Amazon Web Services	Cloud Service Provider	United States
CodeGuard	Cloud Service Provider	United States
Hetzner Online AG	Cloud Service Provider	Germany
LiveDrive	Cloud Service Provider	UK
Level 27 BVBA	Cloud Service Provider	Belguim
Namesilo Inc.	Domain Registrar	United States
Enom	Domain Registrar	United States
Name.com	Domain Registrar	United States
Only Domains	Domain Registrar	New Zealand

How does Practical Cloud use Service Data?

We use Service Data to operate and improve our services, help customers access and use the services, respond to customer inquiries, and send communication related to the services.

What steps does Practical Cloud take to secure Service Data?

Practical Cloud prioritizes data security and combines enterprise-class security features with comprehensive audits of our applications, systems, and networks to ensure customer and business data is always protected.

For example, Practical Cloud servers are hosted at Tier IV or III+, SSAE-16, PCI DSS, or ISO 27001 compliant facilities. Our Support team is on call 24/7 to respond to security alerts and events.

Where will Service Data be stored?

Practical Cloud, through its sub-processors has data centers in three main regions — United States, Asia Pacific, and the European Union. The location depends on the type of service offered.

How does Practical Cloud Respond to Information Requests?

Practical Cloud recognizes that privacy and data security issues are top priorities for customers.

Practical Cloud does not disclose Service Data except as necessary to provide its services to its customers and comply with the law.

How does Practical Cloud respond to legal requests for Service Data?

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal data to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information with relevant law enforcement agencies or public authorities if we believe same to be necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions and Service Level Agreement, or as otherwise required by law.

EU Directive

The EU Data Protection Directive (also known as “Directive 95/46/EC“) addresses the processing of personal data and the free movement of such data. Broadly, this Directive sets out a number of data protection principles and requirements which must be adhered to when personal data is processed.

Directive 95/46/EC established the Article 29 Working Party (“WP29”), which is comprised of representatives from the data protection authorities of all the EU Member States as well as from the European Commission. WP29 works to harmonize the application of data protection rules throughout the EU and also advises the EU Commission on the adequacy of data protection standards in non-EU countries.

How does the EU Directive apply to customers?

Practical Cloud customers that collect and store personal data are considered data controllers under Directive 95/46/EC. Data controllers bear the primary responsibility for ensuring that their processing of personal data is compliant with relevant EU data protection law, including Directive 95/46/EC and the GDPR as of May 25, 2018.

What are the “Model Clauses”?

The European Commission has approved a set of standard provisions called the Standard Contractual Clauses (“Model Clauses”) which provide a data controller a compliant mechanism to transfer personal data to a data processor outside the European Economic Area (“EEA”).

Does Practical Cloud replicate the Service Data it stores?

Practical Cloud periodically replicates data for purposes of archival, backup and audit logs. We use CodeGuard and Rackspace to store some of the information that is backed up, such as database information and attachment files.

Does Service Data hosted in the EU region ever leave that region?

Service data and customer data like encrypted file storage, email, archiving and backup are region specific. We use different providers for different services. Data hosted in the EU region does not leave that region.

GDPR

Since our inception, Practical Cloud’s approach has been anchored with a strong commitment to privacy, security, compliance and transparency. This approach includes supporting our customers’ compliance with EU data protection requirements, including those set out in the General Data Protection Regulation (“GDPR”), which becomes enforceable on May 25, 2018.

If a company collects, transmits, hosts or analyzes personal data of EU citizens, GDPR requires the company to use third-party data processors who guarantee their ability to implement the technical and organizational requirements of the GDPR. Our contractual commitments guarantee that customers can:

Respond to requests from data subjects to correct, amend or delete personal data.
Be made aware of and report personal data breaches to relevant supervisory authorities and data subjects in accordance with GDPR timeframes.
Demonstrate their compliance with the GDPR as pertaining to Practical Cloud’s Services.

Practical Cloud GDPR Product Readiness
The General Data Protection Regulation (GDPR), which goes into effect on May 25, 2018, provides data subjects with an array of privacy rights, which provide individuals with greater transparency into and control over uses of their personal information.

What is the GDPR?

The General Data Protection Regulation (“GDPR”) is a new European privacy regulation which will replace the current EU Data Protection Directive (“Directive 95/46/EC”). The GDPR aims to strengthen the security and protection of personal data in the EU and harmonize EU data protection law.

To whom does the GDPR apply?

The GDPR applies to all organizations operating in the EU and processing “personal identifiable data” of EU residents. Personal data is any information relating to an identified or identifiable natural person.

What implications does GDPR have for organizations processing the personal data of EU citizens?

One of the key aspects of the GDPR is that it creates consistency across EU member states on how personal data can be processed, used, and exchanged securely. Organizations will need to demonstrate the security of the data they are processing and their compliance with GDPR on a continual basis, by implementing and regularly reviewing robust technical and organizational measures, as well as compliance policies.

How has Practical Cloud been preparing for the GDPR?

Practical Cloud will be compliant with the GDPR when it becomes enforceable in May 2018. Our privacy team is working with customers around the world to answer their questions and to help them prepare for using Practical Cloud’s Services after the GDPR becomes effective. Additionally, our privacy team is reviewing Practical Cloud’s current product features and practices to ensure we support our customers with their GDPR compliance requirements.

How can Practical Cloud customers prepare for GDPR enforcement?

Practical Cloud encourages customers to begin preparing for the GDPR by reviewing their privacy and data security processes and policies to ensure compliance by May 2018. Data controllers bear the primary responsibility for ensuring that their processing of personal data is compliant with EU data protection law. Below are some key points to consider for GDPR compliance:

Geographical Application: The GDPR may apply to organizations that are established in the EU as well as certain organizations established outside the EU but which are processing the personal data of EU citizens, depending on their activities.
Rights of End-Users: Organizations should be cognizant of End-Users whose personal data they may be processing. The GDPR establishes enhanced rights for End-Users, and organizations should be able to accommodate those rights.
Data Breach Notifications: Organizations that are controllers of personal data should have clear processes in place in order to comply with the GDPR requirement to report data breaches in accordance with the time frames set out within the GDPR. Practical Cloud will notify affected customers without undue delay if we become aware of a data breach of our services.
Appointment of Data Protection Officer (“DPO”): Customers may need to appoint DPOs to manage issues relating to the processing of personal data.
Data Processing Agreement (“DPA”): Where personal data is transferred outside the EEA, a customer may need DPAs in place with its sub-processors to ensure an adequate level of protection for the transferred data. Practical Cloud’s DPA addresses GDPR and can be obtained by submitting a request to privacy@practicalhost.com.
Data Protection Impact Assessment (“DPIA”): DPIAs usually describe organizations data processes and protective measures, particularly those that may be risky. For data processing activities, customers need to conduct and file with authorities a DPIA.

Which Practical Cloud services and features can support customers compliance with the GDPR?

Customers can use Practical Cloud’s third-party ISO certifications and SOC 2 audit reports to help conduct their risk assessments and determine whether appropriate technical and organizational measures are in place. For additional information, please contact us at privacy@practicalhost.com.

Does Practical Cloud currently provide any product specific Features/Functionality in its Support product to assist us with our GDPR compliance program?

Practical Cloud provides customers the option to delete Service Data that may contain personal data, such as profiles, tickets, images, and attachments, in active Practical Cloud Support accounts. Customers also have full access to delete cloud data, such as emails, archives, backups, databases and website content.