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Security Policy

[Last Updated: March 27, 2019]

Sayollo Media Ltd. (“Company” or “we”) is committed to provide transparency regarding the security measures which it has implemented in order to secure and protect Personal Data (as defined under applicable data protection law, including without limitations, the EU General Data Protection Regulation (“GDPR”) and the upcoming California Consumer Privacy Act (“CCPA”) (collectively “Data Protection Regulation”) processed by the Company for the purpose of providing its services.

This information security policy outlines the Company’s security, technical and organizational practices.

As part of our data protection compliance process we have implemented technical, physical and administrative security measures to protect the Personal Data.

Physical Access Control

The Company ensures the protection of the physical access to the data servers which store the Personal Data for The Company. The data processed by the Company are stored in the Google Cloud, which its security measure can be found here and Amazon Web Services (AWS) US data servers, which its security measure can be found here. Further, the Company secures the physical access to its offices to ensure that solely authorized individuals such as employees and authorized external parties (maintenance staff, visitor, etc.) can access the Company’s offices, including, among others, such measures as security locks, alarm systems etc.

System Control

Access to the Company’s database is highly restricted in order to ensure that solely the appropriate prior approved personnel can access the Company’s database. Safeguards related to remote access and wireless computing capabilities are implemented therein. Employees are assigned private passwords that allow strict access or use related to Personal Data all in accordance with such employee’s position, and solely to the extent such access or use is required. There is constant monitoring of the access to the data and the passwords used to gain login access.

Data Access Control

There are restrictions in place in order to ensure that the access to the Personal Data is restricted to solely to employees who have a permission to access it via user authentication measures, all in order to ensure that Personal Data shall not be accessed, modified, copied, used, transferred or deleted without specific authorization. The access to the Personal Data, as well as any action performed involving the use of the Personal Data requires a password and user name, which is routinely changed, as well as blocked when applicable. The user password is fully encrypted. Each employee is able to perform actions solely according to the permissions determined by the Company. Each access is logged and monitored, and any unauthorized access is automatically reported. Further, the Company has ongoing review of the employees’ who have such authorizations to access Personal Data, in order to assess whether access is still required. The Company revokes access immediately upon termination of employment. Authorized individuals can solely access Personal Data that is established in their individual profiles.

Organizational and Operational Security

The Company invests a multitude of efforts and resources in order to ensure compliance with the Company’s security policies and practices, as well as continuously providing employees with training as relevant to such security policies and practices. The Company strives to raise awareness to the risk involved in the processing of Personal Data. In addition, the Company implemented applicable safeguards for its hardware and software, including firewalls and anti-virus software on applicable Company hardware and software, in order to protect against malicious software.

Transfer Control

All transfer of Personal Data between the client side and the Company’s servers is protected using encryption safeguards, as well as encryption of the Personal Data prior to the transfer of any Personal Data. The Company’s servers are protected by industry best standards including the EU-US privacy shield framework. Furthermore, the destruction of Personal Data following termination of the engagement is included within the contract between the parties. In addition, to the extent applicable, the Company’s business partners execute an applicable Data Processing Agreement, all in accordance with applicable laws.

Input Control

The Company ensures the transparency of input controls, including changing and deletion of data by individual user names (however, not by user groups).

Availability Control

The Company maintains backup policies and measures. Such backup policies also include permanent monitoring of operational parameters as relevant to the backup operations. Furthermore, the Company’s servers include an automated backup procedure on a daily basis. The Company also conducts regular controls of the condition and labelling of data storage devices for data security. The Company ensures that regular checks are carried out to determine whether it is possible to undo the backup, as required and applicable.

Data Retention

Personal Data are retained for as long as needed to provide the services or as required under applicable laws.

Job Control

All of the Company’s employees are required to execute an employment agreement which includes confidentiality provisions as well as applicable provisions binding them to comply with applicable data security practices. In addition, employees undergo a screening process applicable per regional law. In the event of a breach of an employee’s obligation or non-compliance with the Company’s policies, the Company includes repercussions to ensure compliance with the Company’s policies. In addition, prior to the Company’s engagement with third party contractors, the Company undertakes diligence review of such third party contractors, including review such third party’s security policies, specifically their information data security policies to ensure it complies with the Company’s standard for data security protection. The Company agrees with third party contractors on effective rights of control with respect to any Personal Data processed on behalf of the Company. Third party contractors may solely access the Personal Data as explicitly instructed by the Company. The Company includes contractual penalties in the third party contractors have breached their security policies or measures undertakings.

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