Data Protection Policy

Last Updated: September 11, 2025

1. Our Commitment to Data Protection

At EcomATM, protecting your data is not just a legal obligation—it's fundamental to our business. This Data Protection Policy outlines our comprehensive approach to safeguarding personal and business data across our e-commerce automation platform.

2. Data Security Framework

2.1 Technical Security Measures

• Encryption in Transit: All data transmitted using TLS 1.3 encryption
• Encryption at Rest: Database and file storage encrypted with AES-256
• Key Management: Secure key rotation and hardware security modules
• Network Security: Firewalls, intrusion detection, and DDoS protection
• Access Controls: Multi-factor authentication and role-based permissions
• API Security: Rate limiting, authentication tokens, and request validation

2.2 Infrastructure Security

• Cloud Security: Enterprise-grade cloud infrastructure with SOC 2 compliance
• Data Centers: Certified facilities with physical security controls
• Redundancy: Multi-region backups and disaster recovery capabilities
• Monitoring: 24/7 security monitoring and automated threat detection
• Updates: Regular security patches and vulnerability assessments

3. Data Categories and Protection Levels

3.1 Highly Sensitive Data

3.2 Sensitive Data

3.3 Internal Data

4. Access Control and Authentication

4.1 User Access Management

• Role-Based Access Control (RBAC): Granular permissions based on job function
• Principle of Least Privilege: Users get minimum necessary access
• Multi-Factor Authentication: Required for all accounts
• Session Management: Automatic timeouts and secure session handling
• Password Policies: Strong password requirements and regular rotation

4.2 Administrative Access

• Privileged Access Management: Additional controls for admin accounts
• Just-in-Time Access: Temporary elevated permissions when needed
• Administrative Logging: Complete audit trail of admin actions
• Separation of Duties: Critical operations require multiple approvals

5. Data Processing and AI Protection

5.1 AI Data Handling

Special protections for AI-processed data:

• Data Minimization: Only necessary data sent to AI services
• Anonymization: Personal identifiers removed when possible
• Selective Processing: Users control which data is AI-processed
• Third-Party Agreements: Strict data handling contracts with AI providers
• Model Training Exclusion: Your data not used to train external models

5.2 AI Service Providers

6. Data Breach Response

6.1 Incident Response Plan

Our comprehensive response process:

1. Detection: Automated monitoring and threat detection systems
2. Assessment: Rapid evaluation of breach scope and impact
3. Containment: Immediate steps to prevent further data exposure
4. Investigation: Forensic analysis to understand the incident
5. Notification: Timely notification to affected users and authorities
6. Recovery: System restoration and security enhancement
7. Review: Post-incident analysis and process improvement

6.2 Notification Timelines

• Internal Notification: Security team notified within 1 hour
• Management Escalation: Leadership informed within 4 hours
• User Notification: Affected users notified within 72 hours
• Regulatory Notification: Authorities notified as required by law

7. International Data Transfers

7.1 Transfer Mechanisms

We ensure appropriate safeguards for international data transfers:

• Adequacy Decisions: Transfers to countries with adequate protection levels
• Standard Contractual Clauses: EU-approved data transfer agreements
• Binding Corporate Rules: Internal privacy rules across our organization
• Certification Programs: Compliance with recognized data protection standards

7.2 Data Residency Options

We provide data localization options:

• Regional Storage: Data stored in user's preferred region
• Processing Restrictions: Limits on cross-border processing
• Local Compliance: Adherence to local data protection laws
• Enterprise Controls: Advanced residency controls for enterprise customers

8. Compliance and Certifications

8.1 Regulatory Compliance

• GDPR: Full compliance with European data protection regulation
• CCPA: California Consumer Privacy Act compliance
• SOC 2: System and Organization Controls certification
• ISO 27001: Information security management certification
• PCI DSS: Payment card industry data security standards

8.2 Regular Audits

• Internal Audits: Quarterly security and privacy assessments
• External Audits: Annual third-party security audits
• Penetration Testing: Regular security testing by certified experts
• Compliance Reviews: Ongoing regulatory compliance monitoring

9. Employee Data Protection Training

9.1 Mandatory Training Programs

• Security Awareness: Annual training on data protection and security
• Privacy Laws: Training on applicable privacy regulations
• Incident Response: Training on breach detection and response
• Role-Specific Training: Specialized training based on job function

9.2 Ongoing Education

• Monthly security newsletters and updates
• Phishing simulation exercises
• Privacy impact assessment training
• New technology privacy reviews

10. Data Retention and Deletion

10.1 Retention Schedules

10.2 Secure Deletion Process

• Cryptographic Erasure: Destruction of encryption keys
• Physical Destruction: Secure wiping of storage media
• Multi-Pass Overwriting: Multiple overwrite passes for sensitive data
• Verification: Confirmation that data cannot be recovered

11. User Rights and Controls

11.1 Data Subject Rights

You have the right to:

• Access: View all personal data we hold about you
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your personal data
• Portability: Export your data in a machine-readable format
• Restriction: Limit how we process your data
• Objection: Object to certain types of data processing

11.2 Exercising Your Rights

To exercise your rights:

1. Submit a request through your account dashboard
2. Email our Data Protection Officer at dpo@ecomatm.net
3. Verify your identity for security purposes
4. Receive response within 30 days (or as required by law)

12. Third-Party Data Processors

12.1 Vendor Management

We carefully vet all third-party data processors:

• Due Diligence: Comprehensive security and privacy assessments
• Contractual Obligations: Strict data processing agreements
• Regular Reviews: Ongoing monitoring of vendor compliance
• Data Minimization: Limited data sharing with processors

12.2 Key Processors

13. Contact Information

For data protection questions or to exercise your rights, contact us at: