Privacy Policy

1. Purpose

The purpose of this Privacy Policy and Procedure is to protect personal and sensitive information collected, processed, or stored by the company in the operation of its platform. This policy ensures compliance with applicable data protection laws, maintains customer trust, and aligns with secure software development and information security best practices.

2. Scope

This policy applies to:

• All personal data of customers, users, employees, and third parties
• All business units, departments, and personnel handling personal data
• All systems, applications, databases, and cloud infrastructure processing personal data
• Third-party service providers and contractors with access to personal data

3. Policy Statement

The organization commits to:

• Collect, use, and retain personal data only for legitimate business purposes
• Protect personal data through appropriate administrative, technical, and physical controls
• Comply with applicable data protection laws and contractual obligations
• Implement privacy controls throughout the Software Development Life Cycle (SDLC)
• Maintain transparency with customers regarding data collection, processing, and sharing practices

4. Privacy Roles and Responsibilities

• Chief Technology Officer (CTO): Accountable for technical privacy controls, secure software development, and privacy compliance
• Chief Executive Officer (CEO): Provides executive oversight for privacy policies and regulatory compliance
• Product Owners / Business Owners: Ensure privacy requirements are incorporated into product features and business processes
• Engineering / Development Team: Implement privacy controls and follow secure coding and SDLC best practices
• All Employees and Contractors: Comply with this policy and report privacy concerns or breaches

5. Data Classification and Handling

• Personal data is classified according to sensitivity and regulatory requirements
• Data must be accessed, processed, and stored only by authorized personnel
• Encryption and anonymization techniques must be applied where appropriate
• Data retention and deletion procedures must comply with legal and contractual obligations

6. Privacy by Design and SDLC Integration

• Privacy considerations are integrated into each phase of the SDLC
• Threat modeling, secure coding, and data minimization practices are applied during development
• Security and privacy reviews are conducted before production deployment
• Automated tools and code reviews are employed to detect potential vulnerabilities and data exposure

7. Data Subject Rights

• Mechanisms are in place for data subjects to exercise their rights (e.g., access, correction, deletion, data portability)
• Requests are handled within legally required timelines
• Training is provided to employees responsible for processing such requests

8. Third-Party and Vendor Privacy

• Privacy due diligence is conducted for all third-party vendors handling personal data
• Contracts include data protection clauses, confidentiality requirements, and breach notification obligations

9. Incident Management and Breach Response

• Privacy incidents and breaches are identified, reported, and managed according to the Incident Response Procedure
• Notification requirements for affected individuals and regulators are followed in accordance with applicable laws

10. Training and Awareness

• All employees and contractors receive privacy and data protection training at hire and periodically thereafter
• Training includes company policies, legal requirements, and secure handling of personal data

11. Monitoring and Review

• Privacy compliance is monitored through audits, risk assessments, and review of system access and processing activities
• The policy and procedures are reviewed at least annually or upon significant regulatory or operational changes

12. Policy Compliance

• Compliance with this policy is mandatory for all constituents
• Non-compliance may result in disciplinary action, including termination or legal consequences