Order Hero Services Privacy Policy

Scope

This policy covers the privacy practices that Order Hero Corporation and its subsidiaries and affiliates (“Order Hero” or “we”) employ when providing support, consulting, Cloud or other services (the “services”) to its customers (“you” or “your”). Order Hero established this privacy policy in order to clarify that the use of information to which it may be provided access in order to provide services is more limited than the use of information covered by Order Hero general privacy policy.

Customer Information and Services Data

Customer Information is information that we may collect from your use of the Order Hero Web sites and your interactions with us offline. We deal with customer information according to the terms of our general privacy policy.

Services Data is data that resides on Order Hero, customer or third-party systems to which Order Hero is provided access to perform services (including Cloud environments as well as test, development and production environments that may be accessed to perform Order Hero consulting and support services). Order Hero treats services data according to the terms of this policy, and treats services data as confidential in accordance with the terms of your order for services.

To illustrate the difference between customer information and services data, when a customer contracts with Order Hero for Cloud services, the customer provides information about itself, including its name, address, billing information, and some employee contact information. Order Hero may also collect other information about the customer and some employees, for example through its web sites, as part of that interaction. All of that information is customer information, and is treated according to Order Hero general privacy policy.

In contrast, having contracted with Order Hero for Cloud or other services, the customer provides Order Hero access to its production, development or test environment, which may include personal information about its employees, customers, partners or suppliers (collectively “end users”).

How Order Hero Collects and Uses Services Data

Below are the conditions under which Order Hero may access, collect and/or use services data.

To Provide Services and to Fix Issues. Services data may be accessed and used to perform services under your order for support, consulting, Cloud or other services and to confirm your compliance with the terms of your order. This may include testing and applying new product or system versions, patches, updates and upgrades; monitoring and testing system use and performance; and resolving bugs and other issues you have reported to Order Hero. Any copies of services data created for these purposes are only maintained for time periods relevant to those purposes.

As a Result of Legal Requirements. Order Hero may be required to retain or provide access to services data to comply with legally mandated reporting, disclosure or other legal process requirements.

Order Hero may transfer and access services data globally as required for the purposes specified above. If Order Hero hires subcontractors to assist in providing services, their access to services data will be consistent with the terms of your order for services and this services privacy policy. Order Hero is responsible for its subcontractors’ compliance with the terms of this policy and your order.

Order Hero does not use services data except as stated above or in your order. Order Hero may process services data, but does not control your collection or use practices for services data. If you provide any services data to Order Hero, you are responsible for providing any notices and/or obtaining any consents necessary for Order Hero to access, use, retain and transfer services data as specified in this policy and your order.

Access Controls

Order Hero access to services data is based on job role/responsibility. Services data residing in Order Hero-hosted systems is controlled via an access control list (ACL) mechanism, as well as the use of an account management framework. You control access to services data by your end users; end users should direct any requests related to their personal information to you.

Security and Breach Notification

Order Hero is committed to the security of your services data, and has in place physical, administrative and technical measures designed to prevent unauthorized access to that information. Order Hero security policies cover the management of security for both its internal operations as well as the services. These policies, which are aligned with the ISO/IEC 27001:2005 standard, govern all areas of security applicable to services and apply to all Order Hero employees. Order Hero Support, Consulting and Cloud lines of business have developed detailed statements of security practices that apply to many of their service offerings, which are available for review at your request.

Order Hero security policies and procedures are reviewed and overseen by Order Hero Global Information Security (GIS). GIS is responsible for security oversight, compliance and enforcement, and for conducting information security assessments and leading the development of information security policy and strategy.

Order Hero is also committed to reducing risks of human error, theft, fraud, and misuse of Order Hero facilities. Order Hero efforts include making personnel aware of security policies and training employees to implement security policies. Order Hero employees are required to maintain the confidentiality of services data. Employees’ obligations include written confidentiality agreements, regular training on information protection, and compliance with company policies concerning protection of confidential information.

Order Hero promptly evaluates and responds to incidents that create suspicions of unauthorized handling of services data. Order Hero GIS and Legal are informed of such incidents and, depending on the nature of the activity, define escalation paths and response teams to address the incidents. If Order Hero determines that your services data has been misappropriated (including by a Order Hero employee) or otherwise wrongly acquired by a third party, Order Hero will promptly report such misappropriation or acquisition to you.

Compliance

Order Hero has appointed a Chief Privacy Officer. If you believe your services data has been used in a way that is not consistent with this policy, or if you have further questions related to this policy, please contact the Chief Privacy Officer by email support@grublabs.org.

Last Updated: October 2013