GDPR and Data Processing

1. Controller and processor

• You are the controller of the personal data in your Odoo databases, files and backups (Customer Data). You decide why and how it is processed.
• We are your processor for Customer Data. We process it only to provide CloudPilot and on your documented instructions.
• We are a controller for account, billing and website data, as described in our Privacy Policy.

2. Where your data lives

CloudPilot is designed so your Odoo data stays where you choose:

• Your cloud account or server. Odoo databases and files stay on servers in your own cloud account and region, or on machines you add over SSH. You pick the provider and region.
• CloudPilot shared servers (Starter). On the Starter plan, the Odoo database and files are on a server CloudPilot runs in the United States, kept apart from other customers' instances with a separate system user and database role.
• Backups. Backups go to CloudPilot storage in the EU, or to your own Amazon S3 or S3-compatible bucket, Azure Blob Storage, Google Cloud Storage or SFTP server.
• The control plane. The CloudPilot dashboard and API are hosted in the EU, and sign-in is handled in the UK. They hold account and configuration data, not your Odoo databases.

3. Data Processing terms

These terms form part of our Terms of Service and meet the requirements of Article 28 of the UK GDPR and EU GDPR. When we process Customer Data, we will:

1. process it only on your documented instructions, given through your use of the Service and these Terms, unless the law requires otherwise (in which case we will tell you, unless the law forbids it);
2. make sure everyone authorised to process it is bound by confidentiality;
3. apply appropriate technical and organisational security measures (see section 5);
4. use only the sub-processors listed below, give you at least 30 days' notice of new ones so you can object, and impose equivalent data protection terms on them;
5. help you respond to data subject requests and meet your obligations on security, breach notification, data protection impact assessments and prior consultation;
6. notify you without undue delay, and within 48 hours where possible, after becoming aware of a personal data breach affecting Customer Data;
7. at the end of the Service, delete Customer Data we hold (or return it, at your choice), within the periods in our Terms, unless the law requires us to keep it;
8. make available the information needed to show compliance, and allow and contribute to reasonable audits, including inspections, on reasonable notice.

The subject matter is the provision of the Service. The duration is the term of your subscription. The nature and purpose is hosting, backing up, transmitting and managing Customer Data as the Service requires. The personal data and data subjects are whatever you put into your Odoo instances, typically contact, transaction and employee data about your customers, suppliers and staff. If you need a countersigned data processing agreement, email privacy@cloudpilot.app.

4. Sub-processors

Cloud providers, GitHub and storage providers that you connect are not our sub-processors: you choose them, and they act under your own agreement with them.

5. Security measures

• All traffic to the dashboard, API and your Odoo instances is encrypted with TLS, and certificates are issued and renewed automatically.
• Cloud provider, storage and SSH credentials are encrypted at rest and never shown again after you add them.
• The CloudPilot agent connects outward, so no inbound agent port is opened on your servers.
• Servers are hardened when they are set up, and receive automatic security updates.
• Team roles (admin, full and read-only) and per-client access limit who can see and change what. API keys can be read-only and set to expire.
• Access to production systems is limited to staff who need it, and is logged.
• Automated backups, with offsite copies to storage you control, protect against data loss.

6. International transfers

On Pro and Business, Customer Data stays in the region you choose for your servers and backup storage. On Starter, the Odoo database and files are stored in the United States; for that transfer we rely on the UK Extension to the EU-US Data Privacy Framework where it applies, or on the safeguards below. Where a sub-processor processes personal data outside the UK or EEA, we rely on adequacy regulations or on appropriate safeguards, such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

7. Data subject requests

If an individual contacts us about Customer Data, we will pass the request to you and not respond ourselves, unless you ask us to or the law requires it. Your Odoo instances give you direct access to the data you need to handle access, correction and erasure requests.

8. EU customers

The same commitments apply under the EU GDPR. [If you have customers in the EU, state your EU representative under Article 27 here, if one is required.]

9. Contact

For data protection questions or to request a data processing agreement, email privacy@cloudpilot.app. Iraya Digitech Ltd is registered with the Information Commissioner's Office under registration number [ICO registration number].