GDPR Policy

The EU General Data Protection Regulation (GDPR) is now in effect, as of May 25th 2018, and it brings new global data protection rights for individuals in the European Union.

ZAP is committed to support the privacy rights of ZAP customers and we have taken many measures towards full compliance of GDPR. This includes:

An update of our terms of service
The introduction of a EU Data Protection Addendum (DPA), as required by the GDPR
Various cookie protections and opt-out functionality on our website
Further internal and third-party security audits of our processes, Azure-based platform and application

ZAP’s role in GDPR Compliance

ZAP acts as a Data Processor within the realm of GDPR compliance. ZAP is responsible for safeguarding the data of partners or customers’ users as it flows through our services.

Customer’s role in GDPR Compliance

As a ZAP customer (or partner), you are a Data Controller within the GDPR, ZAP is the Data Processor. This means that throughout the time of your subscription to our services, you retain ownership of and control of your Customer or User data. You will want to pay attention to the following non-exhaustive list of items:

Perform your own research, audit, internal training and strategy steps within your company to ensure you understand GDPR and how it applies to your business
Ensure your Terms and Privacy policies are up to date
If you are an organization located in the EU, and/or need to be GDPR compliant, you may request to sign our EU Data Protection Agreement (DPA)
Be mindful of the amount of personal data that may be processed in a ZAP model and limit it as much as possible.
Also ensure that users’ consent is handled appropriately.

What is a Data Processing Agreement (“DPA”)?

This is an agreement that ZAP offers, that governs the relationship between the Customer (acting as a data controller) and ZAP (acting as a data processor). The DPA facilitates ZAP’s customers’ compliance with their obligations under the GDPR. Our DPA contains data transfer frameworks to ensure that our customers can lawfully transfer personal data to ZAP outside of the European Union by relying on one of these mechanisms: Binding Corporate Rules, or Standard Contractual Clauses.

ZAP’s Third-parties / Sub-processors

A sub-processor is a third-party data processor engaged by ZAP, including entities from within ZAP, who has or potentially will have access to or process Service Data (which may contain Personal Data). ZAP uses different types of sub-processors to perform various functions in order to operation its service.

ZAP requires its sub-processors to satisfy equivalent obligations as those required by ZAP (as a data processor). ZAP maintains an up-to-date list of the names and locations of all sub-processors used for hosting or other processing of service data.

Infrastructure and Service Sub-processors

ZAP owns or control access to the infrastructure used to host the Service and Customer data.

Sub-processor	Application	Location
Microsoft Azure	Cloud provider hosting Customer Data User authentication Logging and reporting Only used by ZAP SaaS	Customer data is hosted at the customer’s elected location, as set forth in our Terms of Service.
Microsoft Dynamics 365	Customer Relationship Management Service license provider	United States
Zendesk	Cloud-based Service Provider ZAP Customer HelpDesk	United States
SendGrid	Cloud-based email provider Only used by ZAP SaaS	United States

Other Sub-processors

The following sub-processors may be used by ZAP employees to store the minimum relevant set of data required to perform a specific function:

Sub-processor	Application	Location
Slack	User and applicant data may be discussed here	United States
Box	User data may be stored here	United States
Microsoft Office 365	User data may be discussed or referenced here	United States

ZAP Group Sub-processors