DPF Certification Notice
Effective: February 17, 2025
This DPF notice (“Notice”) governs Astrix Security Inc. (“Astrix”, “We” or “Our”) participation in the EU-U.S. DPF programs with respect to the Processing of Personal Data as further explained in Section 1 below. If there is any conflict between the terms in this Notice and the DPF principles, the DPF principles shall govern. To learn more about the DPF and its principles please visit https://www.dataprivacyframework.gov/s/.
“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Process”, “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1. SCOPE
Astrix’s participation in the DPF applies to Personal Data that is subject to the EU data protection laws. Astrix is a security platform.
2. PURPOSES OF DATA PROCESSING
Astrix complies with the principles of the EU-U.S. DPF regarding the collection, use, and retention of Personal Data transferred to the United States from the European Union. Our DPF program covers transfers of Personal Data in the following cases: (i) to provide and improve (including without limitation by generating statistics and analytics) Astrix’s Services; (ii) to send marketing\advertisement communications; (iii) to contact users in connection with the Services and certain programs or offering registered for; and (iv) to identify and authenticate users access to the parts of the Services that they are authorized to access, as well as for security and fraud detection purposes (the “Services”). The categories of Personal Data collected and Processed by Astrix include, without limitation: Customers’ employees’ full name, work email address, and IP address.
Astrix has certified to the DoC that it adheres to the DPF Principles and Our DPF certification is available here.
3. ONWARD TRANSFERS OF PERSONAL DATA
We will not transfer Personal Data originating in the EU to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of protection to the Personal Data as required by the Principles of the EU-U.S. DPF. We transfer Personal Data to processors, service providers, vendors, contractors, partners and agents (collectively “Processors“) who need the information in order to provide services to or perform activities on Our behalf. We are responsible for such onward transfers to third pursuant to the EU-U.S. DPF.
The abovementioned Processors and the description of the services that they provide and/or the activities that they perform are set out in the table below:
| Processing Activity |
|---|
| Cloud Hosting |
| Raw Data Storage |
| Big Data Processing over AWS |
| Managed authentication solution to login to our portal |
| Managed GraphQL service to provide auto generated API for our frontend while ensuring scalability and security |
| Send notifications from Astrix platform to Slack to inform end users and security admins on relevant events |
| Monitoring errors |
| Log management. Log errors |
To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other public or governmental agencies, or if required to do so by court order (including to meet national security or law enforcement requirement);
If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
Where you have provided your consent to us sharing or transferring your Personal Data.
4. DATA SUBJECT RIGHTS
You have the right to access Personal Data about you, and in some cases you are also allowed to correct, amend, or delete that Personal Data where it is inaccurate, or has been processed in violation of the DPF principles. In addition, you have the choice to limit the use and disclosure of your Personal Data. If you believe that We are Processing your Personal Data within the scope of Our DPF program, you can submit your request to: [email protected]
Please be aware that in specific situations where fulfilling access or other requests might impose a disproportionate burden or expense, or potentially infringe upon the rights of others, we may be required to carefully review and, if permissible under applicable law, respectfully decline your request.
5. INDEPENDENT RECOURSE MECHANISM. ARBITRATION.
In compliance with the DPF principles, We are committed to resolve complaints about Our collection or use of your Personal Data. EU individuals with inquiries or complaints regarding Our DPF policy should first contact Astrix at: [email protected] or by postal mail sent to:
Astrix, Inc.
Attn: DPF Inquiry
155 Federal Street, Suite 700, Boston, MA 02110
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Astrix commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF to EU data protection authorities (EU DPAs) as the independent recourse mechanism, an alternative dispute resolution. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://uscib.org/eu-us-data-privacy-framework/ for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
6. U.S. FEDERAL TRADE COMMISSION ENFORCEMENT
Astrix is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”) to ensure compliance with the EU-US DPF, outlined in this DPF Notice.