Data Processing and Security Terms (Customers)

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Data Processing and Security Terms (Customers)

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Last modified: August 10, 2020

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The customer agreeing to these terms (“Customer”), and Google LLC, Google
Ireland Limited, Google Asia Pacific Pte. Ltd., or any other entity that directly or
indirectly controls, is controlled by, or is under common control with Google LLC (as
applicable, “Google”), have entered into an agreement under which Google has
agreed to provide Google Cloud Platform
(as described at https://cloud.google.com/terms/services)
and related technical support to Customer (as amended from time to time, the
“Agreement”).

## 1. Commencement

These Data Processing and Security Terms, including their appendices
(the “Terms”) will be effective and replace any previously applicable data
processing and security terms as from the Terms Effective Date (as defined below).

These Terms supplement the Agreement. Where the Agreement was entered into offline with
Google Ireland Limited, these Terms supersede the “Privacy” Clause in that
agreement (if applicable).

## 2. Definitions

2.1 Capitalized terms defined in the Agreement apply to these Terms. In addition, in these
Terms:

Additional Security Controls means security resources, features, functionality
and/or controls that Customer may use at its option and/or as it determines, including
the Admin Console, encryption, logging and monitoring, identity and access management,
security scanning, and firewalls.

Agreed Liability Cap means the maximum monetary or payment-based amount at which a
party’s liability is capped under the Agreement.

Alternative Transfer Solution means a solution, other than the Model Contract
Clauses, that enables the lawful transfer of personal data to a third country in
accordance with European Data Protection Law.

Audited Services means the then-current Services indicated as being in-scope for
the relevant certification or report at

https://cloud.google.com/security/compliance/services-in-scope. Google may
not remove a Service from this URL unless that Service has been discontinued in
accordance with the Agreement.

Customer Data has the meaning given in the Agreement or, if no such meaning
is given, means data provided by or on behalf of Customer or Customer End Users via
the Services under the Account.

Customer End Users has the meaning given in the Agreement or, if not such meaning
is given, has the meaning given to “End Users” in the Agreement.

Customer Personal Data means the personal data contained within the Customer Data.

Data Incident means a breach of Google’s security leading to the accidental
or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to,
Customer Data on systems managed by or otherwise controlled by Google.

   - EEA means the European Economic Area.

EU GDPR means Regulation (EU) 2016/679 of the European Parliament and of the
Council of 27 April 2016 on the protection of natural persons with regard to the
processing of personal data and on the free movement of such data, and repealing Directive
95/46/EC.

European Data Protection Law means, as applicable: (a) the GDPR; and/or (b)
the Federal Data Protection Act of 19 June 1992 (Switzerland).

European or National Law means, as applicable: (a) EU or EU Member State law (if
the EU GDPR applies to the processing of Customer Personal Data); and/or (b) the law of
the UK or a part of the UK (if the UK GDPR applies to the processing of Customer Personal
Data).

   - GDPR means, as applicable: (a) the EU GDPR; and/or (b) the UK GDPR.

Google’s Third Party Auditor means a Google-appointed, qualified and
independent third party auditor, whose then-current identity Google will disclose to
Customer.

Model Contract Clauses or MCCs mean standard data protection clauses for
the transfer of personal data to processors established in third countries which do not
ensure an adequate level of data protection, as described in Article 46 of the EU GDPR
and set out at

https://cloud.google.com/terms/eu-model-contract-clause.

Non-European Data Protection Law means data protection or privacy laws in force
outside the European Economic Area, Switzerland and the UK.

Notification Email Address means the email address(es) designated by Customer in
the Admin Console, or in the Order Form or Ordering Document (as applicable), to receive
certain notifications from Google. Customer is responsible for using the Admin Console to
ensure that its Notification Email Address remains current and valid.

Security Documentation means all documents and information made available by Google
under Section 7.5.1 (Reviews of Security Documentation).

Security Measures has the meaning given in Section 7.1.1 (Google’s Security
Measures).

Subprocessor means a third party authorized as another processor under these Terms
to have logical access to and process Customer Data in order to provide parts of the
Services and TSS.

Supervisory Authority means, as applicable: (a) a “supervisory
authority” as defined in the EU GDPR; and/or (b) the “Commissioner” as
defined in the UK GDPR.

Term means the period from the Terms Effective Date until the end of Google’s
provision of the Services, including, if applicable, any period during which provision of
the Services may be suspended and any post-termination period during which Google may
continue providing the Services for transitional purposes.

Terms Effective Date means the date on which Customer accepted, or the parties
otherwise agreed to, these Terms.

UK GDPR means the EU GDPR as amended and incorporated into UK law under the UK
European Union (Withdrawal) Act 2018, if in force.

2.2 The terms “personal data”, “data subject”,
“processing”, “controller” and “processor”
as used in these Terms have the meanings given in the GDPR irrespective of whether European
Data Protection Law or Non-European Data Protection Law applies.

## 3. Duration

These Terms will notwithstanding expiry of the Term, remain in effect until, and
automatically expire upon, deletion of all Customer Data by Google as described in these
Terms.

## 4. Scope of Data Protection Law

4.1 Application of European Law. The parties acknowledge that European Data
Protection Law will apply to the processing of Customer Personal Data if, for example:

the processing is carried out in the context of the activities of an establishment
of Customer in the territory of the EEA or the UK; and/or

the Customer Personal Data is personal data relating to data subjects who are in the
EEA or the UK and the processing relates to the offering to them of goods or services in
the EEA or the UK, or the monitoring of their behavior in the EEA or the UK.

4.2 Application of Non-European Law. The parties acknowledge that Non-European
Data Protection Law may also apply to the processing of Customer Personal Data.

4.3 Application of Terms. Except to the extent these Terms state otherwise, these
Terms will apply irrespective of whether European Data Protection Law or Non-European
Data Protection Law applies to the processing of Customer Personal Data.

## 5. Processing of Data

5.1 Roles and Regulatory Compliance; Authorization.

5.1.1 Processor and Controller Responsibilities. If European Data Protection Law
applies to the processing of Customer Personal Data:

   - the subject matter and details of the processing are described in Appendix 1;

Google is a processor of that Customer Personal Data under European Data Protection Law;

Customer is a controller or processor, as applicable, of that Customer Personal Data under
European Data Protection Law; and

each party will comply with the obligations applicable to it under European Data
Protection Law with respect to the processing of that Customer Personal Data.

5.1.2 Authorization by Third Party Controller. If European Data Protection Law
applies to the processing of Customer Personal Data and Customer is a processor, Customer
warrants that its instructions and actions with respect to that Customer Personal Data,
including its appointment of Google as another processor, have been authorized by the
relevant controller.

5.1.3 Responsibilities under Non-European Law. If Non-European Data Protection
Law applies to either party’s processing of Customer Personal Data, the relevant party
will comply with any obligations applicable to it under that law with respect to the
processing of that Customer Personal Data.

5.2 Scope of Processing.

5.2.1 Customer’s Instructions. Customer instructs Google to process Customer
Personal Data only in accordance with applicable law: (a) to provide the Services and
TSS; (b) as further specified via Customer’s use of the Services (including the Admin
Console and other functionality of the Services) and TSS; (c) as documented in the form
of the Agreement, including these Terms; and (d) as further documented in any other
written instructions given by Customer and acknowledged by Google as constituting
instructions for purposes of these Terms.

5.2.2 Google’s Compliance with Instructions. Google will comply with the
instructions described in Section 5.2.1 (Customer’s Instructions) (including with
regard to data transfers) unless European or National Law to which Google is subject
requires other processing of Customer Personal Data by Google, in which case Google will
notify Customer (unless that law prohibits Google from doing so on important grounds of
public interest) before such other processing.

## 6. Data Deletion

6.1 Deletion by Customer. Google will enable Customer to delete Customer Data
during the Term in a manner consistent with the functionality of the Services. If Customer
uses the Services to delete any Customer Data during the Term and that Customer Data
cannot be recovered by Customer, this use will constitute an instruction to Google to delete
the relevant Customer Data from Google’s systems in accordance with applicable law.
Google will comply with this instruction as soon as reasonably practicable and within
a maximum period of 180 days, unless European or National Law requires storage.

6.2 Deletion on Termination. On expiry of the Term, Customer instructs Google
to delete all Customer Data (including existing copies) from Google’s systems in
accordance with applicable law. Google will, after a recovery period of up to 30 days
following such expiry, comply with this instruction as soon as reasonably practicable
and within a maximum period of 180 days, unless European or National Law requires storage.
Without prejudice to Section 9.1 (Access; Rectification; Restricted Processing;
Portability), Customer is responsible for exporting, before the Term expires,
any Customer Data it wishes to retain.

## 7. Data Security

7.1 Google’s Security Measures, Controls and Assistance.

7.1.1 Google’s Security Measures. Google will implement and maintain technical
and organizational measures to protect Customer Data against accidental or unlawful
destruction, loss, alteration, unauthorized disclosure or access as described in
Appendix 2 (the “Security Measures”). The Security Measures include measures to
encrypt personal data; to help ensure ongoing confidentiality, integrity, availability and
resilience of Google’s systems and services; to help restore timely access to personal
data following an incident; and for regular testing of effectiveness. Google may update the
Security Measures from time to time provided that such updates do not result in the
degradation of the overall security of the Services.

7.1.2 Security Compliance by Google Staff. Google will: (a) take appropriate steps to
ensure compliance with the Security Measures by its employees, contractors and Subprocessors
to the extent applicable to their scope of performance, and (b) ensure that all persons
authorized to process Customer Personal Data are under an obligation of confidentiality.

7.1.3 Additional Security Controls. Google will make Additional Security
Controls available to: (a) allow Customer to take steps to secure Customer Data;
and (b) provide Customer with information about securing, accessing and using Customer Data.

7.1.4 Google’s Security Assistance. Google will (taking into account the
nature of the processing of Customer Personal Data and the information available
to Google) assist Customer in ensuring compliance with its obligations pursuant to
Articles 32 to 34 of the GDPR, by:

implementing and maintaining the Security Measures in accordance with Section 7.1.1
(Google’s Security Measures);

making Additional Security Controls available to Customer in accordance with
Section 7.1.3 (Additional Security Controls);

   - complying with the terms of Section 7.2 (Data Incidents);

providing Customer with the Security Documentation in accordance with Section 7.5.1
(Reviews of Security Documentation) and the information contained in the Agreement
including these Terms; and

if subsections (a)-(d) above are insufficient for Customer to comply with such
obligations, upon Customer’s request, providing additional reasonable assistance.

7.2 Data Incidents.

7.2.1 Incident Notification. Google will notify Customer promptly and without
undue delay after becoming aware of a Data Incident, and promptly take reasonable steps
to minimize harm and secure Customer Data.

7.2.2 Details of Data Incident. Google’s notification of a Data Incident will
describe, to the extent possible, the nature of the Data Incident, the measures taken to
mitigate the potential risks and the measures Google recommends Customer take to
address the Data Incident.

7.2.3 Delivery of Notification. Notification(s) of any Data Incident(s)
will be delivered to the Notification Email Address.

7.2.4 No Assessment of Customer Data by Google. Google has no obligation
to assess Customer Data in order to identify information subject to
any specific legal requirements.

7.2.5 No Acknowledgement of Fault by Google. Google’s notification
of or response to a Data Incident under this Section 7.2 (Data Incidents)
will not be construed as an acknowledgement by Google of any fault or
liability with respect to the Data Incident.

7.3 Customer’s Security Responsibilities and Assessment.

7.3.1 Customer’s Security Responsibilities. Without prejudice to Google’s
obligations under Sections 7.1 (Google’s Security Measures, Controls and Assistance)
and 7.2 (Data Incidents), and elsewhere in the Agreement, Customer is responsible for its
use of the Services and its storage of any copies of Customer Data outside Google’s or
Google’s Subprocessors’ systems, including:

using the Services and Additional Security Controls to ensure a level of security
appropriate to the risk in respect of the Customer Data;

securing the account authentication credentials, systems and devices Customer uses to
access the Services; and

   - backing up its Customer Data as appropriate.

7.3.2 Customer’s Security Assessment. Customer agrees, based on its current and
intended use of the Services, that the Services, Security Measures, Additional Security
Controls and Google’s commitments under this Section 7 (Data Security): (a) meet
Customer’s needs, including with respect to any security obligations of Customer under
European Data Protection Law and/or Non-European Data Protection Law, as applicable, and (b)
provide a level of security appropriate to the risk in respect of the Customer Data.

7.4 Compliance Certifications and SOC Reports. Google will maintain at least
the following for the Audited Services in order to evaluate the continued effectiveness of
the Security Measures: (a) certificates for ISO 27001, ISO 27017 and ISO 27018, and its PCI
DSS Attestation of Compliance (the “Compliance Certifications”); and (b) SOC 2
and SOC 3 reports produced by Google’s Third Party Auditor and updated annually based
on an audit performed at least once every 12 months (the “SOC Reports”).
Google may add standards at any time. Google may replace a Compliance Certification or
SOC Report with an equivalent or enhanced alternative.

7.5 Reviews and Audits of Compliance.

7.5.1 Reviews of Security Documentation. Google will make the Compliance
Certifications and the SOC Reports available for review by Customer to demonstrate
compliance by Google with its obligations under these Terms.

7.5.2 Customer’s Audit Rights.

If European Data Protection Law applies to the processing of Customer Personal Data,
Google will allow Customer or an independent auditor appointed by Customer to conduct
audits (including inspections) to verify Google’s compliance with its obligations
under these Terms in accordance with Section 7.5.3 (Additional Business Terms for Reviews
and Audits). Google will contribute to such audits as described in Section 7.4 (Compliance
Certifications and SOC Reports) and this Section 7.5 (Reviews and Audits of Compliance).

If Customer has entered into the Model Contract Clauses as described in Section 10.2
(Transfers of Data), Google will allow Customer or an independent auditor appointed by
Customer to conduct audits as described in the Model Contract Clauses in accordance with
Section 7.5.3 (Additional Business Terms for Reviews and Audits).

Customer may conduct an audit to verify Google’s compliance with its obligations
under these Terms by reviewing the Security Documentation (which reflects the outcome of
audits conducted by Google’s Third Party Auditor).

7.5.3 Additional Business Terms for Reviews and Audits.

Customer must send any requests for reviews of the SOC 2 report under Section 7.5.1(c) or
audits under Section 7.5.2(a) or 7.5.2(b) to Google’s Cloud Data Protection Team as
described in Section 12 (Cloud Data Protection Team; Processing Records).

Following receipt by Google of a request under Section 7.5.3(a), Google and Customer
will discuss and agree in advance on: (i) the reasonable date(s) of and security and
confidentiality controls applicable to any review of the SOC 2 report under Section
7.5.1(c); and (ii) the reasonable start date, scope and duration of and security and
confidentiality controls applicable to any audit under Section 7.5.2(a) or 7.5.2(b).

Google may charge a fee (based on Google’s reasonable costs) for any audit under
Section 7.5.2(a) or 7.5.2(b). Google will provide Customer with further details of any
applicable fee, and the basis of its calculation, in advance of any such audit. Customer
will be responsible for any fees charged by any auditor appointed by Customer to execute
any such audit.

Google may object in writing to an auditor appointed by Customer to conduct any audit
under Section 7.5.2(a) or 7.5.2(b) if the auditor is, in Google’s reasonable
opinion, not suitably qualified or independent, a competitor of Google, or otherwise
manifestly unsuitable. Any such objection by Google will require Customer to appoint
another auditor or conduct the audit itself.

7.5.4 No Modification of MCCs. Nothing in this Section 7.5 (Reviews and Audits of
Compliance) varies or modifies any rights or obligations of Customer or Google LLC under
any Model Contract Clauses entered into as described in Section 10.2 (Transfers of Data).

## 8. Impact Assessments and Consultations

Google will (taking into account the nature of the processing and the information
available to Google) assist Customer in ensuring compliance with its obligations
pursuant to Articles 35 and 36 of the GDPR, by:

providing Additional Security Controls in accordance with Section 7.1.3 (Additional
Security Controls) and the Security Documentation in accordance with Section 7.5.1
(Reviews of Security Documentation);

   - providing the information contained in the Agreement including these Terms; and

if subsections (a) and (b) above are insufficient for Customer to comply with such
obligations, upon Customer’s request, providing additional reasonable assistance.

## 9. Access etc.; Data Subject Rights; Data Export

9.1 Access; Rectification; Restricted Processing; Portability. During the Term,
Google will enable Customer, in a manner consistent with the functionality of the
Services, to access, rectify and restrict processing of Customer Data, including via the
deletion functionality provided by Google as described in Section 6.1
(Deletion by Customer), and to export Customer Data.

9.2 Data Subject Requests.

9.2.1 Customer’s Responsibility for Requests. During the Term, if
Google’s Cloud Data Protection Team receives a request from a data subject in relation
to Customer Personal Data, and the request identifies Customer, Google will advise the data
subject to submit their request to Customer. Customer will be responsible for responding to
any such request including, where necessary, by using the functionality of the Services.

9.2.2 Google’s Data Subject Request Assistance. Google will (taking into
account the nature of the processing of Customer Personal Data) assist Customer in
fulfilling its obligations under Chapter III of the GDPR to respond to requests for
exercising the data subject’s rights by:

providing Additional Security Controls in accordance with Section 7.1.3 (Additional
Security Controls);

complying with Sections 9.1 (Access; Rectification; Restricted Processing; Portability)
and 9.2.1 (Customer’s Responsibility for Requests); and

if subsections (a) and (b) above are insufficient for Customer to comply with such
obligations, upon Customer’s request, providing additional reasonable assistance.

## 10. Data Transfers

10.1 Data Storage and Processing Facilities. Google may store and process Customer
Data anywhere Google or its Subprocessors maintain facilities, subject to:

Section 10.2 (Transfers of Data) with respect to the Model Contract
Clauses or Alternative Transfer Solution; and

   - the Service Specific Terms with respect to data location.

10.2 Transfers of Data. If the storage and/or processing of Customer Personal Data
involves transfers of Customer Personal Data from the EEA, Switzerland or the UK to any
third country that does not ensure an adequate level of protection under European Data
Protection Law, and European Data Protection Law applies to those transfers, then:

if Customer (as data exporter) enters into the Model Contract Clauses with Google LLC
(as data importer) within the Admin Console, then:

the transfers will be subject to the Model Contract Clauses; and

Google will ensure that Google LLC complies with its obligations under the Model
Contract Clauses in respect of those transfers; or

if Customer does not enter into the Model Contract Clauses as described in Section
10.2(a), then:

if an Alternative Transfer Solution is made available by Google: (A) Customer will be
deemed to be using it and will take any action (which may include execution of
documents) strictly required to give it full effect; and (B) Google will ensure that
the transfers are made in accordance with such Alternative Transfer Solution; or

if an Alternative Transfer Solution is not made available by Google: (A) Customer
(as data exporter) will be deemed to have entered into the Model Contract Clauses
with Google LLC (as data importer); (B) the transfers will be subject to the Model
Contract Clauses; and (C) Google will ensure Google LLC complies with its obligations
under the Model Contract Clauses in respect of those transfers; and

if Customer has entered into the Model Contract Clauses but reasonably determines
subsequently that they do not provide an adequate level of protection, then:

if an Alternative Transfer Solution is made available by Google, Customer may, by
notifying Google LLC via Google’s Cloud Data Protection Team in accordance with
Section 12.1 (Google’s Cloud Data Protection Team), terminate any Model Contract
Clauses applicable under Section 10.1(a), such that Section 10.2(b)(i) will apply; or

if an Alternative Transfer Solution is not made available by Google, Customer may
terminate the Agreement immediately by notifying Google.

10.3 Data Center Information. Information about the locations of Google facilities
is available at:
https://cloud.google.com/about/locations/
(as may be
updated by Google from time to time).

10.4 Disclosure of Confidential Information Containing Personal Data. If Customer
has entered into the Model Contract Clauses as described in Section 10.2
(Transfers of Data), Google will, notwithstanding any term to the contrary in the Agreement,
ensure that any disclosure of Customer’s Confidential Information containing personal
data, and any notifications relating to any such disclosures, will be made in accordance
with such Model Contract Clauses.

## 11. Subprocessors

11.1 Consent to Subprocessor Engagement. Customer specifically authorizes the
engagement as Subprocessors of: (a) those entities listed as of the Terms Effective
Date at the URL specified in Section 11.2 (Information about Subprocessors); and (b)
all other Google Affiliates from time to time. In addition, without prejudice to
Section 11.4 (Opportunity to Object to Subprocessor Changes), Customer generally authorizes
the engagement as Subprocessors of any other third parties (“New Third Party
Subprocessors”). If Customer has entered into the Model Contract Clauses as described
in Section 10.2 (Transfers of Data), the above authorizations constitute
Customer’s prior written consent to the subcontracting by Google LLC of the processing
of Customer Data.

11.2 Information about Subprocessors. Information about Subprocessors, including
their functions and locations, is available at:
https://cloud.google.com/terms/subprocessors
(as may be updated by Google from time to time in accordance with these Terms).

11.3 Requirements for Subprocessor Engagement. When engaging any Subprocessor,
Google will:

   - ensure via a written contract that:

the Subprocessor only accesses and uses Customer Data to the extent required to
perform the obligations subcontracted to it, and does so in accordance with the
Agreement (including these Terms) and the Model Contract Clauses or
Alternative Transfer Solution, as applicable under Section 10.2
(Transfers of Data); and

if the GDPR applies to the processing of Customer Personal Data, the data protection
obligations described in Article 28(3) of the GDPR, as described in these Terms, are
imposed on the Subprocessor; and

remain fully liable for all obligations subcontracted to, and all acts and omissions of,
the Subprocessor.

11.4 Opportunity to Object to Subprocessor Changes.

When any New Third Party Subprocessor is engaged during the Term, Google will, at least
30 days before the New Third Party Subprocessor starts processing any Customer Data,
notify Customer of the engagement (including the name and location of the relevant
subprocessor and the activities it will perform).

Customer may, within 90 days after being notified of the engagement of a New Third Party
Subprocessor, object by terminating the Agreement immediately by notifying Google. This
termination right is Customer’s sole and exclusive remedy if Customer objects to
any New Third Party Subprocessor.

## 12. Cloud Data Protection Team; Processing Records

12.1 Google’s Cloud Data Protection Team. Google’s Cloud Data Protection
Team can be contacted at
https://support.google.com/cloud/contact/dpo
(and/or via such other means as Google may provide from time to time).

12.2 Google’s Processing Records. To the extent the GDPR requires Google to
collect and maintain records of certain information relating to Customer, Customer will,
where requested, use the Admin Console to supply such information and keep it accurate and
up-to-date. Google may make any such information available to the Supervisory Authorities if
required by the GDPR.

## 13. Liability

13.1 Liability Cap. If the Model Contract Clauses have been entered into as
described in Section 10.2 (Transfers of Data) then, subject to Section 13.2 (Liability Cap
Exclusions), the total combined liability of either party and its Affiliates towards the
other party and its Affiliates under or in connection with the Agreement and such Model
Contract Clauses combined will be limited to the Agreed Liability Cap for the relevant
party.

13.2 Liability Cap Exclusions. Nothing in Section 13.1 (Liability Cap) will affect
the remaining terms of the Agreement relating to liability (including any specific
exclusions from any limitation of liability).

## 14. Third Party Beneficiary

Notwithstanding anything to the contrary in the Agreement, where Google LLC is not a party
to the Agreement, Google LLC will be a third party beneficiary of Sections 7.5 (Reviews and
Audits of Compliance), 10.2 (Data Transfers), 11.1 (Consent to Subprocessor Engagement) and
13 (Liability).

## 15. Effect of These Terms

Notwithstanding anything to the contrary in the Agreement, to the extent of any conflict or
inconsistency between these Terms and the remaining terms of the Agreement, these Terms will
govern.

## Appendix 1: Subject Matter and Details of the Data Processing

Subject Matter

Google’s provision of the Services and TSS to Customer.

Duration of the Processing

The Term plus the period from the expiry of the Term until deletion of all Customer Data by
Google in accordance with the Terms.

Nature and Purpose of the Processing

Google will process Customer Personal Data for the purposes of providing the Services and
TSS to Customer in accordance with the Terms.

Categories of Data

Data relating to individuals provided to Google via the Services, by (or at the direction
of) Customer or by Customer End Users.

Data Subjects

Data subjects include the individuals about whom data is provided to Google via the Services
by (or at the direction of) Customer or by Customer End Users.

## Appendix 2: Security Measures

As from the Terms Effective Date, Google will implement and maintain the Security Measures
described in this Appendix 2.

**1. Data Center and Network Security**

(a) Data Centers.

Infrastructure. Google maintains geographically distributed data centers.
Google stores all production data in physically secure data centers.

Redundancy. Infrastructure systems have been designed to eliminate single points of
failure and minimize the impact of anticipated environmental risks. Dual circuits, switches,
networks or other necessary devices help provide this redundancy. The Services are designed
to allow Google to perform certain types of preventative and corrective maintenance without
interruption. All environmental equipment and facilities have documented preventative
maintenance procedures that detail the process for and frequency of performance in
accordance with the manufacturer’s or internal specifications. Preventative and
corrective maintenance of the data center equipment is scheduled through a standard change
process according to documented procedures.

Power. The data center electrical power systems are designed to be redundant and
maintainable without impact to continuous operations, 24 hours a day, 7 days a week. In most
cases, a primary as well as an alternate power source, each with equal capacity, is provided
for critical infrastructure components in the data center. Backup power is provided by
various mechanisms such as uninterruptible power supplies (UPS) batteries, which supply
consistently reliable power protection during utility brownouts, blackouts, over voltage,
under voltage, and out-of-tolerance frequency conditions. If utility power is interrupted,
backup power is designed to provide transitory power to the data center, at full capacity,
for up to 10 minutes until the diesel generator systems take over. The diesel generators are
capable of automatically starting up within seconds to provide enough emergency electrical
power to run the data center at full capacity typically for a period of days.

Server Operating Systems. Google servers use a Linux based implementation customized
for the application environment. Data is stored using proprietary algorithms to augment data
security and redundancy. Google employs a code review process to increase the security of
the code used to provide the Services and enhance the security products in production
environments.

Businesses Continuity. Google has designed and regularly plans and tests its business
continuity planning/disaster recovery programs.

(b) Networks and Transmission.

Data Transmission. Data centers are typically connected via high-speed private links
to provide secure and fast data transfer between data centers. This is designed to prevent
data from being read, copied, altered or removed without authorization during electronic
transfer or transport or while being recorded onto data storage media. Google transfers data
via Internet standard protocols.

External Attack Surface. Google employs multiple layers of network devices and
intrusion detection to protect its external attack surface. Google considers potential
attack vectors and incorporates appropriate purpose built technologies into external facing
systems.

Intrusion Detection. Intrusion detection is intended to provide insight into ongoing
attack activities and provide adequate information to respond to incidents. Google’s
intrusion detection involves:

tightly controlling the size and make-up of Google’s attack surface through
preventative measures;

   - employing intelligent detection controls at data entry points; and

   - employing technologies that automatically remedy certain dangerous situations.

Incident Response. Google monitors a variety of communication channels for security
incidents, and Google’s security personnel will react promptly to known incidents.

Encryption Technologies. Google makes HTTPS encryption (also referred to as SSL or
TLS connection) available. Google servers support ephemeral elliptic curve Diffie-Hellman
cryptographic key exchange signed with RSA and ECDSA. These perfect forward secrecy (PFS)
methods help protect traffic and minimize the impact of a compromised key, or a
cryptographic breakthrough.

**2. Access and Site Controls**

(a) Site Controls.

On-site Data Center Security Operation. Google’s data centers maintain an
on-site security operation responsible for all physical data center security functions 24
hours a day, 7 days a week. The on-site security operation personnel monitor closed circuit
TV (CCTV) cameras and all alarm systems. On-site security operation personnel perform
internal and external patrols of the data center regularly.

Data Center Access Procedures. Google maintains formal access procedures for
allowing physical access to the data centers. The data centers are housed in facilities that
require electronic card key access, with alarms that are linked to the on-site security
operation. All entrants to the data center are required to identify themselves as well as
show proof of identity to on-site security operations. Only authorized employees,
contractors and visitors are allowed entry to the data centers. Only authorized employees
and contractors are permitted to request electronic card key access to these facilities.
Data center electronic card key access requests must be made through e-mail, and require the
approval of the requestor’s manager and the data center director. All other entrants
requiring temporary data center access must: (i) obtain approval in advance from the data
center managers for the specific data center and internal areas they wish to visit; (ii)
sign in at on-site security operations; and (iii) reference an approved data center access
record identifying the individual as approved.

On-site Data Center Security Devices. Google’s data centers employ an
electronic card key and biometric access control system that is linked to a system alarm.
The access control system monitors and records each individual’s electronic card key
and when they access perimeter doors, shipping and receiving, and other critical areas.
Unauthorized activity and failed access attempts are logged by the access control system and
investigated, as appropriate. Authorized access throughout the business operations and data
centers is restricted based on zones and the individual’s job responsibilities. The
fire doors at the data centers are alarmed. CCTV cameras are in operation both inside and
outside the data centers. The positioning of the cameras has been designed to cover
strategic areas including, among others, the perimeter, doors to the data center building,
and shipping/receiving. On-site security operations personnel manage the CCTV monitoring,
recording and control equipment. Secure cables throughout the data centers connect the CCTV
equipment. Cameras record on site via digital video recorders 24 hours a day, 7 days a week.
The surveillance records are retained for up to 30 days based on activity.

(b) Access Control.

Infrastructure Security Personnel. Google has, and maintains, a security policy for
its personnel, and requires security training as part of the training package for its
personnel. Google’s infrastructure security personnel are responsible for the ongoing
monitoring of Google’s security infrastructure, the review of the Services, and
responding to security incidents.

Access Control and Privilege Management. Customer’s administrators must
authenticate themselves via a central authentication system or via a single sign on system
in order to administer the Services.

Internal Data Access Processes and Policies – Access Policy. Google’s internal
data access processes and policies are designed to prevent unauthorized persons and/or
systems from gaining access to systems used to process personal data. Google designs its
systems to (i) only allow authorized persons to access data they are authorized to access;
and (ii) ensure that personal data cannot be read, copied, altered or removed without
authorization during processing, use and after recording. The systems are designed to detect
any inappropriate access. Google employs a centralized access management system to control
personnel access to production servers, and only provides access to a limited number of
authorized personnel. Google’s authentication and authorization systems utilize SSH
certificates and security keys, and are designed to provide Google with secure and flexible
access mechanisms. These mechanisms are designed to grant only approved access rights to
site hosts, logs, data and configuration information. Google requires the use of unique user
IDs, strong passwords, two factor authentication and carefully monitored access lists to
minimize the potential for unauthorized account use. The granting or modification of access
rights is based on: the authorized personnel’s job responsibilities; job duty
requirements necessary to perform authorized tasks; and a need to know basis. The granting
or modification of access rights must also be in accordance with Google’s internal
data access policies and training. Approvals are managed by workflow tools that maintain
audit records of all changes. Access to systems is logged to create an audit trail for
accountability. Where passwords are employed for authentication (e.g., login to
workstations), password policies that follow at least industry standard practices are
implemented. These standards include restrictions on password reuse and sufficient password
strength. For access to extremely sensitive information (e.g., credit card data), Google
uses hardware tokens.

**3. Data**

(a) Data Storage, Isolation and Logging. Google stores data in a multi-tenant
environment on Google-owned servers. Subject to any Customer instructions to the contrary
(for example, in the form of a data location selection), Google replicates Customer Data
between multiple geographically dispersed data centers. Google also logically isolates the
Customer’s data. Customer will be given control over specific data sharing policies.
Those policies, in accordance with the functionality of the Services, will enable Customer
to determine the product sharing settings applicable to Customer End Users for specific
purposes. Customer may choose to make use of logging functionality that Google makes
available via the Services.

(b) Decommissioned Disks and Disk Erase Policy. Disks containing data may experience
performance issues, errors or hardware failure that lead them to be decommissioned
(“Decommissioned Disk”). Every Decommissioned Disk is subject to a series of
data destruction processes (the “Disk Erase Policy”) before leaving Google’s
premises either for reuse or destruction. Decommissioned Disks are erased in a multi-step
process and verified complete by at least two independent validators. The erase results are
logged by the Decommissioned Disk’s serial number for tracking. Finally, the erased
Decommissioned Disk is released to inventory for reuse and redeployment. If, due to hardware
failure, the Decommissioned Disk cannot be erased, it is securely stored until it can be
destroyed. Each facility is audited regularly to monitor compliance with the Disk Erase
Policy.

**4. Personnel Security**

Google personnel are required to conduct themselves in a manner consistent with the
company’s guidelines regarding confidentiality, business ethics, appropriate usage,
and professional standards. Google conducts reasonably appropriate backgrounds checks to the
extent legally permissible and in accordance with applicable local labor law and statutory
regulations.

Personnel are required to execute a confidentiality agreement and must acknowledge receipt
of, and compliance with, Google’s confidentiality and privacy policies. Personnel are
provided with security training. Personnel handling Customer Data are required to complete
additional requirements appropriate to their role (e.g., certifications). Google’s
personnel will not process Customer Data without authorization.

**5. Subprocessor Security**

Before onboarding Subprocessors, Google conducts an audit of the security and privacy
practices of Subprocessors to ensure Subprocessors provide a level of security and privacy
appropriate to their access to data and the scope of the services they are engaged to
provide. Once Google has assessed the risks presented by the Subprocessor, then subject to
the requirements described in Section 11.3 (Requirements for Subprocessor Engagement) of
these Terms, the Subprocessor is required to enter into appropriate security,
confidentiality and privacy contract terms.

Except as otherwise noted, the content of this page is licensed under the Creative Commons Attribution 4.0 License, and code samples are licensed under the Apache 2.0 License. For details, see the Google Developers Site Policies. Java is a registered trademark of Oracle and/or its affiliates.

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