October 1, 2019

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Data Processing and Security Terms (Partners)

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Last modified: 01 October 2019

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The partner agreeing to these terms (“Partner”), 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 Partner as a reseller or supplier of Google Cloud Platform under
the Program (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.

**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 Partner 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 (for example, Privacy
Shield).

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.

Data Incident means a breach of Google’s security leading to the accidental or
unlawful destruction, loss, alteration, unauthorized disclosure of, or access to,
Partner 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 Partner 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 Partner 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 Partner.

   - Model Contract Clauses or MCCs mean the 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.

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 Partner in
the Admin Console or Order Form, to receive certain notifications from Google. Partner is
responsible for using the Admin Console to ensure that its Notification Email Address
remains current and valid.

Privacy Shield means, as applicable, the EU-U.S. Privacy Shield legal framework,
the Swiss-U.S. Privacy Shield legal framework, and any equivalent legal framework that may
apply between the UK and the United States.

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

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 Partner 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 Partner 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 Partner 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 Partner Personal Data if, for example:

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

the Partner 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 behaviour 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 Partner 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 Partner 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 Partner Personal Data:

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

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

Partner is a controller or processor, as applicable, of that Partner 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 Partner Personal Data.

5.1.2 Authorization by Third Party Controller. If European Data Protection Law
applies to the processing of Partner Personal Data and Partner is a processor, Partner
warrants that its instructions and actions with respect to that Partner 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 Partner Personal Data, the relevant party will
comply with any obligations applicable to it under that law with respect to the processing of
that Partner Personal Data.

5.2 Scope of Processing.

5.2.1 Partner’s Instructions. Partner instructs Google to process Partner
Personal Data only in accordance with applicable law: (a) to provide the Services and TSS;
(b) as further specified via Partner’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 Partner (acting on behalf of itself and its Customers) 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 (Partner’s Instructions) (including with regard
to data transfers) unless European or National Law to which Google is subject requires other
processing of Partner Personal Data by Google, in which case Google will notify Partner
(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 Partner. Google will enable Partner to delete Partner Data during the
Term in a manner consistent with the functionality of the Services. If Partner uses the
Services to delete any Partner Data during the Term and that Partner Data cannot be recovered
by Partner, this use will constitute an instruction to Google to delete the relevant Partner
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, Partner instructs Google to
delete all Partner 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), Partner is
responsible for exporting, before the Term expires, any Partner 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 Partner 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 Partner Personal Data are under an obligation of confidentiality.

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

7.1.4 Google’s Security Assistance. Google will (taking into account the nature
of the processing of Partner Personal Data and the information available to Google) assist
Partner 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 Partner in accordance with Section
7.1.3 (Additional Security Controls);

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

providing Partner 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 Partner to comply with such
obligations, upon Partner’s request, providing additional reasonable assistance.

7.2 Data Incidents

7.2.1 Incident Notification. Google will notify Partner promptly and without undue
delay after becoming aware of a Data Incident; and promptly take reasonable steps to minimize
harm and secure Partner 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 Partner 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 Partner Data by Google. Google has no obligation to assess
Partner Data in order to identify information subject to any specific legal requirements.

7.2.5 Notification of Customers. Partner will notify each Customer affected by
a Data Incident without undue delay after becoming aware of the Data Incident.

7.2.6 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 Partner’s Security Responsibilities and Assessment.

7.3.1 Partner’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, as between Partner and Google, Partner
is responsible for its and its Customers’ use of the Services, and its and their storage
of any copies of Partner 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 Partner Data;

securing the account authentication credentials, systems and devices Partner and
its Customers uses to access the Services; and

   - backing up its Partner Data as appropriate.

7.3.2 Partner’s Security Assessment. Partner 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
Partner’s needs, including with respect to any security obligations of Partner 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 Partner 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 Partner to demonstrate compliance by Google with
its obligations under these Terms:

7.5.2 Partner’s Audit Rights.

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

Partner 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.

Partner 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 Partner 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 Partner with further details of any
applicable fee, and the basis of its calculation, in advance of any such audit. Partner will
be responsible for any fees charged by any auditor appointed by Partner to execute any such
audit.

Google may object in writing to an auditor appointed by Partner 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 Partner 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 Partner 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 Partner 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 Partner to comply with such
obligations, upon Partner’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 Partner, in a manner consistent with the functionality of the
Services, to access, rectify and restrict processing of Partner Data, including via
the deletion functionality provided by Google as described in Section 6.1 (Deletion
by Partner), and to export Partner Data.

9.2 Data Subject Requests

9.2.1 Partner’s Responsibility for Requests. During the Term, if Google’s
Cloud Data Protection Team receives a request from a data subject in relation to Partner
Personal Data, and the request identifies Customer, Google will advise the data subject
to submit their request to Partner. Partner 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 Partner Personal Data) assist Partner 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 (Partner’s Responsibility for Requests); and

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

**10. Data Transfers**

10.1 Data Storage and Processing Facilities. Google may store and process Partner Data
anywhere Google or its Subprocessors maintain facilities, subject to Google’s
obligations under:

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

   - the Service Specific Terms with respect to data location.

10.2 Transfers of Data.

10.2.1 Google’s Transfer Obligations. If the storage and/or processing of Partner
Personal Data involves transfers of Partner Personal Data out of the EEA, Switzerland or the
UK, and European Data Protection Law applies to the transfers of such data (“Transferred
Personal Data”), Google will:

ensure that Google LLC enters into Model Contract Clauses with Partner as the exporter of
such data if requested to do so by Partner, and ensure that the transfers are made in
accordance with such Model Contract Clauses; and/or

offer an Alternative Transfer Solution in respect of such data, ensure that the transfers
are made in accordance with such Alternative Transfer Solution, and make information
available to Partner about such Alternative Transfer Solution.

10.2.2 Partner’s Transfer Obligations. In respect of Transferred Personal Data,
Partner will:

enter into Model Contract Clauses as the exporter of such data, if under European Data
Protection Law Google reasonably requires Partner to do so; and

use an Alternative Transfer Solution offered by Google in respect of such data and take any
action (which may include execution of documents) strictly required to give full effect to
such solution if under European Data Protection Law Google reasonably requires Partner to
do so.

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 Partner has
entered into 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 Partner’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. Partner 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), Partner generally authorizes the engagement as
Subprocessors of any other third parties (“New Third Party Subprocessors”). If
Partner has entered into Model Contract Clauses as described in Section 10.2 (Transfers of
Data), the above authorizations constitute Partner’s prior written consent to the
subcontracting by Google LLC of the processing of Partner 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 Partner Data to the extent required to perform
the obligations subcontracted to it, and does so in accordance with the Agreement
(including these Terms) and any Model Contract Clauses entered into or Alternative
Transfer Solution adopted by Google as described in Section 10.2 (Transfers of Data);
and

if the GDPR applies to the processing of Partner 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 Partner Data, notify
Partner of the engagement (including the name and location of the relevant subprocessor and
the activities it will perform).

Partner may, within 90 days after being notified of the engagement of a New Third
Party Subprocessor, object by terminating the Agreement immediately upon written notice to
Google. This termination right is Partner’s sole and exclusive remedy if Partner
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 Partner and Customers, Partner
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 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**

14.1 Google LLC. 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), 11.1 (Consent to Subprocessor Engagement)
and 13 (Liability).

14.2 Customers. For the avoidance of doubt, Customers are not third party beneficiaries
of these Terms.

**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 Partner.

Duration of the Processing

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

Nature and Purpose of the Processing

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

Categories of Data

Data relating to individuals provided to Google via the Services, by (or at the direction
of) Partner, Customers or Partner 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) Partner, Customers or by Partner 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. Partner’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 Partner instructions to the contrary
(for example, in the form of a data location selection), Google replicates Partner Data
between multiple geographically dispersed data centers. Google also logically isolates the
Partner’s data. Partner will be given control over specific data sharing policies. Those
policies, in accordance with the functionality of the Services, will enable Partner to
determine the product sharing settings applicable to Partner End Users for specific purposes.
Partner 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 Partner Data are required to complete
additional requirements appropriate to their role (eg., certifications). Google’s
personnel will not process Partner 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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