Data Protection & Security

1. Overview

At Voleado, we understand that trust is the foundation of every client relationship. This Data Protection & Security Policy outlines our comprehensive approach to protecting the personal and business data entrusted to us.

As a B2B growth and revenue enablement company handling sensitive prospect and client information, we maintain enterprise-grade security practices and comply with international data protection standards including GDPR, CCPA, and applicable Indian regulations.

2. Our Data Protection Commitment

2.1 Core Principles

We commit to protecting data through:

• Confidentiality: Ensuring data is accessible only to authorized parties
• Integrity: Maintaining accuracy and completeness of data
• Availability: Ensuring authorized access when needed
• Accountability: Taking responsibility for data protection
• Transparency: Being open about our data practices

2.2 Legal Foundations

Our data protection practices are guided by:

• General Data Protection Regulation (GDPR)
• California Consumer Privacy Act (CCPA)
• Information Technology Act, 2000 (India)
• Personal Data Protection Bill (India)
• Industry best practices and standards

3. Technical and Organizational Security Measures

3.1 Infrastructure Security

Network Security

• Encryption: TLS 1.3 for data in transit, AES-256 for data at rest
• Firewalls: Multi-layer firewall protection with intrusion detection
• VPN: Secure VPN access for remote operations
• Network Segmentation: Isolated networks for different security zones

Application Security

• Secure Development: Security-by-design principles in all systems
• Code Reviews: Regular security-focused code audits
• Vulnerability Scanning: Automated and manual security testing
• Patch Management: Timely application of security updates

Data Storage Security

• Encrypted Databases: Field-level encryption for sensitive data
• Access Controls: Role-based access with principle of least privilege
• Backup Systems: Encrypted daily backups with geo-redundancy
• Secure Deletion: Cryptographic erasure protocols for data disposal

3.2 Access Management

Authentication

• Multi-factor authentication (MFA) for all system access
• Strong password policies (minimum 12 characters, complexity requirements)
• Single Sign-On (SSO) integration where applicable
• Regular credential rotation and audit

Authorization

• Role-Based Access Control (RBAC) for granular permissions
• Just-in-time access provisioning
• Regular access reviews and recertification
• Automated access revocation upon employee departure

Monitoring & Logging

• Comprehensive audit logging of all system access
• Real-time alerting for suspicious activities
• Security Information and Event Management (SIEM)
• Log retention for compliance and forensic purposes

3.3 Physical Security

• Data Centers: Tier III+ certified facilities with 24/7 monitoring
• Access Control: Biometric access and visitor logging
• Environmental: Climate control, fire suppression, power redundancy
• Device Security: Full disk encryption on all company devices

4. Data Processing Practices

4.1 Data Minimization

We collect and process only the minimum data necessary to deliver our services effectively. This includes:

• Prospect contact information (name, email, phone, job title, company)
• Business context (industry, company size, needs)
• Campaign interaction data (opens, clicks, replies)
• Client business information relevant to service delivery

4.2 Purpose Limitation

Data is processed exclusively for purposes disclosed to data subjects and clients:

• Delivering contracted B2B growth services
• Campaign execution and optimization
• Performance reporting and analysis
• Service improvement and innovation
• Legal and regulatory compliance

4.3 Data Quality

We maintain data accuracy through:

• Multi-source verification for prospect data
• Regular data validation and cleansing
• Automated bounce and unsubscribe handling
• Client feedback integration for corrections

4.4 Storage Limitation

Data retention periods are clearly defined:

• Active Client Data: Duration of engagement + 90 days
• Prospect Data: Campaign duration + 12 months
• Business Records: 7 years for compliance
• Backups: 90 days with automated purging

5. Compliance Framework

5.1 GDPR Compliance (EU/EEA)

For EU/EEA personal data, we ensure:

• Lawful Basis: Clear legal basis for all processing activities
• Data Subject Rights: Mechanisms to honor access, deletion, portability requests
• DPO Designation: Data Protection Officer available for inquiries
• DPIA: Data Protection Impact Assessments for high-risk processing
• Breach Notification: 72-hour notification protocol
• Records of Processing: Detailed documentation per Article 30

5.2 CCPA Compliance (California)

For California residents' data:

• Clear disclosure of data collection and use
• Opt-out mechanisms for data sale (Note: We do not sell data)
• Non-discrimination guarantee for exercising rights
• Designated methods for rights requests
• Verification procedures for identity confirmation

5.3 Indian Regulations

Compliance with Indian data protection laws:

• Reasonable security practices per IT Act, 2000
• Sensitive personal data protections
• Cross-border transfer safeguards
• Upcoming compliance with Personal Data Protection Bill

5.4 Industry Standards

We align with recognized security frameworks:

• ISO/IEC 27001 information security principles
• NIST Cybersecurity Framework
• CAN-SPAM Act for email compliance
• CASL (Canadian Anti-Spam Legislation) where applicable

6. Client Data Protection

6.1 Data Processing Agreement

For clients subject to GDPR, we enter into Data Processing Agreements (DPAs) that clearly define roles, responsibilities, and safeguards. These agreements cover:

• Nature and purpose of processing
• Type of personal data and categories of data subjects
• Duration of processing
• Rights and obligations of both parties
• Sub-processor authorization and oversight

6.2 Client Data Segregation

Each client's data is logically segregated and access-controlled:

• Separate database instances or schemas per client
• Tagged and encrypted storage
• Access restricted to assigned team members only
• No cross-client data commingling

6.3 Data Portability

Clients have full rights to their data:

• Export capabilities in standard formats (CSV, JSON)
• Complete data package available upon request
• 30-day transition support for data migration
• Secure data transfer protocols

7. Security Incident Response

7.1 Incident Response Plan

Our comprehensive incident response protocol includes:

• Detection: 24/7 monitoring and automated alerting
• Assessment: Rapid evaluation of scope and impact
• Containment: Immediate measures to limit exposure
• Eradication: Removal of threats and vulnerabilities
• Recovery: Restoration of normal operations
• Post-Incident: Analysis and prevention improvements

7.2 Data Breach Protocol

In the event of a data breach:

• Internal Notification: Immediate escalation to senior management and DPO
• Investigation: Forensic analysis to determine cause and scope
• Regulatory Notification: 72-hour notification to supervisory authorities (GDPR)
• Client Notification: Prompt notification of affected clients
• Data Subject Notification: Individual notification if high risk
• Documentation: Detailed breach records and response actions

7.3 Business Continuity

Ensuring service continuity:

• Disaster recovery plans tested quarterly
• Redundant systems and failover capabilities
• Regular backup verification and restore testing
• Maximum 24-hour recovery time objective (RTO)

8. Third-Party Vendor Management

8.1 Vendor Selection

We carefully vet all vendors and service providers:

• Security questionnaires and assessments
• Certification verification (SOC 2, ISO 27001, etc.)
• Data protection compliance review
• Financial and operational stability checks

8.2 Vendor Contracts

All vendors sign agreements that include:

• Data protection and security requirements
• Confidentiality obligations
• Sub-processor restrictions
• Audit rights and compliance reporting
• Breach notification requirements
• Liability and indemnification terms

8.3 Ongoing Monitoring

Continuous vendor oversight includes:

• Annual security reassessments
• Performance and SLA monitoring
• Incident tracking and response evaluation
• Periodic contract reviews and updates

9. Employee Training and Awareness

9.1 Security Training Program

All employees undergo comprehensive training:

• Onboarding: Mandatory security and privacy training for new hires
• Annual Refresher: Yearly updates on policies and threats
• Role-Specific: Specialized training based on job responsibilities
• Phishing Simulations: Regular testing and awareness campaigns

9.2 Training Topics

• Data protection principles and regulations
• Secure handling of client and prospect data
• Password management and MFA usage
• Social engineering and phishing recognition
• Incident reporting procedures
• Clean desk and secure communications policies

9.3 Compliance Culture

We foster a security-conscious culture through:

• Regular security updates and newsletters
• Open communication channels for security concerns
• Recognition programs for security vigilance
• Zero-tolerance policy for security violations

10. Audits and Continuous Improvement

10.1 Internal Audits

Regular internal assessments include:

• Quarterly: Access control reviews and permission audits
• Semi-Annual: Security policy compliance checks
• Annual: Comprehensive information security audit
• Ongoing: Automated vulnerability scanning

10.2 External Audits

Independent third-party assessments:

• Annual penetration testing by certified ethical hackers
• Security architecture reviews
• Compliance audits for regulatory requirements
• Vendor security assessments

10.3 Metrics and KPIs

We track security performance through:

• Mean time to detect (MTTD) and respond (MTTR) to incidents
• Vulnerability remediation times
• Security training completion rates
• System uptime and availability
• Data breach/incident frequency

10.4 Continuous Improvement

Security is an ongoing journey:

• Regular review and updates to security policies
• Adoption of emerging security technologies
• Participation in industry security forums
• Lessons learned from incidents and near-misses

11. Contact Information

For Data Protection Inquiries

If you have questions about our data protection practices, wish to exercise your data protection rights, or need to report a security concern, please contact:

Response Times

• Security Incidents: Acknowledged within 2 hours
• Data Subject Requests: Responded to within 30 days
• General Inquiries: Responded to within 2 business days