Data Processing & Security Terms

1. Roles and scope

The Customer is the controller (or “business”) of the personal information it provides through the Service; Bintera is its processor (or “service provider”). Bintera processes it only to provide, secure and support the Service, following the Customer’s documented instructions, which are these terms, the Customer’s settings and its use of the Service. If an instruction appears to break the law, we will tell the Customer.

2. What is processed

• People: the Customer’s employees, contractors and other people it enrolls, and its administrators.
• Information: names, work email addresses, department, site and group, directory identifiers, training assignments, progress, decision-point answers and scores, reported-email metadata, sign-in records and administrator activity logs.
• Not processed: special categories of data, health information, government identifiers or payment card numbers. The Customer agrees not to submit them.
• Duration: for as long as the Customer uses the Service, then until erasure as described in section 7.

3. Confidentiality

Only Bintera personnel who need access to provide or support the Service can reach Customer data, and they are bound by confidentiality obligations.

4. Security measures

• Separation: every record belongs to one organization, every database query is limited to the signed-in organization, and automated tests that try to cross between organizations are run before each release.
• Sign-in: no passwords. Microsoft sign-in or single-use email links that expire after 15 minutes; optional authenticator-app codes with single-use backup codes for administrators; sessions can be ended from any device.
• Encryption: encrypted connections (HTTPS with strict transport security) for all traffic; data encrypted at rest by our hosting provider; authenticator secrets additionally encrypted by Bintera.
• Least access: the Microsoft 365 connection asks only to read the staff list and group membership, never mailboxes. Integration keys are stored as one-way hashes and can be revoked instantly.
• Application protection: strict browser security policies, protection against cross-site request forgery, rate limits on sign-in and reporting, and checks that block connections to internal network addresses.
• Accountability: administrator actions are written to an activity log that cannot be edited or deleted, except when the whole organization is erased at its request.
• Lesson content: videos are served through short-lived links tied to the signed-in person.
• Testing and disclosure: automated security tests are run before each release, and we welcome reports from security researchers through our security.txt.

5. Subprocessors

The Customer authorizes Bintera to use these subprocessors:

We will update this list and email account owners at least 30 days before adding or replacing a subprocessor. The Customer may object on reasonable data protection grounds; if we cannot address the objection, the Customer may end the affected service and receive a refund of prepaid fees for the unused period. Each subprocessor is bound by written terms at least as protective as these.

6. Security incidents

If we become aware of a breach of security leading to unauthorized access to, or loss or disclosure of, Customer personal information, we will notify the account owner without undue delay and in any case within 72 hours, with what we know, what we are doing about it and a contact person, and we will keep the Customer updated.

7. Return and deletion

The Customer can export its data at any time. When the Customer deletes its organization, access ends immediately and all Customer data is permanently erased from the live service after 30 days; our hosting provider’s backups roll over within a further 30 days. We will confirm erasure in writing on request.

8. Assistance and audits

Taking into account the nature of the processing, we will help the Customer respond to requests from individuals exercising their rights, and with data protection impact assessments and consultations with authorities. We will make available the information reasonably needed to demonstrate compliance with these terms, including responses to security questionnaires. Further audits may be agreed in writing, at reasonable times and at the Customer’s cost.

9. International transfers

Where personal information from the European Economic Area, the United Kingdom or Switzerland is transferred to a country without an adequacy decision, the parties agree that the applicable standard contractual clauses (with the UK addendum where relevant) are incorporated by reference, with the Customer as exporter and Bintera as importer.

10. US state privacy laws

Bintera will not sell or share Customer personal information, retain, use or disclose it for any purpose other than providing the Service, or combine it with personal information from other sources except as the law permits for service providers. We will tell the Customer if we can no longer meet these obligations.

11. Order of precedence

If these terms conflict with the Terms of Service, these terms prevail for the processing of personal information. The limits of liability in the Terms of Service apply to these terms.