Cloudamize Data Protection and GDPR
What service is Cloudamize delivering?
Cloudamize is a SAAS platform that companies use to collect metrics on Windows and Linux servers they are looking to migrate to the cloud.
Cloudamize does not collect any personal data within the metrics, rather it takes measurements of servers, such as what is the CPU in the server and how much of the CPU it is using. Cloudamize then uses these measurements and metrics to make recommendations on migration.
Cloudamize collects a small amount of personal data for registration purposes, which is outlined in detail in this document.
What is personal data?
This is data relating to a person, which means they can be identified from the information. This is usually referred to as personal data or personally identifiable information (PII). Herein, this will be referred to as personal data.
This may be one individual source of data (e.g. an email address) or multiple sources of data combined (e.g. an email address with a company identifier and location)
What is confidential data?
Confidential data may contain personal data. However, it can also be data that does
not lead to the identification of a person.
E.g. Business confidential information such as system identification and performance information, MAC addresses, etc.
What personal data does Cloudamize collect?
Cloudamize collects only the personal data about its customers necessary to provide its services. Any personal data collected will be given to Cloudamize directly by the customer and will only be requested by the relevant personnel accessing the services.
Types of personal data collected as part of the registration process to use the Cloudamize Software:
● Name
● Phone number
● Email address
In cases where personal data is passed to Cloudamize that was not intended to be passed by the customer, it is the intention of Cloudamize to destroy this data as soon as it’s identified.
What other data is collected/processed?
See “Data Collected by Cloudamize Agents” attached in Schedule 1. Data is collected either directly or via one of the APIs provided as part of the Cloudamize Software.
What lawful basis under GDPR is Cloudamize relying upon to
collect the data?
Cloudamize relies on the lawful basis of the customer's consent, contractual necessity, and legitimate interest. - we cannot obtain the data without the customer actively handing it over to us. It is also in both parties' legitimate interests, as we cannot provide the services without the data.
What is a Third country, and under which circumstances will
data be transferred to a third country?
Under the GDPR, a Third country is based outside the European Economic Area (EEA) and has not been granted adequacy status by the EU Commission. Adequacy status is where the EU Commission has deemed that the country provides data protection practices equivalent to those in the EU. A list of adequate countries can be found here.
Cloudamize will only share data with third parties where the engagement is sponsored by a Cloud Services Provider (CSP). Cloudamize ensures valid data transfer mechanisms (such as Standard Contractual Clauses) are in place with all CSPs, safeguarding customer data where it is transferred to a third country. Cloudamize does not utilize any third-party tooling to deliver its services.
In what locations will the data be stored?
Data will be stored in the US or Germany, or UAE as per the customer's choice of AWS servers
closest to their location.
Who will access the data within Cloudamize?
The data that Cloudamize collects will be accessible but the individuals the customer authorizes within their organization. Additionally, only Cloudamize staff with a business need and who are in an approved group can access the data.
How long will the data be retained?
Cloudamize offboarding processes ensure the following:
● All Customer information and data collected for Cloudamize processes will be
stored for 30 days after the completion of your project.
● After the 30-day hold, the data will be deleted
● Upon request, Cloudamize can confirm to the Customer that it has requested for
AWS to delete all Customer Data.
● For accounting and tax compliance purposes, Cloudreach will retain the customer name and some details of the engagement for up to a maximum of 10 years, as required by relevant legislation. The exact time frame will be dependent on the geographically applicable legislation. In most cases, this will be up to 6 years.
o Access will be allocated on a need-to-know basis only, and the principle of least privilege” is
applied.
o No system data will be retained within this information.
o Limited types of personal data retained for contractual reasons may include:
> Name
> Company address
SCHEDULE 1
Data Collected by Cloudamize Agents
I. SYSTEM INFORMATION
● Processor, e.g., "Intel(R) Xeon(R) CPU X5482 @ 3.20GHz"
● Other details about the processor, such as processor clock rate, processor
family and processor number of cores, memory
● System board vendor and model, e.g., system vendor="Acer" system
model="Aspire S7-392"
● Operating system, e.g., Microsoft Windows [Version 6.2.9200]
● System identification information
> DNS hostname, e.g., WIN-C3N2VD185F8
> System domain, e.g., WORKGROUP
> System name, e.g., WIN-C3N2VD185F8
> System workgroup, e.g., WORKGROUP
> System part of the domain, e.g., False
> VM Name
> MAC address(es)
> IP address(es)
> NIC type, e.g., Ethernet, Intel(R) 82574L Gigabit Network Connection
> System status
▪ Last shutdown time
▪ Last boot-up time
▪ Disk drives
▪ Interface type
▪ Manufacturer
▪ Serial number
▪ Description
▪ Disk name
II. SYSTEM PERFORMANCE INFORMATION
● CPU usage
● Memory usage
● Disk operations
● Network usage
● Cache usage
III. PROCESS INFORMATION
● Program information
> Executable name
> Vendor
> Other information such as product name, description, URL
> Process performance information
▪ CPU usage
▪ Memory usage
▪ Disk usage
▪ Network usage
▪ Application-specific performance counters
IV. NETWORK BANDWIDTH INFORMATION
● Windows/Linux agents are approximately 5KB to 40KB per 10 minutes