Security Policy

Security Policy

Last Updated: February 8, 2024

This Security Policy describes how Leya AB (also referred to as “Leya”, “we” or “us”) will make sure your data and your client's data are secure when you interact with us, use the services on our platform, or our affiliates, including our application programming interface, software, tools, developer services, data, documentation and websites (“Services'').

This Security Addendum is part of your Agreement with Leya.  Any capitalized terms used but not defined in this Security Addendum have the meaning set forth in the Terms.  The computing services utilized to offer the Leya Platform are cloud-based and provided to Leya via one or more cloud service providers and represent our “Cloud Environment.”

1 Audits and certifications

1.1 The information security management system used to provide the Service shall be assessed by independent third-party auditors as described in the following audits and certifications (“Third-Party Audits”) on not less than an annual basis.  

- ISO 27001 - Leya has been audited by an independent firm who has confirmed that Leya meets the ISO 27001:2022 requirements.

1.2 Third-Party Audits are made available to You as described in Section 8.2.  

1.3 To the extent that Leya decides to discontinue a Third-Party Audit, Leya will adopt an equivalent, industry-recognized framework.  

2 Hosting location of customer data

2.1 Customer Data will be hosted by Leya in data centers located in the EU.

2.2 Any Customer Data that is processed by Leya’s vendors will similarly be restricted to being located in the EU or be fully compliant with GDPR.

3 Encryption

3.1 Leya encrypts Customer Data at-rest using AES 256-bit (or better) encryption.  Leya uses Transport Layer Security 1.2 (or better) for Customer Data in-transit over untrusted networks.  

3.2 With respect to encryption keys, we regularly rotate encryption keys and utilize hardware security modules to safeguard critical security keys.  Leya logically separates encryption keys from Customer Data.  

4 System and network security

4.1 Leya personnel access to our Cloud Environment is with a unique user ID and is consistent with the principle of least privilege.  Access requires a secure connection, multi-factor authentication, and passwords meeting or exceeding reasonable length and complexity requirements.  

4.2 Leya personnel will not access Customer Data except (i) to provide or support the Service or (ii) to comply with the law or a binding order of a governmental body.

4.3 In accessing our Cloud Environment, our personnel will use laptops that utilize security controls that include encryption and that also include endpoint detection and response tools to monitor and alert for suspicious activities and malicious code and vulnerability management as described in Section 4.7.

4.4 Leya shall protect its Cloud Environment using at least industry standard firewall and security practices.

4.5 Our Cloud Environment leverages industry-standard threat detection tools with daily signature updates, which are used to monitor and alert for suspicious activities, potential malware, viruses and/or malicious computer code (collectively, “Malicious Code”). Leya does not monitor Customer Data or Input for Malicious Code.

4.6 Leya engages an independent third party to conduct penetration tests of the Service at least annually.  Summary results of such penetration tests can be made available to You as described in Section 8.2 at your request.

4.7 Vulnerabilities meeting defined risk criteria trigger alerts and are prioritized for remediation based on their potential impact to the Service. Upon becoming aware of such vulnerabilities, Leya will use commercially reasonable efforts to address private and public critical and high vulnerabilities within 30 days, and medium vulnerabilities within 90 days.

5 Administrative controls

5.1 Leya maintains security awareness and training programs for its personnel including at time of on-boarding.

5.2 Leya personnel are required to sign confidentiality agreements and are required to acknowledge responsibility for reporting security incidents involving Customer Data.

5.3 Leya reviews the access privileges of its personnel to Leya cloud environment at least annually, and removes access on a timely basis for all separated personnel.

5.4 Leya ensures that any of its vendors that process Input or Customer Data maintain security measures consistent with our obligations under this Security Addendum.  

6 Physical data center controls

6.1 Our Cloud Environment (Azure) is maintained by one or more cloud service providers.  We ensure that our cloud service providers data centers have appropriate controls as audited under their third-party audits and certifications.  Each cloud service provider shall have SOC 2 Type II annual audit and ISO 27001 certification, or industry recognized equivalent frameworks.  Such controls include:

- Physical access to facilities are controlled at building ingress points;

- Visitors are required to present ID and must be signed in;

- Physical access to servers is managed by access control devices;

- Physical access privileges are reviewed regularly;

- Facilities utilize monitor and alarm response procedures;

- Facilities utilize CCTV;

- Facilities have adequate fire detection and protection systems; 

- Facilities have adequate back-up and redundancy systems; and

- Facilities have appropriate climate control systems. 

6.2 Leya does not maintain physical offices other than for than for limited corporate and executive purposes. Under no circumstances is Customer Data stored or hosted at such offices.  

7 Incident detection and response

7.1 If Leya becomes aware of a breach of security leading to the destruction, loss, alteration, unauthorized disclosure of, or access to Customer Data (a “Security Incident“), Leya shall notify You without undue delay, and in any case, within 72 hours after becoming aware. You will be notified at the security notice email address indicated on your currently operative order form or as otherwise determined appropriate by Leya. 

7.2 In the event of a Security Incident as described above, Leya shall promptly take reasonable steps to contain, investigate, and mitigate any Security Incident. Any logs determined to be relevant to a Security Incident, shall be preserved for at least one year. 

7.3 Leya shall provide You with timely information about the Security Incident, including the nature and consequences of the Security Incident, the measures taken and/or proposed by Leya to mitigate or contain the Security Incident, the status of our investigation, and a contact point from which additional information may be obtained. Notwithstanding the foregoing, Customer acknowledges that because Leya personnel may not have visibility to the content of Customer Data, it may be the case that we are unable to provide detailed analysis of the type of Customer Data impacted by the Security Incident. Communications in connection with a Security Incident shall not be construed as an acknowledgment by Leya of any fault or liability with respect to the Security Incident.

8 Customer rights and shared responsibility

8.1 Upon request, and at no additional cost to Customer, Leya shall provide Customer, and/or its appropriately qualified third-party representative (collectively, the “Auditor“), access to reasonably requested documentation evidencing our compliance with our obligations under this Security Addendum in the form of, as applicable a copy of our (i) progress towards ISO 27001 certification (ii) a summary of the results of our most recently completed penetration test, and (iii) data flow diagrams for the Service (collectively with Third-Party Audits, “Audit Reports”).  Where an Auditor is a third-party, such third party will be required to execute a separate confidentiality agreement with Leya prior to any audit, Pen Test, or review of Audit Reports, and Leya may object in writing to such third party if in Leya’s reasonable opinion, the third party is not suitably qualified. Any such objection will require You to appoint another third party or conduct such audit, Pen Test, or review. Leya is not responsible for any expenses incurred by an Auditor in connection with any review of Audit Reports, or an audit or Pen Test.

8.2 It is the Customer’s responsibility to ensure that it is authorized to use any Input or Customer Data with the Service and that Your usage complies with relevant legal and regulatory obligations.  

8.3 You are responsible for managing and protecting Your credentials to access the Service.  User credentials must be kept confidential and may not be shared with unauthorized parties.  You must promptly report any suspicious activities related to Your account(s) (such as when You reasonably believe that credentials have been compromised).  

8.4 You are responsible for keeping Your relevant IT systems (such as the browser You use to access the Service) up-to-date and appropriately patched.  

9 Contact

If you have any questions about our Security Policy or security-related issues, please contact us at:
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