This Data Protection Policy (“DPP”) governs the treatment (e.g., receipt, storage, usage, transfer, and disposition) of the data collected and retrieved by invi.ai (Invictus).

 

“Personally Identifiable Information” (“PII”) means information that can be used on its own or with other information to identify, contact, or locate an individual or to identify an individual in context. This includes, but is not limited to, a Customer or Seller’s name, address, e-mail address, phone number, gift message content, survey responses, payment details, purchases, cookies, digital fingerprint (e.g., browser, user device), IP Address, geo-location, or Internet-connected device product identifier. “Security Incident” means any actual or suspected unauthorized access, collection, acquisition, use, transmission, disclosure, corruption, or loss of Invictus, or breach of any environment containing Invictus, or managed by Invictus with controls substantially similar to those protecting Invictus. “Seller” means any person or customer on Invictus’s websites. “Invictus” means the company that owns invi.ai, or its managers, or the services depending on context.

 

Data Retention and Recovery.
Invictus retains PII only for the purpose of, and as long as is necessary to fulfill orders. PPI of Customers is automatically removed in 30 days after order shipment.

Invictus’s privacy and data handling policy governs the appropriate conduct and technical controls that is applied in managing and protecting information assets. Invictus keeps inventory of software and physical assets (e.g. computers, mobile devices) with access to PII, and update regularly. A record of data processing activities such as specific data fields and how they are collected, processed, stored, used, shared, and disposed for all PII Information should be maintained to establish accountability and compliance with regulations. Invictus’s according to the privacy policy can rectify, erase, or stop sharing/processing the customers information where applicable.

 

All PII is encrypted at rest using industry best practice standards AES-128, AES-256, or RSA with 2048-bit key size (or higher), this depends on particular server configuration. The cryptographic materials (e.g., encryption/decryption keys) and cryptographic capabilities used for encryption of PII at rest is only accessible to the processes and services. PII is not stored in removable media (e.g., USB) or unsecured public cloud applications (e.g., public links made available through Google Drive). Any printed documents containing PII should be securely disposed.

 

Invictus has implemented fine-grained access control mechanisms to allow granting rights to any party using the Application (e.g., access to a specific set of data at its custody) and the Application’s operators (e.g., access to specific configuration and maintenance APIs such as kill switches) following the principle of least privilege. Application sections or features that vend PII must be protected under a unique access role, and access should be granted on a “need-to-know” basis.

Invictus gathers logs to detect security-related events (e.g., access and authorization, intrusion attempts, configuration changes) to the Application and systems. Invictus implements this logging mechanism on all channels (e.g., service APIs, storage-layer APIs, administrative dashboards) providing access to Invictus. All logs must have access controls to prevent any unauthorized access and tampering throughout their lifecycle. Logs themselves should not contain PII and must be retained for at least 90 days for reference in the case of a Security Incident. Invictus has mechanisms to monitor the logs and all system activities to trigger investigative alarms on suspicious actions (e.g., multiple unauthorized calls, unexpected request rate and data retrieval volume, and access to canary data records). Invictus should perform investigation when monitoring alarms are triggered, and this should be documented in the Incident Response Plan.

 

Invictus has implemented network protection controls to deny access to unauthorized IP addresses and public access must be restricted only to approved users.

 

Invictus assigns a unique ID to each person with computer access to Invictus. Persons with access to data don’t create or use generic, shared, or default login credentials or user accounts. Invictus reviews the list of people and services with access to Invictus on a regular basis (at least quarterly), and remove accounts that no longer require access. Invictus restricts employees from storing Invictus data on personal devices. Invictus will maintain and enforce “account lockout” by detecting anomalous usage patterns and log-in attempts, and disabling accounts with access to Invictus as needed.

 

Invictus encrypts all Invictus in transit (e.g., when the data traverses a network, or is otherwise sent between hosts). This is accomplished using HTTP over TLS (HTTPS). Invictus enforces this security control on all applicable external endpoints used by customers as well as internal communication channels (e.g., data propagation channels among storage layer nodes, connections to external dependencies) and operational tooling. Invictus disables communication channels which do not provide encryption in transit even if unused (e.g., removing the related dead code, configuring dependencies only with encrypted channels, and restricting access credentials to use of encrypted channels). Invictus uses data message-level encryption where channel encryption (e.g., using TLS) terminates in untrusted multi-tenant hardware (e.g., untrusted proxies).

 

Invictus has and maintains a plan to detect and handle Security Incidents. Such plan identifies the incident response roles and responsibilities, defines incident types that may impact Invictus, defines incident response procedures for defined incident types, and defines an escalation path and procedures to escalate Security Incidents to Invictus. Invictus reviews and verifies the plan every six (6) months and after any major infrastructure or system change. Invictus investigates each Security Incident, and document the incident description, remediation actions, and associated corrective process/system controls implemented to prevent future recurrence. Invictus will inform Invictus within 24 hours of detecting any Security Incidents.

 

Invictus within no more than 72 hours after Invictus’s request permanently, and securely delete (in accordance with industry-standard sanitization processes, e.g., NIST 800-88) or return Invictus upon and in accordance with Invictus’s notice requiring deletion and/or return. Invictus also permanently and securely deletes all live (online or network accessible) instances of Invictus within 90 days after Invictus’s notice.