This section outlines Programmer’s Force (PF) role and obligations with respect to personal data processed as part of its services. PF works as a data processor under the instruction of its third party partner, and this policy provides information on data handling, transfers, security, and rights management in compliance with applicable data protecting laws.
1. Role Clarification:
PF acts strictly as a data processor in accordance with the instructions provided by our third party partner. PF does not independently collect, control or store personal data in the contact of the services provided. All processing of personal data is done solely based on the instructions given by our third party partner, and PF does not make any independent decisions regarding the purposes or means of data processing.
2. Data Transfer:
In the course of providing our services, PF may access personal data from jurisdictions outside of the European Union (EU). In compliance with applicable data protection laws, appropriate safeguards, such as Standard Contractual Clauses (SCCs), are in place to ensure the protection of personal data during cross-border transfers.
3. Data Protection Officer (DPO) Contact & Complaints:
For any inquiries or complaints related to data protection or to exercise rights regarding personal data, please contact the designated Data Protection Officer (DPO) of our third-party partner. PF does not directly handle data subject access requests (DSARs), as personal data access, management, and any related requests (such as data deletion) are handled by our partner. PF’s role is limited to processing personal data as instructed.
4. Security:
PF is committed to safeguarding personal data. When accessing our partner’s systems, PF implements strict security controls to ensure the protection of personal data. These controls include:
- Session controls to limit unauthorized access.
- No local storage of personal data on PF’s infrastructure.
- Audit trails for tracking system access and actions taken.
- Encryption of data during transfer to prevent unauthorized access.
These safeguards ensure that any access to personal data by PF’s team is secure and meets the required data protection standards.
5. Data Subject Rights
PF does not handle Data Subject Access Requests (DSARs) directly, as all personal data access and processing occurs within our partner’s infrastructure. Any requests to access, correct, delete, or exercise other rights related to personal data should be directed to our third-party partner, as they are the data controller responsible for these activities.
PF ensures compliance with all applicable data protection regulations and provides necessary support to its third party partner to maintain a high standard of data protection.