OneBar - GDPR Compliance Statement

Introduction

The EU General Data Protection Regulation (“GDPR”) became mandatory across the European Union on the 25th of May 2018 and brought with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, GDPR has been designed to meet the requirements of the digital age.

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The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.

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Our Commitment

We are committed​ to ensuring the security and protection of the personal information that we process and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing laws and abides by the data protection principles. However, we recognize our obligations in updating and expanding this program to meet the demands of the GDPR.

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OneBar Inc​ is dedicated to safeguarding the personal information held in our systems, and in developing a data protection strategy that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for the GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

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Implemented Policies

OneBar Inc​ has always carried a consistent level of data protection and security across every system we manage, and we will continue to remain fully compliant with the GDPR by maintaining these policies/procedures:

Information Audit

Pending quarterly information audits to identify and assess what personal information we hold, where it comes from, how and why it is processed, and if and to whom it is disclosed.

Data Protection

Accountability and governance measures are in place to ensure that we understand and adequately disseminate our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.

Data Retention & Erasure

Our retention policy and schedule ensure that we meet the ​‘data minimization’ ​and ​‘storage limitation’​ principles and that personal information is stored, archived, and destroyed securely, compliantly, and ethically. We have dedicated erasure procedures in place to meet the new ‘​Right to Erasure​’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes, and notification responsibilities.

Data Breaches

Our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate, and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.

International Data Transfers & Third-Party Disclosures

At this time, all data OneBar stores is stored in the United States. Ergo, OneBar​ has robust procedures and safeguarding measures in place to secure, encrypt, and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses, or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights, and have effective legal remedies for data subjects where applicable.

‍Subject Access Request (SAR)‍

Our SAR procedures are built to accommodate the 30-day timeframe for providing the requested information and this provision will be free of charge. Our procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and response templates to ensure that communications with data subjects are compliant, consistent, and adequate.‍

Legal Basis for Processing‍

All processing activities identify the legal basis for doing so, and ensure that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under ​Article 30 of the GDPR ​and ​Schedule 1 of the Data Protection Bill​ are met.

‍Processing Agreements

Where we use a third-party to process personal information on our behalf (i.e. HRIS via API access), we have created due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place, and compliance with GDPR.

Special Categories Data

Where we obtain and process any special category information, we do so in complete compliance with the ​Article 9 ​requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate​ Article 9(2) ​basis or the ​Data Protection Bill Schedule 1 ​condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly posted.

Data Subject Rights

In addition to the aforementioned policies and procedures that ensure individuals can enforce their data protection rights, we provide easy to access information via email or our website of an individual’s right to access any personal information that ​OneBar processes about them and to request information about:

• What personal data we hold about them
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from them, information about the source
• The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
• The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
• The right to lodge a complaint or seek judicial remedy and who to contact in such instances

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Information Security & Technical and Organizational Measures

OneBar takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure, or destruction and have several layers of security measures, including:

• SSL
• Hashed Passwords
• Data Encryption
• Secure AWS tools, such as S3 buckets, Cloud Watch, RDS

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GDPR Roles and Employees

OneBar ​has designated ​Andrei Fan​ as its Data Protection Officer and has created a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. Mr. Fan has significant experience in data protection and security.

Mr. Fan and the team are responsible for continuously promoting awareness of the

GDPR across the organization, assessing the organization’s GDPR readiness, identifying any gap areas, and implementing the new policies, procedures, and measures.

OneBar understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and has involved all employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees.

If you have any questions about our preparation for the GDPR, please contact OneBar's privacy team at ​support@onebar.io​.