Curacel Systems Limited
By:
Name: Jesutomiwa Salam
Title: Software Engineering Lead
Date: 23/1/2025
Customers Name
By: ____________________________
Name:
Title:
Date:
SCHEDULE 1
ANNEX I
A. LIST OF PARTIES
Data exporter(s):
Name : Customer (As set forth in the relevant Order Ford).
Address: As set forth in the relevant Order Form.
Contact person’s name, position, and contact details: As set forth in the relevant Order Form.
Activities relevant to the data transferred under these Clauses: Recipient of the Services provided by Curacel Systems Limited in accordance with the Agreement.
Signature and date: Signature and date are set out in the Agreement.
Role Controller/ Processor): Controller
Data importer(s):
Name: Curacel Systems Limited
Address: 19B Adeyemi Lawson St, Nigeria.
Contact person’s name, position, and contact details: Peter Dada, Chief Data Officer, flash@curacel.ai
Activities relevant to the data transferred under these Clauses: Provision of the Services to the Customer in accordance with the Agreement.
Signature and date: 23rd January 2025
Role (controller/processor): Processor.
B. description of transfer
Categories of data subjects whose personal data is transferred
Customer’s authorized users of the Services.
Categories of personal data transferred
Name, Address, Date of Birth, Age, Education, Email, Gender, Image, Job, Language, Phone, Related person, Related URL, User ID, Username.
Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialized training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.
No sensitive data collected.
The frequency of the transfer (e.g., whether the data is transferred on a one-off or continuous basis).
Continuous basis
Nature of the processing
- Claims administration and Change of Software
Sync with external systems over the bridge
Purpose(s) of the data transfer and further processing
The purpose of the transfer is to facilitate the performance of the Services more fully described in the Agreement and accompanying order forms.
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period
The period for which the Customer Personal Data will be retained is more fully described in the Agreement, Addendum, and accompanying order forms.
For transfers to (sub-) processors, also specify subject matter, nature, and duration of the processing
The subject matter, nature, and duration of the Processing more fully described in the Agreement, Addendum, and accompanying order forms.
C.COMPETENT SUPERVISORY AUTHORITY
Data exporter is established in an EEA country.
The competent supervisory authority is as determined by application of Clause 13 of the EU SCCs.
ANNEX II
TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA
Description of the technical and organisational security measures implemented by Curacel Systems Limited as the data processor/data importer to ensure an appropriate level of security, taking into account the nature, scope, context, and purpose of the processing, and the risks for the rights and freedoms of natural persons.
Security
Security Management System.
- Organization. Curacel Systems Limited designates qualified security personnel whose responsibilities include development, implementation, and ongoing maintenance of the Information Security Program.
- Policies. Management reviews and supports all security related policies to ensure the security, availability, integrity and confidentiality of Customer Personal Data. These policies are updated at least once annually.
- Assessments. Curacel Systems Limited engages a reputable independent third-party to perform risk assessments of all systems containing Customer Personal Data at least once annually.
- Risk Treatment. Curacel Systems Limited maintains a formal and effective risk treatment program that includes penetration testing, vulnerability management and patch management to identify and protect against potential threats to the security, integrity or confidentiality of Customer Personal Data.
- Vendor Management. Curacel Systems Limited maintains an effective vendor management program
- Incident Management. Curacel Systems Limited reviews security incidents regularly, including effective determination of root cause and corrective action.
- Standards. Curacel Systems Limited operates an information security management system that complies with the requirements of ISO/IEC 27001:2022 standard.
Personnel Security.
- Curacel Systems Limited personnel are required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. Curacel Systems Limited conducts reasonably appropriate background checks on any employees who will have access to client data under this Agreement, including in relation to employment history and criminal records, to the extent legally permissible and in accordance with applicable local labor law, customary practice and statutory regulations.
- Personnel are required to execute a confidentiality agreement in writing at the time of hire and to protect Customer Personal Data at all times. Personnel must acknowledge receipt of, and compliance with, Curacel Systems Limited’s confidentiality, privacy and security policies. Personnel are provided with privacy and security training on how to implement and comply with the Information Security Program. Personnel handling Customer Personal Data are required to complete additional requirements appropriate to their role (e.g., certifications). Curacel Systems Limited’s personnel will not process Customer Personal Data without authorization.
Access Controls
- Access Management. Curacel Systems Limited maintains a formal access management process for the request, review, approval and provisioning of all personnel with access to Customer Personal Data to limit access to Customer Personal Data and systems storing, accessing or transmitting Customer Personal Data to properly authorized persons having a need for such access. Access reviews are conducted periodically to ensure that only those personnel with access to Customer Personal Data still require it.
- Infrastructure Security Personnel. Curacel Systems Limited has, and maintains, a security policy for its personnel, and requires security training as part of the training package for its personnel. Curacel Systems Limited’s infrastructure security personnel are responsible for the ongoing monitoring of Curacel Systems Limited’s security infrastructure, the review of the Services, and for responding to security incidents.
- Access Control and Privilege Management. Curacel Systems Limited’s and Customer’s administrators and end users must authenticate themselves via a Multi-Factor authentication system or via a single sign on system in order to use the Services
- Internal Data Access Processes and Policies – Access Policy. Curacel Systems Limited’s internal data access processes and policies are designed to protect against unauthorized access, use, disclosure, alteration or destruction of Customer Personal Data. Curacel Systems Limited designs its systems to only allow authorized persons to access data they are authorized to access based on principles of “least privileged” and “need to know”, and to prevent others who should not have access from obtaining access. Curacel Systems Limited requires the use of unique user IDs, strong passwords, two factor authentication and carefully monitored access lists to minimize the potential for unauthorized account use. The granting or modification of access rights is based on: the authorized personnel’s job responsibilities; job duty requirements necessary to perform authorized tasks; a need to know basis; and must be in accordance with Curacel Systems Limited’s internal data access policies and training. Approvals are managed by workflow tools that maintain audit records of all changes. Access to systems is logged to create an audit trail for accountability. Where passwords are employed for authentication (e.g., login to workstations), password policies follow industry standard practices. These standards include password complexity, password expiry, password lockout, restrictions on password reuse and re-prompt for password after a period of inactivity
Data Center and Network Security
Data Centers.
- Infrastructure. Curacel Systems Limited has AWS as its data center.
- Resiliency. Multi Availability Zones are enabled on AWS and Curacel Systems Limited conducts Backup Restoration Testing on regular basis to ensure resiliency.
- Server Operating Systems. Curacel Systems Limited’s servers are customized for the application environment and the servers have been hardened for the security of the Services. Curacel Systems Limited employs a code review process to increase the security of the code used to provide the Services and enhance the security products in production environments
- Disaster Recovery. Curacel Systems Limited replicates data over multiple systems to help to protect against accidental destruction or loss. Curacel Systems Limited has designed and regularly plans and tests its disaster recovery programs.
- Security Logs. Curacel Systems Limited’s systems have logging enabled to their respective system log facility in order to support the security audits, and monitor and detect actual and attempted attacks on, or intrusions into, Curacel Systems Limited’s systems.
- Vulnerability Management. Curacel Systems Limited performs regular vulnerability scans on all infrastructure components of its production and development environment. Vulnerabilities are remediated on a risk basis, with Critical, High and Medium security patches for all components installed as soon as commercially possible.
Networks and Transmission.
- Data Transmission. Transmissions on production environment are transmitted via Internet standard protocols.
- External Attack Surface. AWS Security Group which is equivalent to virtual firewall is in place for Production environment on AWS.
- Incident Response. Curacel Systems Limited maintains incident management policies and procedures, including detailed security incident escalation procedures. Curacel Systems Limited monitors a variety of communication channels for security incidents, and Curacel Systems Limited’s security personnel will react promptly to suspected or known incidents, mitigate harmful effects of such security incidents, and document such security incidents and their outcomes.
- Encryption Technologies. Curacel Systems Limited makes HTTPS encryption (also referred to as SSL or TLS) available for data in transit.
Data Storage, Isolation, Authentication, and Destruction. Curacel Systems Limited stores data in a multi-tenant environment on AWS servers. Data, the Services database and file system architecture are replicated between multiple availability zones on AWS. Curacel Systems Limited logically isolates the data of different customers. A central authentication system is used across all Services to increase uniform security of data. Curacel Systems Limited ensures secure disposal of Client Data through the use of a series of data destruction processes.
ANNEX III
LIST OF SUB-PROCESSORS
The controller has authorized the use of the following sub-processors:
Name of Sub-Processor: Amazon Web Services
Description of Processing: Hosting the Production Environment
Location of Other Processor: USA
Name of Sub-Processor: Google Cloud Platform
Description of Processing: Hosting Curacel Extraction AI
Location of Other Processor: India
Name of Sub-Processor: Google Workplace
Description of Processing: Hosting Curacel Extraction AI
Location of Other Processor: India
Name of Sub-Processor: Slack
Description of Processing: Communication Channel
Location of Other Processor: USA
Name of Sub-Processor: Freshdesk
Description of Processing: Customer Support Application
Location of Other Processor: India
Name of Sub-Processor: Jira Product
Description of Processing: Project Management application
Location of Other Processor: USA
Name of Sub-Processor: Brevo
Description of Processing: Email Services
Location of Other Processor: USA
Name of Sub-Processor: Mixpanel
Description of Processing: Product Analytics
Location of Other Processor: USA
Name of Sub-Processor: PostHog
Description of Processing: Product Analytics
Location of Other Processor: USA
Name of Sub-Processor: Bitbucket
Description of Processing: Product Analytics
Location of Other Processor: USA