When you register for Orlo we ask for information such as;
In Supporting You
The information we collect is used to improve the content of our Web pages and the quality of our service, and is not shared with or sold to other organizations for commercial purposes, except to provide products or services you’ve requested, when we have your permission, or under the following circumstances:
It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law.
Orlo collects information about accesses (such as clicks) of every orlo.uk Link created through the Services. This information includes, but is not limited to: (i) the IP address and physical location of the devices accessing the orlo.uk Link; (ii) the referring websites or services; (iii) the time and date of each access; and (iv) information about sharing of the orlo.uk Link on Third Party Services such as Twitter and Facebook. This information is used by Orlo to improve their websites and services by, for example, providing value-added features, and to analyze clicks on orlo.uk Links, for example to understand how, when and where orlo.uk Links are clicked.
A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site’s computers and stored on your computer’s hard drive.
Cookies are required to use the Orlo service.
Orlo may disclose personally identifiable information under special circumstances, such as to comply with subpoenas or when your actions violate the Terms of Service.
You can manage your email preferences, such as opt-out or unsubscribe from emails sent by Orlo, by adjusting your preferences in your account settings. You can also opt-out or unsubscribe from any future email communications from within each email correspondence that we send you.
Orlo may periodically update this policy. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your Orlo primary account holder account or by placing a prominent notice on our site.
The General Data Protection Regulation (GDPR) comes into effect on 25 May 2018. In line with the GDPR and to continue the provision of secure, reliable and compliant services, we have created these FAQs which set out our privacy obligations – both legal and contractual.
1. How is Orlo structured to ensure data protection compliance?
The protection of our clients’ data is at the heart of our business. We have a strong culture of compliance, which is embedded within our software, systems and processes.
We have worked hard to establish a GDPR compliance framework with internal policies and procedures that are kept under review. Our personnel are trained to understand the importance of data protection and to apply its principles within their roles.
We have a designated privacy officer to guide our business on compliance and have specialist external advisers that we can call on for additional support.
Compliance is monitored through various activities, including internal auditing and analysis of incidents. We maintain records of our processing activities in compliance with Article 30 of the GDPR.
2. What is Orlo’s role in respect of our data?
You are the data controller of all personal data held in our application under your account and Orlo is merely your data processor in respect of all the services provided to you. Our processing of your personal data is only on your documented instructions as set out in the contract between us. We do not use any of your personal data for anything that is not in the contract.
3. What personal data is stored within the Orlo application?
Our application only holds basic information about your authorised users, this being name, email address, password, last login, IP address, browser and device details. If you opt for two-factor authentication, we will also store the user’s mobile phone number.
Your social media followers may include any type of information (including personal data, images and videos) in their messages to you and your users can add free text to social contacts and messages. We don’t use any of this information for any of our own purposes other than to create aggregated statistics, which do not identify any individuals. Our system is merely a place to store their messages to you and to enable you to manage and retrieve them. You are the data controller of your followers’ messages and your users’ free- text additions. As such, it is your responsibility to ensure you use these in compliance with data protection and other laws.
4. Is our data held separately from that of other Orlo clients?
Data is not physically separated within the Orlo application but it is logically separated. We have security policies and code that is automatically tested with every deployment to ensure that your data is not mixed with other clients’ data.
5. Are the systems used by Orlo GDPR compliant?
We carried out a Privacy Impact Assessment of our software, systems and services and have made changes to ensure we meet and, in some cases, exceed GDPR requirements.
Our system architecture was developed with data protection and data security in mind. The databases in which your personal data is stored are only accessible by a small division of the internal development team who are internally vetted and have worked for us for a substantial amount of time. We do not use live data for testing and it is never stored on local machines.
6 What does Orlo do to protect login credentials?
We offer a number of log-in options:
Ultimately, you are responsible for ensuring your users keep your account log-in credentials secure and for any activities or actions occurring under your account. Our application offers the ability to require “strong” passwords (passwords that use a combination of upper and lower case letters, numbers and symbols) for your account. Administrators can disable email/password as a means of logging into the application and force one of the above options instead.
7. What does Orlo do to keep customer data secure?
We have a suite of security measures in place. These are kept under review and, wherever we consider it appropriate, they are enhanced. These are:
We use Cloud KMS (a cloud-hosted key management service), which lets us manage encryption keys for our services. This allows us to generate, use, rotate and destroy AES256 encryption keys.
For all administration based services, 2FA is enabled.
We have some continual end-to-end testing of our server cluster to ensure specific key indicators are working correctly and use software to log and track with a combination of active checks and, for some things, such as back-ups, passive checks. Our set up allows use to detect unexpected behaviour early and team members are alerted if an expected behaviour has not executed as expected.
Our code is written to log any critical events for our developers to address.
8. What back-ups does Orlo take?
Orlo carries out backup continuously. Whilst our main datastore holds replicas of data at all times, we also run our other databases with duplicate data in ready to swap over should the need arise.
Multiple snapshots of the entire database are taken every day and we store them on a separate server from the one that holds live data.
From these various back-ups, we are able to restore the entire database in the event of a major incident. We test our disaster recovery at least annually.
9. Will you need access to our systems?
We do not need access to your systems to provide our services to you.
10. Does Orlo rely on third parties to provide its services?
To date Orlo has not used external developers and intends to use only in-house developers moving forward. This may change in the future but, if so, external developers would be given only limited access to code bases, no access to live data and all code/contributions would be vetted before been deployed.
We use Cloud KMS to manage encryption keys for our services. We currently use leading providers, Rackspace, Amazon Web Services, Google Cloud Services, SendGrid, Loggly and Twilio to provide hosting services. They have all been vetted and authorised by a designated approver within Orlo as part of our supplier on-boarding process and we have written contracts with each of them incorporating appropriate data protection provisions to protect your personal data.
11. What audit trails are maintained to protect our data?
Our software normally maintains a record of your users’ activities in our application such as which of your users created a post to send out, who edited the post, and who created any free text notes on your followers’ messages. You can view these audit logs through the application.
12. What procedures does Orlo have in place to deal with data breaches?
We are proud of our record of having no reportable data breaches to date. However, we know the importance of being prepared for an incident.
All security incidents and platform wide issues will be recorded in a Major Incident Report which will cover: the nature of the incident, the impact on your business and data subjects the resolution and any preventative action planned to avoid recurrence. We will also make an assessment as to whether the breach must be reported to the Information Commissioner and/ or affected individuals.
In the event of a data breach affecting your personal data, we will report this to you without undue delay through our normal support process.
13. Where will our personal data be processed by Orlo?
We use three of the leading providers to host our data and applications, Rackspace, Amazon Web Services and Google Cloud Services. All of the live data is stored within the UK and a limited number of back-ups are stored within the EU.
Where our designated staff are permitted access to your data to fulfil their roles, they do so only from our premises.
14. What happens to our data at the end of the contract?
You are able to export your social inbox whenever you wish during your contract term. Our reports are printable and downloadable.
Once our contract with you has ended, we expunge all of your data (other than your shortened links) which then propagates through our backups. The deletion process can take up to a month to be completely removed from backups.
We retain your shortened links after our contract so that any social posts created from within our application using our link shortening service continue to redirect users to the correct location. No other information is retained or stored.
15. Will Orlo help us comply with data subject rights?
You have full control over your user data and data from followers so you should be able to manage all data subject rights yourself just by using the application. If you need any specific guidance on how to do this, you can use our ‘help’ feature in the application or consult our user guide or use our online chat facility.
16. Will we be able to audit Orlo premises and systems for compliance?
You will appreciate how important it is that our systems and premises ensure confidentiality for all of our clients and we do not normally allow clients to have access. We do, however, engage an external specialist to check our systems and provide a report on compliance each year and we are happy to make that available to you for your peace of mind.
Of course, if a court or regulatory body requires us to give you access, we will honour that requirement but will require you comply with our security and health and safety requirements in doing so.
17. What changes can we expect to see in our contract and services?
Your services will continue unchanged although you may see some new features within our application and we may make additional security checks when you seek our support.
The GDPR requires you, as a data controller, to include additional things in your contracts with data processors. We have, therefore, prepared new data protection provisions, which will replace those in our current contract with you. We will be in touch with each of our clients to provide details of the changes so that we can all be satisfied that we are meeting our legal obligations.