GDPR Compliance

Effective Date: September 23, 2025

Last Updated: September 23, 2025



Autodeus Technologies Private Limited is committed to full compliance with the General Data Protection Regulation (GDPR) for all users within the European Union. This document outlines our GDPR compliance framework and the rights available to data subjects under this regulation.


The Verk platform architecture incorporates privacy by design principles to ensure GDPR compliance across all functionality, including artificial intelligence features, workflow automation, and data processing activities.


QUICK GDPR OVERVIEW


Your Rights: Access, rectify, erase, restrict, port, object, and withdraw consent for your personal data
Our Commitment: Full GDPR compliance with privacy-by-design principles built into every feature
Data Protection: Enterprise-grade security with encryption, access controls, and audit trails
Legal Basis: Legitimate interest for core features, consent for AI personalization and marketing
Your Control: Granular privacy settings, data export tools, and easy deletion options
Response Time: 30 days maximum for rights requests (often much faster)


1. GDPR FOUNDATIONS AND VERK


1.1 What is GDPR?

The General Data Protection Regulation (GDPR) is a comprehensive privacy law that:

  • Protects EU Residents: Applies to all EU citizens regardless of where they are in the world

  • Strengthens Rights: Provides robust rights over personal data processing

  • Ensures Accountability: Requires organizations to demonstrate compliance

  • Imposes Standards: Sets high standards for data protection and security

  • Enables Control: Gives individuals meaningful control over their personal data


1.2 How Verk Ensures GDPR Compliance


We've built GDPR compliance into every aspect of our platform:

Privacy by Design

  • Data Minimization: We only collect personal data necessary for specified purposes

  • Purpose Limitation: Personal data is processed only for the purposes we've communicated

  • Storage Limitation: Data is retained only as long as necessary for legitimate purposes

  • Security First: Enterprise-grade security protects all personal data

  • Transparency: Clear, understandable information about all data processing activities


Technical and Organizational Measures

  • Encryption: All personal data encrypted in transit and at rest

  • Access Controls: Strict role-based access to personal data

  • Audit Logging: Comprehensive tracking of all data access and modifications

  • Staff Training: Regular GDPR training for all employees handling personal data

  • Vendor Management: GDPR-compliant agreements with all service providers


1.3 When GDPR Applies to Your Verk Usage


GDPR applies to your use of Verk if:

  • EU Residency: You're located in the European Union when using Verk

  • EU Citizenship: You're an EU citizen using Verk from anywhere in the world

  • EU Business: Your organization has EU operations or serves EU customers

  • EU Team Members: Your Verk organization includes EU-based team members


2. YOUR GDPR RIGHTS WITH VERK


2.1 Right to Information (Articles 13-14)


You have the right to know what personal data we process and why.

What We Provide:

  • Clear Privacy Policy: Comprehensive explanation of data processing activities

  • Purpose Explanations: Specific reasons for each type of data collection

  • Legal Basis: The lawful basis for each processing activity

  • Retention Periods: How long we keep different types of personal data

  • Your Rights: Complete information about all your GDPR rights


How to Access This Information:

  • Review our comprehensive Privacy Policy at verkapp.com/legal/privacy

  • Contact privacy@verkapp.com for specific questions about data processing

  • Access your account settings for personalized data processing information


2.2 Right of Access (Article 15)

You can request access to all personal data we hold about you.


What You Can Access:

  • Account Information: Profile data, organization memberships, subscription details

  • Usage Data: How you use Verk features, including AI interactions and workflow patterns

  • Communication Records: Support interactions, email communications, and notifications

  • Technical Data: Login logs, IP addresses, device information, and security events

  • AI Data: AI preferences, personalization settings, and automated decision records


How to Exercise This Right:

  1. Self-Service Access: View most personal data through your Verk account settings

  2. Data Export: Download your data in machine-readable formats (JSON, CSV)

  3. Comprehensive Request: Email privacy@verkapp.com for complete data access

  4. API Access: Use Verk's API to programmatically access your organization's data


Response Timeline:

  • Self-Service: Immediate access through account settings

  • Email Requests: Response within 7 days, complete data within 30 days

  • Complex Requests: May extend to 60 days with notification


2.3 Right to Rectification (Article 16)


You can correct inaccurate or incomplete personal data.


What You Can Correct:

  • Profile Information: Name, email, job title, and contact details

  • Organization Data: Company information, team member details, and roles

  • Preferences: Communication preferences, AI settings, and dashboard configurations

  • Project Data: Task descriptions, project details, and workflow configurations


How to Correct Your Data:

  1. Direct Updates: Edit most information through your Verk account settings

  2. Bulk Corrections: Use Verk's bulk operations for large-scale data updates

  3. Support Assistance: Contact support@verkapp.com for complex corrections

  4. API Updates: Use our API for programmatic data corrections


Automatic Propagation: Corrections automatically update across all Verk features and integrations where applicable.


2.4 Right to Erasure / "Right to be Forgotten" (Article 17)


You can request deletion of your personal data in specific circumstances.


When Erasure Applies:

  • Withdrawal of Consent: When you withdraw consent for data processing

  • Purpose Fulfilled: When personal data is no longer necessary for original purposes

  • Unlawful Processing: If we've processed your data unlawfully

  • Legal Obligation: When required by law to delete personal data

  • Objection Sustained: When you successfully object to processing (see Article 21)


How to Request Erasure:

  1. Account Deletion: Delete your account through account settings (deletes most personal data)

  2. Selective Deletion: Request deletion of specific data types or time periods

  3. Organization Departure: Remove yourself from organizations while preserving team data

  4. Email Request: Send detailed erasure requests to privacy@verkapp.com


Erasure Limitations:

  • Legal Requirements: Some data must be retained for tax, legal, or regulatory compliance

  • Legitimate Interests: Data necessary for fraud prevention or security monitoring

  • Public Interest: Data processing for public health, safety, or scientific research

  • Legal Claims: Data needed for establishing, exercising, or defending legal claims


Erasure Process:

  • Immediate Effect: Most data deleted within 48 hours of confirmed request

  • Backup Systems: Complete removal from backups within 90 days

  • Third Parties: We notify relevant third parties of erasure obligations

  • Confirmation: Written confirmation provided once erasure is complete


2.5 Right to Restrict Processing (Article 18)


You can limit how we process your personal data in specific situations.


When Restriction Applies:

  • Accuracy Disputed: While we verify the accuracy of personal data

  • Unlawful Processing: As an alternative to erasure for unlawful processing

  • Data Not Needed: When we no longer need the data but you need it for legal claims

  • Objection Pending: While we consider your objection to processing


How Restriction Works:

  • Processing Limitation: We can only store the data, not use it for other purposes

  • Access Maintained: You can still access and use your Verk account

  • Limited Features: Some AI and analytics features may be disabled

  • Third Party Notification: We inform relevant third parties of processing restrictions


How to Request Restriction:

  1. Account Settings: Use privacy controls to restrict specific processing activities

  2. Email Request: Send restriction requests to privacy@verkapp.com with specific details

  3. Temporary Measures: Request temporary restrictions while resolving other issues


2.6 Right to Data Portability (Article 20)


You can receive your personal data in a structured, machine-readable format and transfer it to another service.


What Data is Portable:

  • Account Data: Profile information, preferences, and settings in JSON format

  • Project Data: Tasks, projects, deadlines, and team assignments in CSV/JSON

  • Communication Data: Messages, comments, and collaboration history

  • File Data: Documents, images, and other uploaded content

  • Integration Data: Connected service configurations and sync histories

  • AI Data: Personalization settings, automation rules, and workflow preferences


Supported Formats:

  • JSON: Structured data for technical integrations

  • CSV: Spreadsheet-compatible format for business data

  • Standard APIs: RESTful API access for real-time data portability

  • Archive Formats: Comprehensive ZIP archives for complete data exports


How to Export Your Data:

  1. Built-in Export: Use Verk's data export tools in account settings

  2. API Access: Programmatic data access through our comprehensive API

  3. Email Request: Request specific data formats via privacy@verkapp.com

  4. Migration Assistance: Free migration support to help transfer data to other platforms


Third-Party Transfers: We can assist with direct data transfers to other GDPR-compliant services.


2.7 Right to Object (Article 21)


You can object to certain types of personal data processing.


Processing You Can Object To:


  • Legitimate Interest Processing: Object to processing based on our legitimate interests

  • Direct Marketing: Opt out of all marketing communications and personalized offers

  • Profiling: Object to automated profiling for marketing or decision-making

  • AI Personalization: Disable AI learning from your behavior patterns

  • Analytics: Opt out of usage analytics and performance tracking


Absolute Right to Object:


  • Direct Marketing: We must stop all marketing processing immediately upon objection

  • Marketing Profiling: Automated marketing profiles are immediately disabled

Balancing Test for Other Processing:

  • Compelling Interests: We assess whether our legitimate interests override your objection

  • Essential Features: Some objections may limit Verk functionality

  • Alternative Solutions: We'll offer alternatives where possible


How to Object:


  1. Account Settings: Use granular privacy controls to object to specific processing

  2. Unsubscribe Links: One-click objection to marketing emails

  3. Email Request: Send detailed objections to privacy@verkapp.com

  4. AI Settings: Disable AI personalization and automated decision-making


2.8 Rights Related to Automated Decision-Making (Article 22)


You have rights regarding automated decision-making and profiling.


Verk's Automated Processing:

  • AI Task Suggestions: Automated recommendations for task organization and workflow optimization

  • Risk Assessment: AI identification of project risks and bottlenecks

  • Resource Allocation: Automated suggestions for task assignment and workload distribution

  • Content Generation: AI-powered creation of task descriptions and project summaries

  • Integration Recommendations: Automated suggestions for third-party service connections


Your Rights:

  • Human Review: Request human review of any automated decision affecting you

  • Explanation: Receive explanations of automated decision logic and significance

  • Challenge Decisions: Contest automated decisions and request reconsideration

  • Opt-Out: Disable automated decision-making for your account

  • Manual Override: Always maintain ability to override automated suggestions


Safeguards We Implement:


  • Human Oversight: All significant automated decisions include human review options

  • Explanation Interfaces: Clear explanations of AI recommendations and their basis

  • Easy Override: Simple controls to accept, reject, or modify automated suggestions

  • Bias Prevention: Regular testing for discriminatory outcomes in automated systems

  • Feedback Loops: Mechanisms to improve automated decisions based on user feedback


3. LAWFUL BASIS FOR PROCESSING


3.1 Contract (Article 6(1)(b))


We process personal data to provide Verk services under our Terms of Service:

Core Platform Features:

  • Account Management: Creating and maintaining your Verk account

  • Organization Management: Multi-tenant workspace functionality

  • Project and Task Management: Core productivity features

  • Team Collaboration: Real-time communication and file sharing

  • Integration Services: Connecting third-party tools and services

  • Billing and Payments: Subscription management and payment processing


Technical Delivery:

  • Authentication: Secure login and session management

  • Data Synchronization: Keeping your data consistent across devices

  • Performance Optimization: Ensuring fast, reliable service delivery

  • Security Monitoring: Protecting your account and data from threats


3.2 Legitimate Interest (Article 6(1)(f))

We process personal data for legitimate business purposes, balanced against your privacy rights:


Business Operations:

  • Service Improvement: Analyzing usage patterns to enhance Verk features

  • Technical Support: Providing assistance and resolving technical issues

  • Fraud Prevention: Detecting and preventing unauthorized access and abuse

  • Security Monitoring: Protecting our platform and users from security threats

  • Legal Compliance: Meeting regulatory requirements and legal obligations

Product Development:

  • Feature Development: Understanding user needs to build better productivity tools

  • Performance Analytics: Optimizing system performance and reliability

  • Quality Assurance: Testing and improving software quality

  • Research and Development: Advancing AI and productivity technologies

Balancing Assessment: We regularly assess our legitimate interests against user privacy rights and provide opt-out mechanisms where appropriate.


3.3 Consent (Article 6(1)(a))

We obtain explicit consent for specific processing activities:


AI Personalization:

  • Behavioral Learning: AI analysis of your workflow patterns for personalized suggestions

  • Cross-Feature Insights: Connecting insights across different Verk features

  • Predictive Analytics: AI predictions about your productivity needs and preferences

  • Advanced Automation: Complex workflow automation based on personal behavior patterns


Marketing Communications:

  • Product Updates: Non-essential communications about new features and improvements

  • Educational Content: Productivity tips, best practices, and training materials

  • Event Invitations: Webinars, conferences, and community events

  • Survey Participation: Feedback requests and user research studies


Enhanced Features:

  • Beta Testing: Early access to experimental features and capabilities

  • Community Participation: Engagement in user forums and community features

  • Success Story Sharing: Permission to reference your Verk usage in case studies


Consent Management:

  • Granular Controls: Separate consent for different processing purposes

  • Easy Withdrawal: Simple mechanisms to withdraw consent at any time

  • Regular Review: Periodic consent renewal for ongoing processing activities

  • Clear Documentation: Transparent records of what you've consented to


3.4 Legal Obligation (Article 6(1)(c))


We process personal data when required by law:

Regulatory Compliance:

  • Tax Records: Billing and payment information for tax reporting

  • Financial Reporting: Transaction records for financial compliance

  • Data Protection Laws: Processing necessary to comply with GDPR and other privacy laws

  • Industry Regulations: Compliance with sector-specific regulations affecting our business


Legal Proceedings:

  • Court Orders: Data disclosure when required by valid legal process

  • Law Enforcement: Cooperation with legitimate law enforcement requests

  • Regulatory Investigations: Providing information to regulatory authorities

  • Dispute Resolution: Data processing for legal claims and dispute resolution


3.5 Vital Interests (Article 6(1)(d))


We may process personal data to protect vital interests in emergency situations:

Safety and Security:

  • Emergency Response: Sharing information with emergency services when necessary

  • Threat Prevention: Processing data to prevent serious harm to individuals

  • Public Health: Compliance with public health requirements during emergencies

  • Critical Infrastructure: Protecting essential services and systems

Note: This basis is rarely used and only in genuine emergency situations.


4. SPECIAL CATEGORIES OF PERSONAL DATA


4.1 GDPR Article 9 Data

Verk may inadvertently process special categories of personal data if you include them in your content:

Potential Special Category Data:

  • Health Information: Medical appointments or health-related tasks you create

  • Political Opinions: Political projects or activities mentioned in tasks

  • Religious Beliefs: Faith-based events or activities in your calendar

  • Trade Union Membership: Union-related activities or meetings

  • Biometric Data: If you use biometric authentication on your device


4.2 Our Approach to Special Category Data


Prevention First:

  • User Education: Clear guidance about avoiding special category data in work contexts

  • Data Classification: Tools to help identify and protect sensitive information

  • Content Warnings: Alerts when content might contain special category data


When Special Category Data is Present:

  • Minimal Processing: Limited to what's necessary for core Verk functionality

  • Enhanced Security: Additional encryption and access controls

  • Limited Retention: Shorter retention periods where possible

  • User Control: Enhanced deletion and restriction options


Legal Basis for Special Category Processing:

  • Explicit Consent: When you explicitly consent to processing specific special category data

  • Employment Context: When processing is necessary for employment law obligations

  • Public Interest: When processing serves important public interests

  • Vital Interests: In rare emergency situations to protect life or safety


4.3 Biometric Data Considerations

If you use biometric authentication (fingerprint, face ID) with Verk:

  • Local Processing: Biometric data processed locally on your device

  • No Cloud Storage: Verk never stores biometric data on our servers

  • Device Security: Protected by your device's built-in security measures

  • User Control: You can disable biometric authentication at any time


5. DATA TRANSFERS OUTSIDE THE EU


5.1 Where We Transfer Data


Verk operates globally and may transfer personal data outside the EU:


Primary Data Locations:

  • United States: Primary servers hosted on AWS US East (Virginia)

  • Global CDN: Content delivery networks for performance optimization

  • Support Centers: Customer support operations in multiple countries

  • Integration Partners: Third-party services in various jurisdictions


5.2 Transfer Safeguards


We ensure adequate protection for all international transfers:


European Commission Adequacy Decisions:

  • Adequate Countries: Transfers to countries with EU adequacy decisions

  • Updated Assessments: Regular review of adequacy decision status

  • Alternative Mechanisms: Backup protections for countries losing adequacy


Standard Contractual Clauses (SCCs):

  • EU-Approved Clauses: Use of European Commission Standard Contractual Clauses

  • Supplementary Measures: Additional technical and organizational protections

  • Regular Updates: Implementation of new SCC versions as they become available

  • Impact Assessments: Regular evaluation of transfer risks and safeguards


Binding Corporate Rules (BCRs):

  • AWS Infrastructure: Benefit from AWS's comprehensive global privacy framework

  • Vendor Requirements: All processors must implement equivalent protections

  • Audit Rights: Regular audits of international data processing activities


5.3 Specific Transfer Scenarios


AI Processing:

  • Multi-Provider AI: AI requests may be processed by providers in different countries

  • Data Residency: Enterprise customers can request specific AI processing locations

  • Encryption in Transit: All AI data transfers use end-to-end encryption

  • Minimal Data: Only necessary data sent to AI providers for processing


Integration Data:

  • Third-Party Services: Data may be processed in integration partners' countries

  • User Control: You choose which integrations to enable

  • Partner Agreements: All integration partners must provide adequate protections

  • Disconnection Rights: Easy disconnection of any international integrations


Support and Operations:

  • Global Support: Support staff in multiple countries may access your data

  • Limited Access: Support access limited to necessary troubleshooting data

  • Audit Trails: Comprehensive logging of all support access to personal data

  • Escalation Procedures: EU-specific escalation for sensitive support cases


5.4 Brexit Consideration:


Following the UK's exit from the EU:


  • UK Adequacy: Current adequacy decision allows continued transfers to UK

  • Ongoing Monitoring: Regular assessment of UK data protection developments

  • Alternative Arrangements: Backup protections in case adequacy is withdrawn

  • User Notification: Advance notice of any changes to UK transfer arrangements


6. DATA RETENTION AND DELETION


6.1 Retention Principles


We follow data minimization principles for all personal data retention:


Purpose Limitation: Data retained only as long as necessary for original purposes
Legal Requirements: Some data must be retained for regulatory compliance
User Control: You can request deletion of most personal data at any time
Regular Review: Periodic assessment of retention needs and automatic deletion
Secure Deletion: Comprehensive data destruction when retention periods expire


6.2 Specific Retention Periods


Account and Profile Data:

  • Active Accounts: Retained while account is active and for legitimate business needs

  • Closed Accounts: Most data deleted within 30 days of account closure

  • Legal Retention: Some records retained for 7 years for tax and legal compliance

  • Anonymized Data: Aggregated statistics may be retained indefinitely


Usage and Analytics Data:

  • Performance Data: Retained for 90 days for system optimization

  • Error Logs: Kept for 30 days for troubleshooting and quality improvement

  • Security Logs: Retained for 2 years for security monitoring and incident response

  • Anonymized Analytics: Indefinite retention for product improvement


Communication Data:

  • Support Communications: Retained for 2 years for quality assurance

  • Marketing Communications: Retained until you opt out or request deletion

  • Legal Communications: Retained for 7 years or as required by law

  • System Notifications: Deleted after 90 days unless saved by user


AI and Automation Data:

  • AI Preferences: Retained while account is active or until you change settings

  • Personalization Data: Deleted immediately when you disable AI personalization

  • Automation Rules: Retained until you delete or modify them

  • AI Interaction Logs: Temporary retention for quality improvement (30 days)


6.3 Deletion Procedures


User-Initiated Deletion:

  • Self-Service: Most data can be deleted through account settings

  • Bulk Operations: Tools for deleting large amounts of data efficiently

  • Selective Deletion: Choose specific data types or time periods to delete

  • Confirmation Process: Multiple confirmations for irreversible deletions


Automatic Deletion:

  • Retention Policies: Automatic deletion when retention periods expire

  • Account Inactivity: Dormant accounts may be automatically deleted after extended inactivity

  • Legal Compliance: Automatic deletion when legal retention periods end

  • System Cleanup: Regular automated cleanup of temporary and cache data


Secure Deletion Process:

  • Multiple Overwrites: Data securely overwritten multiple times

  • Backup Purging: Systematic removal from all backup systems

  • Third-Party Notification: Deletion requests sent to relevant processors

  • Completion Verification: Technical verification that deletion is complete


7. DATA PROTECTION IMPACT ASSESSMENTS (DPIA)


7.1 When We Conduct DPIAs


We conduct Data Protection Impact Assessments for processing activities that pose high risks to privacy rights:


High-Risk Processing:

  • New AI Features: Novel artificial intelligence capabilities that process personal data

  • Behavioral Analytics: Systems that profile user behavior patterns

  • Automated Decision-Making: Features that make automated decisions affecting users

  • Large-Scale Processing: Processing that affects large numbers of data subjects

  • Sensitive Data: Any processing of special categories of personal data


Regular DPIA Reviews:

  • Annual Assessments: Yearly review of all high-risk processing activities

  • Feature Updates: New DPIA when existing features significantly change

  • Legal Changes: Assessment when privacy laws or regulations change

  • Incident-Driven: Additional DPIA following any privacy incidents


7.2 DPIA Process and Consultation


Our DPIA Methodology:

  1. Risk Identification: Systematic identification of privacy risks

  2. Impact Assessment: Evaluation of potential harm to data subjects

  3. Mitigation Measures: Design of technical and organizational safeguards

  4. Residual Risk Evaluation: Assessment of remaining risks after mitigation

  5. Decision Documentation: Clear records of DPIA conclusions and decisions


Stakeholder Involvement:

  • Privacy Team: Led by our Data Protection Officer

  • Technical Teams: Engineers and architects involved in system design

  • Product Teams: Product managers and user experience designers

  • Legal Consultation: External privacy counsel for complex assessments

  • User Representation: User feedback incorporated into risk assessments


Supervisory Authority Consultation:

  • High-Risk Threshold: Consultation with relevant supervisory authorities when residual risks remain high

  • Pre-Implementation: Consultation before deploying high-risk features

  • Ongoing Communication: Regular updates to supervisory authorities about DPIA outcomes

  • Public Transparency: Summary of DPIA conclusions published where appropriate


7.3 DPIA Outcomes and User Protection

Mitigation Measures Implemented:

  • Privacy by Design: Technical measures built into system architecture

  • User Controls: Enhanced privacy settings and opt-out mechanisms

  • Data Minimization: Reduced data collection and processing scope

  • Enhanced Security: Additional encryption and access controls

  • Transparency Measures: Improved user information and consent mechanisms


Ongoing Monitoring:

  • Regular Reviews: Continuous assessment of DPIA effectiveness

  • User Feedback: Incorporation of user concerns and suggestions

  • Technical Updates: System improvements based on DPIA recommendations

  • Compliance Verification: Regular audits to ensure mitigation measures remain effective


8. DATA BREACHES AND INCIDENT RESPONSE


8.1 Our Breach Response Commitment


We take data breaches seriously and have comprehensive procedures to protect your rights:

Detection and Assessment:

  • 24/7 Monitoring: Continuous surveillance for security incidents

  • Rapid Response: Security team alerted within minutes of potential breaches

  • Initial Assessment: Immediate evaluation of scope and severity

  • Containment: Swift action to prevent further unauthorized access


GDPR Compliance Timelines:

  • Internal Notification: Immediate notification to senior management and DPO

  • Supervisory Authority: Notification within 72 hours of becoming aware of breach

  • Individual Notification: Direct notification within 72 hours if high risk to rights and freedoms

  • Documentation: Comprehensive incident documentation maintained for compliance


8.2 Breach Classification and Response


High-Risk Breaches (Immediate Individual Notification):

  • Sensitive Data: Breaches involving special categories of personal data

  • Financial Information: Unauthorized access to payment or billing data

  • Authentication Data: Compromise of passwords or security credentials

  • Identity Theft Risk: Breaches that could lead to identity theft or fraud

  • Large-Scale Impact: Incidents affecting significant numbers of users


Standard Breach Response:

  • Supervisory Authority Notification: All personal data breaches reported to authorities

  • Risk Assessment: Detailed evaluation of likelihood and severity of harm

  • Individual Notification: Direct communication when breach poses significant risk

  • Remediation: Immediate steps to secure systems and prevent future incidents


Communication Approach:

  • Clear Language: Breach notifications in plain, understandable language

  • Actionable Information: Specific steps users can take to protect themselves

  • Contact Information: Dedicated support for breach-related questions

  • Regular Updates: Ongoing communication as we learn more about incidents


8.3 Preventive Measures


Technical Safeguards:

  • Encryption: All personal data encrypted in transit and at rest

  • Access Controls: Multi-factor authentication and role-based access

  • Network Security: Firewalls, intrusion detection, and DDoS protection

  • Regular Updates: Continuous security patching and system updates

  • Backup Security: Encrypted, geographically distributed backup systems


Organizational Measures:

  • Staff Training: Regular security awareness training for all employees

  • Background Checks: Comprehensive screening for employees with data access

  • Incident Drills: Regular testing of breach response procedures

  • Vendor Management: Security requirements for all third-party processors

  • Continuous Improvement: Regular security audits and penetration testing


9. INTERNATIONAL DATA TRANSFERS - DETAILED SAFEGUARDS


9.1 Transfer Impact Assessments (TIA)


Before any international transfer, we conduct Transfer Impact Assessments:


Assessment Components:

  • Destination Country Analysis: Evaluation of local privacy laws and government access rights

  • Technical Safeguards: Assessment of encryption and access controls during transfer

  • Legal Protections: Review of contractual and regulatory safeguards

  • Practical Enforceability: Evaluation of whether protections can be effectively enforced

  • Supplementary Measures: Additional protections needed beyond standard safeguards


Risk-Based Approach:

  • High-Risk Transfers: Enhanced assessments for transfers to countries with extensive surveillance laws

  • Routine Transfers: Streamlined assessments for transfers with established safeguards

  • Emergency Transfers: Expedited assessments for transfers necessary to protect vital interests

  • Regular Review: Ongoing reassessment as legal and technical landscapes evolve


9.2 Supplementary Measures for High-Risk Transfers


Technical Measures:

  • End-to-End Encryption: Data encrypted before leaving EU with EU-controlled keys

  • Data Pseudonymization: Personal identifiers replaced with pseudonyms before transfer

  • Secure Multi-Party Computation: Processing without revealing underlying data

  • Homomorphic Encryption: Computation on encrypted data without decryption

  • Federated Learning: AI training without centralizing personal data


Organizational Measures:

  • Data Minimization: Only essential data transferred for specific purposes

  • Purpose Limitation: Strict limitations on use of transferred data

  • Retention Limits: Reduced retention periods for internationally transferred data

  • Access Restrictions: Enhanced access controls for transferred data

  • Transparency Obligations: Enhanced reporting on international processing activities


Legal Measures:

  • Enhanced Contracts: Strengthened contractual protections beyond standard SCCs

  • Audit Rights: Regular on-site audits of international processing activities

  • Suspension Rights: Ability to immediately suspend transfers if protections are compromised

  • Notification Obligations: Immediate notification of any government access requests

  • Challenge Obligations: Contractual requirements to challenge disproportionate access requests


9.3 Ongoing Transfer Monitoring


Continuous Assessment:

  • Legal Developments: Monitoring changes in destination country laws

  • Practical Enforcement: Regular assessment of whether safeguards remain effective

  • Government Access: Tracking any government access to transferred data

  • Technical Updates: Evaluation of new technical measures for enhanced protection

  • User Feedback: Incorporation of user concerns about international transfers


Remedial Actions:

  • Immediate Suspension: Ability to suspend transfers if protections become inadequate

  • Alternative Measures: Implementation of additional safeguards when needed

  • Transfer Rerouting: Redirecting transfers to countries with adequate protections

  • Local Processing: Moving processing back to EU when safeguards fail

  • User Notification: Immediate communication of any changes to transfer protections


10. EXERCISING YOUR GDPR RIGHTS - DETAILED PROCEDURES


10.1 How to Submit Rights Requests


Online Portal:

  • Account Settings: Self-service portal for most common rights requests

  • Automated Processing: Immediate processing for straightforward requests

  • Status Tracking: Real-time updates on request processing status

  • Document Download: Secure download of requested data and documentation


Email Requests:

  • Primary Contact: privacy@verkapp.com with "GDPR Request" in subject line

  • Required Information: Full name, email address, specific request details

  • Identity Verification: Additional verification may be required for security

  • Acknowledgment: Automatic confirmation of request receipt within 24 hours


Postal Requests:

  • Physical Address: Requests can be sent to our registered office address

  • Secure Handling: Physical mail processed with enhanced security measures

  • Response Method: We'll respond via your preferred communication method

  • Processing Time: May take longer than electronic requests due to handling requirements


10.2 Identity Verification Procedures


Standard Verification:

  • Account Access: Requests from your registered Verk account email

  • Security Questions: Verification using account security information

  • Two-Factor Authentication: Additional verification for enhanced security

  • Behavioral Verification: Analysis of typical usage patterns for suspicious requests


Enhanced Verification (for sensitive requests):

  • Government ID: Photo identification for high-risk requests

  • Notarized Documents: Notarized verification for inheritance or legal representative requests

  • Video Verification: Live video call verification for complex cases

  • Legal Documentation: Court orders or power of attorney for third-party requests


Third-Party Requests:

  • Legal Representatives: Lawyers acting on behalf of data subjects

  • Estate Executors: Handling requests from deceased users' estates

  • Parental Requests: Parents or guardians requesting minor children's data

  • Corporate Representatives: Authorized representatives of business customers


10.3 Request Processing and Response


Timeline Commitments:

  • Acknowledgment: Within 24 hours of receiving request

  • Standard Processing: Within 30 days of verified request

  • Complex Requests: Up to 60 days with explanation for delay

  • Urgent Requests: Expedited processing for time-sensitive situations


Response Format:

  • Electronic Delivery: Secure download links for digital data

  • Structured Data: JSON, CSV, or XML formats for machine-readable data

  • Human-Readable: Clear explanations accompanying technical data

  • Searchable Format: Data organized for easy searching and navigation


Quality Assurance:

  • Data Accuracy: Verification that all requested data is included

  • Completeness Check: Confirmation that response addresses all request elements

  • Redaction Review: Proper protection of third-party personal data

  • Format Validation: Ensuring data is provided in requested formats


10.4 Fees and Charges


Free Processing:

  • Initial Requests: First request of each type processed free of charge

  • Reasonable Requests: Straightforward requests processed without fees

  • Statutory Rights: No charge for exercising basic GDPR rights

  • Error Correction: Free processing when we've made mistakes


Administrative Fees (when applicable):

  • Excessive Requests: Fees for manifestly unfounded or excessive requests

  • Repetitive Requests: Charges for identical requests within short timeframes

  • Resource-Intensive: Fees for requests requiring disproportionate effort

  • Fee Justification: Clear explanation when fees are charged


Fee Structure:

  • Hourly Rate: €50 per hour for complex manual processing

  • Maximum Limits: Fees capped at reasonable levels relative to request complexity

  • Alternative Options: Offer of alternative, no-cost ways to address request

  • Payment Terms: Fees payable before processing begins


11. GDPR COMPLIANCE MONITORING AND AUDITING


11.1 Internal Compliance Monitoring


Regular Assessments:

  • Monthly Reviews: Internal privacy compliance checks by DPO team

  • Quarterly Audits: Comprehensive review of data processing activities

  • Annual Assessments: Complete GDPR compliance evaluation

  • Trigger Reviews: Additional assessments following incidents or complaints


Compliance Metrics:

  • Rights Request Fulfillment: Tracking response times and completion rates

  • Data Processing Accuracy: Verification that processing matches documented purposes

  • Security Incident Response: Assessment of breach response effectiveness

  • Training Completion: Monitoring staff GDPR training completion rates

  • Vendor Compliance: Regular assessment of processor compliance status


Continuous Improvement:

  • Process Optimization: Regular improvements to rights request handling

  • System Updates: Technical improvements to support compliance

  • Training Enhancement: Regular updates to staff privacy training

  • Policy Updates: Periodic revision of privacy policies and procedures


11.2 External Audits and Certifications


Third-Party Audits:

  • Annual Privacy Audits: Independent assessment of GDPR compliance

  • Security Certifications: SOC 2, ISO 27001, and other relevant certifications

  • Penetration Testing: Regular security testing by external experts

  • Compliance Consulting: Periodic review by external privacy counsel


Certification Maintenance:

  • Continuous Monitoring: Ongoing compliance with certification requirements

  • Regular Recertification: Renewal of certifications on schedule

  • Corrective Actions: Prompt response to any audit findings

  • Documentation Updates: Maintenance of current compliance documentation


11.3 Supervisory Authority Relations

Proactive Communication:

  • Regular Updates: Voluntary updates to relevant supervisory authorities

  • Consultation Requests: Seeking guidance on complex compliance issues

  • Best Practice Sharing: Contributing to industry privacy best practices

  • Incident Reporting: Prompt, accurate breach notifications


Cooperation Commitments:

  • Investigation Support: Full cooperation with supervisory authority investigations

  • Information Provision: Prompt response to authority information requests

  • Corrective Action: Swift implementation of required corrective measures

  • Ongoing Dialogue: Maintenance of positive working relationships with authorities


12. CONTACT INFORMATION FOR GDPR MATTERS

12.1 Data Protection Officer (DPO)


Our Data Protection Officer oversees all GDPR compliance matters:


Primary Contact:

  • Email: dpo@verkapp.com

  • Role: Independent oversight of data protection compliance

  • Response Time: Within 48 hours for GDPR-related inquiries

  • Languages: English (primary), additional languages upon request


DPO Responsibilities:

  • Rights Requests: Oversight of all GDPR rights request processing

  • Compliance Monitoring: Regular assessment of GDPR compliance status

  • Training Coordination: Staff privacy training and awareness programs

  • Authority Relations: Primary contact with supervisory authorities

  • Privacy Impact: Oversight of privacy impact assessments


12.2 EU Representative


While we don't currently have an EU representative, we will appoint one if required by GDPR thresholds.

Appointment Triggers:

  • Regular Monitoring: Assessment of whether EU representative is required

  • Scale Thresholds: Appointment when processing scale requires representation

  • Authority Guidance: Following supervisory authority guidance or requirements

  • Best Practice: Proactive appointment for enhanced user protection


12.3 Privacy Team Contacts

General Privacy Inquiries:

  • Email: privacy@verkapp.com

  • Response Time: Within 72 hours for general privacy questions

  • Scope: Privacy policy questions, data handling concerns, general GDPR inquiries


Rights Request Support:

  • Email: privacy@verkapp.com with "Rights Request" in subject line

  • Processing: Dedicated team for handling GDPR rights requests

  • Support: Assistance with using self-service rights tools

  • Follow-up: Support for complex or multi-part rights requests


Technical Privacy Support:

  • Email: privacy@verkapp.com

  • Scope: Technical questions about data protection measures

  • Expertise: Engineer support for privacy-related technical issues

  • Integration: Privacy aspects of third-party integrations and APIs


CONCLUSION


GDPR compliance is fundamental to how Verk operates.


We're committed to:

  • Protecting Your Rights: Ensuring you have meaningful control over your personal data

  • Transparency: Providing clear, understandable information about data processing

  • Privacy by Design: Building privacy protections into every feature and system

  • Continuous Improvement: Regularly enhancing our privacy practices and protections

  • Responsive Support: Quickly and effectively addressing your privacy concerns


The Verk platform demonstrates that advanced artificial intelligence capabilities and comprehensive privacy protections can be implemented simultaneously in enterprise software systems.


For GDPR-related inquiries or to exercise your data protection rights, contact our Data Protection Officer at dpo@verkapp.com or access the self-service privacy tools in your account settings.


This GDPR Compliance page is effective as of September 23, 2025, and supplements our Privacy Policy and Terms of Service. For the most current information, visit verkapp.com/legal/gdpr

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