zulip/templates/zerver/help/gdpr-compliance.md

GDPR Compliance

This page covers how Zulip interacts with the EU's landmark GDPR legislation; you can read the Zulip Cloud privacy policy for our general privacy policies.

What is GDPR?

The General Data Protection Regulation is a wide-ranging law designed to protect the privacy of individuals in the European Union (EU) and give them control over how their personal data is collected, processed, and used. The law applies to any company that collects or processes the data of European consumers.

Controllers and Processors

There are two key relationships that are defined in the GDPR. As a customer of Zulip Cloud, you operate as the controller when using our products and services. You have the responsibility for ensuring that the personal data you are collecting is being processed in a lawful manner as described above and that you are using processors, such as Zulip Cloud, that are committed to handling the data in a compliant manner.

Zulip Cloud is considered a data processor. We act on the instructions of the controller (you). Similar to controllers, processors are expected to enumerate how they handle personal data, which we have outlined in this document and the legal documents listed below. As a processor, we rely on our customers to ensure that there is a lawful basis for processing.

Processors may leverage other third-parties in the processing of personal data. These entities are commonly referred to as sub-processors. For example, Kandra Labs leverages cloud service providers like Amazon Web Services and Mailgun to host Zulip Cloud.

How Zulip Supports GDPR Compliance

We’re committed to the compliance of all parties including you, third-parties, and us.

To deliver the Zulip Cloud service, Kandra Labs, Inc. acts as a compliant data processor, with each of our customers acting as the data controller. Kandra Labs receives personal data from our customers in the context of providing our Zulip Cloud team chat services to the customer.

Kandra Labs also acts as a data processor to deliver the Mobile Push Notification Service, which uses the same hosting infrastructure and terms of service as Zulip Cloud.

The on-premises section of this page discusses how the Zulip on-premises software works in relation to GDPR compliance.

Zulip Cloud's subprocessors

To support delivery of our Services, Kandra Labs, Inc may engage and use data processors with access to certain Customer Data (each, a "Subprocessor"). This section provides important information about the identity, location and role of each Subprocessor. Terms used on this page but not defined have the meaning set forth in Zulip's Terms of Service or superseding written agreement between Customer and Kandra Labs (the "Agreement").

Third Parties

Zulip currently uses third party Subprocessors to provide infrastructure services, and to help us provide customer support and email notifications. Prior to engaging any third party Subprocessor, we perform diligence to evaluate their privacy, security and confidentiality practices.

Subprocessors

Zulip Cloud may use the following Subprocessors to host Customer Data or provide infrastructure that helps with delivery and operation of our Services:

• Amazon Web Services, Inc. for cloud infrastructure.
• Digital Ocean, Inc. for cloud infrastructure.
• Front, Inc. for customer support.
• Google Inc. for cloud infrastructure and services.
• Mailchimp, Inc. for email processing.
• Mailgun, Inc. for email processing.
• RackSpace, Inc. for cloud infrastructure for our Zephyr mirroring service.
• Sentry, Inc. for error tracking.
• Stripe, Inc. for payment processing.

GDPR compliance with Zulip Cloud

The following features of Zulip are useful to know about when responding to a request from one of your users in relation to the GDPR:

• A Zulip user can change their profile information, delete their messages, uploaded files, etc., directly within the Zulip webapp.
• You can use the organization users panel to deactivate users, edit or delete their account details, etc.
• For complying with access requests, you'll want to start with that user's Zulip profile, which you can access from the right sidebar.
• The Zulip Cloud export supports exporting all the data related to a Zulip user or organization.
• The Zulip REST API lets you automate your processes for handling GDPR requests.

Contact support@zulip.com for any assistance related to this topic.

GDPR compliance on-premises

Compliance is often simpler when running software on-premises, since you can have complete control over how your organization uses the data you collect.

In addition to the features described above that are available in Zulip Cloud (which are also available on-premises), the following tools may be useful:

• The Zulip server comes with a command-line tool, manage.py export_single_user, which is a variant of the main server export tool, that exports a single Zulip user's account details, preferences, stream subscriptions, and message history in a structured JSON format.
• The Django management shell (manage.py shell) and database shell (manage.py dbshell) allows you to query, access, edit, and delete data directly.

There's a lot more that goes into GDPR compliance, including securing your server infrastructure responsibly, internal policies around access, logging, and backups, etc. If you need detailed guidance, we recommend contacting support@zulip.com; our paid support contracts include assistance with understanding GDPR compliance with Zulip.