Enterprise Privacy Policy
Enterprise-Grade Data Protection
This privacy policy demonstrates our commitment to the highest standards of data protection, security, and privacy for enterprise clients. We exceed industry requirements to ensure your trust.
Last updated: August 22, 2025 | Effective Date: August 22, 2025
1. Executive Summary & Commitment
Our Privacy Pledge:
COBOL Pro ("Company," "we," "our," or "us") is committed to maintaining the highest standards of data privacy, security, and transparency. We understand that enterprise clients entrust us with their most valuable digital assets—their legacy COBOL systems and business-critical data. This commitment extends beyond compliance to establishing trust through demonstrable security practices, transparent operations, and unwavering respect for data sovereignty.
This Privacy Policy governs the collection, processing, storage, and protection of all personal data and proprietary information processed through our COBOL modernization platform. We adhere to the most stringent international privacy standards including GDPR, CCPA, SOX, HIPAA, and other applicable regulatory frameworks.
2. Data Classification & Collection Framework
2.1 Enterprise Data Categories
Personally Identifiable Information (PII)
- • Account credentials and authentication data
- • Contact information (name, email, phone)
- • Organizational details and role information
- • Payment and billing information
Proprietary Business Data
- • COBOL source code and applications
- • System architectures and configurations
- • Business logic and proprietary algorithms
- • Database schemas and data structures
2.2 Technical & Operational Data
- System Telemetry: Performance metrics, error logs, system diagnostics (anonymized)
- Usage Analytics: Feature utilization, platform interaction patterns (aggregated)
- Security Monitoring: Access logs, authentication attempts, security events
- Network Data: IP addresses, device identifiers, browser information (encrypted)
Data We Never Collect:
We do not collect: Social Security numbers, financial account details, health records, biometric data, location tracking, personal communications unrelated to service delivery, or any data not explicitly required for service provision.
3. Legal Basis & Purpose Limitation
3.1 Processing Justification
| Data Category | Legal Basis | Specific Purpose |
|---|---|---|
| Account Data | Contractual Necessity | Service delivery and authentication |
| COBOL Code | Legitimate Interest | Code analysis and documentation generation |
| Usage Analytics | Legitimate Interest | Service improvement and optimization |
| Security Logs | Legal Obligation | Security monitoring and compliance |
4. Enterprise Security Architecture
4.1 Zero-Trust Security Model
Encryption at Rest
AES-256 encryption for all stored data with hardware security modules (HSMs) for key management
Encryption in Transit
TLS 1.3 with perfect forward secrecy for all data transmissions and API communications
Encryption in Processing
Homomorphic encryption and secure enclaves for code analysis without decryption
4.2 Access Controls & Authentication
- Multi-Factor Authentication (MFA): Mandatory for all user accounts with hardware token support
- Role-Based Access Control (RBAC): Granular permissions with principle of least privilege
- Just-In-Time Access: Temporary elevated permissions with full audit trails
- Single Sign-On (SSO): SAML 2.0 and OpenID Connect integration with enterprise identity providers
- API Security: OAuth 2.0, rate limiting, and cryptographic request signing
4.3 Infrastructure Security
- Cloud Security: SOC 2 Type II certified infrastructure with AWS/Azure enterprise security features
- Network Segmentation: Isolated processing environments with micro-segmentation
- Intrusion Detection: AI-powered threat detection with 24/7 security operations center
- Vulnerability Management: Continuous security scanning with automated patch management
- Data Loss Prevention: Advanced DLP controls with real-time monitoring and alerting
5. Data Sovereignty & Processing Locations
Data Residency Guarantee
Enterprise clients maintain full control over data location. We offer region-specific processing with data residency guarantees in US, EU, UK, Canada, and other sovereign territories as required.
5.1 Processing Locations
- Primary Regions: United States (Virginia, Oregon), European Union (Ireland, Germany)
- Data Centers: ISO 27001, SOC 2 certified facilities with physical security controls
- Cross-Border Transfers: Standard Contractual Clauses (SCCs) and adequacy decisions
- Government Access: No data access provided except under valid legal process with client notification
5.2 Data Localization Options
- Dedicated regional instances for regulated industries
- On-premises deployment options for maximum control
- Hybrid cloud configurations with customer-managed encryption keys
- Air-gapped processing environments for highly sensitive workloads
6. Data Retention & Lifecycle Management
| Data Type | Retention Period | Deletion Method |
|---|---|---|
| COBOL Source Code | Duration of contract + 90 days | Cryptographic erasure |
| Generated Documentation | Duration of contract + 90 days | Secure deletion (DoD 5220.22-M) |
| Account Information | Contract + 7 years (legal requirement) | Multi-pass overwriting |
| Usage Analytics | 2 years (anonymized after 90 days) | Automated purging |
| Security Logs | 7 years (compliance requirement) | Secure archival then destruction |
Right to be Forgotten
Upon request, we will delete all personal data within 30 days, except where retention is required by law. Deletion certificates provided upon completion.
7. Third-Party Relationships & Data Sharing
7.1 Service Providers & Subprocessors
We maintain a limited list of carefully vetted subprocessors, all bound by Data Processing Agreements (DPAs) with equivalent privacy protections:
- Cloud Infrastructure: AWS, Microsoft Azure (enterprise agreements with BAAs)
- Security Monitoring: SOC-certified security providers for 24/7 monitoring
- Authentication: Enterprise identity providers (customer-controlled)
- Analytics: Privacy-focused analytics with data minimization
7.2 Data Sharing Restrictions
Absolute Prohibitions:
- • No sale, licensing, or commercialization of client data
- • No use of proprietary code for AI training without explicit consent
- • No sharing with competitors, marketing partners, or data brokers
- • No cross-client data exposure or co-mingling
8. Individual Rights & Enterprise Controls
8.1 Individual Data Subject Rights (GDPR Article 12-23)
Comprehensive data reports within 30 days
Data correction and update mechanisms
Complete data deletion with verification
Structured data export in standard formats
Processing limitation controls
Opt-out mechanisms for legitimate interests
Human review of automated processing
Supervisory authority contact information
8.2 Enterprise Admin Controls
- Data Subject Request Management: Centralized portal for handling user requests
- Consent Management: Granular consent controls with audit trails
- Data Governance Dashboard: Real-time visibility into data processing activities
- Compliance Reporting: Automated reports for regulatory requirements
9. Incident Response & Breach Notification
9.1 Incident Response Framework
72-Hour Breach Notification Guarantee
We will notify affected clients and relevant supervisory authorities within 72 hours of discovering any personal data breach, as required by GDPR Article 33.
Detection & Containment
Investigation & Assessment
Notification & Reporting
9.2 Post-Incident Support
- Dedicated incident response team with 24/7 availability
- Forensic analysis and root cause determination
- Remediation planning and implementation
- Credit monitoring services for affected individuals (where applicable)
- Regulatory liaison and compliance support
10. Compliance & Certifications
Privacy Regulations
- • GDPR (EU General Data Protection Regulation)
- • CCPA (California Consumer Privacy Act)
- • PIPEDA (Canada Personal Information Protection)
- • UK Data Protection Act 2018
Security Standards
- • SOC 2 Type II (Security, Availability, Privacy)
- • ISO 27001 (Information Security Management)
- • NIST Cybersecurity Framework
- • FedRAMP (Federal Risk Authorization)
Industry Compliance
- • HIPAA (Healthcare)
- • SOX (Financial Services)
- • PCI DSS (Payment Processing)
- • FISMA (Federal Information Systems)
Continuous Compliance Monitoring
Annual third-party security audits, quarterly compliance assessments, and continuous monitoring ensure ongoing adherence to all applicable standards and regulations.
11. International Data Transfers
11.1 Transfer Safeguards
- Adequacy Decisions: Transfers to countries with adequate protection levels
- Standard Contractual Clauses (SCCs): EU-approved contract terms for third-country transfers
- Binding Corporate Rules (BCRs): Internal data protection rules for multinational processing
- Certification Mechanisms: Privacy Shield successor frameworks and equivalent certifications
11.2 Government Access Limitations
Transparency Commitment
We maintain strict policies against providing data access to government entities without valid legal process. Clients will be notified of any data requests unless legally prohibited.
12. Children's Privacy Protection
Age Restrictions: Our services are designed exclusively for enterprise use and are not directed at individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware of such collection, we will delete the information immediately.
13. Privacy by Design & Default
Our privacy program is built on the principle of Privacy by Design:
- Proactive not Reactive: Privacy measures embedded before risks occur
- Privacy as the Default: Maximum privacy protection without user action required
- Full Functionality: Privacy protection without compromising system functionality
- End-to-End Security: Comprehensive protection throughout the data lifecycle
- Visibility and Transparency: Clear privacy practices and data handling procedures
- Respect for User Privacy: User interests prioritized in all system decisions
14. Policy Updates & Communication
We will notify enterprise clients of any material changes to this Privacy Policy at least 30 days prior to implementation through:
- Email notification to primary account contacts
- In-platform notifications and alerts
- Posted updates on our website with change highlights
- Direct communication for changes affecting data processing
Version Control
Previous versions of this Privacy Policy are archived and available upon request. All changes include effective dates and rationale for modifications.
15. Contact Information & Data Protection Authority
Privacy Office
Chief Privacy Officer
Email: privacy@cobolpro.com
Phone: +1 (555) 123-4567
Address: COBOL Pro Inc.
100 Technology Drive
San Francisco, CA 94105
Response Time: 48 hours for inquiries, 30 days for formal requests
Enterprise Support
Enterprise Data Protection Team
Email: enterprise-privacy@cobolpro.com
Phone: +1 (555) 123-4567 ext. 2
24/7 Emergency: +1 (555) 123-EMERGENCY
Dedicated CSM: Available for Enterprise+ plans
Legal Department: legal@cobolpro.com
Supervisory Authority Contact (EU)
If you are located in the European Union and have concerns about our data processing that cannot be resolved directly with us, you have the right to lodge a complaint with your local supervisory authority.
Lead Supervisory Authority: Irish Data Protection Commission (DPC)
Email: info@dataprotection.ie | Phone: +353 (0)761 104 800
Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
16. Glossary of Terms
Enterprise Trust Commitment
At COBOL Pro, we understand that trust is earned through consistent action, not promises. This comprehensive privacy policy demonstrates our unwavering commitment to protecting your enterprise data with the highest standards of security, privacy, and reliability. Your trust is our most valuable asset, and we work every day to honor it.
Policy Version: 2.0 | Last Reviewed: August 2025 |Next Review: February 2026