On this page, Kladero provides its customers with the information required in accordance with Article 28 of Regulation (EU) 2023/2854 (“Data Act”) and keeps this information up to date.
1. Jurisdiction of the ICT infrastructure used
Kladero’s central application infrastructure, including the application servers, databases and permanent storage of customer data, is hosted by Hetzner Online GmbH in data centers in Germany.
Kladero also uses third-party infrastructure services for network security, traffic management, performance optimization and related edge services. These services may be provided via globally distributed infrastructures.
The primary hosting infrastructure and the infrastructure used for permanent storage of customer data are therefore located within the European Union. Certain supplementary processing operations related to network and security services may, however, be carried out via infrastructures outside the European Union. This is done in compliance with the applicable data protection agreements and safeguards.
2. Technical, organisational and contractual measures
Kladero has implemented a multi-layered protection framework comprising technical, organisational and contractual measures to prevent international governmental access to and international governmental transfer of non-personal data held in the Union, to the extent that such access or transfer would conflict with Union law or the national law of the relevant Member State.
2.1 Technical measures
At the technical level, Kladero consistently secures both the infrastructure and the data themselves so that access is made more difficult or prevented at system level:
- 1) Encryption of data both in transit and at rest in accordance with the state of the art
- 2) Granular access and authorization controls that strictly limit access to data to authorized persons and systems for which such access is required to provide the services
- 3) No dependency on data centers or backup locations outside the European Union for the storage and backup of data
2.2 Organisational and contractual measures
In addition, Kladero uses organisational processes and contractual arrangements with subcontractors to ensure that government authority requests are carefully reviewed from a legal perspective and, where necessary, rejected or challenged:
- 1) Engagement of hosting and storage infrastructure providers for the permanent storage of customer data with server locations within the European Union (currently: Hetzner Online GmbH, Germany)
- 2) Contractual assurances from the providers used by Kladero for the hosting and storage infrastructure that they will not disclose data to third-country authorities unless there is a legal basis for doing so under Union law or the national law of a Member State
- 3) Regular review and updating of these measures in light of new legal and technical developments