Data
security

1. Principles

• Least privilege: every access is justified by an actual responsibility and limited to what is necessary.
• Defence in depth: no single measure is considered sufficient.
• Privacy by design: separation of scopes and data minimisation are built into the product design, in line with Art. 7 FADP.
• Traceability: significant actions are logged so that they can be reconstructed.

This page describes the measures as at the update date shown. It is updated when the architecture changes. It forms an integral part of the data processing agreement: any change that would significantly lower the level of protection is notified sixty (60) days in advance, under the conditions of that agreement. NETZERO SWISS AG does not currently claim any information security management system certification.

2. Infrastructure

• hosting on dedicated infrastructure provided by OVH SAS (OVHcloud), in France;
• a proxy server is the only public entry point; the application only listens on the local interface and is never exposed directly;
• supervised application processes, automatic restart and service availability monitoring;
• separate development, test and production environments; no production data is used in development without prior anonymisation;
• system and dependency security updates applied according to their criticality.

3. Encryption

• all public traffic encrypted with TLS, with automatically renewed certificates and permanent redirection of unencrypted traffic;
• backups encrypted at rest;
• application secrets kept outside the code repository, in restricted-access environment files;
• passwords stored only as hashes computed with a key derivation function of configurable cost.

4. Segregation

The platform separates scopes at four levels: organisation, site and activity, role, assignment. Each organisation keeps its own space, rules and history. Read and write requests are filtered by the user’s scope, whatever interface is used, including the programming interfaces.

5. Access management

• named accounts; sharing credentials is prohibited;
• rights assigned by role, reviewed periodically and withdrawn immediately when an employee leaves or changes role;
• technical administration access reserved to a small number of identified people, protected by strong authentication and logged;
• support access to a customer’s data only when needed to handle a request, and traceably.

6. Logging

Logins, changes to rights, significant actions on assignments and proofs, and administration operations are logged with timestamp and author. Logs are kept for twelve months, protected against modification and accessible only to authorised people.

7. Backups

• daily encrypted backups, each kept for thirty-five (35) days from its creation;
• storage on a medium separate from production;
• maximum tolerable data loss objective: 24 hours;
• recovery time objective after a major incident: 8 business hours;
• periodic, documented restore tests.

8. Development and operations

• review of changes before release to production;
• automated checks: typing, static analysis, regression tests on critical journeys;
• monitoring of known dependency vulnerabilities and updates according to criticality;
• reversible deployments, with a documented rollback procedure;
• no secrets in the code repository.

9. Incident management

Every suspicious event is qualified, contained, analysed for root cause and handled with a documented remediation plan. Incidents affecting availability are communicated to the customers concerned, with regular status updates until service is restored.

In the event of a data security breach, NETZERO SWISS AG informs the customer without undue delay and provides the information needed for the notification required by Art. 24 FADP or Art. 33 GDPR, as described on the Data processing page.

10. Reporting a vulnerability

Responsible reports are welcome. Send to info@netzeroswiss.ch a description of the vulnerability, the steps to reproduce it and the estimated impact.

• acknowledgement within three (3) business days;
• status update within fifteen (15) business days;
• coordinated publication or disclosure after the fix, crediting the reporter if they wish.

NETZERO SWISS AG will take no action against anyone who reports a vulnerability in good faith, provided they have not accessed third-party data beyond what is needed to demonstrate it, degraded the service, or disclosed the flaw before it was fixed. Destructive testing, denial of service and social engineering are excluded from this framework.

11. Shared responsibilities