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Data Protection Addendum

This Data Protection Addendum (“DPA”) is part of the ChannelApe Terms of Service or other underlying agreement between ChannelApe and Customer for ChannelApe’s provision of Services (each, the “Agreement”).  In the event of any conflict between the terms of this DPA and the other terms of this Agreement, this DPA will govern.


  1. In this DPA:
    1. Applicable Law” means all laws, regulations and other legal requirements applicable to either (i) ChannelApe as provider of the Services or (ii) Customer as user of the Services. For example, to the extent applicable, this includes the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”); equivalent requirements in the United Kingdom including the Data Protection Act 2018 and the UK General Data Protection Regulation (“UK Data Protection Law”); the Swiss Federal Act on Data Protection (“Swiss FADP”); the California Consumer Privacy Act, as amended by the California Privacy Rights Act and together with associated regulations (“CCPA”); as well as U.S. state laws laws similar to the CCPA (together with the CCPA, as they become effective, the “U.S. State Privacy Laws,”), such as the Virginia Consumer Data Protection Act; the Colorado Privacy Act and related regulations; the Utah Consumer Privacy Act; the Connecticut Act Concerning Personal Data Privacy and Online Monitoring; the Iowa Consumer Privacy Act; the Indiana Consumer Data Protection Act; and Tennessee Information Protection Act. 
    2. Designated Address” means Customer’s email address for legal notices set forth in the Order Form.
    3. Personal Data” means any information relating to an identified or identifiable individual, within the meaning of the GDPR (regardless of whether the GDPR applies), any information that qualifies as “personal information” under the CCPA (regardless of whether the CCPA applies) and any other information defined as “personal information,” “personal data,” or an analogous term in Applicable Law.  
    4. Personal Data Breach” means the accidental or unlawful destruction, loss, alteration, disclosure or other Processing of, or access to, Personal Data.  
    5. Process” and “Processing” mean any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, creating, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
    6. Standard Contractual Clauses” refers to the clauses issued pursuant to the EU Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, available at http://data.europa.eu/eli/dec_impl/2021/914/oj and completed as described in the “Data Transfers” section below.
    7. Subprocessor” means a subcontractor engaged by ChannelApe for the Processing of Personal Data.
    8. UK SCC Addendum” means the United Kingdom International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (available as of 12 April 2023 at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-data-transfer-agreement-and-guidance/), completed as described in the “Data Transfers” section below.
  2. For ease of reading, some other terms are defined later in the DPA.  Capitalized terms not otherwise defined in the DPA will have the meaning set forth in this Agreement.

Scope, Relationship of the Parties, and Data Use Limitations

  1. This DPA applies to the Personal Data in Customer Data. 
  2. Unless required by Applicable Law, ChannelApe will Process the Personal Data only to (i) provide the Services; and (ii) carry out Customer’s reasonable written instructions that are consistent with this Agreement.  Without limiting the foregoing, ChannelApe:
    1. shall not “sell” the Personal Data, as such term is defined in the U.S. State Privacy Laws (regardless of whether such laws apply);
    2. shall not “share” the Personal Data, as such term is defined in the CCPA (regardless of whether the CCPA applies);
    3. shall not retain, use, or disclose any such data outside of the direct business relationship between Customer and ChannelApe, or for any purpose (including any commercial purpose) other than the limited business purposes specified in this DPA;
    4. shall comply with any applicable restrictions under Applicable Law on combining the Personal Data that ChannelApe receives from, or on behalf of, Customer with Personal Data that ChannelApe receives from, or on behalf of, another person or persons, or that ChannelApe collects from any other interaction between ChannelApe and a data subject;
    5. shall provide the same level of protection for the Personal Data subject to the CCPA as is required under the CCPA; and
    6. hereby certifies that it understands the restrictions and obligations set forth in this DPA and that it will comply with them.
  3. If Applicable Law requires ChannelApe to engage in Processing not permitted by the above, ChannelApe will first inform Customer of the relevant legal requirement, unless the Applicable Law prohibits such notification on important grounds of public interest. ChannelApe will notify Customer as soon as legally permissible if, for any other reason, ChannelApe determines that ChannelApe can no longer meet its obligations under Applicable Law.
  4. Customer has the right to take reasonable and appropriate steps to (a) ensure that ChannelApe is using the Personal Data consistent with Customer’s obligations under Applicable Law, and (b) stop and remediate unauthorized use of the Personal Data.
  5. For the Services, Customer is the “Controller” and ChannelApe is Customer’s “Processor” as such terms are defined in the GDPR (regardless of whether the GDPR applies), and, to the extent the CCPA applies, Customer is the “business” and ChannelApe is Customer’s “service provider” as such terms are defined in the CCPA.  

Confidentiality and Training

  1. ChannelApe will ensure that the persons ChannelApe authorizes to Process the Personal Data are contractually required to maintain the confidentiality of such data. ChannelApe will train relevant employees regarding privacy, confidentiality, and data security.  


  1. ChannelApe will comply with the security obligations of Applicable Law.  ChannelApe will assist Customer in Customer’s compliance with such obligations by implementing technical and organizational measures that comply with Applicable Law and Schedule B.  ChannelApe may make future replacements or updates to the measures, so long as the measures continue to comply with Applicable Law and do not lower the level of security provided for the Personal Data.  


  1. ChannelApe may subcontract the collection or other Processing of Personal Data (i) only in compliance with Applicable Law regarding subprocessing, (ii) only with Customer’s consent and (iii) only if ChannelApe has imposed contractual obligations on the Subprocessor that are substantially the same as, or more restrictive than, those imposed on ChannelApe under this DPA.  
  2. Current Subprocessors are listed at https://www.channelape.com/approved-subprocessors. When any new Subprocessor is engaged, ChannelApe will notify Customer by email to the Designated Address (“Subprocessor Notification”) at least 30 days prior to giving the Subprocessor access to the Personal Data (the “Subprocessor Notification Period”). 
  3. If Customer has any reasonable objection to the new Subprocessor, Customer has 20 days from the date of the Subprocessor Notification to email ChannelApe at privacy@channelape.com, explaining in reasonable detail the basis of the objection and (if Customer desires) Customer’s intent to terminate Customer’s subscription to the Service if it is not resolved to Customer’s satisfaction by the end of the Subprocessor Notification Period.  ChannelApe will give prompt attention to this objection, and, if Customer indicates an intent to terminate and does not withdraw the termination notice in writing to privacy@channelape.com by the end of that period, the termination will take effect at that time.  Promptly after termination, ChannelApe will refund any unused prepaid fees.  Customer is deemed to consent to the new Subprocessor if Customer does not terminate the subscription as set forth above.  
  4. ChannelApe remains liable for its Subprocessors’ acts and omissions to the same extent ChannelApe is liable for its own.

Assistance Responding to Individuals’ Requests to Exercise Rights

  1. If ChannelApe receives a request from an individual or their representative to exercise Personal Data-related rights under Applicable Law (a “Data Subject Request”), such as rights to access, correct, or delete their Personal Data, or a Personal Data-related complaint from an individual or their representative, and the communication identifies Customer, ChannelApe will forward the communication to Customer at the Designated Address:
    1. as soon as commercially practicable; but 
    2. no later than within 72 hours of receipt if the communication arrives via privacy@channelape.com or any other contact method specified in ChannelApe’s then-current publicly available Privacy Policy.
  2. Customer will be responsible for addressing the Data Subject Request, and ChannelApe will provide prompt, reasonable cooperation to Customer in this regard.  

Personal Data Breach Notification 

  1. ChannelApe will comply with the Personal Data Breach-related obligations applicable to it under Applicable Law.  ChannelApe will assist Customer in complying with those applicable to Customer by informing Customer of a confirmed Personal Data Breach without undue delay and in any event within 72 hours of becoming aware and by otherwise complying with this “Personal Data Breach Notification” section of this DPA. 
  2. ChannelApe will provide such notification to Customer at the Designated Address.  
  3. Such notification is not an acknowledgement of fault or responsibility.  The notification will include ChannelApe’s then-current assessment of the following:
    1. The nature of the Personal Data Breach including, where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of Personal Data records concerned;
    2. The likely consequences of the Personal Data Breach; and
    3. Measures taken or proposed to be taken by ChannelApe to address the Personal Data Breach including, where applicable, measures to mitigate its possible adverse effects.
  4. ChannelApe will provide prompt updates to such information as it becomes available.

Assistance with DPIAs and Consultation with Supervisory Authorities

  1. ChannelApe will provide reasonable assistance to and cooperation with Customer for (i) Customer’s performance of any data protection impact assessment of the Processing or proposed Processing of the Personal Data involving ChannelApe, and (ii) related consultation with supervisory authorities.

Data Return and Destruction

  1. ChannelApe will destroy all Personal Data within 90 days after the termination of this Agreement except to the extent Applicable Law requires storage of the Personal Data.  
  2. In the event of such legally required retention of the Personal Data, (i) ChannelApe will inform Customer as soon as legally permitted, (ii) ChannelApe will retain only Personal Data that it is legally required to retain and will retain it only as long as is legally required, (iii) during the retention period, ChannelApe will refrain from Processing the Personal Data and will continue to comply with this DPA with respect to the Personal Data, to the extent legally permitted, and (iv) ChannelApe will destroy the Personal Data and inform Customer of such destruction as soon as legally permissible.
  3. If requested by Customer within 10 days after the termination of this Agreement, ChannelApe will first return a copy of the Personal Data to Customer in any reasonably requested format before the destruction described above.
  4. ChannelApe will provide certification of the destruction and/or return within 10 days of Customer’s written request.  

Compliance Verification and Audits

  1. ChannelApe will make available to Customer all information reasonably necessary to demonstrate compliance with this DPA and, subject to Section 26 below, allow for and contribute to audits of such compliance, including inspections, conducted by an independent third-party auditor mutually agreed upon by the parties, who shall be subject to a confidentiality and security agreement acceptable to ChannelApe. Such audit or inspection will take place not more than once per calendar year.  It shall be conducted at Customer’s expense during normal business hours, at a mutually agreed date, in a manner that will not interfere with ChannelApe’s normal business activities. ChannelApe shall not be required to provide access to its systems, or to any information the disclosure of which could compromise or pose risk to the security, confidentiality, or integrity of ChannelApe’s systems or data, or to any information sought for any reason other than good faith fulfillment of a legal obligation to audit compliance under this DPA.  Customer will promptly provide ChannelApe with a copy of all drafts of the audit report, which shall be confidential information of ChannelApe.  
  2. If the requested audit scope is addressed in an ISO or other audit report issued by a third-party auditor within the prior twelve months and ChannelApe provides such report to Customer and confirms in writing that there are no known material changes in the controls audited, Customer will accept the findings presented in the report in lieu of requesting an audit of the same controls covered by the report.

Data Transfers

  1. Customer authorizes ChannelApe to make international transfers of the Personal Data only if (i) Applicable Law for such transfers is respected and (ii) the transfer is otherwise permitted by this DPA.
  2. To the extent legally required, the Standard Contractual Clauses form part of this DPA and take precedence over the rest of this DPA to the extent of any conflict, and, except as set forth in Sections 29 or 30, they will be deemed completed as follows:
    1. Customer, the exporter, acts as a controller and ChannelApe, the importer, acts as Customer’s processor with respect to the Personal Data subject to the Standard Contractual Clauses, and its Module 2 applies.  Their contact information is set forth in Schedule A.
    2. Clause 7 (the optional docking clause) is included.
    3. Under Clause 9 (Use of sub-processors), the parties select Option 2 (General written authorization). The initial list of sub-processors is set forth at https://www.channelape.com/approved-subprocessors, and ChannelApe shall update that list at least 30 days in advance of any intended additions or replacements of sub-processors.
    4. Under Clause 11 (Redress), the optional requirement that data subjects be permitted to lodge a complaint with an independent dispute resolution body does not apply.
    5. Under Clause 17 (Governing law), the parties choose Option 1 (the law of an EU Member State that allows for third-party beneficiary rights).  The parties select the law of Ireland.
    6. Under Clause 18 (Choice of forum and jurisdiction), the parties select the courts of Ireland.
    7. Annexes I and II of the Standard Contractual Clauses are set forth in Schedule A of the DPA. 
    8. Annex III of the Standard Contractual Clauses (List of subprocessors) is inapplicable.
  1. With respect to Personal Data for which UK Data Protection Law governs the transfer, to the extent legally required, the UK SCC Addendum forms part of this DPA and takes precedence over the rest of this DPA to the extent of any conflict and shall be deemed completed as follows (with capitalized terms not defined elsewhere having the definition set forth in the UK SCC Addendum):
    1. Table 1 of the UK SCC Addendum: The Parties, their details, and their contacts are those set forth in Schedule A.
    2. Table 2 of the UK SCC Addendum: the “Approved EU Standard Contractual Clauses” shall be the Standard Contractual Clauses as set forth in Section 28 of this DPA. 
    3. Table 3 of the UK SCC Addendum: Annexes I(A), I(B), and II are in Schedule A of the DPA, and Annex III is at https://www.channelape.com/approved-subprocessors.
    4. Table 4 of the UK SCC Addendum: neither party may exercise the right set forth in Section 19 of the UK SCC Addendum.
  1. With respect to Personal Data for which the Swiss FADP governs the transfer, the Standard Contractual Clauses shall be deemed to have the following differences to the extent required by the Swiss FADP:
    1. References to the GDPR in the Standard Contractual Clauses are to be understood as references to the Swiss FADP insofar as the data transfers are subject exclusively to the Swiss FADP and not to the GDPR.
    2. The term “member state” in Standard Contractual Clauses shall not be interpreted in such a way as to exclude data subjects in Switzerland from the possibility of suing for their rights in their place of habitual residence (Switzerland) in accordance with Clause 18(c) of the Standard Contractual Clauses. 
    3. References to personal data in the Standard Contractual Clauses also refer to data about identifiable legal entities until the entry into force of revisions to the Swiss FADP that eliminate this broader scope.
    4. Under Annex I(C) of the Standard Contractual Clauses (Competent supervisory authority):
      1. Where the transfer is subject exclusively to the Swiss FADP and not the GDPR, the supervisory authority is the Swiss Federal Data Protection and Information Commissioner.
      2. Where the transfer is subject to both the Swiss FADP and the GDPR, the supervisory authority is the Swiss Federal Data Protection and Information Commissioner insofar as the transfer is governed by the Swiss FADP, and the supervisory authority is as set forth in the Standard Contractual Clauses insofar as the transfer is governed by the GDPR.


  1. This DPA survives termination of this Agreement for so long as ChannelApe continues to Process the Personal Data.

Schedule A to DPA

Annexes I and II of the Standard Contractual Clauses



MODULE TWO: Transfer controller to processor

Data exporter(s):  [Identity and contact details of the data exporter(s) and, where applicable, of its/their data protection officer and/or representative in the European Union] 

  1. Name: Customer, as specified in the Agreement.

Address: 2810 N Church St, PMB 82108, Wilmington, DE, 19802

Contact person’s name, position and contact details: Michael Averto, CEO, privacy@channelape.com

Activities relevant to the data transferred under these Clauses: The importer will perform the Services.

Signature and date: The Parties are deemed to have signed this Annex I by signing the Agreement.

Role (controller/processor): Processor

Data importer(s): [Identity and contact details of the data importer(s), including any contact person with responsibility for data protection] 

  1. Name: ChannelApe, Inc.

Address: 2810 N Church St, PMB 82108, Wilmington, DE, 19802

Contact person’s name, position and contact details: Michael Averto, CEO, privacy@channelape.com

Activities relevant to the data transferred under these Clauses: The importer will perform the Services.

Signature and date: The Parties are deemed to have signed this Annex I by signing the Agreement.

Role (controller/processor): Processor


MODULE TWO: Transfer controller to processor

Categories of data subjects whose personal data is transferred:  Individuals who purchase products from Customer, and individuals to whom such products are shipped.

Categories of personal data transferred: Contact details, and order details.

Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures: No sensitive data will be transferred.

The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis): On a continuous basis.

Nature of the processing:  Receipt, transmission, organization, display, and storage of data.

Purpose(s) of the data transfer and further processing:  Inventory and order management platform, as described in more detail in the Order Form.

The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period: Until 90 days after the exporter no longer is engaging the importer to provide the Services, as described in the DPA.

For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing: Operation of an inventory and order management platform, as described in more detail in the Order Form for the duration described in the DPA.  The purposes of transfers to specific subprocessors in support of that activity are set forth at https://www.channelape.com/approved-subprocessors.


MODULE TWO: Transfer controller to processor

Identify the competent supervisory authority/ies in accordance with Clause 13:

The parties shall follow the rules for identifying such authority under Clause 13 and, to the extent legally permissible, select the Irish Data Protection Commission.


Description of the technical and organisational measures implemented by the data importer(s) (including any relevant certifications) to ensure an appropriate level of security, taking into account the nature, scope, context and purpose of the processing, and the risks for the rights and freedoms of natural persons.

See Schedule B immediately below.

Schedule B to DPA

Information Security Addendum

  1. Overview

This Information Security Policy is intended to protect ChannelApe’s employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.

Internet/Intranet/Extranet-related systems, including but not limited to computer equipment, software, operating systems, storage media, network accounts providing electronic mail, web browsing, and file transfers, are the property of ChannelApe . These systems are to be used for business purposes in serving the interests of the company, and of our clients and customers in the course of normal operations.

Effective security is a team effort involving the participation and support of every ChannelApe employee or contractor who deals with information and/or information systems. It is the responsibility of every team member to read and understand this policy, and to conduct their activities accordingly.

  1. Purpose 

The purpose of this policy is to communicate our information security policies and outline the acceptable use and protection of ChannelApe’s information and assets. These rules are in place to protect customers, employees, and ChannelApe. Inappropriate use exposes ChannelApe to risks including virus attacks, compromise of network systems and services, and legal and compliance issues.

The ChannelApe “Information Security Policy” is comprised of this policy and all ChannelApe policies referenced and/or linked within this document.

  1. Scope 

This policy applies to the use of information, electronic and computing devices, and network resources to conduct ChannelApe business or interact with internal networks and business systems, whether owned or leased by ChannelApe, the employee, or a third party. All employees, contractors, consultants, temporary, and other workers at ChannelApe and its subsidiaries are responsible for exercising good judgment regarding appropriate use of information, electronic devices, and network resources in accordance with ChannelApe policies and standards, and local laws and regulations.

This policy applies to employees, contractors, consultants, temporaries, and other workers at ChannelApe, including all personnel affiliated with third parties. This policy applies to all ChannelApe-controlled company and customer data as well as all equipment, systems, networks and software owned or leased by ChannelApe.

  1. Security Incident Reporting

All users are required to report known or suspected security events or incidents, including policy violations and observed security weaknesses. Incidents should be reported immediately or as soon as possible by emailing privacy@channelape.com.

In your email please describe the incident or observation along with any relevant details. 

  1. Mobile Device Policy

All end-user devices (e.g., mobile phones, tablets, laptops, desktops) must comply with this policy. Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain malware.

System level and user level passwords must comply with the Access Control Policy. Providing access to another individual, either deliberately or through failure to secure its access, is prohibited.

All end-user, personal (BYOD) or company owned devices used to access ChannelApe information systems (i.e. email) must adhere to the following rules and requirements: 

  • Devices must be encrypted with a password-protected screensaver or screen lock after 5 minutes
  • Devices must be locked whenever left unattended
  • Users must report any suspected misuse or theft of a mobile device immediately to ChannelApe’s IT Department
  • Confidential information must not be stored on mobile devices or USB drives (this does not apply to business contact information, e.g., names, phone numbers, and email addresses)
  • Any mobile device used to access company email must not be shared with any other person
  • Upon termination users agree to return all company owned devices and delete all company information and accounts from any personal devices 
  1. Remote Access Policy

Laptops and other computer resources that are used to access the ChannelApe network must conform to the security requirements outlined inChannelApe’s Information Security Policies and adhere to the following standards:

  • To ensure mobile devices do not connect a compromised device to the company network, Antivirus policies require the use and enforcement of client-side antivirus software
  • Users must not connect to any outside network without a secure, up-to-date software firewall configured on the mobile computer.
  • Users are prohibited from changing or disabling any organizational security controls such as personal firewalls, antivirus software on systems used to access ChannelApe resources
  • Use of remote access software and/or services (e.g., VPN client) is allowable as long as it is provided by the company and configured for multifactor authentication (MFA)
  • Unauthorized remote access technologies may not be used or installed on any ChannelApe system
  • Users should use a VPN when transmitting confidential information on public Wi-Fi
  • If you access from a public computer (e.g., business center, hotel, etc.), log out of session and don’t save anything. Don’t check “remember me, collect all printed materials and delete downloaded files (generally is discouraged)
  1. Acceptable Use Policy

ChannelApe proprietary and customer information stored on electronic and computing devices whether owned or leased by ChannelApe, the employee or a third party, remains the sole property of ChannelApe for the purposes of this policy.  Employees and contractors must ensure through legal or technical means that proprietary information is protected in accordance with the Data Management Policy. The use of Google Drive for business file storage is required for users of laptops or company issued devices. Storing important documents on the file share is how you “backup” your laptop.

You have a responsibility to promptly report the theft, loss, or unauthorized disclosure of ChannelApe proprietary information. You may access, use or share ChannelApe proprietary information only to the extent it is authorized and necessary to fulfill your assigned job duties. Employees are responsible for exercising good judgment regarding the reasonableness of personal use of company-provided devices.

For security and network maintenance purposes, authorized individuals within ChannelApe may monitor equipment, systems and network traffic at any time.

ChannelApe reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy.

Unacceptable Use 

The following activities are, in general, prohibited. Employees may be exempted from these restrictions during the course of their legitimate job responsibilities. Under no circumstances is an employee of ChannelApe authorized to engage in any activity that is illegal under local, state, federal or international law while utilizing ChannelApe-owned resources. The list below is not exhaustive, but attempts to provide a framework for activities which fall into the category of unacceptable use.

The following activities are strictly prohibited, with no exceptions: 

  1. Violations of the rights of any person or company protected by copyright, trade secret, patent, or other intellectual property, or similar laws or regulations, including, but not limited to, the installation or distribution of "pirated" or other software products that are not appropriately licensed for use by ChannelApe. 
  2. Unauthorized copying of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books, or other copyrighted sources, copyrighted music, and the installation of any copyrighted software for which ChannelApe or the end user does not have an active license.
  3. Accessing data, a server, or an account for any purpose other than conducting ChannelApe business, even if you have authorized access, is prohibited.
  4. Exporting software, technical information, encryption software, or technology, in violation of international or regional export control laws, is illegal. The appropriate management should be consulted prior to export of any material that is in question.
  5. Introduction of malicious programs into the network or systems (e.g., viruses, worms, Trojan horses, e-mail bombs, etc.).
  6. Revealing your account password to others or allowing use of your account by others. This includes family and other household members when work is being done at home.
  7. Using a ChannelApe computing asset to actively engage in procuring or transmitting material that is in violation of sexual harassment or hostile workplace laws.
  8. Making fraudulent offers of products, items, or services originating from any ChannelApe account.
  9. Making statements about warranty, expressly or implied, unless it is a part of normal job duties.
  10. Effecting security breaches or disruptions of network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient, or logging into a server or account that the employee is not expressly authorized to access, unless these duties are within the scope of regular duties. For purposes of this section, "disruption" includes, but is not limited to, network sniffing, pinged floods, packet spoofing, denial of service, and forged routing information for malicious purposes.
  11. Port scanning or security scanning is expressly prohibited unless prior notification to the ChannelApe engineering team is made.
  12. Executing any form of network monitoring which will intercept data not intended for the employee's host, unless this activity is a part of the employee's normal job/duty.
  13. Circumventing user authentication or security of any host, network, or account.
  14. Introducing honeypots, honeynets, or similar technology on the ChannelApe network.
  15. Interfering with or denying service to any user other than the employee's host (for example, denial of service attack).
  16. Using any program/script/command, or sending messages of any kind, with the intent to interfere with, or disable, a user's session, via any means.
  17. Providing information about, or lists of: ChannelApe employees, contractors, partners, or customers to parties outside ChannelApe without authorization.

Additional Policies and Procedures Incorporated by Reference

When using company resources to access and use the Internet, users must realize they represent the company and act accordingly.

The following activities are strictly prohibited, with no exceptions:

  1. Sending unsolicited email messages, including the sending of "junk mail", or other advertising material to individuals who did not specifically request such material (email spam).
  2. Any form of harassment via email, telephone, or texting, whether through language, frequency, or size of messages.
  3. Unauthorized use, or forging, of email header information.
  4. Solicitation of email for any other email address, other than that of the poster's account, with the intent to harass or to collect replies.
  5. Creating or forwarding "chain letters", "Ponzi", or other "pyramid" schemes of any type. 
  6. Use of unsolicited email originating from within ChannelApe networks or other service providers on behalf of, or to advertise, any service hosted by ChannelApe or connected via ChannelApe’s network.
  1. Additional Policies and Procedures Incorporated by Reference



Access Control Policy

To limit access to information and information processing systems, networks, and facilities to authorized parties in accordance with business objectives.

Asset Management Policy

To identify organizational assets and define appropriate protection responsibilities. 

Business Continuity & Disaster Recovery Plan

To prepare ChannelApe in the event of extended service outages caused by factors beyond our control (e.g., natural disasters, man-made events), and to restore services to the widest extent possible in a minimum time frame.

Cryptography Policy

To ensure proper and effective use of cryptography to protect the confidentiality, authenticity and/or integrity of information.

Data Management Policy

To ensure that information is classified and protected in accordance with its importance to the organization.

Human Resources Policy

To ensure that employees and contractors meet security requirements, understand their responsibilities, and are suitable for their roles.

Incident Response Plan

Policy and procedures for suspected or confirmed information security incidents.

Operations Security Policy

To ensure the correct and secure operation of information processing systems and facilities.

Physical Security Policy

To prevent unauthorized physical access or damage to the organization’s information and information processing facilities.

Risk Management Policy

To define the process for assessing and managing ChannelApe’s information security risks in order to achieve the company’s business and information security objectives.

Secure Development Policy

To ensure that information security is designed and implemented within the development lifecycle for applications and information systems.

Third-Party Management Policy

To ensure protection of the organization's data and assets that are shared with, accessible to, or managed by suppliers, including external parties or third-party organizations such as service providers, vendors, and customers, and to maintain an agreed level of information security and service delivery in line with supplier agreements.

Policy Compliance

ChannelApe will measure and verify compliance to this policy through various methods, including but not limited to, business tool reports, and both internal and external audits.

  1. Exceptions

Requests for an exception to this policy must be submitted to the IT Manager for approval.

  1. Violations & Enforcement

Any known violations of this policy should be reported to the IT Manager. Violations of this policy can result in immediate withdrawal or suspension of system and network privileges and/or disciplinary action in accordance with company procedures up to and including termination of employment.

Last Updated: June 6, 2023