Aligned with ISO/IEC 27001 principles
List CRM - Privacy & Data Protection Framework
This page explains how List CRM and Aqary One handle privacy, personal data, and security in a simple format that is easy to read on web and mobile.
1. PRIVACY POLICY
1.1 Introduction
List CRM is a customizable CRM application within the List One platform, designed to enable organizations to manage customer data, workflows, and business processes securely.
This Privacy Policy explains how data is collected, processed, stored, and protected when using List CRM.
1.2 Platform Architecture & Identity
List CRM operates under List One Identity, a centralized identity and access management system that enables:
- Organization registration
- Application subscriptions (CRM, HRMS, Drive, etc.)
- User provisioning and authentication
1.3 Nature of the Service (Important Legal Positioning)
List CRM is a fully customizable system, where organizations control:
- Modules, fields, and layouts
- Workflows and automation rules
- Permissions, roles, and sharing rules
- Data structure and enrichment
👉 Therefore:
- List CRM = Data Processor
- Customer (Company) = Data Controller
1.4 Types of Data Processed
A. Identity & Access Data
- Login credentials
- User roles
B. Business Data (Customer-Controlled)
- Leads, contacts, accounts
- Property or transactional data
- Activities, communications
- Attachments and documents
C. Customization Data
- Custom modules and fields
- Aqary scripts and automation logic
- Workflows, assignment rules
- Dashboards and widgets
D. System Data
- Logs, IP addresses
- Device and browser metadata
- Usage analytics
1.5 Legal Basis for Processing
We process data based on:
- Contractual necessity (service delivery)
- Legitimate interest (security, improvement)
- Legal obligations
- Customer instructions (as Data Processor)
1.6 Data Protection Principles
We adhere to:
- Data minimization
- Purpose limitation
- Accuracy
- Integrity and confidentiality
1.7 Security Measures
- Encryption (TLS + AES-256)
- Role-Based Access Control (RBAC)
- Audit logs & monitoring
- Multi-factor authentication (optional)
- Secure APIs and sandboxed scripting
1.8 Data Retention
- Controlled by the customer
- Retained during active subscription
- Secure deletion upon request or termination
1.9 Sub processors
We may use sub processors for:
- Cloud hosting
- Email delivery
- Analytics
All sub processors are bound by strict data protection obligations.
2. DATA PROCESSING AGREEMENT (DPA)
2.1 Parties
This DPA is between:
- Customer (Data Controller)
- List CRM / List One (Data Processor)
2.2 Scope of Processing
Includes:
- Storage
- Organization
- Structuring
- Automation (workflows, scripts)
- Retrieval and analysis
2.3 Instructions
List CRM processes data only based on customer configuration, including:
- Modules and schemas
- Automation rules
- Access permissions
2.4 Confidentiality
All personnel are bound by strict confidentiality obligations.
2.5 Security Measures
We implement:
- Logical access controls
- Encryption
- Monitoring and logging
- Incident detection and response
2.6 Data Breach Notification
- Notification within 72 hours of confirmed breach
- Includes impact, mitigation, and actions taken
2.7 Data Subject Requests
- Supported via platform tools
- Customer remains responsible for responding
2.8 Data Return & Deletion
Upon termination:
- Data export available
- Secure deletion within defined retention period
4. INFORMATION SECURITY POLICY (ISO-STYLE)
4.1 Security Governance
List CRM follows a structured Information Security Management approach:
- Defined policies and procedures
- Risk-based controls
- Continuous monitoring
4.2 Access Control
- Role-Based Access Control (RBAC)
- Least privilege principle
- Multi-level permission structure
- Group-based access management
4.3 Data Security
- Encryption at rest and in transit
- Logical data isolation per organization
- Backup and recovery mechanisms
4.4 Application Security
- Secure SDLC practices
- Input validation (especially for scripts & custom fields)
- API security controls
- Regular vulnerability assessments
4.5 Operational Security
- Logging and monitoring
- Incident response procedures
- Change management
4.6 Business Continuity
- Disaster recovery planning
- High availability infrastructure
- Data backup strategies
4.7 Customer Responsibilities
Customers are responsible for:
- Proper configuration of permissions
- Lawful data collection
- Secure use of custom scripts and automations
- Compliance with applicable regulations