Amazon Data Protection Policy

TGL Properties, LLC DBA TGL Direct (TGL Direct) Data Protection Policy w/Personally Identifiable Information (PII)

Data Protection Policy

The Data Protection Policy ("DPP") governs the receipt, storage, usage, transfer, and disposal of Information, including the data vended and retrieved through the Amazon Services API (including the Marketplace Web Service API). This policy is applicable to all systems that store, process, or otherwise handle data vended and retrieved from the Amazon Services API. This Policy supplements the Amazon Services API Developer Agreement and the Acceptable Use Policy. Failure to comply may result in suspension or termination of Amazon Services API access.

1. General Security Requirements

Consistent with industry-leading security, Developers will maintain physical, administrative, and technical safeguards, and other security measures (i) to maintain the security and confidentiality of Information accessed, collected, used, stored, or transmitted by a Developer, and (ii) to protect that Information from known or reasonably anticipated threats or hazards to its security and integrity, accidental loss, alteration, disclosure, and all other unlawful forms of processing. Without limitation, the Developer will comply with the following requirements: 

1.1 Network Protection. TGL Direct's network protection controls including network firewalls and network access control lists to deny access to unauthorized IP addresses. TGL Direct uses network segmentation, anti-virus and anti-malware software on end-user devices. TGL Direct restrict public access only to approved users and carry out data protection and IT security training for everyone with system access. 
 
1.2 Access Management. TGL Direct establish a formal user access registration process to assign access rights for all user types and services by ensuring that a unique ID is assigned to each person with computer access to Information. TGL Direct not create or use generic, shared, or default login credentials or user accounts and prevent user accounts from being shared. TGL Direct implement baselining mechanisms to ensure that at all times only the required user accounts access Information. TGL Direct restrict employees and contractors from storing Information on personal devices. Developers will maintain and enforce "account lockout" by detecting anomalous usage patterns and log-in attempts, and disabling accounts with access to Information. TGL Direct review the list of people and services with access to Information at least quarterly. TGL Direct ensure that access is disabled and/or removed within 24 hours for terminated employees. 
 
1.3 Least Privilege Principle. TGL Direct implement fine-grained access control mechanisms to allow granting rights to any party using the Application and the Application's authorized operators following the principle of least privilege. Access to Information must be granted on a "need-to-know" basis. 
 
1.4 Credential Management. TGL Direct establish minimum password requirements for personnel and systems with access to Information. Password requirements must be a minimum of twelve (12) characters, not include any part of the user’s name, mix of upper-case letters, lower-case letters, numbers, and special characters, including minimum requirements for each. TGL Direct establish a minimum password age of 1-day and a maximum 365-day password expiration for all users. TGL Direct ensure that Multi-Factor Authentication (MFA) is required for all user accounts Developer must ensure that API keys provided by Amazon are encrypted and only required employees have access to them.
 
1.5 Encryption in Transit. TGL Direct encrypt all Information in transit with secure protocols such as TLS 1.2+, SFTP, and SSH-2. TGL Direct enforce this security control on all applicable internal and external endpoints. TGL Direct use data message-level encryption where channel encryption (e.g., using TLS) terminates in untrusted multi-tenant hardware (e.g., untrusted proxies). 
 
1.6 Risk Management and Incident Response Plan. . TGL Direct have a risk assessment and management process that is reviewed by the Developer's senior management annually, which includes, but is not limited to, assessment of potential threats and vulnerabilities as well as likelihood and impact in order to track known risks. TGL Direct create and maintain a plan and/or runbook to detect and handle Security Incidents. Such plans must identify the incident response roles and responsibilities, define incident types that may affect Amazon, define incident response procedures for defined incident types, and define an escalation path and procedures to escalate Security Incidents to Amazon. TGL Direct review and verify the plan every six (6) months and after any major infrastructure or system change, including changes to the system, controls, operational environments, risk levels, and supply chain. TGL Direct notify Amazon (via email to 3p-security@amazon.com) within 24 hours of detecting a Security Incident. It is the Developer’s sole responsibility to inform relevant government or regulatory agencies as required by applicable local laws. TGL Direct investigate each Security Incident, and document the incident description, remediation actions, and associated corrective process/system controls implemented to prevent future recurrence. TGL Direct maintain the chain of custody for all evidences or records collected, and such documentation must be made available to Amazon upon request (if applicable). If a Security Incident occurred, Developers cannot represent or speak on behalf of Amazon to any regulatory authority or customers unless Amazon specifically requests in writing that the Developer do so.
 
1.7 Request for Deletion. TGL Direct permanently and securely delete Information upon and in accordance with Amazon's notice requiring deletion within 30 days of Amazon’s requests unless the data is necessary to meet legal requirements, including tax or regulatory requirements. Secure deletion must occur in accordance with industry-standard sanitization processes such as NIST 800-88. TGL Direct also permanently and securely delete all live (online or network accessible) instances of Information 90 days after Amazon's notice. If requested by Amazon, the Developer will certify in writing that all Information has been securely destroyed. 

1.8 Data attribution. TGL Direct store Information in a separate database or implement a mechanism to tag and identify the origin of all data in any database that contains Information. 

2. Additional Security Requirements Specific to Personally Identifiable Information

The following additional Security Requirements must be met for Personally Identifiable Information ("PII"). PII is granted to Developers for select tax and merchant fulfilled shipping purposes, on a must-have basis. If an Amazon Services API contains PII, or PII is combined with non-PII, then the entire data store must comply with the following requirements: 

2.1 Data Retention. Developers will retain PII for no longer than 30 days after order delivery and only for the purpose of, and as long as is necessary to (i) fulfill orders, (ii) calculate and remit taxes, (iii) produce tax invoices and other legally required documents, and (iv) meet legal requirements, including tax or regulatory requirements. Developers may retain data for over 30 days after order delivery only if required by law and only for the purposes of complying with that law. Per sections 1.5 (“Encryption in Transit”) and 2.4 (”Encryption at Rest”) at no point should PII be transmitted or stored unprotected.
 
2.2 Data Governance. TGL Direct create, document, and abide by a privacy and data handling and classification of policy for their Applications or services, which govern the appropriate conduct and technical controls to be applied in managing and protecting information assets. A record of data processing activities such as specific data fields and how they are collected, processed, stored, used, shared, and disposed for all PII should be maintained to establish accountability and compliance with regulations. TGL Direct establish a process to detect and comply with privacy and security laws and regulatory requirements applicable to their business and retain documented evidence of their compliance. TGL Direct establish and abide by their privacy policy for customer consent and data rights to access, rectify, erase, or stop sharing/processing their information where applicable or required by data privacy regulation. Developer must have technical and organizational processes and systems in place for assisting Authorized Users with data subject access requests. TGL Direct include contractual provisions in employment contracts with employees that process PII to maintain confidentiality of PII.
 
2.3 Asset Management. TGL Direct maintain baseline standard configuration for the information system and keep inventory of software and physical assets (e.g. computers, mobile devices) with access to PII, and update quarterly. Physical assets that store, process, or otherwise handle PII must abide by all of the requirements set forth in this policy. TGL Direct not store PII in removable media, personal devices, or unsecured public cloud applications (e.g., public links made available through Google Drive) unless it is encrypted using at least AES-128 or RSA-2048 bit keys or higher. TGL Direct securely dispose of any printed documents containing PII. Developer must implement data loss prevention (DLP) controls in place to monitor and detect unauthorized movement of data. 

2.4 Encryption at Rest. TGL Direct encrypt all PII at rest using at least AES-128 or RSA with 2048-bit key size or higher. The cryptographic materials (e.g., encryption/decryption keys) and cryptographic capabilities (e.g. daemons implementing virtual Trusted Platform Modules and providing encryption/decryption APIs) used for encryption of PII at rest must be only accessible to the Developer's processes and services. 
 
2.5 Secure Coding Practices. TGL Direct not hardcode sensitive credentials in their code, including encryption keys, secret access keys, or passwords. Sensitive credentials must not be exposed in public code repositories. TGL Direct maintain separate test and production environments. 
 
2.6 Logging and Monitoring. TGL Direct gather logs to detect security-related events to their Applications and systems including success or failure of the event, date and time, access attempts, data changes, and system errors. TGL Direct implement this logging mechanism on all channels (e.g., service APIs, storage-layer APIs, administrative dashboards) providing access to Information. TGL Direct review logs in real-time (e.g. SIEM tool) or on a bi-weekly basis. All logs must have access controls to prevent any unauthorized access and tampering throughout their lifecycle. Logs must not contain PII unless the PII is necessary to meet legal requirements, including tax or regulatory requirements. Unless otherwise required by applicable law, logs must be retained for at least 90 days for reference in the case of a Security Incident. TGL Direct build mechanisms to monitor the logs and all system activities to trigger investigative alarms on suspicious actions (e.g., multiple unauthorized calls, unexpected request rate and data retrieval volume, and access to canary data records). TGL Direct implement monitoring alarms and processes to detect if Information is extracted from or can be found beyond its protected boundaries. Developers should perform investigation when monitoring alarms are triggered, and this should be documented in the Developer's Incident Response Plan. 
 
2.7 Vulnerability Management. TGL Direct create and maintain a plan and/or runbook to detect and remediate vulnerabilities. TGL Direct protect physical hardware containing PII from technical vulnerabilities by performing vulnerability scans and remediating appropriately. TGL Direct conduct vulnerability scanning at least every 180 days, penetration test at least every 365 days, and scan code for vulnerabilities prior to each release. Furthermore, TGL Direct control changes to the storage hardware by testing, verifying changes, approving changes, and restricting access to who may perform those actions. Developer must have appropriate procedures and plans to restore availability and access to PII in a timely manner in the event of a physical or technical incident.

3. Audit and Assessment

TGL Direct maintain all appropriate books and records reasonably required to verify compliance with the Acceptable Use Policy, Data Protection Policy, and Amazon Services API Developer Agreement during the period of this agreement and for 12 months thereafter. Upon Amazon's written request, TGL Direct certify in writing to Amazon that they are in compliance with these policies. 

Upon request, Amazon may, or may have an independent certified public accounting firm selected by Amazon, audit, assess and inspect the books, records, facilities, operations, and security of all systems that are involved with a Developer's Application in the retrieval, storage, or processing of Information. Amazon will keep confidential any nonpublic information disclosed by a Developer as part of this audit, assessment, or inspection that is designated as confidential or that, given the nature of the information or the circumstances surrounding its disclosure, reasonably should be considered confidential. TGL Direct cooperate with Amazon or Amazon's auditor in connection with the audit or assessment, which may occur at the Developer's facilities and/or subcontractor facilities. If the audit or assessment reveals deficiencies, breaches, and/or failures to comply with our terms, conditions, or policies, the Developer must, at its sole cost and expense, and take all actions necessary to remediate those deficiencies within an agreed-upon timeframe. Upon request, Developer must provide remediation evidence in the form requested by Amazon (which may include policy, documents, screenshots, or screen sharing of application or infrastructure changes) and obtain written approval on submitted evidence from Amazon before audit closure. 

4. Definitions

"Amazon Services API" means any application programming interface (API) offered by Amazon for the purpose of helping Amazon Authorized Users to programmatically exchange data. 

"API Materials" means Materials we make available in connection with the Amazon Services API, including APIs, documentation, specifications, software libraries, software development kits, and other supporting materials, regardless of format.

"Application" means a software application or website that interfaces with the Amazon Services API or the API Materials.

"Authorized User means a user of Amazon’s systems or services who has been specifically authorized by Amazon to use the applicable systems or services.

"Customer" means any person or entity who has purchased items or services from Amazon's public-facing websites.

"Developer" means any person or entity (including you, if applicable) that uses the Amazon Services API or the API Materials for a Permitted Use on behalf of an Authorized User.

"Information" means any information that is exposed through the Amazon Services API, Amazon Portals, or Amazon's public-facing websites. This data can be public or non-public, including Personally Identifiable Information about Amazon Customers.

"Personally Identifiable Information" ("PII") means information that can be used on its own or with other information to identify, contact, identify in context, or locate an Amazon Customer or Authorized User. This includes, but is not limited to, a Customer or Authorized User's name, address, e-mail address, phone number, gift message content, survey responses, payment details, purchases, cookies, digital fingerprint (e.g., browser, user device), IP Address, geo-location, nine-digit postal code, or Internet-connected device product identifier.

"Security Incident" means any actual or suspected unauthorized access, collection, acquisition, use, transmission, disclosure, corruption, or loss of Information, or breach of any environment containing Information.

 

Contacting Us
If there are any questions regarding this privacy policy you may contact us using the information below.

https://www.tgldirect.com
44 W Water St.
Chillicothe, OH 45601
United States
smile@tgldirect.com
740.649.1330