| 
   Domain 
   | 
  
   Measures 
   | 
  
   Purpose 
   | 
 
 
  | 
   1. Data transfer 
   | 
  
  
  - Encryption during transfer (TLS 1.2/1.3)
 - Internal: Devices → Gateway → EU cloud
 - Outside: ixi Pro (SIM+GPS) → Mobile network →
  EU cloud
 - Secure push notifications
 
  | 
  
   Confidentiality and integrity of data
  during transfer 
   | 
 
 
  | 
   2. Data storage 
   | 
  
  - Encryption at rest (AES-256)
 - EU-hosted cloud (AWS, with protection against
  DDoS, SOC2/ISO certifications)
 - Audit logging with timestamps and tamper
  resistance
 - Separation of access to systems and backups
  
   | 
  
   Protection of stored data and full
  traceability 
   | 
 
 
  | 
   3. Access management & authentication 
   | 
  - Role-based access control (RBAC,
  need-to-know, in line with least privilege)
 - Availability of multi-factor authentication
  (MFA) for ixicare administrators
 - Controlled support access only after formal
  request from the Controller
 
  | 
  
   Access restriction, abuse prevention and
  accountability 
   | 
 
 
  | 
   4. Data deletion & retention 
   | 
  - Manual deletion by authorised administrators
 - Limited backup retention, then overwriting
 - Secure wipe & reset at end of device life
  (including stop transmit/reset upon deprovisioning)
 
  | 
  
   Compliance with retention policy and
  secure deletion of personal data 
   | 
 
 
  | 
   5. Network & Device Security 
   | 
  
  - Secure firmware and configuration updates
  (OTA)
 - Firewalls and segmentation of cloud and
  application environments
 - Protection via AWS high availability and DDoS
  mitigation
  
   | 
  
   Protection against unauthorised access
  and cyber threats 
   | 
 
 
  | 
   6. Availability & Continuity 
   | 
  
  - Redundant servers and failover for 24/7
  operation
 - Hosting in EU data centres (AWS, high
  availability)
 - Monitoring of platform and devices with
  incident notifications
 - Backup and restore procedures
  
   | 
  
   Uninterrupted service and recovery in the
  event of incidents 
   | 
 
 
  | 
   7. Security monitoring & Change
  Management 
   | 
  
  - External penetration testing
 - Regular vulnerability scans
 - Intrusion detection on cloud platform
 - Peer review and logging of manual actions
  (code, server access)
 - Controlled development and release process
  
   | 
  
   Early detection and mitigation of
  security risks 
   | 
 
 
  | 
   8. Legal & Compliance 
   | 
  - Privacy and security policy
 - Data Processing Agreements (DPAs) with
  customers and subcontractors
 - Privacy risk assessments with re-evaluation
  cycle
 - Supplier management with audit rights and due
  diligence (ISO 27001, SOC 2)
 - Terms of Use and privacy notice
 
  | 
  
   Governance, compliance and chain
  responsibility 
   | 
 
 
  | 
   9. Employees & Awareness 
   | 
  
  - Periodic GDPR and security training
 - Confidentiality clauses (NDAs) for staff and
  contractors
  
   | 
  
   Promotion of awareness and compliance by
  employees 
   | 
 
 
  | 
   10. Incident & Data breach management 
   | 
  
  - Procedure in accordance with the 72-hour GDPR
  reporting obligation
 - Crisis and escalation protocol with
  communication to customers
 - Evaluation and follow-up of incidents
  
   | 
  
   Rapid response, transparency and recovery
  in the event of data breaches 
   | 
 
 
  | 
   11. Rights of data subjects 
   | 
  
  - Procedure for access, correction, data
  portability and deletion of personal data
 - Contact point for GDPR requests from
  customers and data subjects
 - Transparency via privacy notice
  
   | 
  
   Strengthening the rights of data subjects
  and GDPR compliance 
   | 
 
 
  | 
   12. Data minimisation & R&D 
   | 
  - Location data only during active alarms or
  necessary monitoring (no continuous tracking as standard)
 - Use for R&D only with appropriate
  safeguards (notice, anonymisation)
 
  | 
  
   Minimising data processing and secure use
  for innovation 
   |