LeadSquared Security

Data Security GDPR Responsible Disclosure Hall of fame

LeadSquared is ISO 27001:2013 certified by the British Standards Institute (BSI).

The certification is applicable across the entire LeadSquared product, cloud services, IT infrastructure, administration, finance, and internal functions.

At LeadSquared, we understand that securing and protecting your data is the most important responsibility we have. We have instituted organization wide processes across all our business functions to ensure that we fulfil the responsibility of securing your data. The following sections will give you a more detailed account on some of the systems we have put in place.

Physical Security

The LeadSquared development center in Bangalore is under 24×7 physical security protection. Only authorized personnel have access to the building and offices. Employees are granted access to the office only after authorization using biometric authentication. Critical locations in the office are accessible only to authorized individuals. Important documents are stored in cabinets accessible only to authorized persons. The office is equipped with surveillance cameras and its images are regularly monitored by authorized persons. A policy has been implemented to approve and regulate visitor access to the building. The office is provided with 24×7 power supply, supported by an alternative uninterrupted power supply system to ensure smooth functioning in the event of power failure. LeadSquared hosts its application and data in industry-leading Amazon Web Services, whose data centers have been thoroughly tested for security, availability and business continuity. For more details, please refer to the AWS Security Whitepaper.

Application Security

LeadSquared applications and services are all hosted in Amazon Web Services across its multiple regions. The infrastructure for databases and application servers is managed and maintained by the cloud service providers. At LeadSquared, we take an integrated approach to application security, to ensure everything from engineering to deployment, including architecture and quality assurance processes complies with our highest standards of security.

Application Architecture

The application is initially protected by AWS’s firewall which is equipped to counter regular DDoS attacks and other network related intrusions. The second layer of protection is a web application firewall (WAF) which monitors against offending IPs, users and spam. While the application can be accessed only by users with valid user access, it should be noted that security in cloud-based products is a shared responsibility between the company and the businesses who own those accounts on the cloud. In addition to making it easy for administrators to enforce industry-standard password policies on users, our products also come with features aimed at securing business data on the cloud:

Role based access
Sales Groups
Permission Templates
Whitelisting IPs for exclusive access

LeadSquared uses a multi-tenant data model to host all its applications. Each customer has a separate database and we ensure that the code always fetches the data that belongs to only the logged in tenant. Per this design, no customer has access to another customer’s data. Access to the application by the LeadSquared development team is also controlled, managed and audited. Access to the application and the infrastructure are logged for subsequent audits.

Application Engineering and Development

We follow secure software development lifecycle, where security testing is part of development, testing and pre-release acceptance. A security review is a mandatory part of application engineering (development and construction) process at LeadSquared.

Software Changes and Release Management

Changes in our production environment follow a very well-defined, systematic process from development and test environments to verifying the changes finally on staging before production deployment. Production deployments are only done by authorized Devops team members, and nobody else has access to our production environment.

Production Monitoring

We have a dedicated 24×7 NOC team that monitors the application for suspicious activities or attacks. We conduct regular external third-party audits to certify the state of security in our applications and services.

Data Security

LeadSquared takes the protection and security of its customers’ data very seriously. LeadSquared manages the security of its application and customers’ data. The LeadSquared development team has no access to data on production servers. Changes to the application, infrastructure, web content and deployment processes are documented extensively as part of an internal change control process. LeadSquared takes the integrity and protection of customers’ data very seriously. Data at rest is encrypted using AES-256 bit standards (key strength – 1024) with the keys being managed by AWS Key Management Service. All data in transit is encrypted using FIPS-140-2 standard encryption over a secure socket connection for all accounts hosted with us. Different environments are in use for development and testing purposes, access to systems are strictly managed, based on the principles of need to do/know basis appropriate to the information classification, with Segregation of Duties built in, and reviewed on a quarterly basis.

Data Deletion

When your account with us is terminated, we ensure that all your data is deleted cleanly. The details are listed in our terms of service.

Network Security

The LeadSquared office network where updates are developed, deployed, monitored and managed is secured by industry-grade firewalls and antivirus software, to protect internal information systems from intrusion and to provide active alerts in the event of a threat or an incident. Firewall logs are stored and reviewed periodically. Access to the production environment is via SSH and remote access is possible only via the office network. Audit logs are generated for each remote user session and reviewed. Also, the access to production systems are always through a multi-factor authentication mechanism. Our data centers are hosted in AWS are ISO 27001, SSAE-16 and HIPAA compliant.

Reporting issues and threats

At LeadSquared we take the protection of our customer’s data very seriously. If you have found any issues or flaws impacting the data security or privacy of LeadSquared users, please write to security@leadsquared.com with the relevant information so we can get working on it right away. We ask that you do not share or publicize an unresolved vulnerability with/to third parties. If you submit a vulnerability report, the LeadSquared security team and associated development teams will use reasonable efforts to:

Respond in a timely manner, acknowledging receipt of your vulnerability report
Investigate the reported issue and provide an estimated time frame for addressing the vulnerability report. We might ask for your guidance in identifying or replicating the issue and understanding any means to resolving the threat right away
Notify you when the vulnerability has been fixed

We sincerely appreciate your help in detecting and fixing flaws in our platform, and will acknowledge your contribution to the world once the threat is resolved. Public Disclosure Policy By default, this program is in “PUBLIC NONDISCLOSURE” mode which means: “THIS PROGRAM DOES NOT ALLOW PUBLIC DISCLOSURE. ONE SHOULD NOT RELEASE THE INFORMATION ABOUT VULNERABILITIES FOUND IN THIS PROGRAM TO PUBLIC, FAILING WHICH SHALL BE LIABLE FOR LEGAL PENALTIES!” The Fine Print We may modify the terms of this program or terminate this program at any time. We won’t apply any changes we make to these program terms retroactively. LeadSquared/MarketXpander employees and their family members are not eligible for bounties.

LeadSquared is fully committed to following the guidelines cited by GDPR. We promise to safeguard your data.

[Contact privacy@leadsquared.com for any questions/comments]

What is GDPR?

The GDPR (General Data Protection Regulation) is a new EU Regulation which has replaced the 1995 EU Data Protection Directive (DPD) to significantly enhance the protection of the personal data of EU citizens and increase the obligations on organisations who collect or process personal data. It came into force on 25th May 2018. The regulation builds on many of the 1995 Directive’s requirements for data privacy and security, but includes several new provisions to bolster the rights of data subjects and add harsher penalties for violations.

A regulation such as the GDPR is a binding act, which must be followed in its entirety throughout the EU. The GDPR is an attempt to strengthen, harmonize, and modernize EU data protection law and enhance individual rights and freedoms, consistent with the European understanding of privacy as a fundamental human right. The GDPR regulates, among other things, how individuals and organizations may obtain, use, store, and eliminate personal data. It has a significant impact on businesses around the world.

The full text of the GDPR can be found at https://gdpr-info.eu/ .

Does the GDPR apply to me?

While the current EU legislation (the 1995 EU Data Protection Directive) governs entities within the EU, the territorial scope of the GDPR is far wider in that it will also apply to non-EU businesses who a) market their products to people in the EU or who b) monitor the behavior of people in the EU. In other words, even if you’re based outside of the EU but you control or process the data of EU citizens, the GDPR applies to you.

GDPR – important definitions

TERM	DEFINITION
Data Subject	A person who lives in the EU
Personal Data	Any information related to an identified/identifiable data subject (e.g., name, national ID number, address, IP address, health info)
Controller	A company/organisation that collects people’s personal data and makes decisions about what to do with it. So if you’re collecting personal data and are determining how it will be processed (for example using the LeadSquared services to market to prospects and customers), you’re the Controller of that data and must comply with applicable data privacy legislation accordingly.
Processor	A company/organisation that helps a controller by “processing” data based on its instructions, but doesn’t decide what to do with data. So for example, LeadSquared is the processor of the data you collect in your LeadSquared application. We don’t control how you collect or use the data; we merely process it on your behalf and on your instruction.
Processing	Any operation or set of operations which is performed on personal data or on sets of personal data, by automated means or otherwise, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data Protection Officer (DPO)	A representative for a controller/processor who oversees GDPR compliance and is a data-privacy expert
Data Privacy Impact Assessment (DPIA)	A documented assessment of the usefulness, risks, and risk-mitigation options for a certain type of processing
Supervisory Authority	Formerly called “data protection authorities”; one or more governmental agencies in a member state who oversee that country’s data privacy enforcement (e.g., Ireland’s Office of the Data Protection Commissioner, Germany’s 18 national/regional authorities)
Third Countries	Countries outside the EU

What is personal Data as per GDPR?

As per GDPR, personal data is any information relating to an identified or identifiable individual; meaning, information that could be used, on its own or in conjunction with other data, to identify an individual. Personal data will include not only data that is commonly considered to be personal in nature (e.g., social security numbers, names, physical addresses, email addresses), but also data such as IP addresses, behavioral data, location data, biometric data, financial information, and much more. It is also important to note that even personal data that has been “pseudonymized” can be considered personal data if the pseudonym can be linked to any particular individual.

What are the rights of Data Subject under GDPR?

At the heart of GDPR lies a set of rights a person can exercise against organizations processing their personal data. Specifically, individuals have the right to:

Access	Under GDPR, the Data Subject can request access to his/her personal data and learn how an organization uses it.
Erasure	Data Subject has a right to withdraw consent to store and use personal data and have the information erased.
Data Portability	Data Subject has the right to transfer its data from one service provider to another, and current provider must comply with this request.
Rectification	Data Subject can also require any errors in personal data to be corrected, and an organization must reply to the request within one month.
To Be Informed	Under GDPR, companies must be transparent about how they gather personal information, and must do it before they collect the data. As part of this, Data Subject must freely give consent for their data to be gathered for a specific purpose.
Restrict Processing	This gives Data Subject the right to block and suppress processing of their personal data. Under suppressing, an organization can still store personal information but cannot use it in any way.
Stop Processing	Data Subject has the right to object to using and processing their personal data. This includes direct marketing, profiling, processing for scientific or historical research, inclusion in statistical research and much more. Once a Data Subject objects, all his or her data processing must cease immediately.

In the case of LeadSquared’s relationship with a Customer, who is Controller and who is Processor of the data?

Unless explictly clarified in any engagement, LeadSquared is the Processor and the Customer is the Controller. Please refer to definitions in the beginning of this document.

Is it mandatory for LeadSquared to provide EU hosting to its European customers to comply with GDPR?

No, there is no obligation under the GDPR for data to be stored in the EU and the rules regarding transfer of personal data outside the EU will not change. This means that, as long as the personal data is “adequately protected”, data may be transferred abroad.

LeadSquared has amended its Terms of Service and provided a new Data Protection Agreement aligned with GDPR to provide adequate safeguards on data transfer of EU data subjects to non-EU regions.

What does LeadSquared do to ensure lawful data transfers from the EU?

The GDPR permits transfers of personal data outside of the EU subject to certain conditions. The EU model clauses (Standard Contractual Clauses or SCC) provide a valid mechanism to lawfully transfer personal data. LeadSquared offers a Data Processing Agreement that incorporates the model clauses to our EU/EEA customers.

We have created a new Data Processing Agreement (DPA) incorporating the Standard Contractual Clauses (SCC) to meet the requirements of the GDPR in order to permit our Customers to continue to lawfully transfer EU personal data to LeadSquared and permit LeadSquared to continue to lawfully receive and process that data;
We have updated our Terms of Service to refer to DPA as a mechanism to lawfully transfer data of EU Data Subjects to LeadSquared.

Is it mandatory for LeadSquared’s Customers dealing with EU Data Subjects to sign Data Processing Agreement (DPA)?

Yes, it is mandatory. Much before the deadline of 25^th May, LeadSquared has reached out to all its Customers dealing with EU Data Subjects to sign the DPA.

What software changes is LeadSquared planning to do in preparation of GDPR?

We have made the necessary changes to LeadSquared to ensure that we are compliant by May 25^th, 2018, and to help our Customers meet obligations under the GDPR to the extent that LeadSquared is used to collect and store EU personal data. Some of the changes that have been executed:

Making it easy to obtain consent from Data Subject via default unchecked checkboxes with associated descriptions on forms and landing pages
Allowing consent to be taken for different purposes
Providing widget/option for consent on tracking by Cookie when our tracking script is used on web pages
Mandatorily capturing reason for unblocking any lead for email after it has been blocked due to bounce/unsubscribe/spam report.
Mandatory proof of opt-in to be required if data is being imported or pushed via API
Feature to take re-consent for emailing on existing lists
Allowing customer to let a Data Subject exercise his/her right to Access, Erasure, Portability, Rectification, Restrict or Stop Processing. The responsibility of action on such requests will be that of Customer (Controller).

Is LeadSquared able to comply with the right to erasure (right to be forgotten)?

Yes. When one of your contacts (i.e. data subjects) asks you to delete them from your records, you’ll have the ability to do so quickly and easily.

Is double opt-in mandatory?

For those unfamiliar with this term, “double opt-in” is a 2-step mechanism where a person must confirm their email address after initially signing up. The GDPR does not require double opt-in (though certain countries may make this mandatory).

Opt-in proof or proof of legitimate interest will be needed.

I have contacts in my database that I don’t have specific opt-in records for. Should I have deleted them before May 25th 2018?

If you’ve lost track of the opt-in status of your contacts or never confirmed opt-in, you can run an “opt-in confirmation” campaign to remove any unconfirmed contacts from future sends.

A opt-in confirmation is a one-time email campaign that requests any contacts who haven’t already used some form of opt-in to confirm that they would still like to receive emails from you. Only the contacts who confirm their subscription status are then kept on your list. Those who don’t confirm will then be opted out of your marketing emails. The result is a highly engaged list of contacts who have proven that they want to continue receiving marketing emails from your company.

A quick note to think about, though: just because you don’t have record of opt-in doesn’t mean you don’t have lawful basis to process a contact record. Lawful basis comes in multiple forms:

Necessary for performance of a contract. Example: if Kevin buys products from you, you can send him emails related to onboarding, billing, etc.
Legitimate interest. In the above example, you could email Kevin about related products or services.
Consent (with notice). Freely given, affirmative, opt-in consent accompanied with transparent explanation of your purpose for acquiring/using the data.

What contractual changes has LeadSquared made in its agreements with customers & vendors in preparation of GDPR?

We have reviewed all our legal agreements to ensure that we have made all the required changes in order to be compliant with GDPR. Here are some of the planned changes:

We have created a new Data Processing Agreement (DPA) to meet the requirements of the GDPR in order to permit our Customers to continue to lawfully transfer EU personal data to LeadSquared and permit LeadSquared to continue to lawfully receive and process that data;
We have updated our Terms of Service to refer to DPA as a mechanism to lawfully transfer data of EU Data Subjects to LeadSquared.
We have updated our third-party vendor contracts to meet the requirements of the GDPR in order to permit us to continue to lawfully transfer EU personal data to those third parties and permit those third parties to continue to lawfully receive and process that data.

We encourage individuals outside our organization to help us find security vulnerabilities in our platform. Such individuals may use these guidelines to responsibly disclose issues:

Please write to security@leadsquared.com with details of any potential vulnerability in our products, meeting all the below mentioned criteria. We will get back within 48 hours of your submission.
Please refrain from doing security testing in existing customer accounts.
While doing your tests, please ensure that you do not violate our privacy policies, modify/delete unauthenticated user data, disrupt production servers, or degrade user experience.
If your finding is valid and unique, we would be happy to acknowledge your efforts in our Hall of Fame page.

The following domains are in scope:

run.leadsquared.com
api.leadsquared.com

Please exclude the following test cases while conducting your tests:

Denial of Service attacks and Distributed Denial of Service attacks.
Rate limiting, brute force attack.
Missing HTTP security headers and cookie flags on insensitive cookies.
Clickjacking / UI Redressing attack.
Self-XSS and XSS that affects only outdated browsers.
Host header and banner grabbing issues.
Automated tool scan reports. Example: Web, SSL/TLS Scan, Nmap scan results etc.
Login/logout/low-business impact CSRF.
Unrestricted file uploads.
Open redirects – unless they can be used for actively stealing tokens.
User enumeration such as User email, User ID etc.
Session fixation and session timeout.
Phishing / Spam (including issues related to SPF/DKIM/DMARC)
Email spoofing.
Attacks requiring MITM or physical access to a user’s device.
Previously known vulnerable libraries without a working Proof of Concept.
Comma Separated Values (CSV) injection without demonstrating a vulnerability.
Missing best practices in SSL/TLS/HSTS configuration.
Vulnerabilities that send unsolicited bulk messages (spam).
Vulnerabilities reported by automated tools without analysis or qualification. Reports from automated web vulnerability scanners are acceptable only if you demonstrate the vulnerability is reproducible and has a security impact.
Missing best practices in Content Security Policy.
Missing HttpOnly or Secure flags on cookies.
Tabnabbing.
Software version disclosure / Banner identification issues / Descriptive error messages or headers (e.g. stack traces, application or server errors).
Vulnerabilities relying highly on social engineering aspect.
Email flooding.
Vulnerabilities such as xmlrpc that are no more valid on newer versions.

By default, this program is in “PUBLIC NONDISCLOSURE” mode which means: “THIS PROGRAM DOES NOT ALLOW PUBLIC DISCLOSURE. ONE SHOULD NOT RELEASE THE INFORMATION ABOUT VULNERABILITIES FOUND IN THIS PROGRAM TO PUBLIC, FAILING WHICH SHALL BE LIABLE FOR LEGAL PENALTIES!”

We sincerely thank the following individuals who have responsibly disclosed one or more of security vulnerabilities in LeadSquared platform. This has enabled us to serve our customers better.