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Technical and organisational measures

Annex 2 to the data processing agreement (Art. 32 GDPR). What we actually do — only measures that are in place.

Wersja 1.0 · stan na 8 października 2026

1. Confidentiality — physical access

  • MoveMyFile runs no servers of its own. All systems run in data centres of Cloudflare and Supabase (AWS, Frankfurt am Main) certified to ISO/IEC 27001, with access secured by badges, video surveillance and staff.
  • Files are kept in storage bound to the EU jurisdiction, the database in Frankfurt am Main (Germany).

2. Confidentiality — system access

  • Passwords are never stored in readable form, only as a secure hash (bcrypt).
  • Two-factor sign-in (TOTP, authenticator app) available to every user; turning it on or off always sends a security e-mail.
  • Sign-up and sign-in are protected against bots (captcha) and limited against password guessing.
  • Every new device on an account immediately triggers a security e-mail; devices can be removed at any time.
  • Administrative access (hosting, database, code, e-mail delivery) is limited to the management.

3. Confidentiality — data access

  • Who may see what is checked by the database itself on every request (row level security and checked database functions) — not only by the app. Tables are not directly readable for users.
  • Files are delivered only through signed download tickets valid for five minutes.
  • Shared links can have an expiry date, a PIN or password and a download limit; a link is blocked after too many wrong PINs.
  • Roles in teams (owner, admin, member, guest) with graded rights.
  • Teams on Crew or Fleet set sharing rules (PIN required, maximum validity, no public links, allowed recipient domains); the database enforces them — for the API too.
  • Payment data is processed only by Paddle; MoveMyFile never sees card details.

4. Confidentiality — separation

  • Data of every account and every team is logically separated (own workspace, enforced in the database).
  • Test and production systems are fully separate: own database, own file storage, own keys. Test data is not customer data.

5. Confidentiality — pseudonymisation and data minimisation

  • For statistics we keep only the country and language, never the IP address.
  • No advertising, no tracking scripts, no third-party cookies.
  • The content of push notifications is encrypted up to the device.

6. Integrity — transfer control

  • Every connection is encrypted (HTTPS, TLS 1.2 or 1.3); HSTS forces browsers to use HTTPS.
  • Strict content security policy and security headers; independently tested (SSL Labs A+, Mozilla HTTP Observatory A+, Security Headers A+).
  • Internal calls between the application and the database are secured with cryptographic proofs (HMAC).

7. Integrity — input control

  • Protocol of every transfer between a user’s devices (sent, arrived, downloaded with location) and of every device added or removed; kept for 12 months and not deletable by users.
  • Shares record when they were opened and downloaded; changes to plans and limits are logged with time and editor.
  • Deleted files are marked as deleted in the database (evidence); the content itself is removed.
  • Teams on Crew or Fleet: audit log (uploads, sharing, opens, downloads, deletions, members, API) with CSV export for owners and admins.

8. Availability and resilience

  • Daily database backup at the provider; backups are overwritten within about 7 days.
  • Protection against overload attacks (DDoS) and Cloudflare’s worldwide network.
  • Highly durable file storage at the provider (redundant storage).

9. Regular testing and evaluation

  • Before every release more than 600 automated tests run, more than 250 of them checking access rights directly against the database. If a test fails, nothing is released.
  • Database changes are made only through versioned migrations with a prepared rollback; the application starts only with the matching database version.
  • Only the owner of the code repository can release to production; every change is checked on the test system first.
  • Security review of the code before releases; the measures in this document are reviewed at least once a year and on significant changes.

10. Processor control and organisation

  • Sub-processors only with a contract under Art. 28 GDPR; current list in Annex 3, changes are announced in advance.
  • Everyone with access to personal data is bound to confidentiality.
  • Security and privacy reports to support@movemyfile.eu are handled with priority; the processor reports personal data breaches to the controller without undue delay (see DPA § 8).
  • MoveMyFile is explicitly not end-to-end encrypted: technically we could reach stored files. We do not look into them; access only when the law requires it or content is reported as illegal.

Wersja 1.0 · stan na 8 października 2026 · HSE Support Germany s.r.o.

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