Agreement on the
processing of personal data
Standard contractual clauses
SECTION I
Clause 1Purpose and scopea) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.
c) These Clauses apply to the processing of personal data as specified in Annex II.
d) Annexes I to IV are an integral part of the Clauses.
e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.
f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.
Clause 2Invariability of the Clausesa) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.
b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.
Clause 3Interpretationa) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.
b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.
c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.
Clause 4HierarchyIn the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.
Clause 5Docking clausea) Any entity that is not a Party to these Clauses may, with the agreement of all the Parties, accede to these Clauses at any time as a controller or a processor by completing the Annexes and signing Annex I.
b) Once the Annexes in (a) are completed and signed, the acceding entity shall be treated as a Party to these Clauses and have the rights and obligations of a controller or a processor, in accordance with its designation in Annex I.
c) The acceding entity shall have no rights or obligations resulting from these Clauses from the period prior to becoming a Party.
SECTION II
OBLIGATIONS OF THE PARTIES
Clause 6Description of processing(s)
The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.
Clause 7Obligations of the Parties7.1. Instructions
a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.
b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.
7.2. Purpose limitation
The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller
7.3. Duration of the processing of personal data
Processing by the processor shall only take place for the duration specified in Annex II.
7.4. Security of processing
a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.
b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
7.5. Sensitive data
If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences ("sensitive data"), the processor shall apply specific restrictions and/or additional safeguards.
7.6. Documentation and compliance
a) The Parties shall be able to demonstrate compliance with these Clauses.
b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.
c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.
d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.
e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.
7.7. Use of sub-processors
a) GENERAL WRITTEN AUTHORISATION: The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 30 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.
b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.
c) At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.
d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.
e) The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.
7.8. International transfers
a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.
b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.
Clause 8Assistance to the controllera) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.
b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions
c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:
1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a "data protection impact assessment") where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;
2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;
3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;
4) the obligations in Article 32 of Regulation (EU) 2016/679/.
d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required
Clause 9Notification of personal data breachIn the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.
9.1. Data breach concerning data processed by the controller
In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:
a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);
b) in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679/, shall be stated in the controller’s notification, and must at least include:
1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;
2) the likely consequences of the personal data breach;
3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.
Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.
c) in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons
9.2. Data breach concerning data processed by the processor
In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:
a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);
b) the details of a contact point where more information concerning the personal data breach can be obtained;
c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.
Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.
The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679
SECTION III
FINAL PROVISIONS
Clause 10Non-compliance with the Clauses and termination
a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.
b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:
1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;
2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;
3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.
c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.
d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.
ANNEX I
A. LIST OF PARTIESController(s):
1. ................................................................
Signature: ................................................................
Accession date: ................................................................
Processor(s):
Redtrack Technologies LTD, 49 Dromos, 41, Kato Polemidia, undefined Limassol, CY
e-mail: privacy@redtrack.io
Signature: ................................................................
Accession date: ................................................................
ANNEX II
Description of the processing:RedTrack Technologies Ltd. ("Processor") provides advanced ad tracking, attribution, automation, and scaling solutions. The processing activities encompass the collection, management, analysis, and reporting of advertising and campaign data to optimize marketing efforts on behalf of its clients ("Data Controllers").
Categories of data subjects whose personal data is processed:- Clients: Individuals and businesses that use RedTrack’s services to manage and optimize their advertising campaigns.
- End-Users: Customers of RedTrack’s clients who interact with their advertising campaigns.
- Employees and Team Members: Personnel of the Data Controllers who manage campaigns and use the RedTrack platform for collaboration and optimization.
Categories of personal data processed:- Contact Information: First name, last name, email address, phone number.
- Business Information: Business type, monthly ad spend, messenger username.
- Technical Data: IP addresses, device identifiers, browser information, and other technical data related to user interactions with the platform.
- Usage Data: Information about how clients use the RedTrack platform, including campaign performance metrics, optimization activities, and interaction with various integrated services.
Nature of the processing:RedTrack processes personal data to deliver its core services, which include:
- Ad Tracking and Attribution: Collecting and attributing ad performance data across multiple platforms such as Meta (Facebook), Google, TikTok, Bing, and others to provide accurate conversion and revenue matching down to the ad or placement level.
- Centralized Monitoring: Aggregating data from various channels (paid, organic, email, partnerships, referrals) into a single dashboard for real-time monitoring and management.
- Data Synchronization: Synchronizing ad spend and revenue data from integrated ad networks and e-commerce platforms (e.g., Shopify, WooCommerce) to provide a comprehensive view of campaign performance.
- Automation and Optimization: Utilizing built-in automation rules and AI-assisted revenue attribution to optimize campaign performance, scale successful campaigns, and manage costs and revenues effectively.
- Reporting and Analytics: Generating customizable reports and dashboards to enable data-driven decision-making, identify trends, reduce ad waste, and enhance overall marketing strategies.
Duration of the processing:The processing of personal data begins upon the initiation of service usage (e.g., booking a demo, starting a free trial, or subscribing to a paid plan) and continues for the duration of the contractual relationship between the Data Controller and RedTrack. Processing ceases upon termination of the agreement or cessation of service usage, unless otherwise required by law.
ANNEX III
Description of the technical and organisational security measures implemented by the processor(s) to ensure an appropriate level of security, taking into account the nature, scope, context and purpose of the processing, as well as the risks for the rights and freedoms of natural persons.
Measures of Pseudonymisation and Encryption of Personal DataThe pseudonymisation measures in place involve representing users through unique identifiers (IDs) rather than personally identifiable information, which significantly reduces the risk of direct identification. The system ensures that all IP addresses are anonymized upon output to further protect user identity. Personal data is stored in specifically segregated storage systems equipped with enhanced security controls. The ClickHouse database implementation in place includes robust anonymization features for sensitive data. For additional security, all user data within the main data storage is maintained in secure hash formats.
The encryption measures in place include a WireGuard VPN infrastructure that provides secure network connections throughout the systems. HTTPS protocol is enforced for all web communications, and TLS v1.2 or higher is utilized for all data transmissions, with all legacy TLS protocols having been deprecated. The network security is further enhanced through a full-mesh VPN that provides private LAN for secure interconnections between services and data centers.
Measures for Ensuring Ongoing Confidentiality, Integrity, Availability and Resilience of Processing Systems and ServicesThe confidentiality measures in place maintain secure password policies that comply with the French CNIL (Commission Nationale de l'Informatique et des Libertés) requirements. The systems implement account locking mechanisms after failed login attempts and require two-factor authentication (2FA) for access to sensitive systems. All physical facility entrances are secured with access control systems. Account-Based Routing (ABR) has been implemented with strict isolation of accounts through specific processes designed to prevent unauthorized access. Service authentication is secured through a comprehensive API key management system, and JSON Web Tokens (JWT) are utilized for secure information exchange. Regular internal security testing is conducted to verify the effectiveness of account isolation measures. All public port mappings are closed, and internal users are authenticated via SSO (Single Sign-On) with granular groups and roles management.
The data integrity measures in place maintain comprehensive tracking of all system actions and changes through detailed audit logs for all data modifications. Daily MongoDB dumps are performed to private S3 buckets, and ClickHouse inodes metadumps are maintained that provide local snapshots of data files for fast rollback when needed.
The system availability and resilience measures in place include multiple data centers, with two located in Europe providing full data replication. Data redundancy is maintained with replica sets for all data sets, and orchestration for microservices is implemented with geo-shared clusters across multiple service providers. All Docker services are replicated with fixed statement configurations, and routing failover between clusters has been implemented to maintain continuous service availability even during outages.
Measures for Ensuring the Ability to Restore the Availability and Access to Personal Data in a Timely Manner in the Event of a Physical or Technical IncidentThe backup and recovery infrastructure in place consists of multiple geographically distributed data centers with full replication capabilities. Regular backups are performed with scheduled restoration testing to verify recovery procedures. Daily MongoDB dumps are stored in private S3 buckets for secure off-site storage, and ClickHouse inodes metadumps are maintained that enable fast data rollback capabilities when needed. All data replication occurs via secure private networking channels, and the Docker clusters are built with private networks for enhanced security and resilience during recovery operations.
Processes for Regularly Testing, Assessing and Evaluating the Effectiveness of Technical and Organisational Measures in Order to Ensure the Security of the ProcessingThe testing and quality assurance procedures in place include DevOps implementation of end-to-end (E2E) testing conducted by a dedicated QA department, complemented by functional testing performed by development teams. Stress tests are regularly conducted to evaluate system performance under load, and Distributed Denial of Service (DDoS) attacks are simulated to test resilience. Penetration testing is performed on a regular schedule to identify potential vulnerabilities. Security reports are received from independent security researchers and bug finders, and an active bug bounty program is maintained to continuously identify and address security vulnerabilities in the systems.
Measures for User Identification and AuthorisationThe authentication systems in place are built around JSON Web Token (JWT) implementation for secure user verification. Comprehensive password policies with appropriate complexity requirements are enforced, and an authorization engine is utilized that provides granular permissions for users in each account. Role-Based Access Control (RBAC) is implemented throughout the systems to ensure appropriate access levels. Accounts are automatically locked after a defined number of failed login attempts, and two-factor authentication (2FA) is required for access to sensitive systems. SSO has been integrated with Google workspace for centralized identity management across the infrastructure.
Measures for the Protection of Data During TransmissionThe secure data transmission measures in place utilize an encrypted WireGuard VPN for all internal communications and enforce HTTPS protocol for all web-based communications. TLS v1.2 or higher is required for all connections, with older versions having been deprecated for security reasons. All incoming traffic is routed through proxy-gateways (specifically Kong API gateway) with TLS 1.2 or higher. Serf (auto discovery) is employed for IPTables rules distribution across the infrastructure, and all data replication occurs exclusively via private networking channels to prevent exposure.
Measures for the Protection of Data During StorageThe secure data storage approach in place includes data centers with strictly restricted physical and digital access controls. Server-level protection is implemented with comprehensive security measures, and all passwords are stored using secure hash algorithms. The network architecture includes isolation mechanisms that prevent database access from outside networks, with IP restrictions applied to all database connections. Private S3 buckets are utilized for backup storage, with daily MongoDB dumps and ClickHouse inodes metadumps for data protection and recovery capabilities.
Measures for Ensuring Physical Security of Locations at Which Personal Data are ProcessedThe physical security infrastructure in place at data processing locations includes restricted access systems for all data centers housing personal data. Secure entrance systems are maintained for physical facilities, and visitor management systems are implemented with detailed access logs to track and control all physical access to sensitive areas.
Measures for Ensuring Events LoggingThe comprehensive logging systems in place include multiple login monitoring mechanisms with complete login activity tracking. Detailed event logs are maintained for each user action on each account, and comprehensive system logs are implemented for ongoing security monitoring. All API access and usage is logged in detail, and audit trails are maintained for all data modifications to ensure complete visibility of system activities.
Measures for Ensuring System Configuration, Including Default ConfigurationThe secure configuration management measures in place implement default access roles with the principle of least privilege for sales teams and other personnel. Role-based access controls are applied in third-party software to limit customer data access appropriately. Tracking systems are maintained to monitor who accesses what data, and SSO has been integrated with Google workspace using role-based permissions. The HR processes include automated access cancellation for terminated employees, and infrastructure is deployed as code using Ansible, with plans to transition all credentials to a more secure Vault system.
Measures for Internal IT and IT Security Governance and ManagementThe security governance framework in place includes internal password management with role-based permissions and system locking mechanisms to prevent unauthorized access. All customer account access is tracked, and stricter access and authentication requirements are implemented for development processes. Developers are subject to enhanced authentication requirements due to their privileged access. Regular GDPR audits are conducted to ensure compliance, and routine IT security audits are performed to identify and address vulnerabilities. Plans are in place to move all deployments to a more secure ChatOPS flow (utilizing Hubot via Slack with ST2 ChatOPS integrity) and to close SSH port 22 after transitioning to these more secure deployment methods.
Measures for Certification/Assurance of Processes and ProductsThe quality and security assurance processes in place include a dedicated QA department responsible for product quality verification. End-to-end (E2E) testing methodologies are implemented throughout the development lifecycle, and regular stress tests are conducted to evaluate system performance under various conditions. The security team performs DDoS testing to verify system resilience and regular penetration testing to identify potential security vulnerabilities. Active engagement is maintained with independent security researchers for vulnerability assessment, and a bug bounty program is in place to encourage continuous security improvement through external expertise.
Measures for Ensuring Data MinimisationThe data minimisation practices in place include limiting customer profile data collection to necessary information only. All data collection processes are designed to gather only essential information, supported by policies and measures that restrict unnecessary data acquisition and processing. Regular reviews of data collection practices are conducted to ensure continued adherence to minimisation principles across all systems and processes.
Measures for Ensuring Data QualityThe data quality management measures in place include regular data cleanup processes and email verification systems that ensure data accuracy. Validation procedures are implemented for all collected data, and quality checks are performed throughout processing activities to maintain high data integrity standards.
Measures for Ensuring Limited Data RetentionThe data retention controls in place include automated deletion of logs after specified timeframes according to retention policies. Scheduled deletion of past customer data is performed within clearly defined timeframes, and processes are implemented for identifying and removing unused accounts. Regular data retention audits are conducted to ensure compliance with policies and applicable regulations.
Measures for Ensuring AccountabilityThe accountability framework in place encompasses detailed logging of all system access and user actions. Comprehensive audit trails are maintained for all data processing activities, and data protection responsibilities are clearly assigned throughout the organization. Regular compliance reviews are conducted to ensure ongoing adherence to all security and privacy requirements.
Measures for Allowing Data Portability and Ensuring ErasureThe data portability and erasure capabilities in place include systems for exporting user data in machine-readable formats upon request. Processes enable complete data erasure when required, with verification procedures to confirm successful deletion. Documentation of all erasure requests and their completion is maintained to ensure compliance with data subject rights.
For Transfers to (Sub-) ProcessorsThe sub-processor management measures in place include contractual requirements for all sub-processors to maintain equivalent security measures to internal standards. Regular audits of sub-processor compliance are conducted, and secure data transfer mechanisms are implemented between internal systems and those of sub-processors. Clear processes are maintained for controller notification regarding any sub-processor changes, and assistance protocols have been established for handling data subject requests that involve sub-processors. The incident response procedures include comprehensive sub-processor coordination to ensure unified security response when needed.
ANNEX IV
List of sub-processorsEXPLANATORY NOTE:
This Annex needs to be completed in case of specific authorisation of sub-processors (Clause 7.7(a), Option 1).
The controller has authorised the use of the following sub-processors:
Name: CalendlyAddress: 271 17th St NW, Ste 1000, Atlanta, GA 30363, USA
Contact person's name, position and contact details:
Description of the processing: Online scheduling and calendar management tool
Address: Skalitzer Str. 104, 10997 Berlin, Germany
Contact person's name, position and contact details:
Description of the processing: Subscription analytics and revenue reporting
Address: J. Jasinskio g. 16C, 03163 Vilnius, Lithuania
Contact person's name, position and contact details:
Description of the processing: AWS partner providing cloud infrastructure services
Address: 221 Main St, Suite 1550, San Francisco, CA 94105, USA
Contact person's name, position and contact details:
Description of the processing: Provider of electronic signature and digital transaction management services, enabling organizations to manage electronic agreements across various devices
Address: Dropbox, Inc. 1800 Owens Street San Francisco, CA 94158 United States
Contact person's name, position and contact details:
Description of the processing: Provider of electronic signature and digital transaction management services, enabling organizations to manage electronic agreements across various devices
Address: One Dockland Central, Guild St, Dublin, D01 E5R6, Ireland
Contact person's name, position and contact details:
Description of the processing: CRM, marketing automation, and customer service tools
Address: 2700 Coast Ave, Mountain View, CA 94043, USA
Contact person's name, position and contact details:
Description of the processing: Cloud-based accounting software
Address: Kleyerstr. 79 / Tor 13, 60326 Frankfurt am Main, Germany
Contact person's name, position and contact details:
Description of the processing: Hosting and cloud services provider
Address: Luttenbergweg 8, 1101 EC Amsterdam, Netherlands
Contact person's name, position and contact details:
Description of the processing: Hosting and cloud services provider
Address: 67 Ubi Ave 1 #05-13, 408942, Singapore
Contact person's name, position and contact details:
Description of the processing: Hosting and cloud services provider
Address: 9301 Innovation Dr #100, Manassas, VA 20110, USA
Contact person's name, position and contact details:
Description of the processing: Hosting and cloud services provider
Address: 140 2nd Street, 3rd Floor, San Francisco, CA 94105, USA
Contact person's name, position and contact details:
Description of the processing: Video messaging and screen recording tool
Address: 2300 Harrison Street, San Francisco, CA 94110, USA
Contact person's name, position and contact details:
Description of the processing: Collaboration and note-taking platform
Address: 3180 18th Street, San Francisco, CA 94110, USA
Contact person's name, position and contact details:
Description of the processing: AI-based language model and chatbot service
Address: 2 Rue Kellermann, 59100 Roubaix, France
Contact person's name, position and contact details:
Description of the processing: Cloud computing and hosting provider
Address: 500 Howard St, San Francisco, CA 94105, USA
Contact person's name, position and contact details:
Description of the processing: Business communication and collaboration tool
Address: Jungfernstieg 49, 20354 Hamburg, Germany
Contact person's name, position and contact details:
Description of the processing: Sales collaboration platform
Address: 55 Almaden Blvd, 6th Floor, San Jose, CA 95113, USA
Contact person's name, position and contact details:
Description of the processing: Video conferencing and online meetings