Sub-processors
Effective Date
September 10, 2020
Sub-processors are third-party businesses engaged by a processor for performing data processing on behalf of a controller. According to the GDPR, these companies are also accountable for protection of an individual’s personal data. Data protection obligations of sub-processors are to be established by way of contract or other legal acts under the Union or Member State law. This includes providing sufficient guarantees to implement appropriate technical and organizational measures as specified in the regulation.
Inperium uses sub-processors (listed below), to assist in providing services as described in the our Terms of Service or a similar services agreement customers may have signed with us.
Governance
Inperium partners with organizations, that like itself adhere to global standards and regulations. Apart from evaluation for technical requirements, Inperium ensures examination of data protection measures, compliance with Inperium’ security requirements and security audit reports before close of contract. Initial agreements include review and approval of - provision for breach notification in the event of unwarranted data incidents, and necessary security measures for data protection.
Agreements
As part of Inperium’ revised Terms of Service & Privacy Notice for compliance, Inperium provides all EU customers a data processing addendum (DPA) that covers its obligations under the GDPR. You can find our DPA here. It automatically applies to processing of EU personal data and no additional paperwork is required in this regard.
Inperium commits to keep this list updated regularly, to enable Controllers stay informed of the scope of sub-processing associated with Inperium services.
List of Sub-processors
Inperium utilizes both infrastructure and services specific vendors to provide product and services to it’s Controllers (Inperium customers) and end-users. The following is an up-to-date list (as of 25th May 2018) of names and purpose of Inperium sub-processors and 3rd-party vendors:
Infrastructure & Services Sub-processors:
Inperium products and services operate on cloud platforms, listed in the table below. Inperium holds control and access to data hosted on these services, and resides in corresponding data center facilities based on location or choice(plan) of the Controller (Inperium’ customer). Data subsequently remains in the data center unless, shifted to ensure performance and availability of services, or specifically agreed between the Controller and Inperium as per needs of the Controller. The following table describes the services and purpose for which these infrastructure service providers have been engaged.
To be able to provide specific functionality within its products and services, Inperium partners with third-party services. These entities are sub-processors with access to service data (limited to purpose and use of indicated services) and are listed in the table below:
| VENDOR | PURPOSE | DATA CENTERS* | PRODUCTS |
|---|---|---|---|
| Amazon Web Services, Inc. | Primary cloud infrastructure provider for Inperium, where all SaaS applications are hosted. Almost all data stored, processed and transmitted through Inperium products and services resides on Amazon Web Services data centers. | United States European Economic Area | Inperium Sell Inperium Talk |
| SendGrid, Inc. | Email Service Provider - managed mail servers are provided by SendGrid. Emails that are triggered programmatically from the applications are sent via SendGrid. | United States | Inperium Sell Inperium Talk |
| Twilio | Phone calls & SMS provider. Twilio provides a platform to programmatically initiate calls or SMS and also receiving them. Integrated as a service in Inperium application. | United States | Inperium Sell Inperium Talk |
| FullContact Inc. | Identity resolution software for user identification and contact enrichment. Helps obtain social and demographic details of an email or company. | United States | Inperium Sell Inperium Talk |
| Nylas, Inc. | Bi-directional Email, Calendar and Contact synchronization provider. | United States | Inperium Sell Inperium Talk |
| Sentry | Error and performance monitoring tool. Collects anonymous error data. | United States | Inperium Sell Inperium Talk |
*For customers hosted in the EEA datacenter with custom mailbox, only those services are turned on by default, where the specific sub-processor has data centers in the EEA. However, if customers choose to use services like 3rd party integrations and apps, custom apps then data is expected to leave the EEA.
For questions or objections regarding sub-processors please write to support@inperium.com
