ubiDesktop Ltd Subprocessors

Version date 24/05/2018

To support delivery of our Services, ubiDesktop Ltd. (“ubiDesktop”) may engage and use data processors with access to certain Service Data (each, a “Subprocessor”). This page provides important information about the identity, location and role of each Subprocessor.

1. What is a subprocessor
   1. A Subprocessor is a third party data processor engaged by ubiDesktop who has or potentially will have access to or process customer data (which may contain Personal Data). ubiDesktop engages different types of Subprocessors to perform various functions as explained in the tables below.
2. Due Diligence
   1. ubiDesktop undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed Subprocessors that will or may have access to, or process, Service data.
3. Contractual Safeguards
   1. ubiDesktop requires its Subprocessors to satisfy equivalent obligations as those required from ubiDesktop (as a Data Processor) as set forth in either ubiDesktop’s, or the corresponding Subprocessor’s equivalent, Data Processing Addendum (“DPA”), incorporating Standard Contractual Clauses ("SCC") where appropriate, including but not limited to the requirements to:
   2. 1. process Personal Data in accordance with ubiDesktop’s instructions;
      2. in connection with their subprocessing activities, use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, pursuant to applicable data protection laws;
      3. implement and maintain appropriate technical and organisational measures (including measures consistent with those to which ubiDesktop is contractually committed to adhere insofar as they are equally relevant to the Subprocessor’s processing of Personal Data on ubiDesktop’s behalf);
      4. promptly inform ubiDesktop about any actual or potential security breach; and
      5. cooperate with ubiDesktop in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.
   3. This policy does not give users of the Service any additional rights or remedies and should not be construed as a binding agreement. The information here is provided for transparency purposes to illustrate ubiDesktop’s engagement process for Subprocessors as well as to provide the actual list of third party Subprocessors used by ubiDesktop (as of the date of this policy) which ubiDesktop may use in the delivery and support of its Service.
4. Process to engage new subprocessors
   1. As our business grows and evolves, the Subprocessors we engage may also change. We will provide users of the Service with notice of any new Subprocessors to the extent required under the Agreement by posting such updates here. ubiDesktop will provide notice via this policy of updates to the list of Subprocessors that are utilised or which ubiDesktop proposes to utilise to deliver its Service. ubiDesktop undertakes to keep this list updated regularly to enable users of the Service to stay informed of the scope of subprocessing associated with the Service.
   2. Please check back frequently for updates.
   4. The following is an up-to-date list (as of the date of this policy) of the names and locations of ubiDesktop Subprocessors.
5. Infrastructure Subprocessors – Service Data Storage
   1. ubiDesktop operates worldwide infrastructure in co-location and server hosting facilities of our infrastructure partners together with industry leading cloud service providers. ubiDesktop owns and controls logical access to the infrastructure maintained by the entities set forth below, while these entities maintain the physical security of the servers, network and the data center.

   2. Entity Name	Subprocessing Activities	Country(ies)	Adequacy
      Online SAS	Data centre colocation (no access to Service data)	France	ISO 27001
      Amazon Web Services, Inc.	Cloud Service Provider and Email/SMS Service	United States; United Kingdom; Ireland	GDPR Link Privacy Shield ISO 27001 DPA with SCC
      Hetzner Online GmbH	Data centre colocation (no access to Service data)	Germany	ISO 27001 DPA

6. Other Subprocessors
   1. ubiDesktop works with certain third parties to provide specific functionality around and within the Service. These providers are the Subprocessors detailed below. In order to provide the relevant functionality, we may transfer Service data to these Subprocessors. Their use is limited to the indicated activities.

   2. Entity Name	Subprocessing Activities	Country(ies)	Adequacy
      ZenDesk	Customer support services	United States	ISO 27001 DPA with SCC
      Stripe	Outsourced payment management	United States; Europe;	Privacy Policy
      Sofort (Klarna)	Outsourced payment management	Germany	Privacy Policy
      MaxMind	IP Address Lookup	United States	Privacy Policy DPA with SCC
      BulkSMS (Celerity Messaging UK Ltd)	SMS Gateway	United Kingdom	GDPR Link