Brightback Subprocessors and Subcontractors
Brightback, Inc. (“Brightback”) uses certain subprocessors (including members of Brightback, Inc. and third parties, as listed below), subcontractors and content delivery networks to assist it in providing the Brightback Services.
What is a Subprocessor?
A Subprocessor is a third party data processor engaged under Brightback's Data Protection Addendum, to process Customer Personal Data in relation to the Services. Customer Personal Data means any personal data contained within the data provided to or accessed by Brightback by or on behalf of Customer or Customer end users in connection with the Services. Brightback engages different types of subprocessors to perform various functions as explained in the tables below. Brightback refers to third parties that do not have access to or process Service Data but who are otherwise used to provide the Services as “subcontractors” and not subprocessors.
Brightback 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.
Brightback requires its subprocessors to satisfy equivalent obligations as those required from Brightback (as a Data Processor) as set forth in Brightback’s Data Processing Agreement ("DPA").
Process to Engage New Subprocessors
For all Subscribers who have executed Brightback’s standard DPA, Brightback will provide notice via this policy of updates to the list of subprocessors that are utilized or which Brightback proposes to utilize to deliver its Services. Brightback undertakes to keep this list updated regularly to enable its Subscribers to stay informed of the scope of subprocessing associated with the Brightback Services.
Infrastructure Subprocessors – Service Data Storage
Brightback owns or controls access to the infrastructure that Brightback uses to host Service Data submitted to the Services, other than as set forth below. Currently, the Brightback production systems for the Services are primarily located in co-location facilities in the United States via AWS. The following table describes the countries and legal entities engaged by Brightback in the storage of Service Data.
|Entity Name||Entity Type||Entity Country|
|Amazon Web Services Inc.||Cloud Service Provider||United States|
Service Specific Subprocessors
Brightback works with certain third parties to provide specific functionality within the Services. These providers are the Subprocessors set forth below. In order to provide the relevant functionality, these Subprocessors access Service Data. Their use is limited to the indicated Services.
|Entity Name||Purpose||Applicable Services||Entity Country|
|Help Scout||Help Desk||All||United States|
|Github||Source Control||All||United States|
|Google Analytics||Tracking||All||United States|
|Salesforce||Customer Relationship Management||All||United States|
|Amazon SES||Transactional Email||All||United States|
|Autopilot||Marketing Automation||All||United States|
|Amplitude||Product Analytics||All||United States|
|Stripe||Billing and Invoicing||All||United States|
Subcontractors & Content Delivery Networks
As explained above, Brightback’s Services may use content delivery networks (“CDNs”) to provide the Services, for security purposes, and to optimize content delivery. CDNs do not have access to Service Data but are commonly used systems of distributed services that deliver content based on the geographic location of the individual accessing the content and the origin of the content provider. Website content served to website visitors and domain name information may be stored with a CDN to expedite transmission, and information transmitted across a CDN may be accessed by that CDN to enable its functions. The following describes use of CDNs by Brightback’s Services.
|CDN Provider||CDN Services||Location||Description|
|Amazon Web Services, Inc.||All||Global||Public Website Content|