Brightback Subprocessors and Subcontractors

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.

Due Diligence

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.

Contractual Safeguards

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

Segment

Tracking

All

United States

Mixpanel

Reporting

All

United States

Fullstory

Tracking

All

United States

Sendgrid

Bulk Email

All

United States

Google Analytics

Tracking

All

United States

Subcontractors & Content Delivery Networks

As explained above, Brightback also uses certain “subcontractors” to assist in the operations necessary to provide the Brightback Services. The following is a list of the names and locations of material third-party subcontractors.  

Entity Name Entity Type Location
Shrine Development

United States

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
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