Sub-Processors at Paperturn

To support the delivery of our Services, Paperturn ApS (“Paperturn”, “we”, “our”), may engage and use certain third-party data processors (“Sub-Processors”) to provide our Service to our customers. 


This page provides important information about the identity, location and role of each Sub-processor. Terms used on this page but not defined have the meaning set forth in the Customer Terms and Conditions of Service (the "Agreement") and our Privacy Policy.


We currently use the below list of Sub-Processors to provide infrastructure services, customer support, service administration services, and email notifications. Prior to engaging any third party Sub-processor, Paperturn performs due diligence to evaluate their privacy, security and confidentiality practices, and executes an agreement implementing its applicable obligations.



Infrastructure Sub-Processors

 

Amazon Web Services, Inc

  • Type of Service: Hosting and Infrastructure

  • Purpose: ​​Used for hosting services, file storage and backup services

  • Hosting Region: European Union

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum (DPA) in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes 

  • Link to Legal / Privacy Portal(s): AWS Legal Portal


Google LLC

  • Type of Service: Cloud computing provider, statistical reporting

  • Purpose: Used as a cloud computing provider for flipbook statistics

  • Hosting Region: European Union

  • EU & UK Data Transfer Mechanism: UK Adequacy Decision

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes 

  • Link to Legal / Privacy Portal(s): Google Cloud Terms


Hetzner Online GmBH

  • Type of Service: Hosting and Infrastructure

  • Purpose: Used for hosting services, file storage and backup services

  • Hosting Region: European Union

  • EU & UK Data Transfer Mechanism: UK Adequacy Decision

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Not applicable - A TIA is only required when transferring personal data to a third country outside the EEA not covered by an European Commission adequacy decision.

  • Link to Legal / Privacy Portal(s): Hertzner Data Privacy Portal


Content Delivery Networks (CDN)


Amazon Web Services, Inc

  • Type of Service: Content Delivery Network

  • Purpose: Used for optimising flipbook content delivery

  • Hosting Region: Global

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes 

  • Link to Legal / Privacy Portal(s): AWS Legal Portal


Customer Support, Productivity and Communication Sub-Processors


Mailchimp, Inc.

  • Type of Service: Email service provider

  • Purpose: Used to send marketing-related emails

  • Hosting Region: USA

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed? Yes 

  • Link to Legal / Privacy Portal(s): Mailchimp & the GDPR

 

Mailersend, Inc. 

  • Type of Service: Email service provider 
  • Purpose: Email notification services 
  • Hosting Region: European Union 
  • EU & UK Data Transfer Mechanism: UK Adequacy Decision
  • Is there a Data Processing Addendum in place?: Yes
  • Has a Transfer Impact Assessment (TIA) been performed?: Not applicable - A TIA is only required when transferring personal data to a third country outside the EEA not covered by an European Commission adequacy decision.
  • Link to Legal / Privacy Portal(s): Mailersend Legal Portal

 

PayPal (Europe) S.à r.l. et Cie, S.C.A. (Braintree)

  • Type of Service: Payment gateway

  • Purpose: Used to process Paperturn's client subscriptions

  • Hosting Region: USA

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes 

  • Link to Legal / Privacy Portal(s): Braintree Legal Portal


Paypal

  • Type of Service: Payment Gateway

  • Purpose: Used to process Paperturn's client subscriptions

  • Hosting Region: USA

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes 

  • Link to Legal / Privacy Portal(s): PayPal Technology and Security Certification Reports Portal


HubSpot, Inc.

  • Type of Service: CRM system

  • Purpose: Used to facilitate our internal sales and support processes (including online chat and customer relationship management)

  • Hosting Region: USA

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes

  • Link to Legal / Privacy Portal(s): Hubspot Legal Portal


Monday.com, Ltd.

  • Type of Service: Business administration and project management

  • Purpose: Used for internal project management related to marketing, sales and customer support

  • Hosting Region: USA

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes 

  • Link to Legal / Privacy Portal(s): Monday.com Legal Portal


Ora PM, Ltd.

  • Type of Service: Project management software

  • Purpose: Used internally for registering and monitoring technical support, bugs and new feature requests

  • Hosting Region: USA

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes 

  • Link to Legal / Privacy Portal(s): Ora Legal Portal


Dropbox, Inc. (DropboxSign)

  • Type of Service: E-signature tool

  • Purpose: Used for contract signing, internally and externally

  • Hosting Region: USA

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum in Place?: Yes

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes 

  • Link to Legal / Privacy Portal(s): Dropbox Legal Center


Slack, Inc.

  • Type of Service: Communication Software

  • Purpose: Used for internal employee communication

  • Hosting Region: USA

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes 

  • Link to Legal / Privacy Portal(s): Slack Trust & Privacy Center

 

Visma E-conomic A/S

  • Type of Service: Accounting and financial reporting

  • Purpose: Used for invoicing and financial reporting

  • Hosting Region: European Union

  • EU & UK Data Transfer Mechanism: N/A 

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Not applicable - A TIA is only required when transferring personal data to a third country outside the EEA not covered by an European Commission adequacy decision.

  • Link to Legal / Privacy Portal(s): Visma Trust Center


Google LLC (Google Workspace)

  • Type of Service: Cloud computing and business administration

  • Purpose: Business administration tool used for file storage, internal and external email correspondence and customer meetings

  • Hosting Region: European Union

  • EU & UK Data Transfer Mechanism: UK Adequacy Decision

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes

  • Link to Legal / Privacy Portal(s): Google Cloud Terms


Stripe, Inc.

  • Type of Service: Payment gateway

  • Purpose: Payment gateway for Paperturn's clients to facilitate the sale / monetization of their flipbooks

  • Hosting Region: USA

  • EU & UK Data Transfer Mechanism: SCC

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Yes 

  • Link to Legal / Privacy Portal(s): Stripe Privacy Center


Telavox AB

  • Type of Service: Telecommunications provider

  • Purpose: To manage support and contact requests received via phone

  • Hosting Region: European Union

  • EU & UK Data Transfer Mechanism: N/A

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Not applicable - A TIA is only required when transferring personal data to a third country outside the EEA not covered by an European Commission adequacy decision.

  • Link to Legal / Privacy Portal(s): Telavox Privacy Portal


Maetzler Rechtsanwalts GmbH & Co KG (Prighter.com)

  • Type of Service: Data Subject Access Request (DSAR) Software 

  • Purpose: To manage and facilitate data subject requests pertaining to the GDPR and other privacy regulations as well as Paperturn's UK GDPR representative

  • Hosting Region: European Union

  • EU & UK Data Transfer Mechanism: N/A

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Not applicable - A TIA is only required when transferring personal data to a third country outside the EEA not covered by an European Commission adequacy decision.

  • Link to Legal / Privacy Portal(s): Prighter Privacy Policy


Matomo

  • Type of Service: Analytics infrastructure provider

  • Purpose: To provide Paperturn's website analytics and performance data

  • Hosting Region: European Union

  • EU & UK Data Transfer Mechanism: N/A

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Not applicable - A TIA is only required when transferring personal data to a third country outside the EEA not covered by an European Commission adequacy decision.

  • Link to Legal / Privacy Portal(s): Matomo Privacy Policy

 

Visitor Queue 

  • Type of Service: Lead Generation Tool

  • Purpose: Used to facilitate our internal sales via website visitor recognition

  • Hosting Region: Canada

  • EU & UK Data Transfer Mechanism: Adequacy Decision

  • Is there a Data Processing Addendum in place?: Yes 

  • Has a Transfer Impact Assessment (TIA) been performed?: Not applicable
  • Link to Legal / Privacy Portal(s): Visitor Queue Privacy Policy

 

 

Updates

As our business grows and evolves, the Subprocessors we engage may also change. We will endeavor to provide the owner of Customer’s account with notice of any new Subprocessors to the extent required under the Agreement.

 

Last updated: 01.02.2024 


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