In light of the Schrems II decision from last year, which invalidated Privacy Shield, we're adding Hetzner (Germany) and Scaleway S.A.S. (France) as sub-processors. We plan to use Hetzner to host most of our infrastructure in the EU (instead of DigitalOcean), while Scaleway will be used to store recordings long term for our upcoming
We will continue to use existing sub-processors (DigitalOcean and AWS), but mainly for our non-EU regions.
Other changes to the sub-processors list in our DPA:
- Amazon Web Services, Inc (USA) is being replaced by Amazon Web Services EMEA SARL (Luxembourg), another wholly owned subsidiary of Amazon.com, Inc. . Starting with 1 July 2018 AWS started selling to Europe, the Middle East, and Africa from their Luxembourg-based AWS entity.
- Three Hearts Digital Ltd (EmailOctopus) is being removed from this list since they've never been used as sub-processors for data for which we are processors (recordings related data).
- We're adding Webdev S.R.L. (Romania) to the list. This company has been used to host the https://addpipe.com website and the account area and it needs to be part of the list.
As per our current DPA:
10.1 Pipe shall (i) provide an up-to-date list of the Sub-processors it has appointed upon written request from Customer; and (ii) notify Customer (for which email shall suffice) if it adds or removes Sub-processors at least 10 days prior to any such changes.
10.2 Customer may object in writing to Pipe’s appointment of a new Sub-processor within five (5) calendar days of such notice, provided that such objection is based on reasonable grounds relating to data protection. In such event, the parties shall discuss such concerns in good faith with a view to achieving resolution. If this is not possible, Customer may suspend or terminate the Agreement (without prejudice to any fees incurred by Customer prior to suspension or termination).
Here's the complete updated list of sub-processors. A new version of the DPA document is available which contains the new list.
You can object in writing to firstname.lastname@example.org .