Sub-processors are third-party businesses engaged by a processor for performing data processing on behalf of a controller. According to the GDPR, these companies are also accountable for protection of an individual’s personal data. Data protection obligations of sub-processors are to be established by way of contract or other legal acts under the Union or Member State law. This includes providing sufficient guarantees to implement appropriate technical and organizational measures as specified in the regulation.
Priority Reply Networks ("PRN") uses sub-processors (listed below), to assist in providing services as described in the our Terms of Service or a similar services agreement customers may have signed with us.
PRN partners with organizations, that like itself adhere to global standards and regulations. Apart from evaluation for technical requirements, PRN ensures examination of data protection measures, compliance with PRN’s security requirements and security audit reports before close of contract. Initial agreements include review and approval of - provision for breach notification in the event of unwarranted data incidents, and necessary security measures for data protection.
As part of PRN's revised Terms of Service & Privacy Notice for compliance, PRN provides all EU customers a data processing addendum (DPA) that covers its obligations under the GDPR. You can find our DPA here. It automatically applies to processing of EU personal data and no additional paperwork is required in this regard.
RRN commits to keep this list updated regularly, to enable Controllers stay informed of the scope of sub-processing associated with PRN services.
List of Sub-processors
PRN utilizes both infrastructure and services specific vendors to provide product and services to it’s Controllers (PRN customers) and end-users. The following is an up-to-date list (as of 25th May 2018) of names and purpose of PRN sub-processors and 3rd-party vendors:
Infrastructure & Services Sub-processors:
PRN products and services operate on cloud platforms, listed in the table below. PRN holds control and access to data hosted on these services, and resides in corresponding data center facilities based on location or choice(plan) of the Controller (PRN's customer). Data subsequently remains in the data center unless, shifted to ensure performance and availability of services, or specifically agreed between the Controller and PRN as per needs of the Controller. The following table describes the services and purpose for which these infrastructure service providers have been engaged.
To be able to provide specific functionality within its products and services, PRN partners with third-party services. These entities are sub-processors with access to service data (limited to purpose and use of indicated services) and are listed in the table below:
VENDOR; PURPOSE; DATA CENTERS
Amazon Web Services, Inc.; Primary cloud infrastructure provider for PRN, where all SaaS applications are hosted. Almost all data stored, processed and transmitted through PRN products and services resides on Amazon Web Services data centers; United States
Twilio; Phone calls & SMS provider. Twilio provides a platform to programmatically initiate calls or SMS and also receiving them. Integrated as a service in PRN application; United States
Anveo; Call Recording. Anveo provides call recording services to the SaaS platform; United States
For questions or objections regarding sub-processors please write to email@example.com