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
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