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To support the delivery of our services, Appfarm AS may engage and use data processors with access to certain customer data (each, a "data processor"). This page provides vital information about each processor's identity, location, and role. Terms used on this page but not defined have the meaning outlined in the Software Service Agreement or superseding written agreements between the Customer and Appfarm.
Appfarm and its affiliates engage the following third-party entities to assist in connection with the Service as specified below:
* Customer data is continuously stored (and backed up) as long as the customer has an active Appfarm subscription. Customer data is stored up to 1 year after a subscription is canceled (if not otherwise instructed by the customer) to facilitate the customer's data transfer procedures.
*** Data is sent to the closest Cloudflare edge node to the user. For users in Norway, this is Oslo; in other countries, it is most likely the country of origin.
**** Most data is deleted automatically according to Twilio's retention schedule within a maximum of 37 days. Twilio does retain some email event data in pseudonymized form (not including the message body content) for up to a year for security, fraud detection, anti-abuse, and network protection purposes.
* Customer data is continuously stored (and backed up) as long as the customer has an active Appfarm subscription. Customer data is stored up to 1 year after a subscription is canceled (if not otherwise instructed by the Customer) to facilitate the Customer's data transfer procedures.
As our business grows and evolves, the data processors we engage may also change. We will endeavor to provide the owner of the Customer's account with notice of any new data processors to the extent required under the Agreement, along with posting such updates here. Please check back frequently for updates.
Appfarm has, as of today, added new data processors to the list. The new processors are:
- Twilio, Inc.: an email handling and email address validation system, connected to the Service. Twilio is a participant in the Data Privacy Framework (DPF),
- Zendesk, Inc.: a customer support system,
- Hotjar Ltd.: an analytics tool used on Appfarm's website.
The following companies listed as data processors have, since the last update, become participants of the DPF:
- Notion Labs, Inc.
The EU–US Data Privacy Framework is a transatlantic data transfer framework between the United States and the European Union. The European Commission adopted its adequacy decision for the framework on July 10, 2023. The adequacy decision concludes that the United States ensures an adequate level of protection for personal data transferred from the EU to companies participating in the EU-U.S. Data Privacy Framework. With the adoption of the adequacy decision, European entities are able to transfer personal data to participating companies in the United States without having to put in place additional data protection safeguards. Although Appfarm has put in place necessary safeguards (e.g., standard contractual clauses) with all US-based data processors outlined above, this decision will apply to all US-based data processors participating in the framework as the US is now considered a secure third country under GDPR.
The following companies listed as data processors in a third country currently not listed in the Data Privacy Framework are:
- Mailgun Technologies, Inc.
- Notion Labs, Inc.
- Docspring, Inc.
- Civilized Discourse Construction Kit, Inc.
- EdInvent, Inc.
Appfarm has engaged in dialog with the companies in question regarding their timeline to get registered on the list of the Data Privacy Framework.
Appfarm has discontinued use of Atlassian Inc. and their service Trello.
Appfarm has added new data processors in order to provide our existing and prospective customers, users, and partners with an improved and more comprehensive product offering:
- Notion Labs, Inc. (with its service Notion): Internal communication tool, process management, and project management system.
- Contractbook ApS (with its service Contractbook): Contract management platform
- Webflow, Inc. (with its service Webflow): Website services
- Civilized Discourse Construction Kit, Inc. (with its service Discourse): Community and forum platform used to organize engagement and processes
- Docspring, Inc. (with its service Docspring): PDF template management and API service
- Teamtailor AB (with its service Teamtailor): Applicant tracking system
None of these new data processors are directly connected to the Service but offer services Appfarm uses for auxiliary business activities, of which some customer data may be processed.
Appfarm has, as of today, discontinued Freshworks, Inc. and its service Freshworks as a data processor.
Appfarm has, as of today, added EdInvent, Inc. and Mettl Technologies, Inc. as new data processors. Both vendors are used in relation to our certification program and are not connected to the Service.
Appfarm has, as of today, added HubSpot, Inc. as a new data processor. Hubspot is used as a customer relationship management (CRM) system and is not connected to the Service. HubSpot offers regional data hosting, and all data is located in HubSpot’s product infrastructure hosted on Amazon Web Services (AWS) in Germany.
Appfarm has, as of today, added Amazon Web Services (AWS) as a new data processor for the Service processing Customer personal data. The current use of AWS in the Service will be restricted to the use of the Amazon Simple Email Service (SES). Other AWS services may be used at a later time.
The reason for the change is that several Appfarm customers have, at times, experienced poor delivery times with the internal Appfarm email service, which, among others, is used for the delivery of PIN codes for user authentication purposes. The Appfarm engineering team has concluded that the current vendor and data processor (Mailgun Technologies) should be replaced with a more reliable service to secure the highest service quality of the Service.
All Appfarm customers have been notified of the change. In line with the Appfarm Data Processing Agreement (section 7.2), the new data processor will not take effect and become active in use in the Service until 30 days (September 17th, 2021) if not otherwise instructed by Appfarm customers.
Although, in the light of European Court of Justice decision C-311/18 (Schrems-II), in which Privacy Shield as grounds for data transfers to third countries was invalidated, Appfarm is still ensuring that its third-party data processors are compliant with the GDPR framework, either by implementing Standard Contractual Clauses ensuring the same level of protection for its users or similar grounds accepted by the EDPB. This includes but is not limited to, already existing service providers and service providers in the future.
Last modified 20d ago