Privacy Policy – Subprocessors and Subcontractors

BroadSource Group Subprocessors and Subcontractors

Last Updated on 24/05/2018 17:00 AEST

BroadSource Group (“BroadSource”) uses certain subprocessors (including members of the BroadSource Group and third parties, as listed below) to assist it in providing our Products and services.

What is a Subprocessor

A subprocessor is a third party data processor engaged by BroadSource, including entities from within the BroadSource Group, who has or potentially will have access to or process service and marketing related data (which may contain Personal Data).

BroadSource engages different types of subprocessors to perform various functions as explained in the tables below, BroadSource refers to third parties that do not have access to or process Service Data but who are otherwise used to provide the Services as “subcontractors” and not subprocessors.

Due Diligence

BroadSource undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed subprocessors that will or may have access to or process Service Data.

Safeguards

BroadSource requires its subprocessors to satisfy equivalent obligations as those required from BroadSource (as a Data Processor), including but not limited to the requirements to:

  • Only process Personal Data in accordance with data controller’s (i.e. Broadsource or our Subscribers’s) documented instructions (as communicated in writing to the relevant subprocessor by BroadSource)
  • In connection with their subprocessing activities, use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, pursuant to applicable data protection laws
  • Provide regular training in security and data protection to personnel to whom they grant access to Personal Data
  • Implement and maintain appropriate technical and organizational measures (including measures consistent with those to which BroadSource is contractually committed to adhere insofar as they are equally relevant to the subprocessor’s processing of Personal Data on BroadSource’s behalf) and provide an annual certification that evidences compliance with this obligation. In the absence of such certification BroadSource reserves the right to audit the subprocessor
  • promptly inform BroadSource about any actual or potential security breach
  • Cooperate with BroadSource in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.

BroadSource Group Subprocessors

The following entities are part of the BroadSource Group, they act as subprocessors to provide services on behalf of BroadSource:

Entity Country
BroadSource Australia Pty Ltd Australia
BroadSource Europe Limited United Kingdom
BroadSource LLC United States

Third Party Subprocessors

The following third party entities act as subprocessors to provide services on behalf of BroadSource:

Entity Services Provided Subprocessor Location
Zoho Corporation Customer Relationship Management and Email Marketing Services United States
Zendesk Inc Customer Helpdesk and Ticketing Platform United States
Twilio Inc Telephony and SMS Messaging Services United States
Xero Australia Pty Limited Invoicing and Accounting Platform Australia
Microsoft Corporation Office 365 Platform Australia and United States

Subcontractors

The following third party entities act as subcontractors provide service components on behalf of BroadSource:

Entity Services Provided Subprocessor Location
Amazon Web Services Inc Hosting Services and Data Storage United States, Australia and Germany
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