In our ongoing commitment to delivering an exceptional customer experience, we've updated the list of authorized sub-processors for Happeo. Learn more about the changes below.
What is a sub-processor?
A sub-processor is a company that is engaged by a data processor to process personal data on behalf of the data controller. For example, if Happeo engages Hubspot Ireland, Ltd to process its customers' data, Hubspot Ireland, Ltd. would be considered a sub-processor.
Here are Happeo's new sub-processors added to the list:
|
Sub-processor
|
Purpose
|
Processing location
|
| Google Cloud EMEA Limited |
Rerouting data locally to make our services faster and more reliable. |
Main processing in the EU. Processing may occur worldwide as data is rerouted through a processing center located nearest to the user. |
| Amazon Web Services EMEA SARL |
Improve the performance of the services and ensure better disaster recovery. |
Worldwide (data is rerouted through a processing center located nearest to the user). |
| Hubspot Ireland, Ltd |
To improve our offering and enable your platform admins to engage users even better. |
EU and USA |
| Fivetran, Inc. |
Importing data from selected tools in order to better develop the services and provide you with an enhanced offering. |
USA |
Find more information about each of these sub-processors below:
Google Cloud EMEA Limited
What is changing in Happeo’s use of the Google Cloud Platform (GCP)?
In order to make our services faster and more reliable, we have added the possibility for data processed by Google to also be rerouted locally. As an example, this means that for a user located in Asia, viewing an image within the services, the image will be rerouted from the Google EU hosting location through the data center closest to the user in Asia. If you only have users within the EU, this does not affect your organization.
Additionally, the main processing location will be changed so that processing is possible in any GCP EU location. This change is made because some GCP services are hosted in multiple EU regions and replicated to other GCP EU locations in order to cover situations where a specific data center is down.
Why is Happeo making this change?
In order to make our service faster and more reliable, especially to users outside the EU.
What type of data will Google process?
The scope of data processed by Google will not change and therefore, no new categories of data will be processed.
Where do GCP’s processing activities occur?
The main processing location is still in the EU, as specified in the sub-processor list. However, data will now be rerouted locally, meaning that processing can occur outside the EU as well, depending on where a user is located. Processing will only take place in the EU if all of your users are located within the EU.
What is the GDPR transfer mechanism to Google?
Transfers outside the EU are subject to Module 3 of the EU Standard Contractual Clauses (Transfer processor to processor). Google, LLC is certified under the EU-U.S. Data Privacy Framework.
How did Happeo vet GCP’s security practices and how can I learn more?
Google Cloud Platform provides a world-class secure environment for running applications and processing data. Their security practices have continued to evolve in alignment with industry best practices ever since we deployed the first version of Happeo there many years ago. More information can be found here.
Amazon Web Services EMEA SARL
What Amazon Web Services (AWS) offerings will Happeo be using?
Happeo will use AWS services, such as CloudFront (Content Delivery Network) and S3 (Cloud Object Storage), that will enable us to deliver content quickly, ensuring high availability and business continuity.
Why is Happeo making this change?
We have added Amazon Web Services EMEA SARL as a sub-processor in order to improve the performance of the service. The AWS content delivery network will be used in addition to Google in order to be able to provide optimal performance of the Happeo platform in situations where one provider has issues in delivery. Similarly to Google, content will be cached through local data centers closest to the user accessing the services. We are also in the process of storing an additional backup of the platform with Amazon Web Services in order to provide a more dependable solution in case recovery is needed.
What type of data will AWS process?
In the beginning the type of data processed by AWS will be limited to uploaded images and IP addresses. Later, with the intention to store a backup in AWS, the scope of processing, and thus the type of data, will be the same as with Google.
Where do AWS’s processing activities occur?
Mainly in the EU, however, data will now be rerouted locally, meaning that processing can occur outside the EU as well, depending on where a user is located. Processing will only take place in the EU if all of your users are located within the EU.
What is the GDPR transfer mechanism to AWS?
Transfers outside the EU are subject to Module 3 of the EU Standard Contractual Clauses (Transfer processor to processor). Amazon Web Services, Inc. is certified under the EU-U.S. Data Privacy Framework.
How did Happeo vet AWS’s security practices and how can I learn more?
Happeo performs an internal review of all new sub-processors, including their security measures, to ensure that they conform to the required standards. Happeo follows best security practices on AWS by ensuring all data are encrypted in transit and at rest. We further enhance access control security with strong IAM policies with the least privileges permissions and multi-factor authentication to reduce the risk of authorized access. See here for AWS’s security measures.
Hubspot Ireland, Ltd
What Hubspot services will Happeo be using?
Hubspot is the customer relationship management (CRM) tool in use at Happeo.
Why is Happeo making this change?
Hubspot has been added to the list in order to improve our offering and enable your platform admins to engage users even better. As a result of this update, we will be able to e.g. send your admins personalized suggestions on how to enhance the use of your Happeo.
What type of data will Hubspot process?
The type of data processed will include, for example, the names, user roles, and emails of admins.
Where do Hubspot’s processing activities occur?
Processing by Hubspot takes place in the USA.
What is the GDPR transfer mechanism to Hubspot?
The primary transfer mechanism is the EU-U.S. Data Privacy Framework and secondarily Module 3 of the EU Standard Contractual Clauses apply (Transfer processor to processor).
How did Happeo vet Hubspot’s security practices and how can I learn more?
Happeo performs an internal review of all new sub-processors, including their security measures, to ensure that they conform to the required standards. See here for Hubspot’s security measures.
Fivetran, Inc.
What Fivetran service will Happeo be using?
Happeo will use Fivetran Connectors to streamline data integration.
Why is Happeo making this change?
Fivetran, Inc. has been added as a sub-processor in order to be able to import data from selected tools, e.g. Hubspot, to be processed in Happeo’s own systems. Having the required data in-house allows us to better develop the service and provide you with an enhanced offering.
What type of data will Fivetran process?
The type of data processed will depend on the data that is imported. If data is imported from Hubspot, Fivetran will process that data.
Where do Fivetran’s processing activities occur?
Fivetran is a US-based company and is certified under the EU-U.S. Data Privacy Framework. However, Happeo has chosen Fivetran data residency to be in the EU, which entails that data will be processed in the EU.
How did Happeo vet Fivetran’s security practices and how can I learn more?
Happeo performs an internal review of all new sub-processors, including their security measures, to ensure that they conform to the required standards. See here for Fivetran’s security measures.
