Sub-Processors

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Textel uses certain sub-processors to assist in providing Textel’s services. A sub-processor is a third party company engaged by Textel to process data, which may include customers’ personal data (i) on behalf of Textel customers; (ii) in accordance with customer instructions as communicated by Textel (typically as set out in Textel’s Terms of Service and Acceptable Use and Privacy Policies); and (iii) in strict accordance with the terms of a written contract between Textel and the sub-processor. Generally, Textel contractually obligates its sub-processors to implement appropriate technical and organizational measures to ensure that the sub-processing of data is protected to the standards required by applicable data protection laws. Further information relating to sub-processor security measures can be found via the external links below and by reviewing such sub-processors’ websites. Where the engagement of a sub-processor requires the cross-border transfer of personal data, Textel has performed transfer impact assessments for such data transfer or otherwise complied with applicable data protection laws. Textel maintains an up-to-date list of the names and locations of all sub-processors below. Textel customers may check this page for updates to sub-processors.

Sub-processorApplicable Capacity Service(s)Subject matter of processingNature and purpose of processingLocation
Microsoft
Azure
Infrastructure ProviderPersonal data contained in communications sent through Textel’s servicesHosting services and storageUSA for US-based services
EUforEU& UK-based services
Microsoft
O365
Email and Data StoragePersonal data contained in communications sent through Textel’s emailCommunicationsUSA

3NNUX
Implementation and SupportPersonal data contained in communications sent through Textel’s servicesSolution implementation and customer support
Philippines

ChargeOver
Automated Invoicing Software
Billing information

Customer billing
USA

Maxio
Automated Invoicing Software
Billing information

Customer billing
USA
SalesforceSalesforceCustomer personal contact dataCustomer communicationUSA
DatadogLog MonitoringData logsInfrastructure status monitoringUSA for US-based services
EUforEU& UK-based services
StackifyLog Monitoring Data logsInfrastructure status monitoringUSA
BandwidthSMS Text CarrierPersonal data contained in SMS communicationsSMS text carrierUSA for US-based services
EUforEU& UK-based services
iConnectiveSMS Text CarrierPersonal data contained in SMS communicationsSMS text carrierUSA
SinchSMS Text CarrierPersonal data contained in SMS communicationsSMS text carrierUSA for US-based services
EUforEU& UK-based services
SyniverseSMS Text CarrierPersonal data contained in SMS communicationsSMS text carrierUSA for US-based services
EUforEU& UK-based services
TwilioSMS Text CarrierPersonal data contained in SMS communicationsSMS text carrierUSA
ZipwhipSMS Text CarrierPersonal data contained in SMS communicationsSMS text carrierUSA

Duration of processing: For each sub-processor above, processing of personal data will be for the duration that the customer uses and continues to use the applicable features of Textel’s services, and for the retention periods as set out in customer’s agreement with Textel.

Our Terms of Service: Textel’s Terms of Service generally provides that Customer(s) may authorize and provide access to Textel Company Properties (defined therein) to individuals, affiliates (including their users), or another entity (including its users) through Customer’s Account. Customer is solely responsible for all use of the Account and all Services through the Account by each User.

Furthermore, in the Terms of Services, Customer, warrants that the holder of any worldwide intellectual property right, including moral rights, in Customer’s Content (as defined in the Terms of Service), has completely and effectively waived all such rights and validly and irrevocably granted to Customer the right to grant the license stated above. Customer have will maintain the applicable permissions, authorizations, and consents (via its employee handbook, privacy policy

or otherwise) for Textel to access, use, disclose, Make Available (as defined in the Terms of Service), store and process Customer’s Content as permitted thereunder. Customer agree that Customer, not Textel, is responsible for all of Customer’s Content that it Makes Available on or in the Services.