Sub-Processor Policy

Buildworks uses certain sub-processors (including members of the Buildworks Group and third parties, as listed below) to assist it in providing the Buildworks Services as described in the Master Subscription Agreement (“MSA”). Defined terms used herein shall have the same meaning as defined in the MSA.

What is a Sub-processor
A sub-processor is a third party data processor engaged by Buildworks, including entities from within the Buildworks Group, who has or potentially will have access to or process Service Data (which may contain Personal Data). Buildworks engages different types of sub-processors to perform various functions as explained in the tables below.

Due Diligence
Buildworks undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed sub-processors that will or may have access to or otherwise process Service Data.

 

Contractual Safeguards
Buildworks generally requires its sub-processors to satisfy equivalent obligations as those required from Buildworks (as a Data Processor) as set forth in Buildworks’ Data Processing Agreement (“DPA”), including but not limited to the requirements to:

•    Process Personal Data in accordance with data controller’s (i.e. Subscriber’s) documented instructions (as communicated in writing to the relevant sub-processor by Buildworks);
•    In connection with their sub-processing 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 Buildworks is contractually committed to adhere to insofar as they are equally relevant to the sub-processor’s processing of Personal Data on Buildworks’ behalf) and provide an annual certification that evidences compliance with this obligation. In the absence of such certification Buildworks reserves the right to audit the sub-processor;
•    Promptly inform Buildworks about any actual or potential security breach; and
•    Cooperate with Buildworks in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.

The following is a list of the names and locations of Buildworks sub-processors (including members of the Buildworks Group and third parties):

 

Infrastructure Sub-processors – Service Data Storage and Processing
Buildworks owns or controls access to the infrastructure that Buildworks uses to host and process Service Data submitted to the Services, other than as set forth herein. Currently, the Buildworks production systems used for hosting Service Data for the Services are located in Europe and in the infrastructure sub-processors listed below. Subscriber accounts are typically established in one of these regions based on where the Subscriber is located, but may be shifted among locations to ensure performance and availability of the Services. The following table describes the countries and legal entities engaged by Buildworks in the storage of Service Data. Buildworks also uses additional services provided by these sub-processors to process Service Data as needed to provide the Services.

Entity Name                             Entity Type                        Entity Country
Amazon Web Services, Inc.    Cloud Service Provider    Ireland

 

Buildworks Group Sub-processors
The following entities are members of the Buildworks Group. Accordingly, they function as sub-processors to provide the Services.

Entity Name                                 Country
Buildworks America, Inc.            United States
Build.works technologies OÜ    Estonia
 

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