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Overview

Under Section 5 of the DPA, the Customer gives Cloudpepper general written authorisation to engage the Sub-processors listed below. Cloudpepper imposes on each Sub-processor, in substance, the same data protection obligations as the DPA imposes on Cloudpepper for the processing delegated to it, and remains liable to the Customer for their performance as set out in the DPA.

Current sub-processors

The following Sub-processors are authorised as at the “Last updated” date shown above. Capitalised terms have the meaning given to them in the DPA.

Sub-processorPurpose of processingLocationTransfer mechanism
Amazon Web Services EMEA SARLCloud infrastructure and data hosting for the Cloudpepper management platform.EEA (Belgium / Ireland regions)N/A (EEA)
Google Cloud EMEA LimitedCloud infrastructure and data hosting for the Cloudpepper management platform.EEA (Belgium region)N/A (EEA)
OVH SAS (OVHcloud)Backup storage and Kubernetes-based workloads relating to Customer environments.EEA (France)N/A (EEA)
UpCloud LtdHosting infrastructure for the Dedicated Performance deployment tier of the managed Odoo Service.EEA (Customer-selected region; non-EEA available on request)SCCs (where applicable)
The Constant Company, LLC (Vultr)Hosting infrastructure for the High Performance deployment tier of the managed Odoo Service.EEA (Customer-selected region; non-EEA available on request)SCCs
Cloudflare, Inc.CDN, DDoS protection and edge security in front of the Services.Global edge; primary processing EU/USSCCs
Crisp IM SASCustomer support chat, ticketing and support communications, including information the Customer submits for troubleshooting.EEAN/A (EEA)
Functional Software, Inc. (Sentry)Application error monitoring for the Cloudpepper platform.EEA (Germany data region)N/A (EEA); SCCs under Sentry’s DPA for any support access from outside the EEA
Google Ireland Limited (Google Workspace)Company e-mail, including support correspondence.EEA / USSCCs (Google Workspace Data Processing Addendum)

Customer-chosen infrastructure

Where a customer deploys the Services on infrastructure it procures directly from a provider of its choice (any data centre, any provider, any country), that provider is engaged by the customer, not by Cloudpepper, and is not a Sub-processor. The customer is responsible for the data protection arrangements with that provider, including a data processing agreement and any transfer mechanism required for transfers outside the EEA. See Section 6 of the DPA.

Providers that are not sub-processors

Providers that do not process Customer Data are not Sub-processors: for example payment processing (Stripe), accounting and ERP (Odoo SA) and marketing e-mail (Klaviyo). They process data that Cloudpepper itself controls. See Section 5.2 of the DPA and our Privacy Policy.

Notice of changes

Before Cloudpepper adds or replaces a Sub-processor, it e-mails the contact address on the Customer’s account and updates this page. The notice identifies the provider, its role, its locations and the transfer mechanism, and allows at least fourteen (14) days before the new Sub-processor processes Customer Data (DPA, Section 5.4). Keep the contact address on your account current.

Right to object

Under Section 5.5 of the DPA, the Customer may object within the notice period on reasonable grounds relating to data protection. The parties discuss the objection in good faith. Cloudpepper is not obliged to provide an alternative to the notified change. If no solution is found, either party may terminate the affected Services by written notice before the new Sub-processor processes the Customer’s data, without penalty.

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