Third Party Subprocessors

Last reviewed: August 2023

 

Vendor: Amazon Web Services (AWS)

Website: https://aws.amazon.com

Purpose: Database and hosting

Type of personal data processed: Learner Course usage details

Location of processing: Server region set by Elucidat – currently AWS EU (Dublin) Region. (Amazon Web Services EMEA SARL)

Compliance mechanism for ex-EEA transfer: N/A: Contracted not to move data from the AWS region selected by Elucidat

Article 28 Data Processing Agreement: AWS GDPR Data Processing Addendum, part of Service Terms at clause 83 of Service Terms

 

 

Vendor: Elucidat Inc.

Website: https://elucidat.com

Purpose: Process for purpose of sales and technical support as affiliate of Elucidat Group

Type of personal data processed: Learner Course usage details

Location of processing: Processing happening locally in North Carolina

Compliance mechanism for ex-EEA transfer: Standard Contractual Clauses (see our Licence Agreement)

Article 28 Data Processing Agreement: Intra-Group Data Transfer Agreement

 

 

Vendor: Intercom

Website: https://www.intercom.com

Purpose: Customer communication system

Type of personal data processed: Learner Course usage details

Location of processing: US, EEA and UK

Compliance mechanism for ex-EEA transfer: Standard Contractual Clauses

Article 28 Data Processing Agreement: Data Processor Agreement in place complying with Article 28 GDPR 

 

 

Vendor: SendGrid

Website: https://sendgrid.com

Purpose: Cloud-based email delivery platform

Type of personal data processed: Existing Author App usage & Learner Contact details

Location of processing: US and UK

Compliance mechanism for ex-EEA transfer: Standard Contractual Clauses

Article 28 Data Processing Agreement: Data Processor Agreement in place complying with Article 28 GDPR + Signed DPA + Signed DPA in place containing EC Standard Contractual Clauses

 

 

Vendor: Zendesk

Website: https://www.zendesk.co.uk

Purpose: Customer support platform

Type of personal data processed: Learner Course usage details

Location of processing: UK, EU & US

Compliance mechanism for ex-EEA transfer: Signed DPA in place containing EC Standard Contractual Clauses

Article 28 Data Processing Agreement: Data Processor Agreement in place complying with Article 28 GDPR

 

OPTIONAL THIRD PARTY SUBPROCESSORS

The following third party subprocessors will only be in effect when utilising Elucidat Create, our new authoring experience, and only when the optional Artificial Intelligence features are turned on. These subprocessors are not utilised in Elucidat Author, our existing authoring experience. 

Whether or not these subprocessors are in use is determined at the Account level. Individual Authors or Learners are not able to opt out of these subprocessors being utilised if the Account Administrator has enabled them. 

 

Vendor: OpenAI (Developer API)

Website: https://openai.com/

Purpose: Provision of AI powered course creation features

Type of personal data processed: Course content which may at times include Personally Identifiable Information if an Author chooses

Location of processing: UK, EU & US

Compliance mechanism for ex-EEA transfer: Signed DPA in place containing EC Standard Contractual Clauses

Article 28 Data Processing Agreement: Data Processor Agreement in place complying with Article 28 GDPR 

 

Vendor: Grammarly (Developer API)

Website: https://www.grammarly.com/

Purpose: Provision of proofreading and text improvement services during course creation

Type of personal data processed: Course content which may at times include Personally Identifiable Information if an Author chooses

Location of processing: UK, EU & US

Compliance mechanism for ex-EEA transfer: Signed DPA in place containing EC Standard Contractual Clauses

Article 28 Data Processing Agreement: Data Processor Agreement in place complying with Article 28 GDPR

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