Subprocessors and Subcontractors

New Edge Solutions, LLC (“bucket.io”) uses certain subprocessors, subcontractors and content delivery networks to assist it in providing the bucket.io Services as described in the Terms of Service (TOS). Defined terms used herein shall have the same meaning as defined in the TOS.

What is a Subprocessor:

A subprocessor is a third party data processor engaged by bucket.io, who has or potentially will have access to or process Service Data (which may contain Personal Data). Bucket.io engages different types of subprocessors to perform various functions as explained in the tables below. bucket.io refers to third parties that do not have access to or process Service Data but who are otherwise used to provide the Services as “subcontractors” and not subprocessors.

Due Diligence:

bucket.io undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed subprocessors that will or may have access to or process Service Data.

Contractual Safeguards:

bucket.io requires its subprocessors to satisfy equivalent obligations as those required from bucket.io (as a Data Processor) as set forth in bucket.io’s 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 subprocessor by bucket.io);
in connection with their subprocessing 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 bucket.io is contractually committed to adhere insofar as they are equally relevant to the subprocessor’s processing of Personal Data on bucket.io’s behalf) and provide an annual certification that evidences compliance with this obligation. In the absence of such certification bucket.io reserves the right to audit the subprocessor;
promptly inform bucket.io about any actual or potential security breach; and cooperate with bucket.io in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.

This policy does not give Subscribers any additional rights or remedies and should not be construed as a binding agreement. The information herein is only provided to illustrate bucket.io’s engagement process for subprocessors as well as to provide the actual list of third party subprocessors, subcontractors and content delivery networks used by bucket.io as of the date of this policy (which bucket.io may use in the delivery and support of its Services).

If you are a bucket.io Subscriber and wish to enter into our DPA, please see our article on how to sign a DPA at http://help.bucket.io.

Process to Engage New Subprocessors:

For all Subscribers who have executed bucket.io’s standard DPA, bucket.io will provide notice via this policy of updates to the list of subprocessors that are utilized or which bucket.io proposes to utilize to deliver its Services. bucket.io undertakes to keep this list updated regularly to enable its Subscribers to stay informed of the scope of subprocessing associated with the bucket.io Services.

Pursuant to the DPA, a Subscriber can object in writing to the processing of its Personal Data by a new subprocessor within thirty (7) days after updating of this policy and shall describe its legitimate reasons to object. If Subscriber does not object during such time period the new subprocessor(s) shall be deemed accepted.

If a Subscriber objects to the use of a subprocessor pursuant to the process provided under the DPA, bucket.io shall have the right to cure the objection through one of the following options (to be selected at bucket.io’s sole discretion):

bucket.io will cease to use the subprocessor with regard to Personal Data;
bucket.io will take the corrective steps requested by Subscriber in its objection (which remove Subscriber’s objection) and proceed to use the subprocessor to process Personal Data; or
bucket.io may cease to provide or Subscriber may agree not to use (temporarily or permanently) the particular aspect of a bucket.io Service that would involve use of the subprocessor to process Personal Data.

Termination rights, as applicable and agreed, are set forth exclusively in the DPA.

The following is an up-to-date list (as of the date of this policy) of the names and locations of bucket.io subprocessors, subcontractors and content delivery networks:

Infrastructure Subprocessors – Service Data Storage

bucket.io owns or controls access to the infrastructure that bucket.io uses to host Service Data submitted to the Services, other than as set forth below. Currently, the bucket.io production systems for the Services are located in co-location facilities in the United States. The following table describes the countries and legal entities engaged in the storage of Service Data by bucket.io.

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

Service Specific Subprocessors

bucket.io works with certain third parties to provide specific functionality within the Services. These providers are the Subprocessors set forth below. In order to provide the relevant functionality these Subprocessors access Service Data. Their use is limited to the indicated Services.

Entity Name	Purpose	Applicable Services	Entity Country
Functional Software Inc.	Monitor software code for errors processing data	Sentry Error tracking services	United States
Cloudflare, Inc.	Cloudflare, Inc. (“Cloudflare”) provides content distribution, security and DNS services for web traffic transmitted to and from the Services. This allows bucket.io to efficiently manage traffic and secure the Services. The primary information Cloudflare has access to is information in and associated with the bucket.io website URL that the End-User is interacting with (which includes End-User IP address). All information (including Service Data) contained in web traffic transmitted to and from the Services is transmitted through Cloudflare’s systems, but Cloudflare does not have access to this information.	Content Delivery Network	United States

Subcontractors

As explained above, bucket.io also uses certain “subcontractors” to assist in the operations necessary to provide the bucket.io Services as described in the Master Subscription Agreement. The following is a list (as of the date of this policy) of the names and locations of material third-party subcontractors. Subcontractors do not have access to Service Data.

Entity Name	Entity Type	Entity Country
None

Content Delivery Networks

As explained above, bucket.io’s Services may use content delivery networks (“CDNs”) to provide the Services, for security purposes, and to optimize content delivery. CDNs do not have access to Service Data but are commonly used systems of distributed services that deliver content based on the geographic location of the individual accessing the content and the origin of the content provider. Website content served to website visitors and domain name information may be stored with a CDN to expedite transmission, and information transmitted across a CDN may be accessed by that CDN to enable its functions. The following describes use of CDNs by bucket.io’s Services.

CDN Provider	Services using CDN	Location	Description of CDN Services
Cloudflare, Inc.	All bucket.io service	Global	Public website, image and page resources content served to website visitors may be stored with Cloudflare, Inc., and transmitted by Cloudflare, Inc., to website visitors, to expedite transmission.