ABOUT ZEROBOUNCE
AI Security at ZeroBounce
At ZeroBounce, we take a proactive and transparent approach to securing our AI systems. Our commitment is grounded in real-time monitoring, strict adherence to company-wide policies, and a rigorous validation process.
Post-Deployment Monitoring & Governance
All AI deployments are continuously monitored in real time. User inputs are retained for 30 days in accordance with our global data policy, after which they are securely deleted. Systems for appeal, override, decommissioning, incident response, and change management follow established company-wide security protocols.
Content Validation & Bias Mitigation
We ensure our AI generates accurate and responsible content by restricting input data to thoroughly vetted public sources—namely, our website and official documentation. Each AI release undergoes rigorous validation to mitigate risks like bias or hallucination.
Intrusion Detection & Security Controls
ZeroBounce AI systems are engineered with strong defenses against prompt injection, prompt priming, and model tampering. Our architecture prevents any unauthorized access or modification of prompts or models.
Transparency & Explainability
A built-in debug mode provides insights into the AI’s decision-making process, offering visibility into the data reviewed and increasing trust through explainability.
Data Handling & Protection
We do not ingest private or user-submitted datasets into our AI systems—only public data is used. Sensitive company data remains protected behind corporate firewalls and VPNs. Data deletion follows the same 30-day retention rule as the rest of the organization.
Threat Resistance & Risk Management
Threats like data poisoning or model inversion are not considered relevant due to the nature of our public data sources. However, all identified risks are documented and regularly assessed by our Quality Assurance team to ensure continued safety.
In-House AI Infrastructure
All AI models and infrastructure are developed and maintained in-house. We do not rely on third-party vendors, eliminating external exposure and ensuring full control over our AI ecosystem.
Leader in Email Validations
ZeroBounce is a leading online email validation system created to ensure that companies sending complex and high volume emails avoid deliverability issues. The system works by reducing and eliminating invalid, abuse, complaint, inactive, and spam-trap email addresses. These are email addresses that will either bounce or contribute to ruining your sending reputation. ZeroBounce also provides IP address validation and verification of key recipient demographics and has the ability to add missing information on certain emails, such as the name, gender and location of the owner.
We created a guide to help you navigate everything you need to be aware of when sending emails. It's the most comprehensive guide you'll find on the internet and we offer it for free, without any restrictions. You can read it here: THE COMPLETE GUIDE TO IMPROVE INBOX AND DELIVERABILITY
ZeroBounce is the most secure email validationⓘ system you can find. For us, the protection of your data comes first, so we don't cut cost in keeping it safe. We are registered with the BBB and approved for the EU Data Privacy Framework (DPF). We maintain enterprise contracts with all of our vendors, we operate our own data center and own our servers and hardware. We don't use third-party services, like Amazon, Azure, and other cloud services providers, to store your data.
GETTING STARTED
We'll get you up and validating with us really fast! Simply click this link for a walk-through on our validation service: Validation Process
ZEROBOUNCE
California: 10 E Yanonali St, Santa Barbara, CA, 93101, US
Sales: 1-888-500-9521 (9-5 PST)
Email: office@zerobounce.net
Technical Support 24/7 (only via email): support@zerobounce.net
Support Options: /contact-us
Data Protection
At ZeroBounce, we take data protection very seriously, and we are committed to keep your information safe from harm.
Our organization is using one of the most efficient content delivery network systems in the world, supported by CloudFlare. This system ensures additional defense against cyberattacks and data breaches, thanks to the Advanced Firewall.
Furthermore, we are one of the few email verification services that use a military grade encryption algorithm to safeguard your files and personal information.
Whenever you upload a file on our server, we encrypt it using a unique key. Once our email verifier validates that file, we re-encrypt it and protect it with a password that only you have access to. This additional step keeps your data secure during the process of email validation.
An important aspect of our privacy policy is that your data is never stored in our system for more than 30 days. Once you finish using our email verifier, all data, and all aspects of your data, are erased in maximum 30 days. Also, the information you share with us for payment purposes is encrypted.
At ZeroBounce we go out of our way to protect your data, and we developed advanced defense mechanisms against misuse, loss, unauthorized access and improper disclosure. We want to provide the same security that we would want for ourselves. Our customers feel safe knowing that the best email verification service is also the most secure.
Privacy Policy
Do you have any questions on the use of cookies, the traffic data we collect or the security measures we take to protect your personal information?
Our privacy policy answers all these questions – and more.
The ZeroBounce privacy policy states our data collection and protection practices that ensure your private information is safe while using our email validator. The document presents in detail the policies relating to the collection, use and disclosure of information.
Our privacy policy answers all these questions – and more.
- ZeroBounce’s participation in the EU – U.S. DPF and Swiss-U.S. DPF
- the anonymous data our organization collects
- the use of cookies on our email verification and deliverability platform, and how you can enable and disable them
- ZeroBounce’s participation in the EU – U.S. DPF and Swiss-U.S. DPF
- ZeroBounce’s participation in the EU – U.S. DPF and Swiss-U.S. DPF
Terms and Conditions
The terms and conditions of use cover critical aspects regarding your use of our email verification and deliverability platform.
The extensive document covers:
- clear definitions of the parties involved
- license grant and restrictions
- the responsibilities of ZeroBounce and those of our email validator’s customers and users
- the use of identifying information on zerobounce.net
- the consent regarding the traffic data zerobounce.net collects
- the use and handling of cookies
- intellectual property ownership
- privacy
- the charge of payment for email verification and deliverability services
- warranties, potential modifications, force majeure, waivers and amendments.
To ensure you are aware of our terms of conditions, please read the document published on this page: https://www.zerobounce/terms-of-useto find more details about URL . You will be able to access detailed information on using our email validator, the data appending features, the mail server tester, the inbox placement tester, the blacklist monitoring tool and any other features and tools we may release in the future.
Do you have questions about our terms and conditions? Our team is always here to answer them. Please reach out to support@zerobounce.net or get in touch with us through the live chat. We are here for you 24/7 to help clarify any aspects of using zerobounce.net safely and transparently.
Anti Abuse Policy
ACCEPTABLE USE AND ANTI-ABUSE POLICY
ZeroBounce is committed to protecting consumer privacy while recognizing the importance of the open internet and free flow of information and data. ZeroBounce provides various tools to validate data (the “Services”) and expects that those Services will only be used for lawful and legitimate purposes.
The purpose of this Acceptable Use and Anti-Abuse Policy is to outline the acceptable use of the ZeroBounce Services. This policy applies to all uses of the Services and any interaction with ZeroBounce’s systems, interface, network and database.
PROHIBITED USE
The following activities are, in general, prohibited. Under no circumstances are any customers of ZeroBounce authorized to use the Services to:
- engage in any activity that is illegal under local, state, federal or international law;
- send unsolicited email messages in violation of applicable law, including the sending of "junk mail" or other advertising material to individuals who did not specifically request such material (email spam);
- engage in any form of harassment, discrimination or other abusive behavior;
- breach or invade the privacy rights of any natural person;
- engage in phishing (any activity designed to trick persons into divulging sensitive data such as usernames, passwords, or financial data); or
- engage in any other activity generally deemed to be internet abuse.
ZeroBounce reserves the right to refuse service to any person or company, for any reason, including but not limited to, any customer or potential customer that ZeroBounce suspects will use or has used the Services in violation of this policy and may terminate your access to the Services at any time in its sole discretion. In the event ZeroBounce suspects its Services have been, or will be, used for any purpose that is in violation of the law or this policy, ZeroBounce reserves the right to disclose all available information to law enforcement or government officials.
This policy is in addition to the ZeroBounce Privacy Policy & Terms ZeroBounce reserves the right to update or change this policy at any time.
Reports of abuse should be sent to abuse@zerobounce.net.
Data Processing Agreement
EU DATA PROCESSING AGREEMENT
This EU Data Processing Addendum, including any Appendices (collectively, the “Addendum”), forms part of the Terms & Conditions of Use Agreement (the “Service Agreement”), or any other written or electronic agreement between Hertza L.L.C., a Nevada limited liability company, doing business as “ZeroBounce”, and having its principal place of business at 10 E. Yanonali St., Santa Barbara, California 93101 (hereinafter to be referred to as: the “Data Processor”) and the company whose information has been provided as part of the registration process (hereinafter to be referred to as: the “Data Controller”). Data Processor and Data Controller are collectively referred to herein as the “Parties”.
The terms used in this Addendum shall have the meanings set forth in this Addendum. Capitalized terms not otherwise defined herein shall have the meaning given to them in the Service Agreement. Except as modified below, the terms of the Service Agreement shall remain in full force and effect.
In consideration of the mutual obligations set out herein, the Parties hereby agree that the terms and conditions set out below shall be added as an Addendum to the Service Agreement. Except where the context requires otherwise, references in this Addendum to the Service Agreement are to the Service Agreement as amended by, and including, this Addendum.
1. Subject matter of this Data Processing Addendum
1.1 This Data Processing Addendum applies exclusively to the processing of Customer Validation Data which is subject to EU Data Protection Law in the scope of the Terms and Conditions of Use Agreement of even date hereof between the Parties for the provision of the ZeroBounce services (“Services”) (hereinafter to be referred to as: the “Service Agreement”).
2. Definitions
2.1 The term EU Data Protection Law shall mean Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
2.2 Terms such as “Processing”, “Personal Data”, “Data Controller”, “Processor”, and “data subject” shall have the meaning ascribed to them in the EU Data Protection Law.
2.3 “Standard Contractual Clauses” shall, based on the circumstances unique to the Data Controller, mean the Standard Contractual Clauses (Controller to Processor) pursuant to the Commission Implementing Decision (EU) 2021/914 of 4 June 2021, attached hereto as Exhibit A.
3. Details of the Transfer
3.1 Insofar as the Data Processor will be processing Personal Data subject to EU Data Protection Law on behalf of the Data Controller in the course of the performance of the Service Agreement with the Data Controller, the terms of this Addendum shall apply. To ensure that Personal Data, namely, Customer Validation Data, is processed and stored in the European Union, Data Controller must utilize Data Processor’s EU-only endpoint: api-eu.zerobounce.net (http://api-eu.zerobounce.net/). Any Personal Data submitted to Data Controller through other endpoints or means may be processed and stored in any country where Data Processor maintains its servers, namely, the United States and the European Union. The categories of Personal Data to be processed are online identifiers and may include the following: first name; last name; gender; city; state; country; Internet Protocol (IP) Address information and geolocation data; email addresses; and associated metadata related to email usage or validation results. The types of data subjects whose information will be processed are individuals, namely the Data Controller’s customers, contacts, subscribers, end-users, or other individuals whose data is being processed based on contractual necessity, or who have consented to the processing of their personal data. The purposes for which the personal data will be processed include: validation of email lists for deliverability; removal of known email complainers, abusers and spam traps from email address lists; deliverability toolkit services; and to perform any additional services requested by Data Controller. Notwithstanding the foregoing, the Data Controller understands and agrees that Data Processor has personnel located in the United States that have the ability to access its Customer Registration Data.
3. Details of the Transfer
4.1 The Data Controller will determine the scope, purposes, and manner by which the Personal Data may be accessed or processed by the Data Processor. The Data Processor will process the Personal Data only as set forth in Data Controller’s written instructions.
4.2 The Data Processor will only process the Personal Data on documented instructions of the Data Controller in such manner as – and to the extent that – this is appropriate for the provision of the Services, except as required to comply with a legal obligation to which the Data Processor is subject. In such a case, the Data Processor shall inform the Data Controller of that legal obligation before processing, unless that law explicitly prohibits the furnishing of such information to the Data Controller. The Data Processor shall never process the Personal Data in a manner inconsistent with the Data Controller’s documented instructions. The Data Processor shall immediately inform the Data Controller if, in its opinion, an instruction infringes EU Data Protection Law or other Union or Member State data protection provisions.
4.3 The Parties have entered into a Service Agreement in order to benefit from the expertise of the Processor in securing and processing the Personal Data for the purposes set out in Section 3.1. The Data Processor shall be allowed to exercise its own discretion in the selection and use of such means as it considers necessary to pursue those purposes, subject to the requirements of this Addendum.
4.4 Data Controller warrants that it has all necessary rights to provide the Personal Data to Data Processor for the Processing to be performed in relation to the Services. To the extent required by EU Data Protection Law, Data Controller is responsible for ensuring that any necessary data subject consents to this Processing are obtained, and for ensuring that a record of such consents is maintained. Should such a consent be revoked by the data subject, Data Controller is responsible for communicating the fact of such revocation to the Data Processor, and Data Processor remains responsible for implementing any Data Controller instruction with respect to the further processing of that Personal Data.
5. Confidentiality
5.1 Without prejudice to any existing contractual arrangements between the Parties, the Data Processor shall treat all Personal Data as strictly confidential and it shall inform all its employees, agents and/or approved sub-processors engaged in processing the Personal Data of the confidential nature of the Personal Data. The Data Processor shall ensure that all such persons or parties have signed an appropriate confidentiality agreement, are otherwise bound to a duty of confidentiality, or are under an appropriate statutory obligation of confidentiality.
6. Security
6.1 Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, without prejudice to any other security standards agreed upon by the Parties, the Data Controller and Data Processor shall implement appropriate technical and organizational measures to ensure a level of security of the processing of Personal Data appropriate to the risk. These measures shall include as appropriate:
- measures to ensure that the Personal Data can be accessed only by authorized personnel for the purposes set forth in Section 3.1 of this Addendum;
- in assessing the appropriate level of security account shall be taken in particular of all the risks that are presented by processing, for example from accidental or unlawful destruction, loss, or alteration, unauthorized or unlawful storage, processing, access or disclosure of Personal Data;
- measures of pseudonymization and encryption of Personal Data;
- measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- measures for ensuring the ability to restore the availability and access to Personal Data in a timely manner in the event of physical or technical incident;
- processes for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of Personal Data;
- measures for user identification and authorization;
- measures for the protection of data during transmission;
- measures for the protection of data during storage;
- measures for ensuring physical security of locations at which Personal Data are processed;
- measures for ensuring events logging;
- measures for ensuring system configuration, including default configuration;
- measures for internal IT and IT security governance and management;
- measures for certification/assurance of processes and products;
- measures for ensuring data minimization;
- measures for ensuring data quality;
- measures for ensuring limited data retention;
- measures for ensuring accountability;
- measures for allowing data portability and ensuring erasure; and
- measures to identify vulnerabilities with regard to the processing of Personal Data in systems used to provide services to the Data Controller.
ZeroBounce takes the following security measures and those described in Annex II, to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access:
- ZeroBounce is an active participant in the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework;
- ZeroBounce has restricted access to six personnel members with the ability to directly access files containing personal information on ZeroBounce servers in the EU, each of whom have agreed to maintain the confidentiality of any personal information;
- To the extent that the Data Controller utilizes Data Processor’s EU-only endpoint, all data uploads and downloads sent between ZeroBounce and its customers flow through third party CloudFlare’s servers in the EU;
- CloudFlare is an active participant in the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework;
- The ZeroBounce support team does not have access to CloudFlare;
- CloudFlare maintains its own security protections to block threats and limit abusive bots and crawlers. See https://support.cloudflare.com/hc/en-us/articles/205177068-Step-1-How-does-Cloudflare-work-
- To the extent that the Data Controller utilizes Data Processor’s EU-only endpoint, any information that is uploaded by a ZeroBounce customer to ZeroBounce.net is transmitted via SSL through CloudFlare, and all files are stored in an encrypted file using a standard algorithm for protection of stored data defined by IEEE P1619 on ZeroBounce servers in the EU; and
- If customer elects to receive files via email, such files shall be sent encrypted, with a password via a separate email.
6.2 The Data Processor shall at all times have in place an appropriate written security policy with respect to the processing of Personal Data, outlining in any case the measures set forth in Paragraph 6.1.
6.3 At the request of the Data Controller, the Data Processor, shall demonstrate the measures it has taken and shall allow the Data Controller to audit and test such measures. The Data Controller shall be entitled on giving at least 14 days’ notice to the Data Processor to carry out, or have carried out by a third party who has entered into a confidentiality agreement with the Data Processor, audits of the Data Processor’s premises and operations as these relate to the Personal Data. The Data Processor shall cooperate with such audits carried out by or on behalf of the Data Controller and shall grant the Data Controller’s auditors reasonable access to any premises and devices involved with the Processing of the Personal Data. The Data Processor shall provide the Data Controller and/or the Data Controller’s auditors with access to any information relating to the Processing of the Personal Data as may be reasonably required by the Data Controller to ascertain the Data Processor’s compliance with this Addendum.
7. Improvements to Security
7.1 The Parties acknowledge that security requirements are constantly changing and that effective security requires frequent evaluation and regular improvements of outdated security measures. The Data Processor will therefore evaluate the measures as implemented in accordance with Paragraph 6.1 on an on-going basis and will tighten, supplement, and improve these measures in order to maintain compliance with the requirements set out in Paragraph 6.1. The Parties will negotiate in good faith the cost, if any, to implement material changes required by specific updated security requirements set forth in the EU Data Protection Law or by data protection authorities of competent jurisdiction.
7.2 Where an amendment to the Service Agreement is necessary in order to execute a Data Controller instruction to the Data Processor, or to improve security measures as may be required by changes in applicable data protection law from time to time, the Parties shall negotiate an amendment to the Service Agreement in good faith.
8. Data Transfers
8.1 As to any Personal Data received hereunder via Data Processor’s EU-only endpoint: the Data Processor shall not disclose such Personal Data to a third party or transfer it to a non-EU/European Economic Area (EEA) country without the Data Controller’s authorization. Further, the Data Processor shall immediately notify the Data Controller of any (planned) permanent or temporary transfers of Personal Data received hereunder via Data Processor’s EU-only endpoint to a country outside of the EU/EAA without an adequate level of protection and shall only perform such a (planned) transfer after obtaining authorization from the Data Controller, which may be refused at its own discretion.
8.2 To the extent that the Data Controller or the Data Processor are relying on a specific statutory mechanism to normalize international data transfers that is subsequently modified, revoke, or held in a court of competent jurisdiction to be invalid, the Data Controller and the Data Processor agree to cooperate in good faith to promptly terminate the transfer or to pursue a suitable alternate mechanism that can lawfully support the transfer.
9. Information Obligations and Incident Management
9.1 When the Data Processor becomes aware of an incident that impacts the Processing of the Personal Data that is the subject of the Service Agreement, it shall promptly notify the Data Controller about the incident, shall at all times cooperate with the Data Controller, and shall follow the Data Controller’s instructions with regard to such incidents, in order to enable the Data Controller to perform a thorough investigation into the incident, to formulate a correct response, and to take suitable further steps in respect of the incident.
9.2 The term “incident” used in Paragraph 9.1 shall be understood to mean in any case:
- a complaint or a request with respect to the exercise of a data subject’s rights under EU Data Protection Law;
- an investigation into or seizure of the Personal Data by government officials, or a specific indication that such an investigation or seizure is imminent;
- any unauthorized or accidental access, processing, deletion, loss or any form of unlawful processing of the Personal Data;
- any breach of the security and/or confidentiality as set out in Paragraphs 5 and 6 of this Addendum leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the Personal Data, or any indication of such breach having taken place or being about to take place;
- where, in the opinion of the Data Processor, implementing an instruction received from the Data Controller would violate applicable laws to which the Data Controller or the Data Processor are subject.
9.3 The Data Processor shall at all times have in place written procedures which enable it to promptly respond to the Data Controller about an incident. Where an incident is reasonably likely to require a data breach notification by the Data Controller under the EU Data Protection Law, the Data Processor shall implement its written procedures in such a way that it is in a position to notify the Data Controller no later than 24 hours of having become aware of such an incident.
9.4 Any notifications made to the Data Controller pursuant to this Article shall be addressed to the Data Protection Officer or other employee of the Data Controller whose contact details are provided during the registration process, and shall contain:
- a description of the nature of the incident, including where possible the categories and approximate number of data subjects concerned and the categories and approximate number of Personal Data records concerned;
- the name and contact details of the Data Processor’s data protection officer or another contact point where more information can be obtained;
- a description of the likely consequences of the incident; and
- a description of the measures taken or proposed to be taken by the Data Processor to address the incident including, where appropriate, measures to mitigate its possible adverse effects.
10. Contracting with Sub-Processors
10.1 The Data Controller authorizes the Data Processor to engage sub-processors in the country locations for the Service-related activities specified as described in Paragraph 3.1. Data Processor shall inform the Data Controller of any addition or replacement of such sub-processors giving the Data Controller an opportunity to object to such changes.
10.2 Notwithstanding any authorization by the Data Controller with the meaning of the preceding paragraph, the Data Processor shall remain fully liable vis-à-vis the Data Controller for the performance of any such sub-processor that fails to fulfill its data protection obligations.
10.3 The consent of the Data Controller pursuant to Paragraph 10.1 shall not alter the fact that consent is required for the engagement of sub-processors in a country outside the European Economic Area without a suitable level of protection.
10.4 The Data Processor shall ensure that the sub-processor is bound by the same data protection obligations of the Data Processor under this Addendum, shall supervise compliance thereof, and must in particular impose on its sub-processors the obligation to implement appropriate technical and organizational measures in such a manner that the processing will meet the requirements of EU Data Protection Law.
10.5 The Data Controller may request that the Data Processor audit a sub-processor or provide confirmation that such an audit has occurred (or, where available, obtain or assist customer in obtaining a third-party audit report concerning the sub-processor’s operations) to ensure compliance with its obligations imposed by the Data Processor in conforming with this Addendum.
11. Returning or Destruction of Personal Data
11.1 Upon termination of the Service Agreement, upon the Data Controller’s written request, or upon fulfillment of all purposes agreed in the context of the Services whereby no further processing is required, the Data Processor shall, at the discretion of the Data Controller, either delete, destroy, or return all Personal Data to the Data Controller and destroy or return any existing copies.
11.2 The Data Processor shall notify all third parties supporting its own processing of the Personal Data of the termination of the Service Agreement and shall ensure that all such third parties shall either destroy the Personal Data or return the Personal Data to the Data Controller, at the discretion of the Data Controller.
12. Assistance to Data Controller
12.1 The Data Processor shall assist the Data Controller by appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of the Data Controller’s obligation to respond to a request for exercising the data subject’s rights under the GDPR.
12.2 The Data Processor shall assist the Data Controller in ensuring compliance with the obligations pursuant to Paragraph 6 (Security) and prior consultations with supervisory authorities required under Article 36 of the GDPR taking into account the nature of processing and the information available to the Data Processor.
12.3 The Data Processor shall make available to the Data Controller all information necessary to demonstrate compliance with the Data Processor’s obligations and to allow for and contribute to audits, including inspections, conducted by the Data Controller or another auditor mandated by the Data Controller.
13. Liability and Indemnity
13.1 The Data Processor indemnifies the Data Controller and holds the Data Controller harmless against all claims, actions, third party claims, losses, damages and expenses incurred by the Data Controller and arising directly or indirectly out of or in connection with a breach of this Addendum and/or the EU Data Protection Law by the Data Processor. The Data Controller indemnifies the Data Processor and holds the Data Processor harmless against all claims, actions, third party claims, losses, damages and expenses incurred by the Data Processor and arising directly or indirectly out of or in connection with a breach of this Addendum and/or the EU Data Protection Law by the Data Controller.
14. Duration and Termination
14.1 This Addendum shall come into effect on the date the Data Controller signs this Addendum, which may be through electronic means.
14.2 Termination or expiration of the Service Agreement shall not discharge the Data Processor from its confidentiality obligations pursuant to Paragraph 5.
14.3 The Data Processor shall process Personal Data until the date of termination of the Service Agreement, unless instructed otherwise by the Data Controller, or until such data is returned or destroyed on instruction of the Data Controller.
15. Miscellaneous
15.1 In the event of any inconsistency between the provisions of this Addendum and the provisions of the Service Agreement, the provisions of this Addendum shall prevail.
EXHIBIT A: STANDARD CONTRACTUAL CLAUSES
Controller to Processor
SECTION I
Clause 1
Purpose and scope
(a) The purpose of these standard contractual clauses is to ensure compliance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) for the transfer of data to a third country.
(b) The Parties:
(i) the natural or legal person(s), public authority/ies, agency/ies or other body/ies (hereinafter ‘entity/ies’) transferring the personal data, as listed in Annex I.A (hereinafter each ‘data exporter’), and
(ii) the entity/ies in a third country receiving the personal data from the data exporter, directly or indirectly via another entity also Party to these Clauses, as listed in Annex I. (hereinafter each ‘data importer’)
have agreed to these standard contractual clauses (hereinafter: ‘Clauses’).
(c) These Clauses apply with respect to the transfer of personal data as specified herein.
(d) The Appendix to these Clauses containing the Annexes referred to therein forms an integral part of these Clauses.
Clause 2
Effect and invariability of the Clauses
(a) These Clauses set out appropriate safeguards, including enforceable data subject rights and effective legal remedies, pursuant to Article 46(1) and Article 46(2)(c) of Regulation (EU) 2016/679 and, with respect to data transfers from controllers to processors and/or processors to processors, standard contractual clauses pursuant to Article 28(7) of Regulation (EU) 2016/679, provided they are not modified, except to select the appropriate Module(s) or to add or update information in the Appendix. This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a wider contract and/or to add other clauses or additional safeguards, provided that they do not contradict, directly or indirectly, these Clauses or prejudice the fundamental rights or freedoms of data subjects.
(b) These Clauses are without prejudice to obligations to which the data exporter is subject by virtue of Regulation (EU) 2016/679.
Clause 3
Third-party beneficiaries
(a) Data subjects may invoke and enforce these Clauses, as third-party beneficiaries, against the data exporter and/or data importer, with the following exceptions:
(i) Clause 1, Clause 2, Clause 3, Clause 6, Clause 7;
(ii) Clause 8.1(b), 8.9(a), (c), (d) and (e);
(iii) Clause 9(a), (c), (d) and (e);
(iv) Clause 12(a), (d) and (f);
(v) Clause 13;
(vi) Clause 15.1(c), (d) and (e);
(vii) Clause 16(e);
(viii) Clause 18(a) and (b).
(b) Paragraph (a) is without prejudice to rights of data subjects under Regulation (EU) 2016/679.
Clause 4
Interpretation
(a) Where these Clauses use terms that are defined in Regulation (EU) 2016/679, those terms shall have the same meaning as in that Regulation.
(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679.
(c) These Clauses shall not be interpreted in a way that conflicts with rights and obligations provided for in Regulation (EU) 2016/679.
Clause 5
Hierarchy
In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties, existing at the time these Clauses are agreed or entered into thereafter, these Clauses shall prevail.
Clause 6
Description of the transfer(s)
The details of the transfer(s), and in particular the categories of personal data that are transferred and the purpose(s) for which they are transferred, are specified in Annex I.B.
Clause 7 - Optional
Omitted
SECTION II – OBLIGATIONS OF THE PARTIES
Clause 8
Data protection safeguards
The data exporter warrants that it has used reasonable efforts to determine that the data importer is able, through the implementation of appropriate technical and organisational measures, to satisfy its obligations under these Clauses.
8.1 Instructions
(a) The data importer shall process the personal data only on documented instructions from the data exporter. The data exporter may give such instructions throughout the duration of the contract.
(b) The data importer shall immediately inform the data exporter if it is unable to follow those instructions.
8.2 Purpose limitation
The data importer shall process the personal data only for the specific purpose(s) of the transfer, as set out in Annex I.B, unless on further instructions from the data exporter.
8.3 Transparency
On request, the data exporter shall make a copy of these Clauses, including the Appendix as completed by the Parties, available to the data subject free of charge. To the extent necessary to protect business secrets or other confidential information, including the measures described in Annex II and personal data, the data exporter may redact part of the text of the Appendix to these Clauses prior to sharing a copy, but shall provide a meaningful summary where the data subject would otherwise not be able to understand the its content or exercise his/her rights. On request, the Parties shall provide the data subject with the reasons for the redactions, to the extent possible without revealing the redacted information. This Clause is without prejudice to the obligations of the data exporter under Articles 13 and 14 of Regulation (EU) 2016/679.
8.4 Accuracy
If the data importer becomes aware that the personal data it has received is inaccurate, or has become outdated, it shall inform the data exporter without undue delay. In this case, the data importer shall cooperate with the data exporter to erase or rectify the data.
8.5 Duration of processing and erasure or return of data
Processing by the data importer shall only take place for the duration specified in Annex I.B. After the end of the provision of the processing services, the data importer shall, at the choice of the data exporter, delete all personal data processed on behalf of the data exporter and certify to the data exporter that it has done so, or return to the data exporter all personal data processed on its behalf and delete existing copies. Until the data is deleted or returned, the data importer shall continue to ensure compliance with these Clauses. In case of local laws applicable to the data importer that prohibit return or deletion of the personal data, the data importer warrants that it will continue to ensure compliance with these Clauses and will only process it to the extent and for as long as required under that local law. This is without prejudice to Clause 14, in particular the requirement for the data importer under Clause 14(e) to notify the data exporter throughout the duration of the contract if it has reason to believe that it is or has become subject to laws or practices not in line with the requirements under Clause 14(a).
8.6 Security of processing
(a) The data importer and, during transmission, also the data exporter shall implement appropriate technical and organisational measures to ensure the security of the data, including protection against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to that data (hereinafter ‘personal data breach’). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purpose(s) of processing and the risks involved in the processing for the data subjects. The Parties shall in particular consider having recourse to encryption or pseudonymisation, including during transmission, where the purpose of processing can be fulfilled in that manner. In case of pseudonymisation, the additional information for attributing the personal data to a specific data subject shall, where possible, remain under the exclusive control of the data exporter. In complying with its obligations under this paragraph, the data importer shall at least implement the technical and organisational measures specified in Annex II. The data importer shall carry out regular checks to ensure that these measures continue to provide an appropriate level of security.
(b) The data importer shall grant access to the personal data to members of its personnel only to the extent strictly necessary for the implementation, management and monitoring of the contract. It shall ensure that persons authorised to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
(c) In the event of a personal data breach concerning personal data processed by the data importer under these Clauses, the data importer shall take appropriate measures to address the breach, including measures to mitigate its adverse effects. The data importer shall also notify the data exporter without undue delay after having become aware of the breach. Such notification shall contain the details of a contact point where more information can be obtained, a description of the nature of the breach (including, where possible, categories and approximate number of data subjects and personal data records concerned), its likely consequences and the measures taken or proposed to address the breach including, where appropriate, measures to mitigate its possible adverse effects. Where, and in so far as, it is not possible to provide all information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.
(d) The data importer shall cooperate with and assist the data exporter to enable the data exporter to comply with its obligations under Regulation (EU) 2016/679, in particular to notify the competent supervisory authority and the affected data subjects, taking into account the nature of processing and the information available to the data importer.
8.7 Sensitive data
Where the transfer involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (hereinafter ‘sensitive data’), the data importer shall apply the specific restrictions and/or additional safeguards described in Annex I.B.
8.8 Onward transfers
The data importer shall only disclose the personal data to a third party on documented instructions from the data exporter. In addition, the data may only be disclosed to a third party located outside the European Union (in the same country as the data importer or in another third country, hereinafter ‘onward transfer’) if the third party is or agrees to be bound by these Clauses, under the appropriate Module, or if:
(i) the onward transfer is to a country benefitting from an adequacy decision pursuant to Article 45 of Regulation (EU) 2016/679 that covers the onward transfer;
(ii) the third party otherwise ensures appropriate safeguards pursuant to Articles 46 or 47 Regulation of (EU) 2016/679 with respect to the processing in question;
(iii) the onward transfer is necessary for the establishment, exercise or defence of legal claims in the context of specific administrative, regulatory or judicial proceedings; or
(iv) the onward transfer is necessary in order to protect the vital interests of the data subject or of another natural person.
Any onward transfer is subject to compliance by the data importer with all the other safeguards under these Clauses, in particular purpose limitation.
8.9 Documentation and compliance
(a) The data importer shall promptly and adequately deal with enquiries from the data exporter that relate to the processing under these Clauses.
(b) The Parties shall be able to demonstrate compliance with these Clauses. In particular, the data importer shall keep appropriate documentation on the processing activities carried out on behalf of the data exporter.
(c) The data importer shall make available to the data exporter all information necessary to demonstrate compliance with the obligations set out in these Clauses and at the data exporter’s request, allow for and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or audit, the data exporter may take into account relevant certifications held by the data importer.
(d) The data exporter may choose to conduct the audit by itself or mandate an independent auditor. Audits may include inspections at the premises or physical facilities of the data importer and shall, where appropriate, be carried out with reasonable notice.
(e) The Parties shall make the information referred to in paragraphs (b) and (c), including the results of any audits, available to the competent supervisory authority on request.
Clause 9
Use of sub-processors
(a) The data importer shall not sub-contract any of its processing activities performed on behalf of the data exporter under these Clauses to a sub-processor without the data exporter’s prior specific written authorisation. The data importer shall submit the request for specific authorisation at least thirty days prior to the engagement of the sub-processor, together with the information necessary to enable the data exporter to decide on the authorisation. The list of sub-processors already authorised by the data exporter can be found in Annex III. The Parties shall keep Annex III up to date.
(b) Where the data importer engages a sub-processor to carry out specific processing activities (on behalf of the data exporter), it shall do so by way of a written contract that provides for, in substance, the same data protection obligations as those binding the data importer under these Clauses, including in terms of third-party beneficiary rights for data subjects. The Parties agree that, by complying with this Clause, the data importer fulfils its obligations under Clause 8.8. The data importer shall ensure that the sub-processor complies with the obligations to which the data importer is subject pursuant to these Clauses.
(c) The data importer shall provide, at the data exporter’s request, a copy of such a sub-processor agreement and any subsequent amendments to the data exporter. To the extent necessary to protect business secrets or other confidential information, including personal data, the data importer may redact the text of the agreement prior to sharing a copy.
(d) The data importer shall remain fully responsible to the data exporter for the performance of the sub-processor’s obligations under its contract with the data importer. The data importer shall notify the data exporter of any failure by the sub-processor to fulfil its obligations under that contract.
(e) The data importer shall agree a third-party beneficiary clause with the sub-processor whereby – in the event the data importer has factually disappeared, ceased to exist in law or has become insolvent – the data exporter shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.
Clause 10
Data subject rights
(a) The data importer shall promptly notify the data exporter of any request it has received from a data subject. It shall not respond to that request itself unless it has been authorised to do so by the data exporter.
(b) The data importer shall assist the data exporter in fulfilling its obligations to respond to data subjects’ requests for the exercise of their rights under Regulation (EU) 2016/679. In this regard, the Parties shall set out in Annex II the appropriate technical and organisational measures, taking into account the nature of the processing, by which the assistance shall be provided, as well as the scope and the extent of the assistance required.
(c) In fulfilling its obligations under paragraphs (a) and (b), the data importer shall comply with the instructions from the data exporter.
Clause 11
Redress
(a) The data importer shall inform data subjects in a transparent and easily accessible format, through individual notice or on its website, of a contact point authorised to handle complaints. It shall deal promptly with any complaints it receives from a data subject.
(b) In case of a dispute between a data subject and one of the Parties as regards compliance with these Clauses, that Party shall use its best efforts to resolve the issue amicably in a timely fashion. The Parties shall keep each other informed about such disputes and, where appropriate, cooperate in resolving them.
(c) Where the data subject invokes a third-party beneficiary right pursuant to Clause 3, the data importer shall accept the decision of the data subject to:
(i) lodge a complaint with the supervisory authority in the Member State of his/her habitual residence or place of work, or the competent supervisory authority pursuant to Clause 13;
(ii) refer the dispute to the competent courts within the meaning of Clause 18.
(d) The Parties accept that the data subject may be represented by a not-for-profit body, organisation or association under the conditions set out in Article 80(1) of Regulation (EU) 2016/679.
(e) The data importer shall abide by a decision that is binding under the applicable EU or Member State law.
(f) The data importer agrees that the choice made by the data subject will not prejudice his/her substantive and procedural rights to seek remedies in accordance with applicable laws.
Clause 12
Liability
(a) Each Party shall be liable to the other Party/ies for any damages it causes the other Party/ies by any breach of these Clauses.
(b) The data importer shall be liable to the data subject, and the data subject shall be entitled to receive compensation, for any material or non-material damages the data importer or its sub-processor causes the data subject by breaching the third-party beneficiary rights under these Clauses.
(c) Notwithstanding paragraph (b), the data exporter shall be liable to the data subject, and the data subject shall be entitled to receive compensation, for any material or non-material damages the data exporter or the data importer (or its sub-processor) causes the data subject by breaching the third-party beneficiary rights under these Clauses. This is without prejudice to the liability of the data exporter and, where the data exporter is a processor acting on behalf of a controller, to the liability of the controller under Regulation (EU) 2016/679 or Regulation (EU) 2018/1725, as applicable.
(d) The Parties agree that if the data exporter is held liable under paragraph (c) for damages caused by the data importer (or its sub-processor), it shall be entitled to claim back from the data importer that part of the compensation corresponding to the data importer’s responsibility for the damage.
(e) Where more than one Party is responsible for any damage caused to the data subject as a result of a breach of these Clauses, all responsible Parties shall be jointly and severally liable and the data subject is entitled to bring an action in court against any of these Parties.
(f) The Parties agree that if one Party is held liable under paragraph (e), it shall be entitled to claim back from the other Party/ies that part of the compensation corresponding to its/their responsibility for the damage.
(g) The data importer may not invoke the conduct of a sub-processor to avoid its own liability.
Clause 13
Supervision
(a) [Where the data exporter is established in an EU Member State:] The supervisory authority with responsibility for ensuring compliance by the data exporter with Regulation (EU) 2016/679 as regards the data transfer, as indicated in Annex I.C, shall act as competent supervisory authority.
[Where the data exporter is not established in an EU Member State, but falls within the territorial scope of application of Regulation (EU) 2016/679 in accordance with its Article 3(2) and has appointed a representative pursuant to Article 27(1) of Regulation (EU) 2016/679:] The supervisory authority of the Member State in which the representative within the meaning of Article 27(1) of Regulation (EU) 2016/679 is established, as indicated in Annex I.C, shall act as competent supervisory authority.
[Where the data exporter is not established in an EU Member State, but falls within the territorial scope of application of Regulation (EU) 2016/679 in accordance with its Article 3(2) without however having to appoint a representative pursuant to Article 27(2) of Regulation (EU) 2016/679:] The supervisory authority of one of the Member States in which the data subjects whose personal data is transferred under these Clauses in relation to the offering of goods or services to them, or whose behaviour is monitored, are located, as indicated in Annex I.C, shall act as competent supervisory authority.
(b) The data importer agrees to submit itself to the jurisdiction of and cooperate with the competent supervisory authority in any procedures aimed at ensuring compliance with these Clauses. In particular, the data importer agrees to respond to enquiries, submit to audits and comply with the measures adopted by the supervisory authority, including remedial and compensatory measures. It shall provide the supervisory authority with written confirmation that the necessary actions have been taken.
SECTION III – LOCAL LAWS AND OBLIGATIONS IN CASE OF ACCESS BY PUBLIC AUTHORITIES
Clause 14
Local laws and practices affecting compliance with the Clauses
(a) The Parties warrant that they have no reason to believe that the laws and practices in the third country of destination applicable to the processing of the personal data by the data importer, including any requirements to disclose personal data or measures authorising access by public authorities, prevent the data importer from fulfilling its obligations under these Clauses. This is based on the understanding that laws and practices that respect the essence of the fundamental rights and freedoms and do not exceed what is necessary and proportionate in a democratic society to safeguard one of the objectives listed in Article 23(1) of Regulation (EU) 2016/679, are not in contradiction with these Clauses.
(b) The Parties declare that in providing the warranty in paragraph (a), they have taken due account in particular of the following elements:
(i) the specific circumstances of the transfer, including the length of the processing chain, the number of actors involved and the transmission channels used; intended onward transfers; the type of recipient; the purpose of processing; the categories and format of the transferred personal data; the economic sector in which the transfer occurs; the storage location of the data transferred;
(ii) the laws and practices of the third country of destination– including those requiring the disclosure of data to public authorities or authorising access by such authorities – relevant in light of the specific circumstances of the transfer, and the applicable limitations and safeguards;
(iii) any relevant contractual, technical or organisational safeguards put in place to supplement the safeguards under these Clauses, including measures applied during transmission and to the processing of the personal data in the country of destination.
(c) The data importer warrants that, in carrying out the assessment under paragraph (b), it has made its best efforts to provide the data exporter with relevant information and agrees that it will continue to cooperate with the data exporter in ensuring compliance with these Clauses.
(d) The Parties agree to document the assessment under paragraph (b) and make it available to the competent supervisory authority on request.
(e) The data importer agrees to notify the data exporter promptly if, after having agreed to these Clauses and for the duration of the contract, it has reason to believe that it is or has become subject to laws or practices not in line with the requirements under paragraph (a), including following a change in the laws of the third country or a measure (such as a disclosure request) indicating an application of such laws in practice that is not in line with the requirements in paragraph (a).
(f) Following a notification pursuant to paragraph (e), or if the data exporter otherwise has reason to believe that the data importer can no longer fulfil its obligations under these Clauses, the data exporter shall promptly identify appropriate measures (e.g. technical or organisational measures to ensure security and confidentiality) to be adopted by the data exporter and/or data importer to address the situation. The data exporter shall suspend the data transfer if it considers that no appropriate safeguards for such transfer can be ensured, or if instructed by the competent supervisory authority to do so. In this case, the data exporter shall be entitled to terminate the contract, insofar as it concerns the processing of personal data under these Clauses. If the contract involves more than two Parties, the data exporter may exercise this right to termination only with respect to the relevant Party, unless the Parties have agreed otherwise. Where the contract is terminated pursuant to this Clause, Clause 16(d) and (e) shall apply.
Clause 15
Obligations of the data importer in case of access by public authorities
15.1 Notification
(a) The data importer agrees to notify the data exporter and, where possible, the data subject promptly (if necessary with the help of the data exporter) if it:
(i) receives a legally binding request from a public authority, including judicial authorities, under the laws of the country of destination for the disclosure of personal data transferred pursuant to these Clauses; such notification shall include information about the personal data requested, the requesting authority, the legal basis for the request and the response provided; or
(ii) becomes aware of any direct access by public authorities to personal data transferred pursuant to these Clauses in accordance with the laws of the country of destination; such notification shall include all information available to the importer.
(b) If the data importer is prohibited from notifying the data exporter and/or the data subject under the laws of the country of destination, the data importer agrees to use its best efforts to obtain a waiver of the prohibition, with a view to communicating as much information as possible, as soon as possible. The data importer agrees to document its best efforts in order to be able to demonstrate them on request of the data exporter.
(c) Where permissible under the laws of the country of destination, the data importer agrees to provide the data exporter, at regular intervals for the duration of the contract, with as much relevant information as possible on the requests received (in particular, number of requests, type of data requested, requesting authority/ies, whether requests have been challenged and the outcome of such challenges, etc.).
(d) The data importer agrees to preserve the information pursuant to paragraphs (a) to (c) for the duration of the contract and make it available to the competent supervisory authority on request.
(e) Paragraphs (a) to (c) are without prejudice to the obligation of the data importer pursuant to Clause 14(e) and Clause 16 to inform the data exporter promptly where it is unable to comply with these Clauses.
15.2 Review of legality and data minimisation
(a) The data importer agrees to review the legality of the request for disclosure, in particular whether it remains within the powers granted to the requesting public authority, and to challenge the request if, after careful assessment, it concludes that there are reasonable grounds to consider that the request is unlawful under the laws of the country of destination, applicable obligations under international law and principles of international comity. The data importer shall, under the same conditions, pursue possibilities of appeal. When challenging a request, the data importer shall seek interim measures with a view to suspending the effects of the request until the competent judicial authority has decided on its merits. It shall not disclose the personal data requested until required to do so under the applicable procedural rules. These requirements are without prejudice to the obligations of the data importer under Clause 14(e).
(b) The data importer agrees to document its legal assessment and any challenge to the request for disclosure and, to the extent permissible under the laws of the country of destination, make the documentation available to the data exporter. It shall also make it available to the competent supervisory authority on request.
(c) The data importer agrees to provide the minimum amount of information permissible when responding to a request for disclosure, based on a reasonable interpretation of the request.
SECTION IV – FINAL PROVISIONS
Clause 16
Non-compliance with the Clauses and termination
(a) The data importer shall promptly inform the data exporter if it is unable to comply with these Clauses, for whatever reason.
(b) In the event that the data importer is in breach of these Clauses or unable to comply with these Clauses, the data exporter shall suspend the transfer of personal data to the data importer until compliance is again ensured or the contract is terminated. This is without prejudice to Clause 14(f).
(c) The data exporter shall be entitled to terminate the contract, insofar as it concerns the processing of personal data under these Clauses, where:
(i) the data exporter has suspended the transfer of personal data to the data importer pursuant to paragraph (b) and compliance with these Clauses is not restored within a reasonable time and in any event within one month of suspension;
(ii) the data importer is in substantial or persistent breach of these Clauses; or
(iii) the data importer fails to comply with a binding decision of a competent court or supervisory authority regarding its obligations under these Clauses.
In these cases, it shall inform the competent supervisory authority of such non-compliance. Where the contract involves more than two Parties, the data exporter may exercise this right to termination only with respect to the relevant Party, unless the Parties have agreed otherwise.
(d) Personal data that has been transferred prior to the termination of the contract pursuant to paragraph (c) shall at the choice of the data exporter immediately be returned to the data exporter or deleted in its entirety. The same shall apply to any copies of the data. The data importer shall certify the deletion of the data to the data exporter. Until the data is deleted or returned, the data importer shall continue to ensure compliance with these Clauses. In case of local laws applicable to the data importer that prohibit the return or deletion of the transferred personal data, the data importer warrants that it will continue to ensure compliance with these Clauses and will only process the data to the extent and for as long as required under that local law.
(e) Either Party may revoke its agreement to be bound by these Clauses where (i) the European Commission adopts a decision pursuant to Article 45(3) of Regulation (EU) 2016/679 that covers the transfer of personal data to which these Clauses apply; or (ii) Regulation (EU) 2016/679 becomes part of the legal framework of the country to which the personal data is transferred. This is without prejudice to other obligations applying to the processing in question under Regulation (EU) 2016/679.
Clause 17
Governing law
These Clauses shall be governed by the law of one of the EU Member States, provided such law allows for third-party beneficiary rights. The Parties agree that this shall be the law of Ireland.
Clause 18
Choice of forum and jurisdiction
(a) Any dispute arising from these Clauses shall be resolved by the courts of an EU Member State.
(b) The Parties agree that those shall be the courts of Ireland.
(c) A data subject may also bring legal proceedings against the data exporter and/or data importer before the courts of the Member State in which he/she has his/her habitual residence.
(d) The Parties agree to submit themselves to the jurisdiction of such courts.
UK Data Processing Agreement
UK PDF Version:UK Data Processing ADDENDUM
UK Data Processing ADDENDUM
This UK Data Processing Addendum, including any Appendices (collectively, the “Addendum”), forms part of the Terms & Conditions of Use Agreement (the “Service Agreement”), or any other written or electronic agreement between Hertza L.L.C., a Nevada limited liability company, doing business as “ZeroBounce”, and having its principal place of business at 10 E. Yanonali St., Santa Barbara, California 93101 (hereinafter to be referred to as: the “Importer”) and the company whose information has been provided as part of the registration process (hereinafter to be referred to as: the “Exporter”). Importer and Exporter are collectively referred to herein as the “Parties”.
The terms used in this Addendum shall have the meanings set forth in this Addendum. Capitalized terms not otherwise defined herein shall have the meaning given to them in the Service Agreement. Except as modified below, the terms of the Service Agreement shall remain in full force and effect.
In consideration of the mutual obligations set out herein, the Parties hereby agree that the terms and conditions set out below shall be added as an Addendum to the Service Agreement. Except where the context requires otherwise, references in this Addendum to the Service Agreement are to the Service Agreement as amended by, and including, this Addendum.
1. Subject Matter of this Addendum
1.1 This Addendum applies exclusively to the processing of Customer Validation Data which is subject to the UK GDPR in the scope of the Terms and Conditions of Use Agreement of even date hereof between the Parties for the provision of the ZeroBounce services (“Services”) (hereinafter to be referred to as: the “Service Agreement”). The parties would like to rely on the European Commission’s Standard Contractual Clauses for international data transfers adopted by European Decision 914/2021/EU (“EU SCC”), and the UK International Data Protection Addendum for the transfer of personal data from the UK.
2. Definitions
2.1 “UK GDPR” shall mean Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (United Kingdom General Data Protection Regulation), tailored by the Data Protection Act 2018.
2.2 “Applicable Data Protection Law” means the data protection law of the UK which is the UK GDPR and the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended), and other data protection or privacy legislation in force from time to time in the United Kingdom;
2.3 Terms such as “Personal Data”, “Special Categories of Data”, “Process/Processing”, “Exporter”, “Importer”, “data subject”, “sub-processor,” and “technical and organisational security measures” shall have the same meaning ascribed to them in the UK GDPR.
2.4 “Standard Contractual Clauses” shall, based on the circumstances unique to the Exporter, mean the International Data Transfer Addendum to the EU Commission SCCs, promulgated by the IOC, attached hereto as Exhibit A.
3. Details of the Transfer
3.1 Insofar as the Importer will be processing Personal Data subject to the UK GDPR on behalf of the Exporter in the course of the performance of the Service Agreement with the Exporter the terms of this Addendum shall apply. Unless the Exporter instructs otherwise, the Exporter will transfer Personal Data, namely, Customer Validation Data, to be processed by the Importer on computer servers located in the European Union. The categories of Personal Data to be processed are online identifiers and may include the following: first name; last name; gender; city; state; country; Internet Protocol (IP) Address information; and email addresses. The types of data subjects whose information will be processed are individuals, namely the Data Controller’s customers who have consented to the processing of their Personal Data. The purposes for which the Personal Data will be processed include: validation of email lists for deliverability; removal of known email complainers, abusers and spam traps from email address lists; deliverability toolkit services; and to perform any additional services requested by Exporter. Notwithstanding the foregoing, the Exporter understands and agrees that the Importer has personnel located in the United States that have the ability to access its Customer Registration Data.
4. The Exporter and the Importer
4.1 The Exporter will determine the scope, purposes, and manner by which the Personal Data may be accessed or processed by the Importer. The Importer will process the Personal Data only as set forth in Exporter’s written instructions.
4.2 The Importer will only process the Personal Data on documented instructions of the Exporter in such manner as – and to the extent that – this is appropriate for the provision of the Services, except as required to comply with a legal obligation to which the Importer is subject. In such a case, the Importer shall inform the Exporter of that legal obligation before processing, unless that law explicitly prohibits the furnishing of such information to the Exporter. The Importer shall never process the Personal Data in a manner inconsistent with the Exporter’s documented instructions. The Importer shall immediately inform the Exporter if, in its opinion, an instruction infringes the UK GDPR.
4.3 The Parties have entered into a Service Agreement in order to benefit from the expertise of the Importer in securing and processing the Personal Data for the purposes set out in Section 3.1 above. The Importer shall be allowed to exercise its own discretion in the selection and use of such means as it considers necessary to pursue those purposes, subject to the requirements of this Addendum.
4.4 Exporter warrants that it has all necessary rights to provide the Personal Data to Importer for the Processing to be performed in relation to the Services. To the extent required by the UK GDPR, Exporter is responsible for ensuring that any necessary data subject consents to this Processing are obtained, and for ensuring that a record of such consents is maintained. Should such a consent be revoked by the data subject, Exporter is responsible for communicating the fact of such revocation to the Importer, and Importer remains responsible for implementing any Exporter instruction with respect to the further processing of that Personal Data.
5. Confidentiality
5.1 Without prejudice to any existing contractual arrangements between the Parties, the Importer shall treat all Personal Data as strictly confidential and it shall inform all its employees, agents and/or approved sub-processors engaged in processing the Personal Data of the confidential nature of the Personal Data. The Importer shall ensure that all such persons or parties have signed an appropriate confidentiality agreement, are otherwise bound to a duty of confidentiality, or are under an appropriate statutory obligation of confidentiality.
6. Security
6.1 Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, without prejudice to any other security standards agreed upon by the Parties, the Exporter and Importer shall implement appropriate technical and organizational measures to ensure a level of security of the processing of Personal Data appropriate to the risk. These measures shall include as appropriate:
(a) measures to ensure that the Personal Data can be accessed only by authorized personnel for the purposes set forth in Section 3.1 of this Addendum;
(b) in assessing the appropriate level of security account shall be taken in particular of all the risks that are presented by processing, for example from accidental or unlawful destruction, loss, or alteration, unauthorized or unlawful storage, processing, access or disclosure of Personal Data;
(c) measures of pseudonymization and encryption of Personal Data;
(d) measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
(e) measures for ensuring the ability to restore the availability and access to Personal Data in a timely manner in the event of physical or technical incident;
(f) processes for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of Personal Data;
(g) measures for user identification and authorization;
(h) measures for the protection of data during transmission;
(i) measures for the protection of data during storage;
(j) measures for ensuring physical security of locations at which Personal Data are processed;
(k) measures for ensuring events logging;
(l) measures for ensuring system configuration, including default configuration;
(m) measures for internal IT and IT security governance and management;
(n) measures for certification/assurance of processes and products;
(o) measures for ensuring data minimization;
(p) measures for ensuring data quality;
(q) measures for ensuring limited data retention;
(r) measures for ensuring accountability;
(s) measures for allowing data portability and ensuring erasure; and
(t) measures to identify vulnerabilities with regard to the processing of Personal Data in systems used to provide services to the Exporter.
ZeroBounce takes the following security measures and those described in Appendix 2, to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access:
• Unless otherwise specifically instructed by the Exporter, all Personal Data received hereunder will be stored and processed in the EU;
• ZeroBounce is an active participant in the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework;
• ZeroBounce has restricted access to four personnel members with the ability to directly access files containing personal information on ZeroBounce servers in the EU, each of whom have agreed to maintain the confidentiality of any personal information;
• All data uploads and downloads sent between ZeroBounce and its customers flow through third party CloudFlare’s servers in the EU;
• CloudFlare is an active participant in the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework;
• The ZeroBounce support team does not have access to CloudFlare;
• CloudFlare maintains its own protections to block threats and limit abusive bots and crawlers. See https://support.cloudflare.com/hc/en-us/articles/ security 205177068-Step-1-How-does-Cloudflare-work-
• Any information that is uploaded by a ZeroBounce customer to ZeroBounce.net is transmitted via SSL through CloudFlare, and all files are stored in an encrypted file using a standard algorithm for protection of stored data defined by IEEE P1619 on ZeroBounce servers in the EU; and
• If customer elects to receive files via email, such files shall be sent encrypted, with a password via a separate email.
6.2 The Importer shall at all times have in place an appropriate written security policy with respect to the processing of Personal Data, outlining in any case the measures set forth in Paragraph 6.1.
6.3 At the request of the Exporter, the Importer, shall demonstrate the measures it has taken and shall allow the Exporter to audit and test such measures. The Exporter shall be entitled on giving at least 14 days notice to the Importer to carry out, or have carried out by a third party who has entered into a confidentiality agreement with the Importer, audits of the Importer’s premises and operations as these relate to the Personal Data. The Importer shall cooperate with such audits carried out by or on behalf of the Exporter and shall grant the Exporter’s auditors reasonable access to any premises and devices involved with the Processing of the Personal Data. The Importer shall provide the Exporter and/or the Exporter’s auditors with access to any information relating to the Processing of the Personal Data as may be reasonably required by the Exporter to ascertain the Importer’s compliance with this Addendum.
7. Improvements to Security
7.1 The Parties acknowledge that security requirements are constantly changing and that effective security requires frequent evaluation and regular improvements of outdated security measures. The Importer will therefore evaluate the measures as implemented in accordance with Paragraph 6.1 on an on-going basis and will tighten, supplement, and improve these measures in order to maintain compliance with the requirements set out in Paragraph 6.1. The Parties will negotiate in good faith the cost, if any, to implement material changes required by specific updated security requirements set forth in the UK GDPR or by data protection authorities of competent jurisdiction.
7.2 Where an amendment to the Service Agreement is necessary in order to execute an Exporter instruction to the Importer, or to improve security measures as may be required by changes in applicable data protection law from time to time, the Parties shall negotiate an amendment to the Service Agreement in good faith.
8. Data Transfers
8.1 For the Services, unless otherwise specifically instructed by the Exporter, Exporter will transfer Personal Data to be processed by the Importer on computer servers located in the EU. The Importer shall not disclose Personal Data received hereunder to a third party or transfer it to a non-EU/European Economic Area (EEA) country without the Exporter’s authorization. The Importer shall immediately notify the Exporter of any (planned) permanent or temporary transfers of Personal Data to a country outside of the EU/EAA without an adequate level of protection and shall only perform such a (planned) transfer after obtaining authorization from the Exporter, which may be refused at its own discretion.
8.2 To the extent that the Exporter or the Importer are relying on a specific statutory mechanism to normalize international data transfers that is subsequently modified, revoke, or held in a court of competent jurisdiction to be invalid, the Exporter and the Importer agree to cooperate in good faith to promptly terminate the transfer or to pursue a suitable alternate mechanism that can lawfully support the transfer.
9. Information Obligations and Incident Management
9.1 When the Importer becomes aware of an incident that impacts the Processing of the Personal Data that is the subject of the Service Agreement, it shall promptly notify the Exporter about the incident, shall at all times cooperate with the Exporter, and shall follow the Exporter’s instructions with regard to such incidents, in order to enable the Exporter to perform a thorough investigation into the incident, to formulate a correct response, and to take suitable further steps in respect of the incident.
9.2 The term “incident” used in Paragraph 9.1 shall be understood to mean in any case:
(a) a complaint or a request with respect to the exercise of a data subject’s rights under the UK GDPR;
(b) an investigation into or seizure of the Personal Data by government officials, or a specific indication that such an investigation or seizure is imminent;
(c) any unauthorized or accidental access, processing, deletion, loss or any form of unlawful processing of the Personal Data;
(d) any breach of the security and/or confidentiality as set out in Paragraphs 5 and 6 of this Addendum leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the Personal Data, or any indication of such breach having taken place or being about to take place;
(e) where, in the opinion of the Importer, implementing an instruction received from the Exporter would violate applicable laws to which the Exporter or the Importer are subject.
9.3 The Importer shall at all times have in place written procedures which enable it to promptly respond to the Exporter about an incident. Where an incident is reasonably likely to require a data breach notification by the Exporter under the UK GDPR, the Importer shall implement its written procedures in such a way that it is in a position to notify the Exporter no later than 24 hours of having become aware of such an incident.
9.4 Any notifications made to the Exporter pursuant to this Article shall be addressed to the Data Protection Officer or other employee of the Exporter whose contact details are provided during the registration process, and shall contain:
(a) a description of the nature of the incident, including where possible the categories and approximate number of data subjects concerned and the categories and approximate number of Personal Data records concerned;
(b) the name and contact details of the Importer’s data protection officer or another contact point where more information can be obtained;
(c) a description of the likely consequences of the incident; and
(d) a description of the measures taken or proposed to be taken by the Importer to address the incident including, where appropriate, measures to mitigate its possible adverse effects.
10. Contracting with Sub-Processors
10.1 The Exporter authorizes the Importer to engage sub-processors in the country locations for the Service-related activities specified as described in Paragraph 3.1. Importer shall inform the Exporter of any addition or replacement of such sub-processors giving the Exporter an opportunity to object to such changes.
10.2 Notwithstanding any authorization by the Exporter with the meaning of the preceding paragraph, the Importer shall remain fully liable vis-à-vis the Exporter for the performance of any such sub-processor that fails to fulfill its data protection obligations.
10.3 The consent of the Exporter pursuant to Paragraph 10.1 shall not alter the fact that consent is required for the engagement of sub-processors in a country outside the European Economic Area without a suitable level of protection.
10.4 The Importer shall ensure that the sub-processor is bound by the same data protection obligations of the Importer under this Addendum, shall supervise compliance thereof, and must in particular impose on its sub-processors the obligation to implement appropriate technical and organizational measures in such a manner that the processing will meet the requirements of the UK GDPR.
10.5 The Exporter may request that the Importer audit a sub-processor or provide confirmation that such an audit has occurred (or, where available, obtain or assist customer in obtaining a third-party audit report concerning the sub-processor’s operations) to ensure compliance with its obligations imposed by the Importer in conforming with this Addendum.
11. Returning or Destruction of Personal Data
11.1 Upon termination of the Service Agreement, upon the Exporter’s written request, or upon fulfillment of all purposes agreed in the context of the Services whereby no further processing is required, the Importer shall, at the discretion of the Exporter, either delete, destroy, or return all Personal Data to the Exporter and destroy or return any existing copies.
11.2 The Importer shall notify all third parties supporting its own processing of the Personal Data of the termination of the Service Agreement and shall ensure that all such third parties shall either destroy the Personal Data or return the Personal Data to the Exporter, at the discretion of the Exporter.
12. Assistance to Data Exporter
12.1 The Importer shall assist the Exporter by appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of the Exporter’s obligation to respond to a request for exercising the data subject’s rights under the UK GDPR.
12.2 The Importer shall assist the Exporter in ensuring compliance with the obligations pursuant to Paragraph 6 (Security) and prior consultations with supervisory authorities required under Article 36 of the UK GDPR taking into account the nature of processing and the information available to the Importer.
12.3 The Importer shall make available to the Exporter all information necessary to demonstrate compliance with the Importer’s obligations and to allow for and contribute to audits, including inspections, conducted by the Exporter or another auditor mandated by the Exporter.
13. Liability and Indemnity
13.1 The Importer indemnifies the Exporter and holds the Exporter harmless against all claims, actions, third party claims, losses, damages and expenses incurred by the Exporter and arising directly or indirectly out of or in connection with a breach of this Addendum and/or the UK GDPR by the Importer. The Exporter indemnifies the Importer and holds the Importer harmless against all claims, actions, third party claims, losses, damages and expenses incurred by the Importer and arising directly or indirectly out of or in connection with a breach of this Addendum and/or the UK GDPR by the Exporter.
14. Duration and Termination
14.1 This Addendum shall come into effect on the date the Exporter signs this Addendum, which may be through electronic means.
14.2 Termination or expiration of the Service Agreement shall not discharge the Importer from its confidentiality obligations pursuant to Paragraph 5.
14.3 The Importer shall process Personal Data until the date of termination of the Service Agreement, unless instructed otherwise by the Exporter, or until such data is returned or destroyed on instruction of the Exporter.
15. Miscellaneous
15.1 In the event of any inconsistency between the provisions of this Addendum and the provisions of the Service Agreement, the provisions of this Addendum shall prevail.
EXHIBIT A: INTERNATIONAL DATA TRANSFER ADDENDUM TO THE EU COMMISSION STANDARD CONTRACTUAL CLAUSES
Part 1: Tables
Table 1: Parties
| Start date | Effective date of the Service Agreement between Importer and Exporter | |
| The Parties | Exporter (who sends the Restricted Transfer) | Importer (who receives the Restricted Transfer) |
| Parties’ details | Full legal name and contact details: Customer, as noted in the Service Agreement | Full legal name and contact details: Supplier, as noted in the Service Agreement |
| Key Contact | As noted in the Service Agreement | As noted in the Service Agreement |
Table 2: Selected SCCs, Modules and Selected Clauses
| Addendum EU SCCs | The version of the Approved EU SCCs which this Addendum is appended to, detailed below, including the Appendix Information: Date: Reference (if any): Other identifier (if any): Or the Approved EU SCCs, including the Appendix Information and with only the following modules, clauses or optional provisions of the Approved EU SCCs brought into effect for the purposes of this Addendum: |
| Module | Module in operation | Clause 7 (Docking Clause) | Clause 11 (Option) | Clause 9a (Prior Authorisation or General Authorisation) | Clause 9a (Time period) | Is personal data received from the Importer combined with personal data collected by the Exporter? |
| 2 | N/A | N/A | General Written Authorisation | As set out in the Service Agreement | No |
Table 3: Appendix Information
“Appendix Information” means the information which must be provided for the selected modules as set out in the Appendix of the Approved EU SCCs (other than the Parties), and which for this Addendum is set out in:
Annex 1A: List of Parties:
Exporter:
Name: Customer as noted in the Service Agreement
Address: Customer’s address as noted in the Service Agreement
Contact person’s name, position, and contact details: Customer’s contact details as noted in the Service Agreement
Activities relevant to the data transferred under these Clauses: processing of personal data in connection with Customer’s use of the agreed upon Services
Importer:
Name: Provider as noted in the Service Agreement
Address: Provider’s address as noted in the Service Agreement
Contact person’s name, position, and contact details: Provider’s contact details as noted in the Service Agreement
Activities relevant to the data transferred under these Clauses: validation of email lists for deliverability; removal of known email complainers, abusers, and spam traps from email address lists; deliverability toolkit services; and to perform any additional services requested by Customer/Exporter
Importer’s representative in the European Union: Vlad Cristescu
Importer’s representative in the European Union email address: vlad.cristescu@zerobounce.net; gdpr@zerobounce.net
Importer’s representative in the UK: Vlad Cristescu
Importer’s Data Protection Officer’s email address: vlad.cristescu@zerobounce.net; gdpr@zerobounce.net
Role (controller/processor): processor
Annex 1B: Description of Transfer:
Categories of data subjects whose personal data is transferred:
Customer may submit Customer Validation Data to the Services, the extent of which is determined and controlled by Customer in its sole discretion, and which may include, but is not limited to Personal Data relating to the following categories of data subjects: Customer’s prospects, customers, business partners and vendors.
Categories of personal data transferred:
The categories of Personal Data to be processed includes: first name; last name; gender; city; state; country; Internet Protocol (IP) Address information; and email addresses.
Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialized training), keeping a record of access to the data, restrictions for onward transfers or additional security measures: Not applicable.
The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis):
Exporter determines the frequency with which it transfers personal data (could be one-time, or could be multiple-times).
Nature of the processing:
Importer will process personal data as necessary to perform the Services and as further instructed by Exporter in its use of the Services, which may include validation of email lists for deliverability; removal of known email complainers, abusers, and spam traps from email lists; deliverability toolkit services; and to perform any additional services requested by Data Controller.
Purpose(s) of the data transfer and further processing:
To receive Services under the Service Agreement, which may include validation of email lists for deliverability; removal of known email complainers, abusers, and spam traps from email lists; deliverability toolkit services; and to perform any additional services requested by Exporter.
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period:
the earlier of: (i) expiration of thirty (30) days from receipt; (ii) the termination of the Service Agreement, or (iii) Exporter’s election to delete the personal data submitted to Importer.
For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing:
Personal data may be transferred to (sub-) processors for performance of the Services, used in limited instances for duration of the Service Agreement, where Exporter submits a request for support using our chat function/form, attaches an email list in conjunction with a request for support, or where improper use of our API occurs, resulting in the generation of an error log. Processing may include collection, storage, and retrieval.
Annex II: Technical and organisational measures including technical and organisational measures to ensure the security of the data:
The following technical and organizational measures are performed on the processes taken by Importer:
Please refer to the description of the Importer’s security measures set out in Paragraph 6.1 of the Addendum. Importer has implemented and shall maintain a security program in accordance with SOC2 Type II standards. Importer’s security program includes the following technical and organizational security measures:
Measures of pseudonymization and encryption of Personal Data
ZeroBounce utilizes full disk encryption for all device that store Personal Data. ZeroBounce uses data hashing to anonymize cached data. ZeroBounce encrypts customer validation data using customer unique keys. ZeroBounce uses the latest industry best practices to ensure confidentiality through encryption of customer data both at rest and in transit, with the latest versions of TLS protocol and full disk encryption.
Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services
Our data integrity is protected by Cloudflare's perimeter security and Bitdefender engine on the internal side, where we use anti-ransomware, anti-malware and antivirus artifacts. Daily backups and periodic testing of the backups ensure our own and our customer's data availability and resilience.
Measures for ensuring the ability to restore the availability and access to Personal Data in a timely manner in the event of physical or technical incident
ZeroBounce’s Business Continuity and Disaster Recovery plans and procedures form the foundation of our operational team's methods of ensuring the possibility of almost immediate recovery and restore of data from a secondary location, in case of a natural or technical disaster. In addition, ZeroBounce’s full, differential or incremental backup procedures are set up so the data can be restored without issues in the fastest way possible.
Processes for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of Personal Data
ZeroBounce uses ISO, NIST and other industry known trusted sources for recommendations on how to implement its security controls. Being both ISO 27001 and SOC 2 Type II certified, we ensure that our code is built with security principles as the foundation; we test it using world's top security researchers before deploying it on production servers and we contract top industry hackers to test all the missing bits, so that we can fix and improve continuously. Besides our state of the art proprietary algorithms, we keep track of all non-conformities or vulnerabilities found; we assign and keep track of rectifying such with high priority.
Measures for user identification and authorization
ZeroBounce is partnered with OKTA for customer identity management.
Measures for the protection of data during transmission
ZeroBounce utilizes end to end encryption for all data transmissions.
Measures for the protection of data during storage
ZeroBounce utilizes full disk encryption for all devices that store data.
Measures for ensuring physical security of locations at which Personal Data are processed
Access to our data centers is provided by state of the art access control systems that permit entry only to authorized personnel, following a strict schedule. All access is monitored and logged. Environmental conditions in our data centers are closely observed and ideal conditions are maintained by modern HVAC systems.
Measures for ensuring events logging
ZeroBounce systems log all relevant data access events.
Measures for internal IT and IT security governance and management
ZeroBounce has IT and IT Security governance policies and procedures that align with ISO 27001 and SOC Type2 standards. These include but are not limited to measures to categorize and mitigate risks, measure for threat and vulnerability analysis and mitigation, measures for data governance, measures for identity and role based access management.
Measures for certification/assurance of processes and products
ZeroBounce is ISO 27001 and SOC 2 Type II certified. We have a yearly accreditation plan for both certifications and we have a continuous improvement and monitoring system in place. This is done using ZeroBounce’s Security and Compliance team and all the policies and procedures are re-evaluated on a yearly basis.
Measures for ensuring data minimization
ZeroBounce has data governance measures in place that ensure all data stored is adequate, relevant and limited to what is necessary for the validation and commercial process.
Measures for ensuring limited data retention
ZeroBounce utilizes a data retention policy that clearly defines data types, format, retention period, archiving and deletion process and procedures in the event of a violation. ZeroBounce will not store single validation requests and output unless users opt in to “Help make Zerobounce better”. ZeroBounce will store files sent for validation for up to 30 days with the option granted to the user to delete files at will. ZeroBounce has robust measures in place to deal with data erasure requests.
Measures for ensuring accountability
ZeroBounce enforces accountability through process ownership, so that each business process, service or division has a single owner who takes full responsibility and accountability. ZeroBounce shall require its sub-processors to take appropriate technical and organizational measures to provide assistance to the Importer and/or Exporter that are no less restrictive than those within the ZeroBounce Data Security Policy
Annex III: List of Sub processors (Modules 2 and 3 only): The list below contains the third-party Sub-Processors that are currently relied upon by Supplier in connection with the Services and may be used in connection with Supplier’s Processing of Customer Data.
1. Zendesk, Inc.
989 Market St.
San Francisco, CA 94103
Used in the limited instance where a customer submits a request for support using our chat function/form. Processing may include collection, storage, and retrieval.
2. Google
1600 Amphitheatre Parkway
Mountain View, CA 94043
Used in the limited instance where a customer attaches an email list in conjunction with a request for support. Processing may include collection and storage.
3. Cloudflare, Inc.
101 Townsend St.
San Francisco, CA 94107
Used in the limited instance where improper use of our API occurs, resulting in the generation of an error log (e.g., connection is from a banned location, or too many connections were attempted in a short timespan triggering a rate limit). Processing may include collection and storage.
Table 4: Ending this Addendum when the Approved Addendum Changes
| Ending this Addendum when the Approved Addendum changes | Which Parties may end this Addendum as set out in Section 19: Importer Exporter neither Party |
Part 2: Mandatory Clauses
Entering into this Addendum
1. Each Party agrees to be bound by the terms and conditions set out in this Addendum, in exchange for the other Party also agreeing to be bound by this Addendum.
2. Although Annex 1A and Clause 7 of the Approved EU SCCs require signature by the Parties, for the purpose of making Restricted Transfers, the Parties may enter into this Addendum in any way that makes them legally binding on the Parties and allows data subjects to enforce their rights as set out in this Addendum. Entering into this Addendum will have the same effect as signing the Approved EU SCCs and any part of the Approved EU SCCs.
Interpretation of this Addendum
3. Where this Addendum uses terms that are defined in the Approved EU SCCs those terms shall have the same meaning as in the Approved EU SCCs. In addition, the following terms have the following meanings:
| Addendum | This International Data Transfer Addendum which is made up of this Addendum incorporating the Addendum EU SCCs. |
| Addendum EU SCCs | The version(s) of the Approved EU SCCs which this Addendum is appended to, as set out in Table 2, including the Appendix Information. |
| Appendix Information | As set out in Table 3. |
| Appropriate Safeguards | The standard of protection over the personal data and of data subjects’ rights, which is required by UK Data Protection Laws when you are making a Restricted Transfer relying on standard data protection clauses under Article 46(2)(d) UK GDPR. |
| Approved Addendum | The template Addendum issued by the ICO and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as it is revised under Section 18. |
| Approved EU SCCs | The Standard Contractual Clauses set out in the Annex of Commission Implementing Decision (EU) 2021/914 of 4 June 2021. |
| ICO | The Information Commissioner. |
| Restricted Transfer | A transfer which is covered by Chapter V of the UK GDPR. |
| UK | The United Kingdom of Great Britain and Northern Ireland. |
| UK Data Protection Laws | All laws relating to data protection, the processing of personal data, privacy and/or electronic communications in force from time to time in the UK, including the UK GDPR and the Data Protection Act 2018. |
| UK GDPR | As defined in section 3 of the Data Protection Act 2018. |
4. This Addendum must always be interpreted in a manner that is consistent with UK Data Protection Laws and so that it fulfils the Parties’ obligation to provide the Appropriate Safeguards.
5. If the provisions included in the Addendum EU SCCs amend the Approved SCCs in any way which is not permitted under the Approved EU SCCs or the Approved Addendum, such amendment(s) will not be incorporated in this Addendum and the equivalent provision of the Approved EU SCCs will take their place.
6. If there is any inconsistency or conflict between UK Data Protection Laws and this Addendum, UK Data Protection Laws applies.
7. If the meaning of this Addendum is unclear or there is more than one meaning, the meaning which most closely aligns with UK Data Protection Laws applies.
8. Any references to legislation (or specific provisions of legislation) means that legislation (or specific provision) as it may change over time. This includes where that legislation (or specific provision) has been consolidated, re-enacted and/or replaced after this Addendum has been entered into.
Hierarchy
9. Although Clause 5 of the Approved EU SCCs sets out that the Approved EU SCCs prevail over all related agreements between the parties, the parties agree that, for Restricted Transfers, the hierarchy in Section 10 will prevail.
10. Where there is any inconsistency or conflict between the Approved Addendum and the Addendum EU SCCs (as applicable), the Approved Addendum overrides the Addendum EU SCCs, except where (and in so far as) the inconsistent or conflicting terms of the Addendum EU SCCs provides greater protection for data subjects, in which case those terms will override the Approved Addendum.
11. Where this Addendum incorporates Addendum EU SCCs which have been entered into to protect transfers subject to the General Data Protection Regulation (EU) 2016/679 then the Parties acknowledge that nothing in this Addendum impacts those Addendum EU SCCs.
Incorporation of and changes to the EU SCCs
12. This Addendum incorporates the Addendum EU SCCs which are amended to the extent necessary so that:
a. together they operate for data transfers made by the Exporter to the Importer, to the extent that UK Data Protection Laws apply to the Exporter’s processing when making that data transfer, and they provide Appropriate Safeguards for those data transfers;
b. Sections 9 to 11 override Clause 5 (Hierarchy) of the Addendum EU SCCs; and
c. this Addendum (including the Addendum EU SCCs incorporated into it) is (1) governed by the laws of England and Wales and (2) any dispute arising from it is resolved by the courts of England and Wales, in each case unless the laws and/or courts of Scotland or Northern Ireland have been expressly selected by the Parties.
13. Unless the Parties have agreed alternative amendments which meet the requirements of Section 12, the provisions of Section 15 will apply.
14. No amendments to the Approved EU SCCs other than to meet the requirements of Section 12 may be made.
15. The following amendments to the Addendum EU SCCs (for the purpose of Section 12) are made:
a. References to the “Clauses” means this Addendum, incorporating the Addendum EU SCCs;
b. In Clause 2, delete the words:
“and, with respect to data transfers from controllers to processors and/or processors to processors, standard contractual clauses pursuant to Article 28(7) of Regulation (EU) 2016/679”;
c. Clause 6 (Description of the transfer(s)) is replaced with:
“The details of the transfers(s) and in particular the categories of personal data that are transferred and the purpose(s) for which they are transferred) are those specified in Annex I.B where UK Data Protection Laws apply to the Exporter’s processing when making that transfer.”;
d. Clause 8.7(i) of Module 1 is replaced with:
“it is to a country benefitting from adequacy regulations pursuant to Section 17A of the UK GDPR that covers the onward transfer”;
e. Clause 8.8(i) of Modules 2 and 3 is replaced with:
“the onward transfer is to a country benefitting from adequacy regulations pursuant to Section 17A of the UK GDPR that covers the onward transfer;”
f. References to “Regulation (EU) 2016/679”, “Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation)” and “that Regulation” are all replaced by “UK Data Protection Laws”. References to specific Article(s) of “Regulation (EU) 2016/679” are replaced with the equivalent Article or Section of UK Data Protection Laws;
g. References to Regulation (EU) 2018/1725 are removed;
h. References to the “European Union”, “Union”, “EU”, “EU Member State”, “Member State” and “EU or Member State” are all replaced with the “UK”;
i. The reference to “Clause 12(c)(i)” at Clause 10(b)(i) of Module one, is replaced with “Clause 11(c)(i)”;
j. Clause 13(a) and Part C of Annex I are not used;
k. The “competent supervisory authority” and “supervisory authority” are both replaced with the “Information Commissioner”;
l. In Clause 16(e), subsection (i) is replaced with:
“the Secretary of State makes regulations pursuant to Section 17A of the Data Protection Act 2018 that cover the transfer of personal data to which these clauses apply;”;
m. Clause 17 is replaced with:
“These Clauses are governed by the laws of England and Wales.”;
n. Clause 18 is replaced with:
“Any dispute arising from these Clauses shall be resolved by the courts of England and Wales. A data subject may also bring legal proceedings against the Exporter and/or Importer before the courts of any country in the UK. The Parties agree to submit themselves to the jurisdiction of such courts.”; and
o. The footnotes to the Approved EU SCCs do not form part of the Addendum, except for footnotes 8, 9, 10 and 11.
Amendments to this Addendum
16. The Parties may agree to change Clauses 17 and/or 18 of the Addendum EU SCCs to refer to the laws and/or courts of Scotland or Northern Ireland.
17. If the Parties wish to change the format of the information included in Part 1: Tables of the Approved Addendum, they may do so by agreeing to the change in writing, provided that the change does not reduce the Appropriate Safeguards.
18. From time to time, the ICO may issue a revised Approved Addendum which:
a. makes reasonable and proportionate changes to the Approved Addendum, including correcting errors in the Approved Addendum; and/or
b. reflects changes to UK Data Protection Laws;
The revised Approved Addendum will specify the start date from which the changes to the Approved Addendum are effective and whether the Parties need to review this Addendum including the Appendix Information. This Addendum is automatically amended as set out in the revised Approved Addendum from the start date specified.
19. If the ICO issues a revised Approved Addendum under Section 18, if any Party selected in Table 4 “Ending the Addendum when the Approved Addendum changes”, will as a direct result of the changes in the Approved Addendum have a substantial, disproportionate and demonstrable increase in:
a. its direct costs of performing its obligations under the Addendum; and/or
b. its risk under the Addendum,
and in either case it has first taken reasonable steps to reduce those costs or risks so that it is not substantial and disproportionate, then that Party may end this Addendum at the end of a reasonable notice period, by providing written notice for that period to the other Party before the start date of the revised Approved Addendum.
20. The Parties do not need the consent of any third party to make changes to this Addendum, but any changes must be made in accordance with its terms.
Enterprise Plans
As your company grows, so does your need for powerful tools that can support your expansion. Our Enterprise plans offer you just the perfect mix of capacity, simplicity, and automation – so you can save resources and thrive.
ENTERPRISE PLANS: WHAT’S IN IT FOR YOU
There are many things you need to juggle when running a large company, and we understand time is of the essence. One thing you won’t need to worry about is keeping your email databases up-to-date.
To accommodate our larger partners, we put together a set of exclusive benefits to help you scale and evolve with ease. Take a look at what you get access to once you activate your Enterprise Plans.
Designated Account Manager
When validating large batches of email addresses, you may need some guidance as to how you can make the most of our service. As soon as your Enterprise plan starts, we’ll assign one of our email validationⓘ experts to assist you. From discussing your technical needs to advising you on the ins and outs of the email verification process, your Account Manager will always be there for you.
Customer Solution Engineer
We strive to make email verification easy for you, and our platform allows you to clean your list in three easy steps: upload – validate – download. Should any complex issues arise, your Customer Solution engineer is hands-on. He or she knows our system in and out and is ready to troubleshoot any glitch. You’ll be up and running in no time.
Dedicated Customer Success Engineer
Let’s say you’ve validated your email list, got your results, and are ready to import your results back into your email service provider. Before you send a new email, take some time to understand your ZeroBounce report. If you’re not sure whether certain contacts are safe to use, your Customer Success engineer is there to answer any questions. He gathers feedback, shares it with the team, and together they offer the insight you need. Plus, you can reach out to your Customer Success engineer anytime to adjust your email verification strategy for the best results.
Pricing benefits
The more email addresses you verify, the less your pay for each validation – this is our overall pricing principle at ZeroBounce. However, companies that choose the Enterprise Plans receive unique pricing benefits. You validate a high number of contacts. Not only do we want you to enjoy your bonus services, but we work with you to find the most advantageous pricing plan for your business.
Custom agreements
We know how important is it for you to feel safe and protected while validating your email list with ZeroBounce. That’s why we take this mission seriously. Thanks to our custom agreements, you can rest assured that we protect your confidentiality.
SLA: 99.99.6% guaranteed uptime
When you have so many daily tasks to complete and goals to fulfill, you want to know you’re using the most reliable tools. With the ZeroBounce Service Level Agreement (SLA), you get 99.99.6% uptime on our email verification platform. You can count on us.
24/7 technical support
What customers love the most about ZeroBounce is the accuracy we guarantee on email validationⓘ. Their second favorite thing is that we offer 24/7 customer support. With the Enterprise Plans, all of your perks are accessible 24/7. Need your Account Manager or your Customer Success engineer? You can talk to them anytime and find a solution to any issue you may encounter while – or after – cleaning your list.
Email validationⓘ coaching
When it comes to email validationⓘ, even the savviest of email marketers run into unknown territory sometimes. Maybe you’re not sure what to do about the catch- all emails we discover in your list. Or perhaps you get some soft bounces and don’t know how to interpret the codes and how to handle them. Such situations can occur, and it gives you peace of mind knowing you have someone who will shed some light on these dilemmas. The Enterprise Plans come with free email validationⓘ coaching – just reach out and ask, we’ve got you covered.
Early BETA access to all new features
Just like you and your business, ZeroBounce is constantly evolving. We’re on a mission to perfect our service and offer you the best email validationⓘ and email deliverabilityⓘ platform. And you get to be a part of the journey.
Our developers and engineers are always working on a new product. As part of the Enterprise Plans, you get to test the BETA versions, share your feedback, and help us make ZeroBounce better for you. We grow together like we’ve been doing from day one.
Apart from all the above benefits, you have access to the features that make ZeroBounce a favorite of thousands of customers worldwide:
- global content delivery network
- unsurpassed data protection, with military-grade encryption on your files
- our innovative A.I. email scoringⓘ and catch-all validation service
- a powerful and reliable API that you can use either in bulk or in real time, for both email validationⓘ and email scoringⓘ
- free deduplication: we remove duplicate email addresses from your database at no charge
- email data appending: get missing information added to your list, such as your subscribers’ name, gender, and location.
WHY SHOULD I GET THE ENTERPRISE PLANS?
If you’re on the fence about getting the Enterprise Plans, think about it this way: you could sign up for any of our subscriptions and enjoy all the great features ZeroBounce offers, at a set retail price. Or you could opt for a plan that gives you just what you need – and a bit more – at rates that are exclusive to you.
The Enterprise plans offer all the support you need when validating email list for your large company. Get a dedicated account manager and pricing benefits.
WHAT ARE THE REQUIREMENTS FOR ENTERPRISE PLANS?
If you’re ready to start an Enterprise account, or switch from your existing subscription, reach out to us today. An account manager will meet with you and discuss your monthly service expectations.
Certifications and Accreditations
From the time ZeroBounce was only a business idea, security was at the top of our minds. We wanted to create an accurate email verification service that would operate safely and fulfill the most advanced data protection standards.
Today, it gives our customers great peace of mind knowing that their data is in good hands while they can focus on restoring the quality of their email lists.
Take a look at the list of certifications and accreditations ZeroBounce received. They all confirm our dedication to protecting your files while you enjoy using our email verifier.
SOC 2 Type 2 Certification
ZeroBounce has undergone an examination of its internal controls and is SOC 2 Type 2-certified as of March 22, 2022.
The examination was conducted by external auditors under the guidelines established by the AICPA. The technical auditing process evaluated ZeroBounce’s internal controls to ensure customer data is managed according to AICPA’s criteria: security, availability, processing integrity, confidentiality and privacy.
ZeroBounce’s SOC 2 Type 2 compliance reinforces our commitment to the highest data security and privacy standards.
SOC2 Type 2 Certification: https://trust.zerobounce.net/ to find more details about URL
SOC 2 Certification
ZeroBounce was audited by a certified auditing firm and is proud to have successfully met the criteria of SOC 2 compliance effective July 9th, 2021.
SOC stands for “Systems and Organization Controls.” Developed by the American Institute of CPAs (AICPA), SOC 2 regulates how service organizations should manage customer data. It is a report on controls relating to security, availability, processing integrity, confidentiality and privacy.
SOC 2 reports are intended to meet the needs of a broad range of users that require detailed information and assurance about the controls at a service organization. These controls pertain to the security, availability and processing integrity of the systems that an organization uses to process users’ data. They are also relevant to the confidentiality and privacy of the information processed by these systems.
SOC 2 reports can play an important role in the:
- Oversight of the organization
- Vendor management programs
- Internal corporate governance and risk management processes
- Regulatory oversight
ISO/IEC 27001:2013 Management System, MSECB Certificate
ZeroBounce is ISO 27001:2013 certified as of August 24, 2022, when it attained the MSECB Management System Certificate. Our organization has been assessed and found to be in accordance with the management system requirements for ISO/IEC 27001:2013 (Information Technology)
You can see our status on this IAF profile page to find more details about URL
ISO 27001:2013 sets standards for establishing, implementing, maintaining and improving an information security management system within an organization.
This internationally recognized certification, which is regularly reviewed by an independent auditor, demonstrates our continual commitment to improving and protecting important digital assets.

https://www.zerobounce.net/assets_next/docs/images/pdf/ISO-IEC-27001.pdf to find more details about URL
Health Insurance Portability and Accountability Act (HIPAA)
The Health Insurance Portability and Accountability Act of 1996 is a United States privacy rule that mandates “covered entities” to protect your confidential healthcare information. The most common examples of these entities are doctors, healthcare providers, insurance companies, or clinics.
All governed entities must adhere to this privacy rule when storing or sharing confidential healthcare information with other “covered entities.” These institutions may never share this data with a third party that does not also satisfy the conditions for HIPAA certification and compliance.
ZeroBounce attained HIPAA privacy certification in August of 2023 after successfully satisfying all examination requirements in accordance with guidelines established by the AICPA for the reporting standard SOC 2 plus HIPAA Type 2.
This certification grants ZeroBounce the ability to work with these “covered entities” described above. ZeroBounce will continue to take the necessary steps to adhere to HIPAA privacy standards and renew its HIPAA certification when applicable.


https://www.zerobounce.net/assets_next/docs/images/pdf/HIPAACertification.pdf to find more details about URL
CYBER SMART DEFENCE
ZeroBounce received a Cyber Smart Defence (CSD) certification in 2023 to safeguard our system from any potential security breaches. Created by world-class experts in cybersecurity, CSD ensures our email verification platform remains a safe space for partners and customers worldwide.
At ZeroBounce, CSD specialists run periodical IT security audits, penetration tests, and vulnerability assessments. Furthermore, our team participates in periodic training sessions with the CSD team to stay on top of the latest cybersecurity developments.
PCI COMPLIANCE
PCI stands for Payment Card Industry, which is a set of standards that ensures all online transactions involving credit cards are made safely. ZeroBounce adheres to PCI standards to protect customers’ data during the payment process on zerobounce.net.
We partner with world-class, well-respected cybersecurity companies to assess our systems on a monthly basis. These comprehensive tests focus on all aspects of our application. Ensuring all transactions take place safely and responsibly is paramount to us.
EU GDPR COMPLIANCEⓘ
The General Data Protection Regulation (GDPR) aims to improve data privacy laws across Europe and create a safer online environment for consumers worldwide. ZeroBounce became EU GDPR Compliant a few months before the new regulations came into force on May 25, 2018.
Our email list verification platform abides by all GDPR requirements, established by the European Parliament and the Council of the European Union. Following GDPR protocols ensures your data is safeguarded while you validate your email lists and make payments on our platform. ZeroBounce is committed to processing personal data that is subject to the GDPR in a lawful, fair, and transparent manner.
Our Data Protection Officer conducts regular assessments on ZeroBounce’s GDPR complianceⓘ. Moreover, a third-party security company runs monthly audits to confirm our ongoing commitment to your data privacy.
Data Privacy Framework (DPF)
The EU-U.S. and Swiss-U.S. Data Privacy Framework (DPF) are sets of regulations that provide companies with the mechanisms to transfer personal data securely during transatlantic commerce. The EU-US and Swiss-US Data Privacy Framework (DPF) Programs require annual registration and re-certification.
ZeroBounce joined the Data Privacy Framework (DPF) voluntarily and complies with the Framework’s requirements. These requirements revolve around privacy principles such as notice, access, choice, and accountability for onward transfer. As a data processor, ZeroBounce provides users with a secure upload mechanism and uses encryption ciphers for the email databases download process.
Since December 2017, our company has been an active participant in the EU-U.S. and Swiss-U.S. Data Privacy Framework (DPF) Programs.
BBB ACCREDITED BUSINESS
The Better Business Bureau (BBB) is an organization whose mission is to foster trust between businesses and consumers and to support best practices in the marketplace. The BBB sets standards that maintain and encourage good marketplace behavior and helps build a more transparent business community.
After careful evaluation by the BBB Board of Directors, the organization established that ZeroBounce meets BBB accreditation standards. Some of these standards include a positive track record in the marketplace, adherence to fair advertising and selling, and the honest representation of products and services.
Our company became a BBB Accredited Business in September 2017.
ZeroBounce has taken all necessary steps to renew each of these certifications and accreditations. Our team is collaborating with third-party experts who help us periodically assess our status and undertake thorough compliance measures.

BBB Certification
https://www.zerobounce.net/assets_next/docs/images/pdf/BBBCertification.pdf to find more details about URL
ZeroBounce List of Sub-processors and Service Providers
What is a Sub-Processor?
A sub-processor is a third party engaged by a data processor to perform specific processing activities on behalf of a data controller. In the context of data protection and privacy regulations, such as the General Data Protection Regulation (GDPR), the following roles are defined:
- Data Controller: The entity that determines the purposes and means of processing personal data.
- Data Processor: The entity that processes personal data on behalf of the data controller.
- Sub-Processor: Any third party that the data processor uses to assist in processing the personal data.
In our case, in connection with ZeroBounce’s services such as email validationⓘ and list cleaning, a ZeroBounce customer (who acts as a data controller) outsources its data processing to a service provider (data processor - ZeroBounce). The service provider then hires another company (sub-processor) to perform some specialized task, like data storage. That third company becomes a sub-processor.
Under laws like the GDPR, data processors are required to obtain the controller's authorization before engaging sub-processors. Also, they must ensure that sub-processors adhere to the same data protection obligations as the original processor.
Due Diligence
ZeroBounce is committed to conducting thorough due diligence when engaging with third parties, ensuring that they are assessed prior to onboarding and as part of our annual risk management program.
We hold our service providers to strict contractual obligations, requiring them to process personal data solely for the purpose of delivering services to ZeroBounce. These contracts ensure that service providers comply with our commitments to ZeroBounce customers and adhere to applicable data protection laws.
List of Sub-processors
Sub-processors involved in processing customer registration data
- NameExchanged dataPurpose
- LinkedIn AdsEmail address and cookie tracking dataAd placement
- Google AdsEmail address and cookie tracking dataAd placement
- MicrosoftEmail address and cookie tracking dataAd placement
- MetaEmail address and cookie tracking dataAd placement
- OutbrainEmail address and cookie tracking dataAd placement
- TaboolaEmail address and cookie tracking dataAd placement
- QuantcastEmail address and cookie tracking dataAd placement
- RedditEmail address and cookie tracking dataAd placement
- QuoraEmail address and cookie tracking dataAd placement
- HubspotEmail addressMarketing aggregator
- ZendeskEmail addressCustomer service ticketing and communication; also used in the limited instance where a customer submits a request for support using our chat function/form.
- OpenAIname, email address, purchase details, payment details and customer behaviourUsed to generate analytical reports and insights on ad performance, payment activity, subscription churn, and customer support interactions by processing pseudonymized operational data to identify trends, improve decision-making, and enhance user experience.
- MailchimpEmail addressUsed as a backup provider to send transactional emails by processing recipient email addresses, message content, and delivery metadata to ensure reliable communication delivery.
- TrustPilotEmail addressTo send review invitations and collect genuine user feedback about our services.
- G2Email addressTo send review invitations and collect genuine user feedback about our services.
Sub-processors involved in the email validationⓘ process
- NameExchanged dataPurpose
- CloudflareEmail addressPerimeter security, Web application firewall (WAF). Customer email addresses will be logged only in the case of API validation calls if the customer exceeds the technical recommendation of product usage (e.g., sending request limits, IP violations, etc.)
Cloudflare - email address, purpose: perimeter security, web application firewall. Customer email address will be logged only in case of API calls validation if the client exceeds technical recommendation of product usage (e.g., sending request limits, IP violations etc.).
List of Service Providers
ZeroBounce works with the service providers listed below for email validationⓘ service delivery.
- NamePurpose of processingExchanged dataEntity country
- OktaIdentity management providerEmail addressUS
- StripePayment gatewayCardholder dataUS
- PayPalPayment gatewayCardholder dataUS
- M247Infrastructure hosting & internet providernoneEU
- DigitalRealtyColocation hosting providernoneUS
- EquinixColocation hosting providernoneUS
- CogentInternet providernoneUS
- NTTInternet providernoneUS
- CloudflareInternet providernoneUS
- AtlassianProject managementLimited email addressUS
- DocuSignElectronic SignaturesBusiness User DataUS
- CalendlyMeeting OrganizerBusiness User DataUS
- QwilrQuote ToolBusiness User DataUS
- SlackCommunication ToolLimited email addressUS
Updates to this page
Given the global scope of our business and the large number of customers we serve, our business needs and service providers may change periodically.
For instance, we may discontinue a service provider to streamline and reduce the number of providers we use or add a new service provider if it improves our ability to deliver our email validationⓘ service.
We will regularly update this page to reflect any changes, including the addition or removal of service providers or sub-processors.