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List of subsequent subcontractors

Dated June 24th 2021

List of Sarbacane Software's subsequent data processors

Data processor Activity description Processing countries Products

HighConnexion (1)
France

from July 30th 2021

Sending SMS communications and receiving the associated responses

France

Sarbacane
Mailify

SINCH (1)
Sweden

Sending SMS communications and receiving the associated responses

Ireland
Sweden

Sarbacane
Mailify
Primotexto

CM (1)
France

Sending SMS communications and receiving the associated responses

Netherlands

Sarbacane
Mailify
Primotexto

FRESHWORKS INC.(2)
USA

Ticket management solution by email, allowing the follow-up of the discussions between our customers and our staff or the staff of our branch offices.

United States of America

Transfer under the protection of the European Commission's standard contractual clauses

All services

OVH
France

Server hosting dedicated to the products' applications

France

Sarbacane
Mailify
Jackmail
Primotexto
Tipimail
Layout

ASK Technologies *
France

Ticket management solution by instant messaging (chat)

France / Belgium

Websites
Sarbacane
Mailify
Sarbacane Chat

Sarbacán Software SL
Spain

from July 30th 2021

Customer relations, technical support

Spain

All services

(1) The data processors involved in the SMS activities are implemented in case of a SMS service subscription or the use of the possible offered SMS credits.

(2) Freshworks inc / ASK Technologies: When our customers contact us through the available channels, whether from our products or our websites, the messages exchanged, including any attachments, are included in an exchange tracking ticket hosted on the provider's servers. These exchanges may include personal data, for example in cases of solicitation to solve a specific problem on a contact list. Messages (communications, newsletters, SMS) sent to our customers' recipients do not transit through the provider's servers.


Any changes regarding the addition or replacement of subsequent data processors shall be made under the conditions specified in the personal data treatment agreement or by special conditions, if applicable for the latter. Additional data processors may be required and shall be specified by name in the relevant service agreement.

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