Thinkific Sub-processors

What Is a Sub-processor?

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

Due Diligence

Thinkific applies a commercially reasonable selection process by which it evaluates the security, privacy, and confidentiality practices of proposed sub-processors that will or may have access to or process Customer Data.

Contractual Safeguards

Thinkific requires its sub-processors to satisfy equivalent obligations as those required from Thinkific (as a Data Processor) as set forth in Thinkific’s Terms of Service, including but not limited to the requirements to:

• process personal data in accordance with data controller’s (i.e. Customer’s) documented instructions (as communicated in writing to the relevant sub-processor by Thinkific);
• in connection with their sub-processing activities, use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, pursuant to applicable data protection laws;
• provide regular training in security and data protection to personnel to whom they grant access to personal data;
• implement and maintain appropriate technical and organizational measures (including measures consistent with those to which Thinkific is contractually committed to adhere insofar as they are equally relevant to the sub-processor’s processing of personal data on Thinkific’s behalf)
• promptly inform Thinkific about any actual or potential security breaches; and cooperate with Thinkific in order to facilitate requests from data controllers, data subjects, or data protection authorities, as applicable.

This notice does not give Customers any additional rights or remedies and should not be construed as a binding agreement. The information herein is to provide the actual list of third-party sub-processors and content delivery networks used by Thinkific as of the date of this notice (which Thinkific may use in the delivery and support of its Services).

Infrastructure Sub-processors – Customer Data Storage

Thinkific controls access to the infrastructure that Thinkific uses to host Customer Data submitted to the Services, other than as set forth below. Currently, the Thinkific production systems for the Thinkific Platform are located in co-location facilities in the United States. Customers may be shifted among data centers within a region to promote performance and availability of the Services. The following table describes the countries and legal entities engaged in the storage of Customer Data by Thinkific.

Service Specific Sub-processors

Thinkific works with certain third parties to provide specific functionality within its services. These providers are the sub-processors set forth below. In order to provide the relevant functionality these sub-processors access Customer Data. Their use is limited to the indicated Services.

Content Delivery Networks

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

As of August 19th, 2022