Thinkific Sub-processors
Thinkific Labs, Inc. (“Thinkific”) uses certain sub-processors and content delivery networks to assist with the interoperability of the Thinkific Platform. Capitalized terms used and not otherwise defined below will have the meanings given to such terms in our Terms of Service.
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.
| Entity Name | Entity Type | Entity Country | Legal Safeguard |
|---|---|---|---|
| Amazon Web Services, Inc. | Cloud Service Provider | United States | Data Processing Agreement with Standard Contractual Clauses |
| Cloud Service Provider | United States | Data Processing Agreement with Standard Contractual Clauses |
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.
| Entity Name | Purpose | Applicable Services | Entity Country | Legal Safeguard |
|---|---|---|---|---|
| Ada | Delivers automated Chat support | Thinkific Support | Canada | Data Processing Agreement with Standard Contractual Clauses |
| Apollo | Provides GraphQL hosting for the Thinkific platform | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Avalara | Tax compliance for Thinkific subscriptions | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Baremetrics | Subscription analytics and insights | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Bigmarker | Virtual conferencing and virtual events | Thinkific Marketing | United States | Data Processing Agreement with Standard Contractual Clauses |
| Breadcrumbs.io | Lead scoring utilizing customer attribute data | Thinkific Sales and Marketing | Canada | Data Processing Agreement with Standard Contractual Clauses |
| Brightback | Dunning service for Thinkific subscriptions | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Calendly | Call scheduling with Thinkific customers | Thinkific Customer Success and, Support | United States | Data Processing Agreement with Standard Contractual Clauses |
| Carry Technologies, Inc. dba Hightouch | Used to transfer data between Thinkific Services and other listed Sub-processors | Thinkific Data Team | United States | Data Processing Agreement with Standard Contractual Clauses |
| Chili Piper | Call scheduling and lead routing | Thinkific Sales | United States | Data Processing Agreement with Standard Contractual Clauses |
| Clearbit.com | Enriching customer level data | Thinkific Sales and Marketing | United States | Data Processing Agreement with Standard Contractual Clauses |
| Cloudflare Inc. | DNS, SSL Termination and Web Application Firewall | Thinkific Platform | United States | Data Processing Agreement with Standard Contractual Clauses |
| Crossbeam | Customer data aggregation service to evaluation partnership potential | Thinkific Platform Partnerships | United States | Data Processing Agreement with Standard Contractual Clauses |
| Delighted | Net Promoter Score to gather customer feedback | Thinkific Marketing | United States | Data Processing Agreement with Standard Contractual Clauses |
| Dooly | Customer notetaking to track client conversations | Thinkific Customer Success | United States | Data Processing Agreement with Standard Contractual Clauses |
| EnjoyHQ | Stores, organizes and synthesizes qualitative customer data (video, text, images) | Thinkific Service | United Kingdom | Data Processing Agreement with Standard Contractual Clauses |
| eSentire | Manage Detect Response provider | Thinkific Service | Canada | Data Processing Agreement with Standard Contractual Clauses |
| FileStack | Transmits uploads to the Thinkific platform | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Fullstory | Product analytics and insights | Thinkific Support | United States | Data Processing Agreement with Standard Contractual Clauses |
| Communication, collaboration, analytics and insights | Thinkific Marketing, Sales, Platform Partnerships, Support and, Customer Success | United States | Data Processing Agreement with Standard Contractual Clauses | |
| Gong.io | Sales conversations intelligence platform | Thinkific Sales, and, Customer Success | United States | Data Processing Agreement with Standard Contractual Clauses |
| Hubspot | Provides lead qualification, personalized experience, and emails for Thinkific customers | Thinkific Marketing | United States | Data Processing Agreement with Standard Contractual Clauses |
| JUSTT.AI | To automate chargeback disputes | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Looker | Big data analytics platform used by internal Thinkific teams | Thinkific Data Team | United States | Data Processing Agreement with Standard Contractual Clauses |
| Mailgun | Used by the Thinkific platform to provide email services | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Mimecast | Email security and Data Loss Prevention | Thinkific Security | United States | Data Processing Agreement with Standard Contractual Clauses |
| Mixpanel | Event tracking analytics and insights | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Mode | Data analytics within the Thinkific platform | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Onetrust | Cookie Consent Management | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Netskope | Cloud Access Security Broker | Thinkific Security | United States | Data Processing Agreement with Standard Contractual Clauses |
| New Relic | Application Performance Management | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| OpenAI, L.L.C. | Service provider for AI powered features. | Thinkific Service, Thinkific Support | United States | Data Processing Agreement with Standard Contractual Clauses |
| Outreach | Customer contact tool utilized across sales to automate emailing | Thinkific Sales and, Customer Success | United States | Data Processing Agreement with Standard Contractual Clauses |
| Profitwell | Dunning service for Thinkific subscriptions | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Salesforce | Stores customer contact information, subscription status, and other customer related information | Thinkific Service, Sales, and, Customer Success | United States | Data Processing Agreement with Standard Contractual Clauses |
| Slack | Real time chat communication with Thinkific Partners | Thinkific Partnerships | United States | Data Processing Agreement with Standard Contractual Clauses |
| Stitch Data | ETL service | Thinkific Data Team | United States | Data Processing Agreement with Standard Contractual Clauses |
| Stripe | Security Information and Event Management | Thinkific Security | United States | Data Processing Agreement with Standard Contractual Clauses |
| TypeForm | Request product feedback from Thinkific customers | Thinkific Product Management and, Customer Success | Spain | Data Processing Agreement with Standard Contractual Clauses |
| Unbounce | Lead generation dynamic landing page platform | Thinkific Marketing | Canada | Data Processing Agreement with Standard Contractual Clauses |
| UserPilot | Delivers contextual in-app communications | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Wistia | Video hosting platform for the Thinkific platform | Thinkific Service | United States | Data Processing Agreement with Standard Contractual Clauses |
| Workday | Customer invoicing and payment information stored for accounting purposes | Thinkific Finance | United States | Data Processing Agreement with Standard Contractual Clauses |
| Zapier | Workflow Automation tool | Thinkific Marketing | United States | Data Processing Agreement with Standard Contractual Clauses |
| Zendesk | Used by technical support and the customer success team to manage tickets concerning product support, billing, and other related issues | Thinkific Support | United States | Data Processing Agreement with Standard Contractual Clauses |
| Zoom | Video conferencing | Thinkific Sales, Marketing and, Support | United States | Data Processing Agreement with Standard Contractual Clauses |
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.
| CDN Provider | Services Using CDN | CDN Location | Description of CDN Services | Legal Safeguard |
|---|---|---|---|---|
| Amazon Web Services, Inc. | Thinkific Service | Global | Public website content served to website visitors may be stored with Amazon Web Services, Inc., and transmitted by Amazon Web Services, Inc., to website visitors, to expedite transmission. | Data Processing Addendum with Standard Contractual Clauses |
| Cloudflare, Inc. | Thinkific Service | Global | Public website content served to website visitors may be stored with Cloudflare, Inc., and transmitted by Cloudflare, Inc., to website visitors, to expedite transmission. | Data Processing Addendum with Standard Contractual Clauses |