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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 NameEntity TypeEntity CountryLegal Safeguard
Amazon Web Services, Inc.Cloud Service ProviderUnited StatesData Processing Agreement with Standard Contractual Clauses
GoogleCloud Service ProviderUnited StatesData 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 NamePurposeApplicable ServicesEntity CountryLegal Safeguard
Active CampaignProvides lead qualification, personalized experience, and emails for Thinkific customersThinkific MarketingUnited StatesData Processing Agreement with Standard Contractual Clauses
AdaDelivers automated Chat supportThinkific SupportCanadaData Processing Agreement with Standard Contractual Clauses
AppcuesDelivers contextual in-app communicationsThinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
ApolloProvides GraphQL hosting for the Thinkific platformThinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
AvalaraTax compliance for Thinkific subscriptionsThinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
BaremetricsSubscription analytics and insightsThinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
BigmarkerVirtual conferencing and virtual eventsThinkific MarketingUnited StatesData Processing Agreement with Standard Contractual Clauses
BrightbackDunning service for Thinkific subscriptionsThinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
CalendlyCall scheduling with Thinkific customersThinkific Customer Success and, SupportUnited StatesData Processing Agreement with Standard Contractual Clauses
Carry Technologies, Inc. dba HightouchUsed to transfer data between Thinkific Services and other listed Sub-processorsThinkific Data TeamUnited StatesData Processing Agreement with Standard Contractual Clauses
Chili PiperCall scheduling and lead routingThinkific SalesUnited StatesData Processing Agreement with Standard Contractual Clauses
CrossbeamCustomer data aggregation service to evaluation partnership pottentitalThinkific Platform PartnershipsUnited StatesData Processing Agreement with Standard Contractual Clauses
DelightedNet Promoter Score to gather customer feedbackThinkific MarketingUnited StatesData Processing Agreement with Standard Contractual Clauses
DoolyCustomer notetaking to track client conversationsThinkific Customer SuccessUnited StatesData Processing Agreement with Standard Contractual Clauses
EnjoyHQStores, organizes and synthesizes qualitative customer data (video, text, images)Thinkific ServiceUnited KingdomData Processing Agreement with Standard Contractual Clauses
eSentireManage Detect Response providerThinkific Service CanadaData Processing Agreement with Standard Contractual Clauses
FileStackTransmits uploads to the Thinkific platformThinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
FullstoryProduct analytics and insightsThinkific SupportUnited StatesData Processing Agreement with Standard Contractual Clauses
GoogleCommunication, collaboration, analytics and insightsThinkific Marketing, Sales, Platform Partnerships, Support and,  Customer SuccessUnited StatesData Processing Agreement with Standard Contractual Clauses
Gong.ioSales conversations intelligence platformThinkific Sales, and,  Customer SuccessUnited StatesData Processing Agreement with Standard Contractual Clauses
HellosigneSignature tool for contractsThinkific Sales and,  Customer SuccessUnited StatesData Processing Agreement with Standard Contractual Clauses
HubspotProvides lead qualification, personalized experience, and emails for Thinkific customersThinkific MarketingUnited StatesData Processing Agreement with Standard Contractual Clauses
LookerBig data analytics platform used by internal Thinkific teamsThinkific Data TeamUnited StatesData Processing Agreement with Standard Contractual Clauses
MailgunUsed by the Thinkific platform to provide email services Thinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
MazeConducts research and user testingThinkific ServiceParisData Processing Agreement with Standard Contractual Clauses
MimecastEmail security and Data Loss PreventionThinkific SecurityUnited StatesData Processing Agreement with Standard Contractual Clauses
MixpanelEvent tracking analytics and insightsThinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
ModeData analytics within the Thinkific platformThinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
OnetrustCookie Consent ManagementThinkific Service United StatesData Processing Agreement with Standard Contractual Clauses
NetskopeCloud Access Security Broker Thinkific SecurityUnited StatesData Processing Agreement with Standard Contractual Clauses
New RelicApplication Performance ManagementThinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
OutreachCustomer contact tool utilized across sales to automate emailing Thinkific Sales and,   Customer SuccessUnited StatesData Processing Agreement with Standard Contractual Clauses
ProfitwellDunning service for Thinkific subscriptionsThinkific Service United StatesData Processing Agreement with Standard Contractual Clauses
SalesforceStores customer contact information, subscription status, and other customer related informationThinkific Service, Sales, and, Customer SuccessUnited StatesData Processing Agreement with Standard Contractual Clauses
SlackReal time chat communication with Thinkific PartnersThinkific PartnershipsUnited StatesData Processing Agreement with Standard Contractual Clauses
Stitch DataETL serviceThinkific Data TeamUnited StatesData Processing Agreement with Standard Contractual Clauses
StripeCredit Card billing processor for Thinkific customer subscriptions and customer salesThinkific ServiceIrelandData Processing Agreement with Standard Contractual Clauses
Sumo LogicSecurity Information and Event Management Thinkific SecurityUnited StatesData Processing Agreement with Standard Contractual Clauses
TypeFormRequest product feedback from Thinkific customersThinkific Product Management and,   Customer SuccessSpainData Processing Agreement with Standard Contractual Clauses
UnbounceLead generation dynamic landing page platformThinkific MarketingCanadaData Processing Agreement with Standard Contractual Clauses
WistiaVideo hosting platform for the Thinkific platform Thinkific ServiceUnited StatesData Processing Agreement with Standard Contractual Clauses
WorkdayCustomer invoicing and payment information stored for accounting purposes Thinkific FinanceUnited StatesData Processing Agreement with Standard Contractual Clauses
ZapierWorkflow Automation tool Thinkific Marketing United StatesData Processing Agreement with Standard Contractual Clauses
ZendeskUsed by technical support and the customer success team to manage tickets concerning product support, billing, and other related issuesThinkific SupportUnited StatesData Processing Agreement with Standard Contractual Clauses
ZoomVideo conferencing Thinkific Sales, Marketing and, SupportUnited StatesData 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 CDNCDN LocationDescription of
CDN Services
Legal Safeguard
Amazon Web Services, Inc.Thinkific ServiceGlobalPublic 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
Fastly, Inc.Thinkific ServiceGlobalPublic website content served to website visitors may be stored with Fastly, Inc, and transmitted by Fastly, Inc., to website visitors, to expedite transmission.Data Processing Addendum with Standard Contractual Clauses

 

As of August 19th, 2022