Who does Fresh Relevance transfer data to and why?
As Fresh Relevance is a Dotdigital Company, many of Fresh Relevance Ltd’s global entities are associated with the Dotdigital Group, which include:
- Dotdigital EMEA Limited
- Dotdigital Inc
- Dotdigital APAC Pty Limited
- Dotdigital B.V
- dotmailer SA Pty Ltd
- Dotdigital SG Pte, Ltd
- Dotdigital Poland Sp. Z.O.O.
- Dynmark International Ltd
- Fresh Relevance Inc
We engage with external subprocessors for the purposes of platform hosting, network management, security, internet and network services, data back-ups, storage out of hours support and third party integrations, these are:
- Amazon Web Services, Inc.
The following sub-processors will be introduced throughout 2024 as part of the Dotdigital acquisition integration:
- Cloudflare: For Content Delivery Network (CDN) and web proxy services. Reverse proxy in which some connections between our client’s system and the platform are routed. The HTTPS connection is terminated here, and then re-established through to Fresh Relevance.
- Elasticsearch Ltd: Provision of tools for log monitoring and storage of customer data.
- Microsoft Azure: For the provision of the Fresh Relevance service including storage of customer data.
- Tray.ai: Operator of “middleware” for certain third-party integrations offered by Dotdigital and Fresh Relevance that may be connected to a Fresh Relevance or Dotdigital account (as configured by the client).
- Google Cloud Platform: For the provision of the Fresh Relevance service including storage of customer data.
- PartnerHero: Established in the US, PartnerHero is used for the provision of multi-lingual & out of hours support during non-business hours.
- Phoenix47: Based in the UK, Phoenix47 is used for the provision of out of hours support during non-business hours.
Will data be transferred outside of the EEA?
Yes, but only in limited circumstances and all such transfers are protected by safeguards in place. In particular, such transfers relate to Internal Global Entities of Fresh Relevance, a Dotdigital company. As a standard, UK and EU client data will be stored in the EU. There may however be a transfer outside of the EEA in the event employee’s from Dotdigital’s global entities access customer accounts in connection with providing the service. This would typically be for support and account management purposes.
What measures does Fresh Relevance have in place to protect data transferred outside of the EEA?
Currently we have established Intra-group Data Processing Addendums and Standard Contractual Clauses to cover the different transfers made outside of the EEA to Fresh Relevance global entities.
Does Fresh Relevance inform clients where a new third-party sub-processor is being engaged and can we object?
Yes, we would always notify clients at least 30 days in advance when we are planning on engaging a new external sub-processor. This is usually by way of an email to the email address provided by you on the Service Agreement. As a client, you will always be given 10 days to object to Fresh Relevance engaging a new sub-processor where you have any data protection concerns.
