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Kami GDPR-compliant Data
Processing AGREEMENT
under Art. 28 (3) and (4) of Regulation (EU) 2016/679
Last Modified: December 12, 2022
1. Kami Limited, Data Processor – Kami is an education software company that
provides products and services to learners and institutions. It is situated in 8605
Santa Monica Blvd, PMB 57387, West Hollywood, California 90069-4109 USA.
You can contact us here: [email protected]
INTRODUCTION
This Kami Data Processing Agreement (“DPA”) reflects the parties’ agreement with respect
to the terms governing the processing of Personal Data under the Kami standard Terms of
Service and the Kami Privacy Policy (together, the “TOS”). This DPA is an amendment to the
TOS and is effective upon its incorporation into the TOS, which incorporation may be
specified in an Order or an executed amendment to the TOS. Upon its incorporation into the
TOS, the DPA will form a part of the TOS.
In all cases Kami (“Processor”), or a third party acting on behalf of Processor, acts as the
processor of Personal Data and you (“Controller”) remain controller of Personal Data. The
term of this DPA shall follow the term of the TOS. Terms not otherwise defined herein shall
have the meaning as set forth in the TOS.
. …, Data Controller - …
Named together “Parties”
General provisions
1. The purpose of this Agreement is to ensure compliance with Article 28(3) and
(4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April
2016 on the protection of natural persons with regard to the processing of personal data and
on the free movement of such data.
2. This Agreement is prepared in accordance with the Strandard Contractual
Clauses, adopted by Commission Implementing Decision (EU) 2021/915 of 4 June 2021 on
standard contractual clauses between controllers and processors under Article 28(7) of
Regulation (EU) 2016/679 of the European Parliament and of the Council.
3. The controllers and processors listed in Annex I have agreed to this Agreement
in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or
Article 29 (3).
4. This Agreement apply to the processing of personal data as specified in Annex
II.
5. Annexes I to IV are an integral part of the Agreement.
6. This Agreement is without prejudice to obligations to which the controller is
subject by virtue of Regulation (EU) 2016/679.
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7. This Agreement do not by themselves ensure compliance with obligations
related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679.
8. The Parties undertake not to modify these Clauses, except for adding
information to the Annexes or updating information in them. This does not prevent the Parties
from including the standard contractual clauses laid down in these Clauses in a broader
contract, or from adding other clauses or additional safeguards provided that they do not
directly or indirectly contradict the Clauses or detract from the fundamental rights or
freedoms of data subjects.
9. Where these Clauses use the terms defined in Regulation (EU) 2016/679, those
terms shall have the same meaning as in that Regulation.
10. These Clauses shall be read and interpreted in the light of the provisions of
Regulation (EU) 2016/679.
11. These Clauses shall not be interpreted in a way that runs counter to the rights
and obligations provided for in Regulation (EU) 2016/679 or in a way that prejudices the
fundamental rights or freedoms of the data subjects.
12. In the event of a contradiction between these Clauses and the provisions of
related agreements between the Parties existing at the time when these Clauses are agreed or
entered into thereafter, these Clauses shall prevail.
Obligations of the Parties
13. The details of the processing operations, in particular the categories of personal
data and the purposes of processing for which the personal data is processed on behalf of the
controller, are specified in Annex II.
14. 1. The processor shall process personal data only on documented instructions
from the controller, unless required to do so by Union or Member State law to which the
processor is subject. In this case, the processor shall inform the controller of that legal
requirement before processing, unless the law prohibits this on important grounds of public
interest. Subsequent instructions may also be given by the controller throughout the duration
of the processing of personal data. These instructions shall always be documented.
14.2. The processor shall immediately inform the controller if, in the processor’s
opinion, instructions given by the controller infringe Regulation (EU) 2016/679 or the
applicable Union or Member State data protection provisions.
15. The processor shall process the personal data only for the specific purpose(s)
of the processing, as set out in Annex II, unless it receives further instructions from the
controller.
16. Processing by the processor shall only take place for the duration specified in
Annex II.
17. 1. The processor shall at least implement the technical and organisational
measures specified in Annex III to ensure the security of the personal data. This includes
protecting the data against a breach of security leading to accidental or unlawful destruction,
loss, alteration, unauthorised disclosure or access to the data (personal data breach). In
assessing the appropriate level of security, the Parties shall take due account of the state of the
art, the costs of implementation, the nature, scope, context and purposes of processing and the
risks involved for the data subjects.
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17.2. The processor shall grant access to the personal data undergoing processing to
members of its personnel only to the extent strictly necessary for implementing, managing
and monitoring of the contract. The processor shall ensure that persons authorised to process
the personal data received have committed themselves to confidentiality or are under an
appropriate statutory obligation of confidentiality.
18. If the processing involves personal data revealing racial or ethnic origin,
political opinions, religious or philosophical beliefs, or trade union membership, genetic data
or biometric data for the purpose of uniquely identifying a natural person, data concerning
health or a person’s sex life or sexual orientation, or data relating to criminal convictions and
offences (“sensitive data”), the processor shall apply specific restrictions and/or additional
safeguards.
19.1. The Parties shall be able to demonstrate compliance with these Clauses.
19.2. The processor shall deal promptly and adequately with inquiries from the
controller about the processing of data in accordance with these Clauses.
19.3. The processor shall make available to the controller all information necessary
to demonstrate compliance with the obligations that are set out in these Clauses and stem
directly from Regulation (EU) 2016/679. At the controller’s request, the processor shall also
permit and contribute to audits of the processing activities covered by these Clauses, at
reasonable intervals or if there are indications of non-compliance. In deciding on a review or
an audit, the controller may take into account relevant certifications held by the processor.
19.4. The controller may choose to conduct the audit by itself or mandate an
independent auditor. Audits may also include inspections at the premises or physical facilities
of the processor and shall, where appropriate, be carried out with reasonable notice.
19.5. The Parties shall make the information referred to in this Clause, including the
results of any audits, available to the competent supervisory authority/ies on request.
Use of sub-processors
20. The processor has the controller’s general authorisation for the engagement of
sub-processors from an agreed list. The processor shall specifically inform in writing the
controller of any intended changes of that list through the addition or replacement of
sub-processors at least 90 days in advance, thereby giving the controller sufficient time to be
able to object to such changes prior to the engagement of the concerned sub-processor(s). The
processor shall provide the controller with the information necessary to enable the controller
to exercise the right to object.
21. Where the processor engages a sub-processor for carrying out specific
processing activities (on behalf of the controller), it shall do so by way of a contract which
imposes on the sub-processor, in substance, the same data protection obligations as the ones
imposed on the data processor in accordance with these Clauses. The processor shall ensure
that the sub-processor complies with the obligations to which the processor is subject
pursuant to these Clauses and to Regulation (EU) 2016/679.
22. At the controller’s request, the processor shall provide a copy of such a
sub-processor agreement and any subsequent amendments to the controller. To the extent
necessary to protect business secret or other confidential information, including personal data,
the processor may redact the text of the agreement prior to sharing the copy.
23. The processor shall remain fully responsible to the controller for the
performance of the sub-processor’s obligations in accordance with its contract with the
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processor. The processor shall notify the controller of any failure by the sub-processor to fulfil
its contractual obligations.
24. The processor shall agree a third party beneficiary clause with the
sub-processor whereby - in the event the processor has factually disappeared, ceased to exist
in law or has become insolvent - the controller shall have the right to terminate the
sub-processor contract and to instruct the sub-processor to erase or return the personal data.
International transfers
25. Any transfer of data to a third country or an international organisation by the
processor shall be done only on the basis of documented instructions from the controller or in
order to fulfil a specific requirement under Union or Member State law to which the processor
is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679.
26. The controller agrees that where the processor engages a sub-processor in
accordance with this Agreement for carrying out specific processing activities (on behalf of
the controller) and those processing activities involve a transfer of personal data within the
meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can
ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard
contractual clauses adopted by the Commission in accordance with of Article 46(2) of
Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual
clauses are met.
Assistance to the controller
27. The processor shall promptly notify the controller of any request it has
received from the data subject. It shall not respond to the request itself, unless authorised to
do so by the controller.
28. The processor shall assist the controller in fulfilling its obligations to respond
to data subjects’ requests to exercise their rights, taking into account the nature of the
processing. In fulfilling its obligations in accordance with this Clause and Art.27, the
processor shall comply with the controller’s instructions.
29. In addition to the processor’s obligation to assist the controller pursuant to
Art.28, the processor shall furthermore assist the controller in ensuring compliance with the
following obligations, taking into account the nature of the data processing and the
information available to the processor:
(1) the obligation to carry out an assessment of the impact of the envisaged
processing operations on the protection of personal data (“personal data protection impact
assessment”) where a type of processing is likely to result in a high risk to the rights and
freedoms of natural persons;
(2) the obligation to consult the competent supervisory authority/ies prior to
processing where a data protection impact assessment indicates that the processing would
result in a high risk in the absence of measures taken by the controller to mitigate the risk;
(3) the obligation to ensure that personal data is accurate and up to date, by
informing the controller without delay if the processor becomes aware that the personal data it
is processing is inaccurate or has become outdated;
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(4) the obligations in Article 32 Regulation (EU) 2016/679.
30. The Parties shall set out in Annex III the appropriate technical and
organisational measures by which the processor is required to assist the controller in the
application of this Clause as well as the scope and the extent of the assistance required.
Notification of personal data breach
31. In the event of a personal data breach, the processor shall cooperate with and
assist the controller for the controller to comply with its obligations under Articles 33 and 34
Regulation (EU) 2016/679, where applicable, taking into account the nature of processing and
the information available to the processor.
Data breach concerning data processed by the controller
32. In the event of a personal data breach concerning data processed by the
controller, the processor shall assist the controller:
(a) in notifying the personal data breach to the competent supervisory
authority/ies, without undue delay after the controller has become aware of it, where
relevant/(unless the personal data breach is unlikely to result in a risk to the rights and
freedoms of natural persons);
(b) in obtaining the following information which, pursuant to Article 33(3)
Regulation (EU) 2016/679 shall be stated in the controller’s notification, and must at least
include:
(1) the nature of the personal data including where possible, the categories and
approximate number of data subjects concerned and the categories and approximate number
of personal data records concerned;
(2) the likely consequences of the personal data breach;
(3) the measures taken or proposed to be taken by the controller to address the
personal data breach, including, where appropriate, measures to mitigate its possible adverse
effects.
33. Where, and insofar as, it is not possible to provide all this information at the
same time, the initial notification shall contain the information then available and further
information shall, as it becomes available, subsequently be provided without undue delay.
34. In complying, pursuant to Article 34 Regulation (EU) 2016/679, with the
obligation to communicate without undue delay the personal data breach to the data subject,
when the personal data breach is likely to result in a high risk to the rights and freedoms of
natural persons.
Data breach concerning data processed by the processor
35. In the event of a personal data breach concerning data processed by the
processor, the processor shall notify the controller without undue delay after the processor
having become aware of the breach. Such notification shall contain, at least:
(a) a description of the nature of the breach (including, where possible, the
categories and approximate number of data subjects and data records concerned);
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(b) the details of a contact point where more information concerning the personal
data breach can be obtained;
(c) its likely consequences and the measures taken or proposed to be taken to
address the breach, including to mitigate its possible adverse effects.
36. Where, and insofar as, it is not possible to provide all this information at the
same time, the initial notification shall contain the information then available and further
information shall, as it becomes available, subsequently be provided without undue delay.
37. The Parties shall set out in Annex III all other elements to be provided by the
processor when assisting the controller in the compliance with the controller’s obligations
under Articles 33 and 34 of Regulation (EU) 2016/679.
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FINAL PROVISIONS
38. Without prejudice to any provisions of Regulation (EU) 2016/679, in the event
that the processor is in breach of its obligations under these Clauses, the controller may
instruct the processor to suspend the processing of personal data until the latter complies with
these Clauses or the contract is terminated. The processor shall promptly inform the controller
in case it is unable to comply with these Clauses, for whatever reason.
39. The controller shall be entitled to terminate the contract insofar as it concerns
processing of personal data in accordance with these Clauses if:
(1) the processing of personal data by the processor has been suspended by the
controller pursuant to point (a) and if compliance with these Clauses is not restored within a
reasonable time and in any event within one month following suspension;
(2) the processor is in substantial or persistent breach of these Clauses or its
obligations under Regulation (EU) 2016/679;
(3) the processor fails to comply with a binding decision of a competent court or
the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or
to Regulation (EU) 2016/679.
40. The processor shall be entitled to terminate the contract insofar as it concerns
processing of personal data under these Clauses where, after having informed the controller
that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b),
the controller insists on compliance with the instructions.
41. Following termination of the contract, the processor shall, at the choice of the
controller, delete all personal data processed on behalf of the controller and certify to the
controller that it has done so, or, return all the personal data to the controller and delete
existing copies unless Union or Member State law requires storage of the personal data. Until
the data is deleted or returned, the processor shall continue to ensure compliance with these
Clauses.
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ANNEX I LIST OF PARTIES
Controller(s): [Identity and contact details of the controller(s), and, where applicable, of the
controller’s data protection officer]
1. Name: …
Address: …
Contact person’s name, position and contact details: …
Signature and accession date: …
2.
…
Processor(s): [Identity and contact details of the processor(s) and, where applicable, of the
processor’s data protection officer]
1. Name: …
Address: …
Contact person’s name, position and contact details: …
Signature and accession date: …
2.
…
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ANNEX II: DESCRIPTION OF THE PROCESSING
Categories of data subjects whose personal data is processed
Students and staff of schools which contract with Kami to provide services.
Categories of personal data processed
Name, email address, password, role, IP address, organisation, user-generated content.
Sensitive data processed (if applicable) and applied restrictions or safeguards that fully take
into consideration the nature of the data and the risks involved, such as for instance strict
purpose limitation, access restrictions (including access only for staff having followed
specialised training), keeping a record of access to the data, restrictions for onward transfers
or additional security measures.
NA
Nature of the processing
Users can open or upload documents in Kami online; can annotate, comment; and can share
the document with other Kami users for collaborative working.
Purpose(s) for which the personal data is processed on behalf of the controller
To provide the Kami collaborative document annotation services to users. When teachers
share assignments to students, or students share project work for collaborative work, they
need to be able to identify or recognize other users in the service. When Kami provide user
support, Kami staff need to be able to associate the user and their account. When a user logs
into Kami, Kami needs to be able to authenticate the user and identify their organisation.
Duration of the processing
For the duration of the contracted period. User accounts and all user data will be deleted
within 30 days of the receipt of an instruction from the user or the customer.
For processing by (sub-) processors, also specify subject matter, nature and duration of the
processing
● Microsoft – if you choose to log into Kami using your Microsoft account (often
referred to as Single Sign-on or “SSO”), your login will be authenticated by Microsoft.
If you open/save files on OneDrive, Microsoft will first request authorization for this.
You can review Microsoft’s Privacy Policy for use of your Microsoft account here;
and update or revoke your permissions as described here.
● Google – if you choose to log into Kami using your Google account, your login will
be authenticated by Google. If you open/save files on Google Drive, Google will first
request authorization for this. You can review Google’s Privacy Policy for use of your
Google account here; and update or revoke your Google Permissions here.
● Groove – Groove is a platform our Support Team use internally to coordinate
customer support activities in response to requests from our customers. Our
contractual agreement with Groove complies with the terms of this policy.
● Google Analytics & Tag Manager – an analytics service used to help analyze your use
of our Website and allow us to improve our Service and provide you information on
the Service. Our agreement with Google complies with the terms of this policy.
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● Stripe – when you upgrade your account online using a credit card, your payment is
securely processed using Stripe’s e-payments service. Our contractual agreement with
Stripe complies with the terms of this policy.
ANNEX III TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING
TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY
OF THE DATA
EXPLANATORY NOTE:
The technical and organisational measures need to be described concretely and not
in a generic manner.
Below is a description of the technical and organisational measures implemented by
the Processor (including any relevant certifications) to ensure an appropriate level of
security, taking into account the nature, scope, context and purpose of the
processing, and the risks for the rights and freedoms of natural persons.
Where applicable this Table will serve as Annex III to the SCCs.
Measure Description
Measures of For the purpose of transfer control, Encryption is used
pseudonymisation and during transit for connections between users’ browsers
encryption of Personal and our backend services. We employ industry
Data best-standard cipher suites and protocols - currently TLS
1.2 with ECDHE_RSA key exchange and AES
encryption.
For bulk transfer of data or initial data setup we employ a
secure folder on Google drive, set up per school to allow
data separation, files are uploaded to it encrypted or non
encrypted with keys being sent out of band, we also have
a Secure file transfer server that usesSSH keys not
passwords to share data. All personal data is destroyed
as per our data destruction policies when no longer used.
Measures for ensuring Access to data necessary for the performance of the
ongoing confidentiality, particular task is ensured within the systems and
integrity, availability and applications by a corresponding role and authorisation
resilience of processing concept. In accordance to the “least privilege” and
systems and services “need-to-know” principles, each role has only those rights
which are necessary for the fulfilment of the task to be
performed by the individual person. To maintain data
access control, state of the art encryption technology is
applied to the Personal Data itself where deemed
appropriate to protect sensitive data based on risk.
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Measures for ensuring Your data is protected using streaming replication to
the ability to restore the geographically distributed backup servers and log
availability and access shipping to secure storage. We create daily backups
to Personal Data in a using multiple independent systems and store them
timely manner in the across multiple different providers. Our backups are
event of a physical or encrypted on dm-crypt encrypted disks with strong
technical incident passwords.
We conduct disaster recovery drills quarterly to ensure
we can quickly restore services without data loss in
cases of emergency.
Processes for regularly All changes to code and systems relating to customer
testing, assessing and data is peer reviewed and audited, some automation
evaluating the scripts are run over source code to validate compliance
effectiveness of to policy and adherence to industry standards. all
technical and aspects of the systems that retain customer data are
organisational tested at least annually via an independent third party
measures in order to where defects and recommendations are logged and
ensure the security of rectified. staff also have regular (at least annual) process
the processing and policy revision as well as security awareness
training. Automated tools are running continually auditing
the data processing systems with reports generated and
critical defect alerted to us 24/7.
Measures for user Staff require SSH keys and 2FA-login (via hardware
identification and tokens) to access our networks.
authorisation We implement best-practice protective measures against
attacks including XSS, CSRF, and SQL injection.
We support both authentication with a username and
password, and SSO through Google OAuth.
Passwords are stored using bcrypt with a high stretching
factor.
Measures for the Data in transit is protected by Transport Layer Security
protection of data (“TLS”). Encryption is used during transit for connections
during transmission between users’ browsers and our backend services. We
employ industry best-standard cipher suites and
protocols - currently TLS 1.2 with ECDHE_RSA key
exchange and AES encryption.
We use HSTS to ensure all HTTP requests through our
domains shall always be encrypted and prevent MITM
attacks.
Data is protected at rest using encryption provided by our
cloud services providers (Amazon Web Services and
Google Cloud Platform).
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Measures for the Personal Data is only retained internally on encrypted
protection of data disks, and on the third party data centre servers, which
during storage are covered by Amazon Web Services (AWS) and
Google Cloud Platform (GCP) certifications and can be
found on their respective sites found on both AWS and
Google Cloud Platform.
PII students is stored only in our Third party Data centres
not locally.
Measures for ensuring The Processor utilises third party data centres that
physical security of maintain current ISO 27001 certifications and/or SSAE
locations at which 16 SOC 1 Type II or SOC 2 Attestation Reports. The
Personal Data are Processor will not utilise third party data centres that do
processed not maintain the aforementioned certifications and/or
attestations, or other substantially similar or equivalent
certifications and/or attestations. The Processor’s main
office is secured with keyfob entry. When it is not
occupied, it is locked securely and covered by a remotely
monitored alarm. A central log of keyholders is
maintained and access is revoked when an employee is
terminated. The Processor’s employees that work from
home are expected to comply with our security policy in
full at all times. Our disciplinary procedure covers failure
to meet these standards.
Measures for ensuring System inputs are recorded in the form of log files
events logging therefore it is possible to review retroactively whether
and by whom Personal Data was entered, altered or
deleted, this is stored in our respective data centres
maintained by AWS and GCP
Measures for ensuring System configuration is applied and maintained by
system configuration, software tools that ensure the system configurations do
including default not deviate from the specifications, containers are
configuration generated from image repositories stored in GCP, we
maintain Infrastructure as code as at our core and all
changes go via peer review and change control, systems
changes are made via a continuous integration (CI)
continuous deployment (CD) through non production and
promoted in to product via controls and automation (no
manual deployments)
Measures for internal IT Employees are instructed to collect, process and use
and IT security Personal Data only within the framework and for the
governance and purposes of their duties (e.g. service provision). At a
management technical level, multi-client capability includes separation
of functions as well as appropriate separation of testing
and production systems. The Controller’s Personal Data
is stored in a way that logically separates it from other
customer data.
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Measures for The Processor utilises third party data centres that
certification/assurance maintain current ISO 27001 certifications and/or SSAE
of processes and 16 SOC 1 Type II or SOC 2 Attestation Reports. The
products Processor will not utilise third party data centres that do
not maintain the aforementioned certifications and/or
attestations, or other substantially similar or equivalent
certifications and/or attestations. Upon the Controller’s
written request (no more than once in any 12 month
period), the Processor shall provide within a reasonable
time, a copy of the most recently completed certification
and/or attestation reports (to the extent that to do so
does not prejudice the overall security of the Services).
Any audit report submitted to the Controller shall be
treated as Confidential Information and subject to the
confidentiality provisions of the Agreement between the
parties. The processor is also independently audited
yearly to verify compliance with industry best practice,
upon request and executive summary can be obtained.
Measures for ensuring If Personal Data is no longer required for the purposes
data minimisation for which it was processed, it is deleted promptly in
accordance with the relevant legal legislation of the
country of origin of the requester of known and requested
to do so, otherwise personal data is disposed of in
accordance with our data destruction policy. Kami only
collects data that is used explicitly required to provide
and maintain the service to you
Category Elements
Application technology
meta data IP address, cookies
Application usage statistics meta data on interaction with app
Authentication Oauth key
First name, last name (if entered
User information email address
User-generated data Filenames, annotations, commen
A Document itself is only uploade
servers if shared by the user with
for collaborative annotation. The
Documents are fingerprinted and
and are not stored persistently o
servers. (The sharing function m
be disabled for a given domain)
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Measures for ensuring All of the data that we possess is provided by the
data quality Controller. The Processor does not assess the quality of
the data provided by the Controller. The Processor
provides reporting tools within its product to help the
Controller understand and validate the data that is
stored. The Controller can at anytime contact the
Processor to get data updated after going through the
processors identity verification process.
Measures for ensuring All data that is stored is subject to our retention policy,
limited data retention this specifies how each type of data is retained. When a
record with Personal Data is deleted then it will be
permanently evicted from the Processor’s active
databases. The data is retained in the Processor’s
backups until they are rotated out by more recent
backups per the data retention policy.
Measures for ensuring All employees that handle sensitive data must
accountability acknowledge the information security policies. All
employees go through annual training to reinforce and
advise of any changes in policies. A disciplinary policy is
in place for employees that do not adhere to information
security policies.
Measures for allowing The processor has policies in place to allow transfer of
data portability and personal data you have provided us to another
ensuring erasure organization this export, you will receive your personal
data in a structured, commonly used and machine
readable format.
In case you provided your consent to the processing of
personal data, you may withdraw consent at any time,
without affecting the lawfulness of processing based on
consent before its withdrawal.
If your personal data are transferred outside the
European Economic Area, you have the right to obtain
copy of such data as well as indication of the
Country/Countries where the personal data have been
made available.
Measures to be taken The transfer of Personal Data to a third party (e.g.
by the (Sub-) processor customers, sub-contractors, service providers) is only
to be able to provide made if a corresponding contract exists, and only for the
assistance to the specific purposes. If Personal Data is transferred outside
Controller (and, for the EEA, the Processor provides that an adequate level
transfers from a of data protection exists at the target location or
Processor to a organisation in accordance with the European Union’s
Sub-processor, to the data protection requirements, e.g. by employing
Data Exporter). contracts based on the EU SCCs.
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ANNEX IV: LIST OF SUB-PROCESSORS
The controller has authorised the use of the following sub-processors:
1. Google Cloud Platform – cloud hosting, storage and data processing
2. Amazon Web Services – cloud hosting, storage and data processing
3. Groove – user support ticketing platform
4. Stripe – secure credit card payment platform
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