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Momentive provides its products around the world, and uses global subprocessors to help us provide those products and services. In our contract with you, we commit that every transfer of personal data to us is compliant with data protection laws. We also ensure that when we transfer personal data onward, the recipient protects the personal data with safeguards that are no less onerous than the standard that we apply to personal data in our control.
To assist you in determining that there is an adequate level of protection for personal data transferred to Momentive and onward - taking into account the July 16, 2020 judgment of the EU Court of Justice (“CJEU”) in Case C-311/18, Data Protection Commissioner v Facebook Ireland Limited and Maximilian Schrems (“Schrems II”) and the European Data Protection Board’s (“EDPB”) guidance on supplementary measures - we provide some information below about how your information is protected as it travels.
If you are a US Customer, your contract will include a Data Protection Addendum (“DPA”) with Momentive’s US entity: Momentive Inc. If you have users in the European Economic Area (“EEA”) or the United Kingdom (“UK”) and therefore require a transfer mechanism for user data to Momentive, you can request that we add EU and/or UK Standard Contractual Clauses (“SCCs”).
If you are a Customer based in the EEA or UK, your contract will include a Data Protection Addendum (“DPA”) with Momentive’s Irish entity: Mometive Europe UC. Since the transfer from you to Momentive is between European entities for which no transfer mechanism is needed (or that have recognized each others’ adequacy status), no other transfer mechanisms are needed.
If you are a Customer based outside of the US, EEA, or UK - but you have users in the EEA or UK and need to ensure there is a transfer mechanism for onward transfer - your contract will include a DPA with Momentive’s Irish entity, Mometive Europe UC, and you can request that we add EU and/or UK SCCs.
You transfer personal data to Momentive so that we may process the personal data for the following purposes:
You should evaluate if you transfer data for any differing purposes.
The Customer personal data transferred to Momentive can contain as much or as little personal data as you decide to provide in your questions in surveys, forms, and questionnaires. As a platform we assume that a large variety of personal data - including potential special category data - is collected by you.
As noted above, you will contract with a Momentive entity in the US or Ireland - depending on your location. Based on advice from outside counsel specialized in data protection and analysis of the laws to which Momentive is subject, we believe the risk associated with the legal regime in the US to be low, and the risk associated with the legal regime in Ireland to be of no material risk to the data subject. See the section ‘Supplementary Measures: Organizational’ below for more information on US law specifically.
Even where there is low or no material risk due to the legal regime in the destination country, Momentive has implemented supplementary measures to further safeguard personal data. The supplementary measures are divided into three categories: (i) contractual; (ii) organizational; and (iii) technical safeguards.
As described above, Momentive will agree to enter into SCCs with Customers. The Schrems II judgment indicates that parties may use SCCs and (where appropriate) additional safeguards for transfer of personal data from the United Kingdom and the European Economic Area (“European Data”) to the United States. If you have entered into an agreement with or are otherwise obtaining services from Momentive that will require Momentive to process personal data of European data subjects, Momentive will (as appropriate depending on the Momentive entity you are contracting with):
For more information about our agreement to be bound by the Standard Contractual Clauses, please see the Terms of Use (for self-serve customers), the Governing Services Agreement (for SurveyMonkey Enterprise or GetFeedback Digital customers), or such other agreement you may have negotiated with Momentive.
The CJEU’s concerns about transfers of data to the United States were based on the US government’s collection of data under US Executive Order 12333 (“EO 12333”) and under Section 702 of the Foreign Intelligence Surveillance Act (“FISA § 702”), especially “upstream” surveillance under FISA § 702. The risks posed by these US legal provisions either do not apply to Momentive’s processing of personal data or can be sufficiently mitigated by organizational safeguards that Momentive offers.
Momentive is not eligible to receive “upstream” or bulk surveillance orders under FISA § 702. Momentive Inc. acts, in part, as an electronic communications service (“ECS”) and also potentially a remote computing service (“RCS”) (as defined in Sections 2510 and 2711 of Title 18 USC., respectively) in connection with certain services or product features we provide to Customers. Momentive Inc. thus is among the large group of companies upon which the United States government could serve a targeted directive under FISA § 702. However, as the US government has interpreted and applied FISA § 702, Momentive is not eligible to receive the type of order that was of principal concern to the CJEU in the Schrems II decision—i.e., a FISA § 702 order for “upstream” surveillance. As the US government has applied FISA § 702, it uses upstream orders only to target traffic flowing through internet backbone providers that carry Internet traffic for third parties (i.e., telecommunications carriers). For example, see the report of the Privacy and Civil Liberties Oversight Board, Report on the Surveillance Program Operated Pursuant to Section 702 of the Foreign Intelligence Surveillance Act (July 2, 2014), pp. 35-40, available at https://fas.org/irp/offdocs/pclob-702.pdf. Momentive does not provide such Internet backbone services, as we only carry traffic involving our own customers. As a result, we are not eligible to receive the type of order principally addressed in, and deemed problematic by, the Schrems II decision.
Momentive has not received any directive under FISA § 702, and we are unlikely to receive any. As of the date of this statement, Momentive has not received any directive under FISA § 702 and has no reason to believe that such a directive would be made to Momentive. The personal data Momentive processes for our customers –feedback data – is highly unlikely to be relevant to the foreign intelligence activities governed by FISA § 702. Moreover, in the event any such personal data were relevant to such an investigation, the government is more likely to seek such data through other forms of legal process (such as a search warrant approved by a judge) that do satisfy the high standards for government access to data described in the Schrems II decision. This is because it would be much faster and easier for the government to seek an order or warrant under something other than FISA § 702 than to put in place the mechanisms required for the government to serve directives on Momentive under FISA § 702.
Momentive does not assist — and cannot be ordered to assist — US authorities in their collection of information under Executive Order 12333. Momentive does not and will not provide any assistance to US authorities conducting surveillance under EO 12333. EO 12333 does not provide the US government the ability to compel companies to provide assistance with those activities, and Momentive will not do so voluntarily. As a result, Momentive does not, and cannot be ordered to, take any action to facilitate the type of bulk surveillance under EO 12333 the Schrems II decision deemed problematic.
Momentive provides a range of technical measures that further defeat the core deficiencies cited in the Schrems II decision referred to above (bulk surveillance under FISA § 702 and bulk interceptions under EO 12333).
Momentive encrypts all data at rest in our data centres using AES 256 based encryption. Additionally, Momentive encrypts all data in motion using (i) RSA with 2048 bit key length based certificates generated via a public Certificate Authority, for communications with entities outside Momentive’s data centres, and (ii) RSA 256 certificates generated via Internal Certificate Authority, for all the data within the data centre. These encryption efforts are aimed at prevention of unauthorised acquisition of data in an intelligible form and prevention of unauthorised wiretapping / tampering when data is in transit between two end-points.
Some Momentive Customers (for example, Customers of GetFeedback Digital) have their data stored only in the European Union. In those instances the data is not stored in the US and only very minimal access to that data occurs in the United States for limited purposes (for example, to provide Customer support on request, for follow the sun security support and/or limited engineer resourcing to resolve technical issues/bugs or build out systems).
Momentive also maintains strict administrative, technical, and physical procedures to protect information stored on its servers. Access to personal information is limited through login credentials to those employees who require it to perform their job functions. Momentive implements data minimization techniques to limit the amount of personal data which is transferred from the EU to third party jurisdictions to include, where appropriate, pseudonymization or deidentification of data. In addition, Momentive uses access controls such as multi-factor authentication, Single Sign On, access on an as-needed basis, strong password controls, and restricted access to administrative accounts.
Additionally, as an ECS/RCS, Momentive is subject to the US Electronic Communications Privacy Act, 18 USC. § 2701, et seq. (“ECPA”), which provides protection to Momentive’s Customers. For example, ECPA prohibits governmental entities from seeking information about Customers of services like Momentive unless such governmental entities first obtain appropriate legal process, including a court order or search warrant for information other than basic subscriber information. Likewise, both FISA and ECPA provide Momentive’s Customers with redress against the US government (including monetary damages or disciplinary actions against the relevant governmental authorities) if it improperly obtains information about them (see 18 USC. § 2712).
Further, Momentive’s long time outside legal counsel is experienced in responding to US governmental requests for user data, including US national security requests under FISA § 702. It is Momentive’s policy to escalate any such requests to Momentive’s own internal compliance team and, as necessary, to such outside counsel for review. Where appropriate, Momentive intends to use available legal mechanisms to challenge demands for data access using FISA § 702 (including any non-disclosure provisions or orders attached thereto) in the unlikely event Momentive receives such a demand. The demand would then receive review by a US tribunal (the FISA Court).
Momentive also recognizes that an order to provide data access under FISA § 702 would require Momentive to notify our Customers that we could no longer comply with the Standard Contractual Clauses, allowing them to terminate their agreement with us and suspend data flows to us. We have never needed to issue such a notice.
Taking into account the above analysis, we believe the risk of harm to the data subject is not material.
The table below summarizes our transfer impact assessment conclusion.
“Non-material” risk means that personal data is transferred to a jurisdiction that has been considered adequate by the European Commission (and so the legal protections are equivalent to legal protections in Europe), and that there are contractual, technical, and organizational measures in place to further protect the data.
“Low” risk means that personal data is transferred to a jurisdiction with a GDPR Chapter V mechanism other than adequacy. While the legal protections are not necessarily equivalent to legal protections in Europe, the transfer is still legally-compliant and is bolstered by contractual, technical, and organizational measures in place to further protect the data.
Sender | Recipient | Transfer Destination | Transfer Mechanism | Risk |
US Customer with users in EU or UK | Momentive Inc. | US | SCCs + supplementary measures | Low |
EEA or UK Customer | Momentive Europe UC | Ireland | Adequacy + supplementary measures | Non-material |
Non-US/EEA/UK Customer with users in EU or UK | Momentive Europe UC | Ireland | SCCs + supplementary measures | Non-material |
Subprocessors are Momentive vendors that process your users’ personal data in order to help Momentive provide the service to you. All Momentive subprocessors are bound by contract to protect the personal data with safeguards that are no less onerous than the standard that we apply to personal data in our control.
When Momentive transfers personal data to subprocessors, we conduct a Transfer Impact Assessment (“TIA”) similar to the steps outlined above. We do this to ensure that your personal data is protected at each step, as required by data protection law and our contract with you. We have provided a summary of the salient points of the TIA for each subprocessor below.
Please note that not all subprocessors are used in the provision of all of our Services. Our subprocessor list is segmented into specific Momentive services.
If you wish to receive email notifications of updates to our Subprocessor List, please subscribe here.
Subprocessor | Purpose | Personal Data | Location and Assessment of Legal Regime Risk | Transfer Mechanism | Supplementary Measures: Contractual, Organizational, and Technical |
Amazon Web Services (“AWS”) | Data storage services for storing assets and database hosting; Content distribution network (“CDN”) services; storage used to support data analysis features (OpenSearch). | Personal Data Names of Individuals (First and/or Last Names) Any unique identifier that can be used to tie to a particular person in the real world Vehicle registration plate number Data of Birth Email Address Phone Number Physical Address (i.e. 123 Fake St) ZIP/Postal Code Apartment Numbers (i.e. Address Line 2) IP address IMSI/IMEI numbers MAC address Insurance details Family members and Dependents Sensitive Personal Data can be included in survey response or form data and so AWS may store any of the following: Government/National ID (e.g. SSN, SIN), Driver's License number, Passport number Username and password, Authentication credentials Financial and Payment information (account log‐in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account) Geolocation Race/ethnicity Religious/Political/Trade Union Affiliation Sex life or Sexual Orientation Health data (incl. prescription medications, medical procedures and tests, diagnoses, medical practitioners and area of practice, health card numbers etc.) Biometrics (e.g. fingerprints, voice recordings, photos) Genetic data Salary/Income (or ranges of same) Customer survey responses (responses received by a customer to the survey they create within Momentive accounts) Credit score/record Communications - the contents of a consumer’s private communications, unless the company is the intended recipient of the communication Criminal record Quasi identifiers: This could include data which is not personal unless linked to other data e.g. web identifiers, device information, browser data and other metadata which may in some cases be linkable to other categories of data listed above. | United States - low Canada - non-material Ireland - non-material | SCCs | Please see AWS’s commitments to data control, data privacy, and security. Specifically, Momentive uses the latest generation of EC2 which automatically gain the protection of the AWS Nitro System. Using purpose-built hardware, firmware, and software, AWS Nitro provides unique and industry-leading security and isolation by offloading the virtualization of storage, security, and networking resources to dedicated hardware and software. This enhances security by minimizing the attack surface and prohibiting administrative access while improving performance. All data in transit between our secure datacenter facilities, availability zones, and regions is encrypted automatically at the hardware level. Momentive also utilizes AWS Key Management Services to control and manage our own keys within FIPS-140-2 certified hardware security modules. Regardless of whether data is encrypted or unencrypted, we will always work vigilantly to protect data from any unauthorized access. Our security team has carried out a comprehensive review of all AWS cloud infrastructure services and changes are kept under continual review. Momentive encrypts all data at rest in our data centres using AES 256 based encryption. Additionally, Momentive encrypts all data in motion using (i) RSA with 2048 bit key length based certificates generated via a public Certificate Authority, for communications with entities outside Momentive’s data centres, and (ii) RSA 256 certificates generated via Internal Certificate Authority, for all the data within the data centre. These encryption efforts prevent the acquisition of data in an intelligible form This also deters wiretapping between the two end-points while such data is in transmission or in storage. |
Microsoft (Sharepoint) | Internal document repository | Customer Data as requested to provide Professional Services (eg: survey design and response analysis) | USA - low | SCCs | Please see Microsoft Cloud Transfer Whitepaper and security documentation. |
Momentive Affiliates (Momentive Inc., Momentive Australia Pty Limited) | Customer and product support services; product development, infrastructure, and technology services. | Respondent: Contact Information, Usage Information, Device Information, Cookie and other tracking information | Australia - low USA - low | SCCs | Please see description above and our Security Statement and GDPR Whitepaper. |
Momentive Affiliates (Momentive Canada Inc., Momentive UK Ltd.) | Customer and product support services; product development, infrastructure, and technology services. | Respondent: Contact Information, Usage Information, Device Information, Cookie and other tracking information | Canada - non-material UK - non-material | Adequacy | Please see description above and our Security Statement and GDPR Whitepaper. |
Salesforce (including Sales Cloud, Service Cloud, Community Cloud, Chatter, Salesforce Platform, Customer Data Platform, Marketing Cloud, Mulesoft, and Tableau CRM) | Customer Support | Names of Individuals (First and/or Last Names) , Email, Phone Number, Content of communications sent during provision of Customer Support | USA - low | SCCs | Please see Salesforce’s Security Whitepaper, security certifications, DPA FAQ, and Trust and Compliance documentation. |
Snowflake | Storage of usage data for analytics and product development. | IP Address, Email address (first and last name), Quasi identifiersRespondent ID | USA - low | SCCs | Momentive data is stored encrypted at rest on AWS S3. Snowflake uses strong AES 256 bit encryption with a hierarchical key model. Snowflake implements a comprehensive monitoring and logging system. Snowflake is ISO 27001 and SOC 2 certified and these certifications have been reviewed by the Momentive security team in full as part of our risk review. Employees are provided with both Security and Privacy Awareness Training overview which they are required to complete at hire and then on an annual basis thereafter. In addition, as needed, other quarterly training on featured security and privacy related topics and role specific training for personnel whose role responsibilities require additional security procedures are provided. Access to any production environment is based on least privileged access rules and role based access controls and deprovisioning is similarly managed and monitored. See Snowflake’s documentation for more information: Data Security and Trust Center. |
Sparkpost | Email delivery service. | Email address, meta data (open clicks, date stamps) | USA - low | SCCs | See: Security Program - SparkPost SparkPost maintains Customer Data in an encrypted format at rest and in transit using SSL, HTTPS, and opportunistic TLS as applicable. Customer Data is encrypted when in transit between Customer and SparkPost Services using HTTPS. Customer Data is encrypted when in transit between SparkPost and Recipient using opportunistic TLS. SparkPost conducts various third-party audits to attest to various frameworks including SOC 2 Type II and regular application vulnerability and penetration testing. SparkPost does not store the message body of an Email after it has either been delivered to the Recipient or has bounced or otherwise been rejected by the mailbox provider, which typically occurs within seconds. In the event of a rejection or bounce, SparkPost will retain the message body for a limited period of time to allow for the Email transmission to be retried. If the transmission is still unsuccessful, the message body is permanently deleted. SparkPost only stores Recipient Personal Data in raw form for a limited amount of time after the transmission of an Email to a Recipient. After the initial retention period, the Personal Data is pseudonymized through a one-way hash and is only stored in its pseudonymized form. For more information about this process please see the Sparkpost Data FAQs available here. |
Splunk | Software for searching, monitoring, and analyzing machine-generated data. | Respondent ID, Respondent email address, First and last name, phone number, Browser information, Open text response data | USA - low | SCCs | Please see Splunk’s security documentation and compliance certificates. |
Twilio | SMS delivery. | Respondent phone number, Content of SMS communications | USA - low | SCCs | Please see Twilio’s security certification, security statement, and security overview. |
Upwork | Support team task augmentation (contractors). | Names of Individuals (First and/or Last Names) , Email, Phone Number, Content of communications sent during provision of Customer Support | Philippines - low | SCCs | Please see Upwork’s security page, in addition to the information below. Momentive employs remote desktop control over contracted support agents. All personnel handling personal data are subject to confidentiality obligations. Anti-malware and malicious software detection controls are in place to ensure no unauthorised access to data can take place, and all data are encrypted when transferred over public networks. There are also specific data handling procedures in place which ensure strict ‘need to know’ access controls are in place, as well as policies which ensure the deletion of the data after use. Further access controls also require specific identification of the terminal user on the relevant systems, as well as requiring identification codes and password complexity standards for anyone who needs to access the data. VPNs, two-factor authentication and role-based access are also baked into the main access control procedures. During transmission, data are subject to various strict transmission controls including procedures preventing the data from being read, copied, altered or deleted while in transit. Encryption technologies and the use of firewalls are in place to protect gateways and firewalls through which the data travels, and VPN connections safeguard the data connection to internal networks. Infrastructure is constantly monitored (e.g. through ICMP-Ping at network level), and the end-to-end security monitoring takes place to ensure the completeness and correctness of all transfers. All encryption solutions are deployed with no less than a 128-bit key for symmetric encryption and a 1024 (or larger) bit key length for asymmetric encryption. Input control ensures that it is possible to check and establish whether and by whom Personal Data has been input into data processing systems or removed. Such controls include authentication and logging. Vulnerability management is in place to detect and immediately remedy any system vulnerabilities. Data destruction procedures also ensure that data subject to the transfer are secured and not held for any longer than necessary to achieve the purposes of customer support. |
Xoriant, InfoSol, Tredence, Impetus, Valuelabs | Data & Analytics team task augmentation (contractors). | Data as listed for Snowflake | USA - low | SCCs | All the security controls available and listed above for Snowflake are utilized to ensure least privileged access for our third party contractors. We utilize remote desktop security as well as the other security controls which apply to any internal Momentive systems. See our security statement for further details. |
Subprocessor | Purpose | Personal Data | Location and Assessment of Legal Regime Risk | Transfer Mechanism | Supplementary Measures: Contractual, Organizational, and Technical |
AWS | See above | See above | See above | See above | See above |
Microsoft | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Inc., Momentive Australia Pty Limited) | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Canada Inc., Momentive UK Ltd.) | See above | See above | See above | See above | See above |
Salesforce | See above | See above | See above | See above | See above |
Snowflake | See above | See above | See above | See above | See above |
Sparkpost | See above | See above | See above | See above | See above |
Splunk | See above | See above | See above | See above | See above |
Twilio | See above | See above | See above | See above | See above |
Upwork | See above | See above | See above | See above | See above |
Xoriant, InfoSol, Tredence, Impetus, Valuelabs | See above | See above | See above | See above | See above |
Subprocessor | Purpose | Personal Data | Location and Assessment of Legal Regime Risk | Transfer Mechanism | Supplementary Measures: Contractual, Organizational, and Technical |
AWS | See above | See above | See above | See above | See above |
Open-text response translation feature requested by a subset of GetFeedback Digital customers. | Survey Response data. This may or may not include personal data, depending on the types of questions in the survey and how the respondent chooses to answer the questions. | USA - low | SCCs | https://cloud.google.com/security/ | |
Momentive Affiliates (Momentive Inc., Momentive Australia Pty Limited) | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Canada Inc., Momentive UK Ltd.) | See above | See above | See above | See above | See above |
ScaleGrid | Database hosting | Names of Individuals (First and/or Last Names) Any unique identifier that can be used to tie to a particular person in the real world Vehicle registration plate number Data of Birth Email Address Phone Number Physical Address (i.e. 123 Fake St) ZIP/Postal Code Apartment Numbers (i.e. Address Line 2) IP address IMSI/IMEI numbers MAC address Insurance details Family members and Dependents Sensitive Personal Data can be included in survey response or form data and so AWS may store any of the following: Government/National ID (e.g. SSN, SIN), Driver's License number, Passport number Username and password, Authentication credentials Financial and Payment information (account log‐in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account) Geolocation Race/ethnicity Religious/Political/Trade Union Affiliation Sex life or Sexual Orientation Health data (incl. prescription medications, medical procedures and test, diagnoses, medical practitioners and area of practice, health card numbers etc.) Biometrics (e.g. fingerprints, voice recordings, photos) Genetic data Salary / Income (or ranges of same) Customer survey responses (responses received by a customer to the survey they create within Momentive accounts) Credit score / record Communications - the contents of a consumer’s private communications, unless the company is the intended recipient of the communication Criminal record Quasi identifiers: This could include data which is not personal unless linked to other data e.g. web identifiers, device information, browser data and other meta data which may in some cases be linkable to other categories of data listed above. | Ireland - non-material | Data is not transferred out of Europe. | https://mongodb.scalegrid.io/hubfs/Whitepaper-ScaleGrid-Infrastructure-Security.pdf |
Subprocessor | Purpose | Personal Data | Location and Assessment of Legal Regime Risk | Transfer Mechanism | Supplementary Measures: Contractual, Organizational, and Technical |
AWS | See above | See above | See above | See above | See above |
Functional Software Inc. (Sentry) | Applications error capturing (site health monitor). | Direct identifying information (e.g. name, email address, telephone) Indirect identifying information (e.g. job title, gender, date of birth) Device identification data and traffic data (e.g. IP addresses, MAC addresses, web logs, browser agents) Any personal data supplied by end users of the Service. | USA - low | SCCs | See Sentry’s security page for more details. |
Hosts survey assets and respondent assets, NLP for respondent data, respondent data hosted on Google platform for searching/indexing dashboards. | Survey Response data. This may or may not include personal data, depending on the types of questions in the survey and how the respondent chooses to answer the questions. | USA - low | SCCs | https://cloud.google.com/security/ | |
Heroku (if you utilize GetFeedback Direct’s EU Data Center, Heroku is not a subprocessor) | Application host and data store that runs on AWS. | See ‘Amazon/AWS’ above | USA - low | SCCs | Please see Heroku’s security certifications and Trust and Compliance documentation. |
IPdata | Geolocation lookup for Respondents | IP address | USA - low | SCCs | Please see IPdata’s Privacy Policy for more information. |
Momentive Affiliates (Momentive Inc., Momentive Australia Pty Limited) | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Canada Inc., Momentive UK Ltd.) | See above | See above | See above | See above | See above |
Salesforce | See above | See above | See above | See above | See above |
Splunk | See above | See above | See above | See above | See above |
Subprocessor | Purpose | Personal Data | Location and Assessment of Legal Regime Risk | Mechanism of Transfer | Supplementary Measures: Contractual, Organizational, and Technical |
AWS | See above | See above | See above | See above | See above |
Microsoft | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Inc., Momentive Australia Pty Limited) | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Canada Inc., Momentive UK Ltd.) | See above | See above | See above | See above | See above |
Salesforce | See above | See above | See above | See above | See above |
Snowflake | See above | See above | See above | See above | See above |
Sparkpost | See above | See above | See above | See above | See above |
Splunk | See above | See above | See above | See above | See above |
Subprocessor | Purpose | Personal Data | Location and Assessment of Legal Regime Risk | Transfer Mechanism | Supplementary Measures: Contractual, Organizational, and Technical |
AWS | See above | See above | See above | See above | See above |
Engine Yard | Website hosting tool and cloud application management. | See ‘AWS’ above | US - low | SCCs | Engine Yard is contractually committed to: host data at a secure facility (such as AWS) with data center access restrictions, monitoring, security staff, and other commercially reasonable physical security measures; maintain restricted network access, firewalls, server hardening measures, user authentication protocols, event logging, and other commercially reasonable system and network security measures designed to protect the security of personal data; encrypt personal data where feasible and commercially reasonable in accordance with industry standards for encryption at rest and in transit; and grant access on the principle of least privilege on a role basis and subject to authorization and deactivation practices of Momentive. |
Microsoft | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Inc., Momentive Australia Pty Limited) | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Canada Inc., Momentive UK Ltd.) | See above | See above | See above | See above | See above |
Salesforce | See above | See above | See above | See above | See above |
Subprocessor | Purpose | Personal Data | Location and Assessment of Legal Regime Risk | Transfer Mechanism | Supplementary Measures: Contractual, Organizational, and Technical |
AWS | See above | See above | See above | See above | See above |
Engine Yard | See above | See above | See above | See above | See above |
Microsoft | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Inc., Momentive Australia Pty Limited) | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Canada Inc., Momentive UK Ltd.) | See above | See above | See above | See above | See above |
Salesforce | See above | See above | See above | See above | See above |
Subprocess | Purpose | Personal Data | Location and Assessment of Legal Regime Risk | Transfer Mechanism | Supplementary Measures: Contractual, Organizational, and Technical |
AWS | See above | See above | See above | See above | See above |
Bridgewater Labs | Task augmentation (engineering contractors) | All possible personal data categories collected in SM Apply forms. | Canada - non-material | SCCs | All the security controls available and listed above for AWS are utilized to ensure least privileged access for our third party contractors. We utilize remote desktop security as well as the other security controls which apply to any internal Momentive systems. See our security statement for further details. |
Microsoft | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Inc., Momentive Australia Pty Limited) | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Canada Inc., Momentive UK Ltd.) | See above | See above | See above | See above | See above |
Salesforce | See above | See above | See above | See above | See above |
Subprocessor | Purpose | Personal Data | Location and Assessment of Legal Regime Risk | Transfer Mechanism | Supplementary Measures: Contractual, Organizational, and Technical |
AWS | See above | See above | See above | See above | See above |
Microsoft | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Inc., Momentive Australia Pty Limited) | See above | See above | See above | See above | See above |
Momentive Affiliates (Momentive Canada Inc., Momentive UK Ltd.) | See above | See above | See above | See above | See above |
Salesforce | See above | See above | See above | See above | See above |