Zendesk, Inc. (“Zendesk”) uses certain subprocessors (including members of the Zendesk Group and third parties, as listed below), subcontractors and content delivery networks to assist it in providing the Zendesk Services as described in the Master Subscription Agreement (“MSA”). Defined terms used herein shall have the same meaning as defined in the MSA.
What is a Subprocessor
A subprocessor is a third party data processor engaged by Zendesk, including entities from within the Zendesk Group, who has or potentially will have access to or process Service Data (which may contain Personal Data). Zendesk engages different types of subprocessors to perform various functions as explained in the tables below. Zendesk refers to third parties that do not have access to or process Service Data but who are otherwise used to provide the Services as “subcontractors” and not subprocessors.
Zendesk undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed subprocessors that will or may have access to or process Service Data.
Zendesk requires its subprocessors to satisfy equivalent obligations as those required from Zendesk (as a Data Processor) as set forth in Zendesk’s Data Processing Agreement (“DPA”), including but not limited to the requirements to:
- Process Personal Data in accordance with data controller’s (i.e. Subscriber’s) documented instructions (as communicated in writing to the relevant subprocessor by Zendesk);
- In connection with their subprocessing 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 Zendesk is contractually committed to adhere to insofar as they are equally relevant to the subprocessor’s processing of Personal Data on Zendesk’s behalf) and provide an annual certification that evidences compliance with this obligation. In the absence of such certification Zendesk reserves the right to audit the subprocessor;
- Promptly inform Zendesk about any actual or potential security breach; and
- Cooperate with Zendesk in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.
This policy does not give Subscribers any additional rights or remedies and should not be construed as a binding agreement. The information herein is only provided to illustrate Zendesk’s engagement process for subprocessors as well as to provide the actual list of third party subprocessors, subcontractors and content delivery networks used by Zendesk as of the date of this policy (which Zendesk may use in the delivery and support of its Services).
If you are a Zendesk Subscriber and wish to enter into our DPA, please email us at firstname.lastname@example.org.
Process to Engage New Subprocessors:
For all Subscribers who have executed Zendesk’s standard DPA, Zendesk will provide notice via this policy of updates to the list of subprocessors that are utilized or which Zendesk proposes to utilize to deliver its Services. Zendesk undertakes to keep this list updated regularly to enable its Subscribers to stay informed of the scope of subprocessing associated with the Zendesk Services. Zendesk Subscribers may subscribe to receive notifications of updates to this policy by clicking “Follow updates” at the top of this policy.
Pursuant to the DPA, a Subscriber may object in writing to the processing of its Personal Data by a new subprocessor within thirty (30) days following the update of this policy and such objection shall describe Subscriber's legitimate reason(s) for objection. If Subscriber does not object during such time period the new subprocessor(s) shall be deemed accepted.
If a Subscriber objects to the use of a new subprocessor pursuant to the process provided under the DPA, Zendesk shall have the right to cure the objection through one of the following options (to be selected at Zendesk’s sole discretion):
(a) Zendesk will cease to use the new subprocessor with regard to Personal Data;
(b) Zendesk will take the corrective steps requested by Subscriber in its objection (which remove Subscriber’s objection) and proceed to use the subprocessor to process Personal Data; or
(c) Zendesk may cease to provide or Subscriber may agree not to use (temporarily or permanently) the particular aspect of a Zendesk Service that would involve use of the subprocessor to process Personal Data.
Termination rights, as applicable and agreed, are set forth exclusively in the DPA.
The following is an up-to-date list (as of the date of this policy) of the names and locations of Zendesk subprocessors, subcontractors and content delivery networks (including members of the Zendesk Group and third parties):
Infrastructure Subprocessors – Service Data Storage
Zendesk owns or controls access to the infrastructure that Zendesk uses to host Service Data submitted to the Services, other than as set forth below. Currently, the Zendesk production systems for the Services are primarily located in co-location facilities in the United States and Europe. Subscriber accounts are established in one of these regions based on where the Subscriber is located; the Subscriber’s Service Data subsequently remains in that region unless agreed between Subscriber and Zendesk, but may be shifted among data centers within a region to ensure performance and availability of the Services. The following table describes the countries and legal entities engaged by Zendesk in the storage of Service Data.
|Entity Name||Entity Type||Entity Country|
|Amazon Web Services, Inc.||Cloud Service Provider||United States|
|Amazon Data Services Ireland Ltd||Cloud Service Provider||Ireland|
|Google Inc.||Cloud Service Provider||United States|
Service Specific Subprocessors
Zendesk works with certain third parties to provide specific functionality within the Services. These providers are the Subprocessors set forth below. In order to provide the relevant functionality these Subprocessors access Service Data. Their use is limited to the indicated Services.
|Entity Name||Purpose||Applicable Services||Entity Country|
|Twilio, Inc.||Zendesk Talk’s cloud center software is built on Twilio, Inc.’s (“Twilio”) development platform. Twilio’s development platform provides the APIs from which Zendesk Talk accesses the telecommunications infrastructure, including phone numbers, voice minutes, web client, and phone call recording and transcription. Twilio has access to Subscribers’ and End-Users’ information as needed to deliver the Talk and Text messages between Subscribers and End-Users. This includes Service Data contained in the messages and the Personal Data of Subscribers’ Agents and End-Users as needed to send and deliver the messages. Zendesk Support also uses Twilio for two-factor authentication of End-Users. The only information Twilio has access to for this purpose is End-User phone number.||Zendesk Talk, Zendesk Support||United States|
|GoodData Corporation||GoodData Corporation (“GoodData”) is the analytics provider that Zendesk uses to provide Insights and Analytics within the Services.||All||United States|
|Smooch Technologies Inc.||Smooch Technologies Inc. (“Smooch”) provides some of the connectors between the Zendesk Message functionality available within Zendesk Chat and certain third party messaging platforms. No other Zendesk Services use Smooch. Smooch has access to Subscribers’ and End-Users’ information as needed to deliver the messages sent through the connectors. This includes Service Data contained in the messages and the Personal Data of Subscribers’ Agents and End-Users as needed to send and deliver the messages.||Zendesk Chat||Canada|
|Cloudflare, Inc.||Cloudflare, Inc. (“Cloudflare”) provides content distribution, security and DNS services for web traffic transmitted to and from the Services. This allows Zendesk to efficiently manage traffic and secure the Services. The primary information Cloudflare has access to is information in and associated with the Zendesk website URL that the End-User is interacting with (which includes End-User IP address). All information (including Service Data) contained in web traffic transmitted to and from the Services is transmitted through Cloudflare’s systems, but Cloudflare does not have access to this information.||All||United States|
|Pendo.io, Inc.||Pendo.io, Inc. (“Pendo”) is a third-party analytics provider that Zendesk uses to capture how users interact with the Service. Zendesk uses this information to analyze and improve the Services. The primary information Pendo has access to is information in and associated with the Zendesk website URL that the Agent and End-User is interacting with, such as time spent on page, items clicked (including Service Data contained in those items), Agent email addresses, End-User email addresses, etc.||All||United States|
|DataVisor, Inc.||DataVisor, Inc. (“DataVisor”) is a third party service used to prevent fraudulent account registrations for the Service and to prevent spamming and other harmful use of the Services. The primary information that DataVisor has access to is information provided by Subscribers at trial creation (Subscriber email address, IP address, company name, etc.), Guide content and comments, and Support ticket content and associated End-User ticket metadata.||All||United States|
|Metaverse Mod Squad||Metaverse Mod Squad (“Metaverse”) is a third-party service provider that assists Zendesk with the provision of customer support only and is not involved in technical operations which would include the prevention of and addressing technical or service issues. Metaverse has limited access to Subscribers’ information, including Service Data. This limited access is with the dependent on permission granted by Subscribers to Metaverse. Metaverse may have access to the following identifying information about Subscribers and End-Users for the sole purpose of dealing with Subscribers’ support requests: first and last name, email address and phone number. In addition and with Subscriber permission, this Metaverse may be provided access to Service Data for the purpose of dealing with support requests.||Zendesk Support||Ireland|
Zendesk Group Subprocessors
The following entities are members of the Zendesk Group. Accordingly, they function as subprocessors to provide the Services.
|Zendesk, Inc.||United States|
|Zendesk International Ltd||Ireland|
|Zendesk Pty. Ltd||Australia|
|Zendesk UK Ltd||United Kingdom|
|Zendesk Singapore Pte. Ltd.||Singapore|
|Zendesk Brasil Software
|Kabushiki Kaisha Zendesk||Japan|
|We Are Cloud SAS||France|
As explained above, Zendesk also uses certain “subcontractors” to assist in the operations necessary to provide the Zendesk Services as described in the Master Subscription Agreement. The following is a list (as of the date of this policy) of the names and locations of material third-party subcontractors. Subcontractors do not have access to Service Data.
|Entity Name||Entity Type||Location|
|Equinix, Inc.||Data Center||European Union (Ireland and Germany)|
|RagingWire Enterprise Solutions, Inc.||Data Center||United States (Virginia and California)|
Content Delivery Networks
As explained above, Zendesk’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 Service 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 use of CDNs by Zendesk’s Services.
|CDN Provider||Services Using CDN||CDN Location||Description of CDN Services|
|Akamai||All Zendesk Services||Global||Public website content served to website visitors may be stored with Akamai, and transmitted by Akamai to website visitors, to expedite transmission.|
|Amazon Web Services, Inc.||All Zendesk Services||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.|
|Verizon Digital Media Services, Inc.||All Zendesk Services||Global||Public website content served to website visitors may be stored with Verizon Digital Media Services, and transmitted by Verizon Digital Media Services to website visitors, to expedite transmission.|