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Sub-processors

Last updated: Wednesday, 22th Feb ’23

To ensure an efficient provision of Infobip Services, Infobip sometimes may engage its affiliates (list of affiliates is available here) and third parties as Sub-processors. In order to provide specific functionalities within Infobip Services, these Sub-processors may have access to the personal data processed on behalf of the customers (customer’s data), as specified in the data processing agreement concluded with the customer. Below you will find details on where we store and how we access customer’s data, and a complete list of currently engaged Sub-processors.

Information about storage and access

With 40+ data centers all around the globe, Infobip is in a position to support provision of its Services and storage of customer’s data in line with the customer’s choice and preferences.

Unless otherwise agreed upon with the customer in writing (and whenever the customer requires it), Infobip shall ensure that the customer’s data are stored and processed at the processing systems located in Infobip data centers within the European Union. Any transfer of personal data to Infobip’s data centers located outside the European Union can be made only upon such an explicit instruction of the customer.

Nevertheless, Infobip is a global company and it is possible that authorized employees from our affiliated companies have access to customer’s data. Namely, Infobip is able to offer customer care and technical support to its customers by operating a 24/7 “follow the sun” support model that leverages its support engineers in countries where Infobip operates so sometimes Infobip will provide such support from outside the European Union (EU). This support is carried out only by accessing customer data on its original location (data center chosen by the customer) without transferring it into another jurisdiction, and is performed in a secure way enabled by strong authentication measures and access protocols according to Infobip Group security policies.

However, if requested so by the customer, customer’s data will be stored in our EU region-locked data center within the European Union and our support model can be limited so customer data can be accessed by authorized Infobip staff in the EU and countries with adequate data protection. Exceptionally and only for purpose of complex troubleshooting when using E-mail or Voice product customer support might be provided by Infobip’s team from Bosnia and Herzegovina (following a transfer impact assessment and implementation of supplementary measures). For more information about this exceptional case please check the list of sub-processors engaged below.

All Infobip’s intercompany processing is regulated by the Infobip Group intercompany data processing agreement and, where applicable, EC Standard Contractual Clauses.

You can find an up-to-date list of Sub-processors below.

List of Sub-processors

Sub‑processor	Purpose of sub-processing	Sub-processing location	Transfer mechanism
Microsoft Ireland Operations Limited	Provisioning of cloud services for storage and computing, networking, monitoring and analytics, including proxying and balancing; supporting services for Text-to-Speech (TTS); supporting GenAI services.	Customer Data is hosted at the customer’s selected location, as set out in agreement for INFOBIP Services	N/A
Amazon Web Services, Inc.	Provisioning of cloud hosting for various services – data analysis, email campaigns, proxying and balancing for white-label customers. That includes auxiliary utilities such as DNS, monitoring and support. Storage, provision of products and services used for communication between Infobip platform and other origination or termination points for various communication services; supporting services for Text-to-Speech (TTS) like Amazon Polly.	Customer Data is hosted at the customer’s selected location, as set out in agreement for INFOBIP Services	EC Standard Contractual Clauses
Google LLC	Provisioning of Google Cloud Platform and related technical support for Text-to-Speech (TTS).	USA	EC Standard Contractual Clauses
GoodData Ireland Limited	Product analytics	Customer Data is hosted at the customer’s selected location, as set out in agreement for INFOBIP Services.	N/A
Infobip Affiliates	Provisioning of customer care and technical support.	Global	EC Standard Contractual Clauses

List of sub-processors engaged when using EU region-locked data center

Sub‑processor	Purpose of sub-processing	Sub-processing location	Transfer mechanism
Infobip Croatia	Provisioning of customer care and technical support.	Croatia	N/A
Infobip United Kingdom	Provisioning of customer care and technical support.	United Kingdom	N/A
Infobip Bosnia & Herzegovina	Exceptionally and only for purpose of complex troubleshooting when using E-mail or Voice product provision of technical suppport might be provided by Infobip’s team from Bosnia and Herzegovina. In this exceptional case access will be temporary, remote and only to a limited set of data necessary to resolve the troubleshooting.	Bosnia & Herzegovina	EC Standard Contractual Clauses

Transfer impact assessment (TIA)

Performing a TIA requires conducting several steps which include identifying specific circumstances of the proposed data transfer; considering the laws and practices in the destination country; considering contractual, organizational or technical supplemental measures to safeguard the data; considering the risk of harm to which a data subject may be exposed by taking into account the specific circumstances of the transfer. Final decision about the level of risk to personal data being transferred is assessed based on the collected information.

TIA for Bosnia & Herzegovina

Exceptionally and only for purpose of complex troubleshooting when using E-mail or Voice product customer support might be provided by Infobip’s team from Bosnia and Herzegovina. In this exceptional case access will be temporary, with strict access controls, and only to a limited set of data necessary to resolve the troubleshooting. Our team will resolve the troubleshooting only by accessing customer data remotely on its original location without transferring it into another jurisdiction and is performed in a secure way enabled by strong authentication measures and access protocols according to Infobip Group security policies. In this case, data will be transferred from Infobip Affiliates in Croatia and United Kingdom to Infobip Affiliate in Bosnia and Herzegovina. Upon conducting above mentioned TIA steps it was concluded that the residual risk to personal data transferred outside of the European Union to Bosnia & Herzegovina is likely to be low.

At the link below customers may subscribe to receive notifications of changes within the Sub-processors’ list.

If you are interested in other categories of recipients of customer data please read the Infobip Privacy Noti ce and Cookie Policy.

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You will receive an email every time the sub-processors list is updated. By submitting to this form you confirm that you have read our Privacy Notice.

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