Last reviewed: August 2023
Vendor: Amazon Web Services (AWS)
Website: https://aws.amazon.com
Purpose: Database and hosting
Type of personal data processed: Learner Course usage details
Location of processing: Server region set by Elucidat – currently AWS EU (Dublin) Region. (Amazon Web Services EMEA SARL)
Compliance mechanism for ex-EEA transfer: N/A: Contracted not to move data from the AWS region selected by Elucidat
Article 28 Data Processing Agreement: AWS GDPR Data Processing Addendum, part of Service Terms at clause 83 of Service Terms
Vendor: Elucidat Inc.
Website: https://elucidat.com
Purpose: Process for purpose of sales and technical support as affiliate of Elucidat Group
Type of personal data processed: Learner Course usage details
Location of processing: Processing happening locally in North Carolina
Compliance mechanism for ex-EEA transfer: Standard Contractual Clauses (see our Licence Agreement)
Article 28 Data Processing Agreement: Intra-Group Data Transfer Agreement
Vendor: Intercom
Website: https://www.intercom.com
Purpose: Customer communication system
Type of personal data processed: Learner Course usage details
Location of processing: US, EEA and UK
Compliance mechanism for ex-EEA transfer: Standard Contractual Clauses
Article 28 Data Processing Agreement: Data Processor Agreement in place complying with Article 28 GDPR
Vendor: SendGrid
Website: https://sendgrid.com
Purpose: Cloud-based email delivery platform
Type of personal data processed: Existing Author App usage & Learner Contact details
Location of processing: US and UK
Compliance mechanism for ex-EEA transfer: Standard Contractual Clauses
Article 28 Data Processing Agreement: Data Processor Agreement in place complying with Article 28 GDPR + Signed DPA + Signed DPA in place containing EC Standard Contractual Clauses
Vendor: Zendesk
Website: https://www.zendesk.co.uk
Purpose: Customer support platform
Type of personal data processed: Learner Course usage details
Location of processing: UK, EU & US
Compliance mechanism for ex-EEA transfer: Signed DPA in place containing EC Standard Contractual Clauses
Article 28 Data Processing Agreement: Data Processor Agreement in place complying with Article 28 GDPR
OPTIONAL THIRD PARTY SUBPROCESSORS
The following third party subprocessors will only be in effect when utilising Elucidat Create, our new authoring experience, and only when the optional Artificial Intelligence features are turned on. These subprocessors are not utilised in Elucidat Author, our existing authoring experience.
Whether or not these subprocessors are in use is determined at the Account level. Individual Authors or Learners are not able to opt out of these subprocessors being utilised if the Account Administrator has enabled them.
Vendor: OpenAI (Developer API)
Website: https://openai.com/
Purpose: Provision of AI powered course creation features
Type of personal data processed: Course content which may at times include Personally Identifiable Information if an Author chooses
Location of processing: UK, EU & US
Compliance mechanism for ex-EEA transfer: Signed DPA in place containing EC Standard Contractual Clauses
Article 28 Data Processing Agreement: Data Processor Agreement in place complying with Article 28 GDPR
Vendor: Grammarly (Developer API)
Website: https://www.grammarly.com/
Purpose: Provision of proofreading and text improvement services during course creation
Type of personal data processed: Course content which may at times include Personally Identifiable Information if an Author chooses
Location of processing: UK, EU & US
Compliance mechanism for ex-EEA transfer: Signed DPA in place containing EC Standard Contractual Clauses
Article 28 Data Processing Agreement: Data Processor Agreement in place complying with Article 28 GDPR
