Version 1.0: This list of subprocessors was produced on 15th May 2018. It may be updated in the future and we'll post the updated version here on our website.
To support delivery of our Service, SailingClubManager Ltd. ( "SailingClubManager") may engage and use data processors with access to certain Service data (each, a "Subprocessor"). This page provides important information about the identity, location and role of each Subprocessor. Terms used on this page but not defined have the meaning set forth in our Terms of Service (the "Agreement"). Defined terms used herein shall have the same meaning as defined in the Agreement.
What is a subprocessor
A Subprocessor is a third party data processor engaged by SailingClubManager who has or potentially will have access to or process Service data (which may contain Personal Data). SailingClubManager engages different types of Subprocessors to perform various functions as explained in the tables below.
SailingClubManager 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.
SailingClubManager requires its Subprocessors to satisfy equivalent obligations as those required from SailingClubManager (as a Data Processor) as set forth in either SailingClubManager's, or the corresponding Subprocessor's equivalent, Data Processing Addendum ("DPA"), incorporating Standard Contractual Clauses ("SCC") where appropriate, including but not limited to the requirements to:
- process Personal Data in accordance with SailingClubManager's instructions;
- 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;
- implement and maintain appropriate technical and organisational measures (including measures consistent with those to which SailingClubManager is contractually committed to adhere insofar as they are equally relevant to the Subprocessor's processing of Personal Data on SailingClubManager's behalf);
- promptly inform SailingClubManager about any actual or potential security breach; and
- cooperate with SailingClubManager in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.
This policy does not give users of the Service any additional rights or remedies and should not be construed as a binding agreement. The information here is provided for transparency purposes to illustrate SailingClubManager's engagement process for Subprocessors as well as to provide the actual list of third party Subprocessors used by SailingClubManager (as of the date of this policy) which SailingClubManager may use in the delivery and support of its Service.
Process to engage new subprocessors
As our business grows and evolves, the Subprocessors we engage may also change. We will provide users of the Service with notice of any new Subprocessors to the extent required under the Agreement by posting such updates here.
SailingClubManager will provide notice via this policy of updates to the list of Subprocessors that are utilised or which SailingClubManager proposes to utilise to deliver its Service. SailingClubManager undertakes to keep this list updated regularly to enable users of the Service to stay informed of the scope of subprocessing associated with the Service.
Please check back frequently for updates.
The following is an up-to-date list (as of the date of this policy) of the names and locations of SailingClubManager Subprocessors.
Infrastructure Subprocessors – Service Data Storage
SailingClubManager owns and controls access to the physical infrastructure that SailingClubManager uses to host Service data submitted to the Service, other than as set forth below. SailingClubManager production systems for the Service are located in co-location facilities in the United Kingdom. SailingClubManager may use the following Subprocessors to host Service data or provide other infrastructure that helps with the delivery of the Service.
|Entity Name||Subprocessing Activities||Country(ies)||Adequacy|
|BrightBox||Data centre services||UK||ISO 27001|
|Amazon Web Services, Inc.||Cloud service provider||
DPA with SCC
|Google, Inc.||Cloud service provider||United States||
DPA with SCC
SailingClubManager does not store payment card information. Payment processing is handled directly by the following third parties according to their respective Privacy Policies and Terms of Service.
|Entity Name||Subprocessing Activities||Country(ies)||Policy|
|Paypal||Outsourced payment management||
|WorldPay||Outsourced payment management||Europe|
|SagePay||Outsourced payment management||Europe|
SailingClubManager6 Marina Walk
Isle of Wight
Last updated 10:25 on 30 May 2019