SUBPROCESSORS AND SUBCONTRACTORS
Last Modified: August 24, 2018
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AppExtremes, LLC dba Conga (“Conga”) uses certain Subprocessors (including members of the Conga Group and third-parties, as listed below), to assist it in providing the Conga 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 engaged by Conga, including entities from within the Conga Group, who may have access to production infrastructure or process Customer Data (which may contain Personal Data).
Conga engages different types of Subprocessors to perform various functions as explained in the tables below. Conga refers to third-parties that do not have access to or process Customer Data but who are otherwise used to provide the Services as “subcontractors” and not Subprocessors.
*Please note that Conga Grid and Conga Orchestrate are native Salesforce applications which processes your data completely within Salesforce. When using Conga Grid and Conga Orchestrate, the solution does not send or store any data outside of your Salesforce instance, unless it is configured by you to work in tandem with other services which may do such.
Conga undertakes due diligence around the data privacy and security posture of potential Subprocessors prior to engagement. Our activities are designed to ensure that processing is only performed by entities with sufficient ability to meet data protection obligations.
Conga requires its Subprocessors to satisfy equivalent obligations as those required from Conga (as a Data Processor) as set forth in Conga’s Data Processing Agreement (“DPA”), including but not limited to the requirements to:
- process Personal Data in accordance with data controller’s (i.e. Customer’s) documented instructions (as communicated in writing to the relevant Subprocessor by Conga);
- 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 Conga is contractually committed to adhere insofar as they are equally relevant to the Subprocessor’s processing of Personal Data on Conga’s behalf) and provide an annual certification that evidences compliance with this obligation. In the absence of such certification Conga reserves the right to audit the Subprocessor;
- promptly inform Conga about any actual or potential security breach; and
- cooperate with Conga in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.
This policy does not give Customers any additional rights or remedies and should not be construed as a binding agreement. The information herein is only provided to illustrate Conga’s engagement process for Subprocessors as well as to provide the actual list of third party Subprocessors and subcontractors used by Conga as of the date of this policy (which Conga may use in the delivery and support of its Services).
If you need to execute an data protection or transfer addendum with Conga, you can find Conga’s DPA here: https://getconga.com/resources/conga-dpa. Upon request, we will review and consult with our Customer’s business-specific needs around the DPA. Please send an email to CongaDPA@getconga.com to request a copy of Conga’s DPA or with any other DPA related questions.
Process to Engage New Subprocessors:
For all Customers who have executed Conga’s standard DPA, Conga will provide notice via this policy of updates to the list of Subprocessors that are utilized or which Conga proposes to utilize to deliver its Services. Conga undertakes to keep this list updated regularly to enable its Customers to stay informed of the scope of subprocessing associated with the Conga Services.
Pursuant to the DPA, a Customer can object in writing to the processing of its Personal Data by a new Subprocessor within ten (10) business days after updating of this policy and shall describe its legitimate reasons to object. If Customer does not object during such time period, the new Subprocessor(s) shall be deemed accepted.
If a Customer objects to the use of a Subprocessor pursuant to the process provided under the DPA, Conga shall have the right to cure the objection through one of the following options (to be selected at Conga’s sole discretion):
(a) Conga will cease to use the Subprocessor with regard to Personal Data;
(b) Conga will take the corrective steps requested by Customer in its objection (which remove Customer’s objection) and proceed to use the Subprocessor to process Personal Data; or
(c) Conga may cease to provide, or Customer may agree not to use (temporarily or permanently) the particular aspect of a Conga 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 Conga Subprocessors (including members of the Conga Group and third parties):
Conga owns or controls access to the infrastructure that Conga uses to process Customer Data submitted to the services. Customer’s services are established in one of these regions based on where the Customer’s Salesforce instance is located; the Customer’s data subsequently remains in that region unless agreed between the Customer and Conga 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 in the processing of Customer Data by Conga.
|Applicable Services||Entity Name||Entity Type||Entity Country|
|Contracts, Contracts for Salesforce®, Composer, Sign, Collaborate, Conga Quote Generation for Salesforce CPQ, Conga Invoice Generation for Salesforce||Amazon Web Services, Inc.||Cloud Service Provider||United States|
|Contracts, Contracts for Salesforce®, Composer, Sign, Conga Quote Generation for Salesforce CPQ, Conga Invoice Generation for Salesforce||Amazon Web Services Ireland Limited||Cloud Service Provider||Ireland|
|Contracts, Contracts for Salesforce®, Composer, Sign, Conga Quote Generation for Salesforce CPQ, Conga Invoice Generation for Salesforce||Amazon Web Services||Cloud Service Provider||Germany|
|Contracts, Contracts for Salesforce®, Composer, Sign, Conga Quote Generation for Salesforce CPQ, Conga Invoice Generation for Salesforce||Amazon Web Services Australia Pty, Ltd.||Cloud Service Provider||Australia|
As explained above, Conga also uses certain “subcontractors” to assist in the operations necessary to provide the Conga 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 Customer Data.
|Applicable Services||Entity Name||Entity Type||Entity Country(ies)|
|Contracts (formerly known as Novatus)||Equinix, Inc.||Data Center||Netherlands, France|
|Contracts (formerly known as Novatus)||DataSite||Data Center||United States|
|Contracts (formerly known as Novatus)||Peer1||Data Center||United States|
|Contracts (formerly known as Novatus)||Iron Mountain||Secure Media Storage||United States|
Service Specific Subprocessors
Conga 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 may have access to Customer Data. Their use is limited to the indicated Services.
|Applicable Services||Entity Name||Purpose||Entity Country|
|MixForms||Efficient Technology Inc.||Web-based Forms||United States|
|Collaborate||Box.com||Cloud-based Document Storage||United States|
|Collaborate||Engine Yard||Platform as a Service (within United States AWS)||United States|
|Collaborate||Kami||Document Annotation||New Zealand|
|Collaborate||Pusher||Hosted APIs||United Kingdom, or United States|
|Collaborate||Twilio||Cloud-based Communication Services||United States|
|Collaborate||WalkMe||Digital Adoption Platform||United States|
|Collaborate||Webmerge||Web-based Forms||United States|
|Collaborate||easyPDF Cloud, BCL Technologies*||Document Conversion (PDF to Word)||United States|
|Collaborate||FullStory*||Temporary Bug Reproduction||United States|
|Collaborate||ConvertAPI, UAB Baltsoft*||Document Conversion (PDF to PowerPoint)||United States|
* These subprocessors utilized only in those specific feature use cases.
Conga Group Group Affiliates
Conga may engage any of its affiliates listed below as a Subprocessor, depending where a customer may be geographically located, and the services used by the Customer.
|Entity Name||Entity Country|
|AppExtremes, LLC dba Conga||United States|
|Conga APAC Pty Ltd.||Australia|
|Conga EMEA Ltd.||United Kingdom|
|Octiv, Inc.||United States|