WHAT IS A SUB-PROCESSOR? A Sub-Processor is a third-party data processor engaged by Pando who is used to process some of the data that is generated or used by the Pando Services (“Service Data”).Pando engages different types of Sub-Processors to perform various functions as explained in the sections to follow. In some cases, Service Data includes Personal Data as defined by the General Data Protection Regulation (“GDPR”). Any sharing of personal data with a Sub-Processor is detailed in full in the sections to follow.
DUE DILIGENCE Pando undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed Sub-Processors that may be processing Service Data.We require all Sub-Processors to satisfy the same obligations as those required by you as a Data Controller, from us as a Data Processor, as set forth in our Privacy Policy.As a minimum, we ensure that Pando’s Sub-Processors store and process all Service Data we share with them in a manner that is compliant with EU data protection requirements under GDPR.
CHANGES TO THIS SUB-PROCESSOR POLICY We will keep this policy updated regularly to enable Pando users to stay informed of the scope of sub-processing associated with the Pando Services.As a Pando user, you can object to changes to this Sub-Processor policy, but this may result in you no longer being able to use the Services in their entirety.Termination rights, as applicable and agreed, are set forth exclusively in our Terms of Service.