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Hornbill partners with a number of organizations for services that contribute to the delivery of our platform service as described in our Terms of Service. Because our suppliers provide us with services that we use in order to deliver our service to our customers, our suppliers could be considered subprocessors.
What is a Subprocessor
A subprocessor is a third-party data processor engaged by Hornbill, which includes other entities from within the Hornbill Group, who has or potentially will have access to or process Service Data (which may contain Personal Data). Hornbill engages different types of subprocessors to perform various functions as set out below.
Security by Design
Hornbill designs its platform applying a “Secure by Design” philosophy. In the case of partnering with third-party contractors or subprocessors, Hornbill’s platform is designed to eliminate or minimize to the greatest possible extent exposure of customer data to subcontractor/subprocessor personnel. A good example of this would be, while we partner with data center providers we either provide our own hardware or buy/lease bare metal upon which we run our own software stack.
Contractual Safeguards
Hornbill requires all of its subprocessors to satisfy equivalent obligations as those obligations delivered under Hornbills Terms of Service, including, but not limited to…
- Must process any Personal Data in accordance with Hornbills obligations under its Terms of Service.
- In relation to any activity that constitutes sub-processing activity, they will only use 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;
- They will ensure they provide regular training in security and data protection to personnel to whom they grant access to any Personal Data;
- They will implement and maintain good technical and organizational measures (including measures aligned with those to which Hornbill is contractually obliged to deliver insofar as they are equally relevant to the sub-processor’s processing of Personal Data on Hornbill’s behalf) and provide an annual industry recognized certification that evidences compliance with this obligation.
- They will promptly notify Hornbill about any actual or potential security breach; and
- They will cooperate with Hornbill in order to deal with requests from data controllers, data subjects, or data protection authorities, as applicable.
Due Diligence
Hornbill uses all commercially reasonable steps in its sub-processor selection and partnering process in order to evaluate the security, privacy, and confidentiality practices of its subprocessors that will or may have access to or process service data. This policy does not give Hornbill Subscribers any additional rights or remedies and the details provided here should not be construed as a binding agreement.
The information here is only provided to illustrate Hornbill’s approach to selecting and engaging with subprocessors as part of providing the overall service to our customers.
Infrastructure and Data Storage subprocessors Hornbill does not operate its own data centers, instead, we partner with Tier 1 data center providers. Our computing model is either co-location or bare metal lease, in both cases, the software stack is entirely managed by ourselves.
Partner Subprocessors
Customer data is stored in an appropriate geographic data center and personal data is not transferred outside of the country or controlling region unless the prior written consent of the Customer has been obtained and one of the exceptions outlined in Hornbill’s Terms of Service applies.
| Entity/Name | Purpose | Country |
|---|---|---|
| RapidSwitch - Maidenhead | Primary UK Data center, Co-Location (ISO27001:2013, ISO9001:2015, ISO50001:2011 | UK |
| Equinix - London 3 | Primary UK Data center, Co-Location (ISO27001:2013, ISO9001:2015, ISO50001:2011 | UK |
| Hornbill Technologies Ltd - London | Beta Zone, Backup UK Data center (ISO27001:2013) | UK |
| Peer1\Aptum – Los Angeles | Primary US Data center, Bare Metal (SSAE 16 Type II) | North America |
| Peer1\Aptum – Washington DC | Backup US Data center, Bare Metal (SSAE 16 Type II) | North America |
| Amazon Data Services Ltd | Off-line Data Backup/Storage | UK |
| Amazon Web Services, Inc. | Off-line Data Backup/Storage | North America |
Service Subprocessors
| Entity/Name | Purpose | Scope |
|---|---|---|
| Google, Inc. | We use a number of services provided by Google in order to enhance the productivity and usability capability of Hornbill | In-App Translations, Mobile Messaging, GEO data lookups, and mapping. |
| Apple, Inc. | We provide a native iOS app and integrate with Apple’s mobile data services. | Mobile Data and Messaging. |
| Cloudflare, Inc. | Cloudflare provides a number of services for Hornbill’s platform, specifically its front-end (excluding user data), including Content Delivery Network, caching, optimization, performance, threat management, and shielding, security, and statistical usage insights. | All Hornbill Services Globally |
| OpenAI, LLC. | OpenAI is an AI research and deployment company specializing in Artificial Inlelligence LLVM’s, Machine Learning and associated services. Hornbill uses the OpenAI platform for AI relates functions and capabilities. | |
| Microsoft Azure | Azure OpenAI Services for Generative AI Text Generation. Hornbill uses the Azure OpenAI platform for Generative AI functions and capabilities only when you have specifically opted in. The Region of Azure used is related to your instance. | All Hornbill Applications that have HAI capability |
Group Members
| Entity/Name | Purpose | Country |
|---|---|---|
| Hornbill Technologies Ltd (HTL) | Hornbill platform and cloud services provider and data processor | UK |
| Hornbill Corporate Ltd (HCL) | Sales, marketing, support, and devolopment of Hornbill services and applications | UK |
| SPHK | Support and development of Hornbill services and applications | Albania |
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