This Data Processing Agreement (the “DPA”) constitutes a legally binding agreement between the Client and Fyno.
This DPA forms an integral part of the online terms of service available at Terms (collectively, the “Agreement”) and is applicable where Fyno is the Processor of Customer’s Personal Data forming part of Customer Data.
Fyno and the Customer are hereinafter referred to individually as a “Party” and collectively as the “Parties”.
1. Definitions
Capitalised terms not specifically defined herein shall have the meaning ascribed thereto in the Agreement.
In this DPA, the following terms shall have the following meanings:
“Controller” shall mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
“Data Protection Laws” shall mean the data protection laws that is applicable to Fyno in connection with its provision of Fyno Solutions under the Agreement, including but not limited to (a) the GDPR; (b) in respect of the UK, the GDPR as saved into United Kingdom by virtue of section 3 of the United Kingdom European Union (Withdrawal) Act 2018 (“UK GDPR”) and the Data Protection Act, 2019 (together, “UK Data Protection Laws”); (c) the Swiss Federal Data Protection Act and its implementing regulations (“Swiss DPA”); and (d) California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”) and all regulations issued by the California Attorney General and/or the California Privacy Protection Agency implementing CCPA and CPRA (“CA Privacy Laws”) (e) Colorado Privacy Rights Act (“Colorado Privacy Laws”) (f) Connecticut Data Privacy Act (“CTDPA”) (g) Virginia Consumer Data Protection Act (“VCDPA”) ; (h) Utah Consumer Privacy Act (“UCPA”); (i) Texas Data Privacy and Security Act (“TDPSA”); (j) Oregon’s Consumer Data Privacy Act (“OCDPA”); (k) The State of Washington’s My Health My Data (“MHMD”); (l) The State of Nevada’s Senate Bill No. 370 (“NVSB”) (m) Delaware Personal Data Privacy Act (“Delaware’s PDPA”), (n) Iowa Consumer Data Protection Act (“ICDPA”), (o) Nebraska Data Privacy Act (“NEDPA”), (p) New Hampshire Data Privacy Act (“NHDPA”), (q) New Jersey Data Protection Act (“NJDPA”), (r) Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”); (s) India’s Digital Personal Data Protection Act (“DPDPA”),in each case, as may be amended, superseded or replaced.
“Data Subject” shall mean any identified or identifiable natural person to whom the Personal Data relates.
“GDPR” shall mean the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).
“Personal Data” shall mean any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person forming a part of Client Data.
“Personal Data Breach” shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
“Processing” shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
“Restricted Transfer” means: (i) where the GDPR applies, a transfer of Personal Data from the EEA to a country outside the EEA which is not subject to an adequacy determination by the European Commission; (ii) where the UK GDPR applies, a transfer of Personal Data from the UK to any other country which is not based on adequacy regulations pursuant to Section 17A of the Data Protection Act 2018; and (iii) where the Swiss DPA applies, a transfer of Personal Data to a country outside of Switzerland which is not included on the list of adequate jurisdictions published by the Swiss Federal Data Protection and Information Commissioner.
“Sensitive Personal Information” shall mean information that relates to an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person's sex life or sexual orientation. It also includes information about an individual's criminal offences or convictions, as well as any other information deemed sensitive under applicable Data Protection Laws.
“Standard Contractual Clauses” or “SCCs” means (i) where the GDPR applies, the standard contractual clauses as approved by the European Commission (Implementing Decision (EU) 2021/914 of 04 June 2021) Implementing Decision (EU) 2021/914 of 04 June 2021) and available at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914 (“EU SCCs”); (ii) where the UK GDPR applies, the International Data Transfer Addendum to the EU SCCs issued by the UK Information Commissioner, Version B1.0, in force from 21 March 2022 set forth as Schedule D (“UK SCCs”) and (iii) where the Swiss DPA applies, the applicable standard data protection clauses issued, approved or recognized by the Swiss Federal Data Protection and Information Commissioner (the “Swiss SCCs”) (in each case, as updated, amended or superseded from time to time).
2. Scope and Responsibilities
2.1. This DPA applies to the Processing of Personal Data forming part of the Client Data. Fyno shall process Personal Data only on the Customer’s behalf, as a Processor and at all times only in accordance with this DPA. For the avoidance of doubt, Fyno shall be the Processor where Customer is the Controller of the Personal Data and where Customer is the Processor, Fyno shall be the sub-processor of Personal Data.
2.2. Within the scope of the Agreement, each Party shall be responsible for complying with its respective obligations as Controller and Processor under the applicable Data Protection Laws and the Customer shall issue Processing instruction only in compliance with applicable Data Protection Laws.
3. Term and Termination
3.1. This DPA becomes effective upon the Customer subscribing to the Fyno Solution by agreeing to the Agreement. It shall continue to be in force and effect as long as Fyno is Processing Personal Data pursuant to the Agreement and shall terminate automatically thereafter.
3.2. Where amendments are required to ensure compliance of this DPA or a Schedule with applicable Data Protection Laws, the Parties shall make reasonable efforts to agree on such amendments upon the Customer’s request. Where the Parties are unable to agree upon such amendments, either Party may terminate the Agreement in accordance with the termination procedure contained therein.
4. Processing Instructions
4.1. Fyno will Process Personal Data in accordance with the Customer’s instructions. This DPA contains the Customer’s initial instructions to Fyno. The Parties agree that the Customer may communicate any change in its initial instructions to Fyno by way of amendment to this DPA, which shall be signed by the Parties.
4.2. For the avoidance of doubt, any instructions that would lead to Processing outside the scope of this DPA (e.g., because a new Processing purpose is introduced) will require a prior agreement between the Parties and, where applicable, shall be subject to the contract change procedure under the respective agreement.
4.3. Fyno shall without undue delay inform the Customer in writing if, in its opinion, an instruction infringes applicable Data Protection Laws and provide a detailed explanation of the reasons for its opinion in writing.
5. Processor Personnel
Fyno will restrict its personnel from Processing Personal Data without authorization. Fyno will impose appropriate contractual obligations upon its personnel, including relevant obligations regarding confidentiality, data protection, and data security, as required under the applicable Data Protection Laws.
6. Disclosure to Third Parties; Data Subjects Rights
6.1. Fyno will not disclose Personal Data to any government agency, court, or law enforcement except with the Customer’s written consent or as necessary to comply with applicable mandatory laws. If Fyno is obliged to disclose Personal Data to a law enforcement agency, Fyno agrees to give the Customer reasonable notice of the access request prior to granting such access, to allow the Customer to seek a protective order or other appropriate remedy. If such notice is legally prohibited, Fyno will take reasonable measures to protect the Personal Data from undue disclosure as if it were Fyno’s own confidential information being requested and shall inform the Customer promptly as soon as possible if and when such legal prohibition ceases to apply.
6.2. To the extent required by the applicable Data Protection Laws Fyno shall reasonably provide the Customer with full cooperation, information and assistance (“Assistance”), in case the Customer receives any request or communication from Data Subjects relating to the Processing of Personal Data ("Request”)
6.3. Where Fyno receives a Request, it shall (i) not directly respond to such Request, unless required to do so under the applicable Data Protection Laws (ii) forward the Request to the Customer within five (5) business days of identifying the Request as being related to the Customer and (iii) provide Assistance according to further instructions from Customer.
7. Technical and Organizational Measures
Fyno shall implement and maintain appropriate technical and organizational security measures to ensure that Personal Data is Processed according to this DPA and applicable Data Protection Laws, and to protect Personal Data against a Personal Data Breach ("TOMs"). Such measures shall include the measures set out in Schedule B.
8. Assistance with Data Protection Impact Assessment
To the extent Data Protection Impact Assessment (“DPIA”) is required for Processing of Personal Data by the applicable Data Protection Laws, Fyno shall provide, upon request, to the Customer any information and assistance reasonably required for the DPIA including assistance for any communication with data protection authorities, where required, unless the requested information or assistance is not pertaining to Fyno’s obligations under this DPA.
9. Information Rights and Audit
9.1. Upon Customer’s written request at reasonable intervals, Fyno shall make available to Customer relevant information regarding Fyno’s Processing of Personal Data in the form of Fyno’s most recent third-party audits and certifications, which may include its ISO 27001 certification, SOC 2 Type II report, to ensure compliance with Fyno’s obligations set out in this DPA. Customer agrees that such third-party audits and certifications are sufficient to demonstrate Fyno’s compliance with the obligations set out in this DPA.
9.2. Fyno will immediately refer to the Customer any requests received from national data protection authorities that relate to its Processing of Personal Data.
9.3. To the extent required by the applicable Data Protection Laws Fyno undertakes to reasonably cooperate with the Customer in its dealings with national data protection authorities and with any audit requests received from national data protection authorities that relate to the Processing of Personal Data.
10. Personal Data Breach Notification
In respect of any Personal Data Breach (actual or reasonably suspected), to the extent required and as prescribed by the applicable Data Protection Laws Fyno shall:
10.1. Notify the Customer of a Personal Data Breach involving Fyno or a sub-processor without undue delay and as prescribed by the applicable Data Protection Laws.
10.2. If mandated under applicable laws, notify the concerned national authorities including the data protection authorities and/or the affected Data Subjects of a Personal Data Breach involving Fyno, in the manner required under such laws
10.3. Provide reasonable information, cooperation, and assistance to the Customer in relation to any action to be taken in response to a Personal Data Breach under applicable Data Protection Laws, including regarding any communication of the Personal Data Breach to Data Subjects and national data protection authorities.
11. Use of sub-processors:
11.1. Fyno shall have the Customer’s general authorization for the engagement of third-party sub-processors from an agreed list, as set forth in Schedule A. Where required under applicable Data Protection Laws, Fyno will notify the Customer’s account administrator of any intended changes to that list through the appointment or replacement of any sub-processor at least fifteen (15) days in advance. The Customer may object to Fyno’s appointment or replacement of a sub-processor prior to its appointment or replacement, provided such objection is based on reasonable grounds relating to data protection. In such an event, Fyno will either not appoint or replace the sub-processor or, if this is not possible, Fyno may suspend or terminate the provision of the Fyno Solution to the Customer (without prejudice to any fees accrued prior to such suspension or termination).
11.2. Where Fyno, with the Customer’s authorisation, engages a sub-processor, it shall do so only by way of a binding written contract which imposes on the sub-processor essentially the same data protection obligations as the ones imposed on Fyno under this DPA.
11.3. Where the sub-processor fails to fulfil its data protection obligations under the subcontracting agreement, Fyno shall remain fully liable to the Customer for the fulfilment of its obligations under this DPA and for the performance of the sub-processor’s obligations.
12. International Data Transfers
12.1. The Parties agree that when there is a transfer of Personal Data from the country where the Customer is established to another country, Fyno shall provide an adequate level of protection and security that is in accordance with the requirements of the applicable Data Protection Laws.
12.2. The Parties agree that when the transfer of Personal Data from the Customer to Fyno is a Restricted Transfer and applicable Data Protection Laws require that appropriate safeguards are put in place, such transfer shall be subject to the appropriate Standard Contractual Clauses, which shall be deemed incorporated into and form part of this DPA as set forth in Annexure-I.
13. Deletion or Return of Personal Data
Upon termination of Customer’s Account, Fyno may delete all Client Data, including Personal Data in accordance with the procedure set forth in the Agreement. This requirement shall not apply to the extent that Fyno is permitted by applicable law to retain some or all of the Personal Data, in which event Fyno shall isolate and protect the Personal Data from any further processing.
14. Obligations under Privacy Laws in the US
14.1. Notwithstanding anything to the contrary in this DPA, this Section shall apply to the Personal Information of the residents of the State of California, USA. In this section the following terms “Business”, “Service Provider”, “Personal Information”, “Consumers”, “Sell”, and “Share”, shall have the meaning given in the CA Privacy Laws,
- Customer acknowledges and agrees that Customer is the Business and Fyno is the Service Provider with respect to Personal Information of Consumers (as those terms are understood under the CA Privacy Laws) disclosed by Customer to Fyno forming part of Client Data.
- Fyno will not Sell, or Share the Personal Information of Consumers that Fyno processes on Customer’s behalf for providing Fyno Solutions under the Agreement and this DPA.
- Fyno will not retain, use, or disclose Personal Information of Consumers that Fyno processes on Customer’s behalf when providing Fyno Solutions under the Agreement and this DPA for any purpose other than providing Fyno Solutions specified in the Agreement or as otherwise permitted by the CA Privacy Laws.
- Fyno will not combine the Personal Information that is received from or on Customer’s behalf with Personal Information that is received from or on behalf of any other person or persons or from Fyno’s direct interaction with the Consumers except as permitted under the CA Privacy Laws.
- Fyno will delete the Personal Information at Customer’s direction as per a Consumer request for deletion of the Personal Information and will also direct any of the Sub-processor engaged to delete such Personal Information. Fyno shall not directly respond to a Consumer’s deletion request without Customer’s prior authorization unless legally compelled to do so.
- Fyno acknowledges and agrees that Customer shall be responsible for providing the required notice to Consumers with respect to sharing their Personal Information with Fyno.
- Fyno acknowledges that Customer has the right upon notice to take reasonable and appropriate steps to stop and remediate the unauthorized use of the Personal Information.
- During the Term, to the extent that Customer, in Customer’s use of Fyno Solutions, do not have the ability to address a request from Consumers, including a request to delete Personal Information, Fyno shall provide reasonable cooperation to assist Customer to respond to any such requests from individuals Consumers or applicable data protection authorities relating to the processing of Personal Information under the Agreement and/or this DPA when Customer is required to respond to such requests under CA Privacy Laws. In the event that any such request is made directly to Fyno, Fyno shall not respond to such communication directly without Customer’s prior authorization, unless legally compelled to do so.
- Fyno shall notify Customer immediately if Fyno determines that Fyno can no longer comply with the obligations under CCPA.
- Fyno certifies that Fyno understands the restrictions in this Section and will comply with such restrictions.
- The Customer discloses the Personal Information to Fyno solely for (i) valid Business Purpose and (ii) to enable Fyno to Process the Personal Information for providing Fyno Solutions.
- In addition to the other provisions of this DPA, (a) in case of Processing of the Personal Data of the residents of the State of Colorado, Virginia, Connecticut, Oregon, Texas, Utah, Delaware in the USA, Fyno shall provide reasonable assistance to the Customer in meeting its obligations under the applicable Data Protection Laws in relation to the security of Processing the Personal Data and (b) in case of Processing of Personal Data that is linked or reasonably linkable to a Data Subject and that identifies the Data Subject’s past, present, or future physical or mental health status of the residents of (i) the State of Washington, Fyno shall implement appropriate technical and organizational measures to assist the Customer in meeting its obligations under the MHMD and (ii) the State of Nevada, Fyno shall provide reasonable assistance to the Customer in meeting its obligations under the NVSB.
15. Miscellaneous
15.1. In case of any conflict, the provisions of this DPA shall take precedence over the Agreement or provisions of any other agreement with Fyno. In case of any conflict between this DPA and the SCCs, the SCCs shall take precedence over the provisions of the rest of the DPA.
15.2. This DPA shall not apply to the Processing of Personal Data where Fyno is deemed to be the Controller under applicable Data Protection Laws.
15.3. No Party shall receive any remuneration for performing its obligations under this DPA except as explicitly set out herein or in another agreement.
15.4. Where this DPA requires a “written notice” or “written request”, such notice or request can also be communicated per email to the other Party. Notices shall be sent to the contact persons set out in Schedule A.
15.5. Any supplementary agreements or amendments to this DPA must be made in writing and signed by both Parties.
15.6. Should individual provisions of this DPA become void, invalid or non-viable, this shall not affect the validity of the remaining conditions of this DPA.
Annexure I
Standard Contractual Clauses
I. In relation to transfers of Personal Data originating from the EEA and subject to the EU GDPR, the SCCs shall apply, completed as follows:
(i) Module 2 (Controller to Processor) shall apply where the Customer is a Controller and Fyno is a Processor. Module 3 (Processor to Processor) shall apply where the Customer is a Processor and Fyno is a sub-processor;
(ii) in Clause 7, the optional docking clause will apply;
(iii) in Clause 9(a), Option 2 shall apply;
(iv) in Clause 11, the optional language will not apply;
(v) in Clause 17, Option 1 will apply, and the EU SCCs will be governed by Irish law;
(vi) in Clause 18(b), disputes shall be resolved before the courts of Ireland;
(vii) Annex I, II and III of the EU SCCs shall be deemed completed with the information set out in Schedule A, B and C to this DPA respectively; and
II. In relation to transfers of Personal Data originating from the UK or Switzerland and subject to the UK GDPR or Swiss DPA, the EU SCCs as implemented under sub-paragraph (a) above will apply with the following modifications and shall constitute the Swiss SCCs and UK SCC, as applicable:
(i) references to Regulation (EU) 2016/679; shall be interpreted as references to the UK Data Protection Laws or Swiss DPA as applicable;
(ii) references to specific Articles of Regulation (EU) 2016/679; shall be replaced with the equivalent article or section of the Swiss DPA;
(iii) references to “EU”, “Union”, “Member State”, and “Member State law” shall be replaced with references to “Switzerland” or “UK”, “UK Law” “Swiss law” as applicable;
(iv) the term “member state” shall not be interpreted in such a way as to exclude Data Subjects in UK or Switzerland from the possibility of suing for their rights in their place of habitual residence (i.e., UK or Switzerland);
(v) Clause 13(a) and Part C of Annex I are not used and the “competent supervisory” is the UK Information Commissioner or Swiss Federal Data Protection Information Commissioner as applicable;
(vi) references to the “competent supervisory authority” and “competent courts” shall be replaced with references to the “Information Commissioner” or “Swiss Federal Data Protection Information Commissioner” and “the court of England or Wales” or “applicable courts of Switzerland”;
(vii) in Clause 17, the Standard Contractual Clauses shall be governed by the laws of England and Wales or laws of Switzerland as applicable; and
(viii) with respect to transfers to which UK Data Protection Laws apply, Clause 18 shall be amended to state “Any dispute arising from these Clauses shall be resolved by the courts of England and Wales. A data subject may bring legal proceeding against the data exporter and/or data importer before the courts of any country in the UK. The Parties agree to submit themselves to the jurisdiction of such courts” and with respect to transfers to which the Swiss DPA applies, Clause 18(b) shall state that disputes shall be resolved before the applicable courts of Switzerland.
III. In relation to transfers of Personal Data originating from the United Kingdom and subject to the UK GDPR, the UK SCCs are hereby incorporated as an amendment to the EU SCCs and updated to reflect the details as follows:
Part 1: Tables
a. In Table 1 of the UK SCCs, the Parties’ details and key contact information shall be as set forth in Schedule A.A.
b. In Table 2 of the UK SCCs, information about the version of the Approved EU SCCs, modules and selected clauses which this UK SCC is appended to shall be as set forth in I (i), (ii), (iii), (iv) of this Annexure-I.
c. In Table 3 of the UK SCCs:
(i)Schedule A: List of Parties
(ii) Schedule A.B: Description of Transfer
(iii) Schedule B: Technical and organisational measures including technical and organisational measures to ensure the security of the data
d. In Table 4 of the UK SCCs, both the data importer and the data exporter may end the UK SCCs in accordance with the terms of the UK SCCs.
Part 2: Mandatory Clauses
Mandatory Clauses of the Approved Addendum, being the template Addendum B.1.0 issued by the ICO and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as it is revised under Section 18 of those Mandatory Clauses.
IV. For the purposes of descriptions in the SCCs, and the UK SCCs, the Customer agrees that it is the “data exporter” and Fyno is the “data importer”.
V. The Parties agree that if the Standard Contractual Clauses are replaced, amended or no longer recognized as valid under Data Protection Laws, or if a Supervisory Authority and/or Data Protection Law requires the adoption of an alternative transfer solution, the data exporter and data importer will: (i) promptly take such steps requested including putting an alternative transfer mechanism in place to ensure the processing continues to comply with Data Protection Laws; or (ii) cease the transfer of Personal Data and at the data exporter’s option, delete or return the Personal Data to the data exporter.
SCHEDULE A
A. LIST OF PARTIES UNDER THE SCCs
Data exporter(s):
The data exporter is the entity that has subscribed to the Agreement and their contact details are as provided by them while subscribing to the Agreement.
Signature & Date:
By entering into the Agreement, the data exporter is deemed to have signed these SCCs incorporated herein, including their Schedules, as of the Effective Date of the Agreement.
Role: Controller/Processor
Data importer(s):
Name: The Fyno entity that has executed the Agreement with the Customer
Address: Fyno’s address as mentioned in the Agreement
Contact person’s name, position and contact details: Ashwin Aggarwal, ashwin@fyno.io
Activities relevant to the data transferred under these Clauses: As specified in Part B of Schedule A
Signature & Date: By entering into the Agreement, the data importer is deemed to have signed these SCCs incorporated herein, including their Annexes, as of the Effective Date of the DPA.
Role (controller/processor): Processor/sub-processor of data exporter
B. DESCRIPTION OF TRANSFER
Categories of data subjects whose personal data is transferred
Unless provided otherwise by the data exporter, transferred Personal Data relates to the following categories of Data Subjects: data exporter’s customers, data exporter’s users, prospects, data exporter’s employees, data exporter’s admins or other individuals whose Personal Data is transmitted or made available to the data importer by the data exporter in the course of data exporter’s use of Fyno Solutions.
Categories of personal data transferred
The transferred Personal Data concerns the following categories of data:
The data exporter determines the categories of Personal Data which could be transferred per Fyno Solutions as stated in the Agreement. Such categories may include the following categories of data: name, phone numbers, e-mail address, IMEI Number, IP address, and any application-specific data transferred by authorized personnel of the data exporter.
Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.
No Sensitive Personal Information transferred by the data exporter to the data importer. The data exporter shall not disclose (and shall not permit any individual to disclose) any Sensitive Personal Information to the data importer for processing.
The frequency of the transfer (e.g., whether the data is transferred on a one-off or continuous basis)
Personal Data is transferred on a continuous basis during the term of the Customer’s account.
Nature of the processing
Collection, organisation, structuring, storage, retrieval, adaptation, use, disclosure by transmission, dissemination or otherwise making available, or otherwise making available, erasure, or destruction (whether or not by automated means).
Purpose(s) of the data transfer and further processing
Personal Data is transferred in the course of access and use by the data exporter of Fyno Solutions so that the data importer may provide, support, maintain and improve Fyno Solutions.
The data importer may further transfer Personal Data to third-party service providers that host and maintain the data importer’s applications, backup, storage, and other services as specified in the section on sub-processors below. These third-party service providers may have access to or Process Personal Data for the purpose of providing these services to the data importer.
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period
Upon termination of the data exporter’s account, the data importer will delete all Personal Data in accordance with clause 13 of the DPA.
For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing
The details about the processing by the sub-processors engaged by data importer can be accessed at https://trust.fyno.io/subprocessors.
C. COMPETENT SUPERVISORY AUTHORITY
In respect of the SCCs:
Module 2: Transfer Controller to Processor
Module 3: Transfer Processor to Processor
Where the Customer is the data exporter, the supervisory authority shall be the competent supervisory authority that has over the Customer in accordance with Clause 13 of the SCCs.
SCHEDULE B
TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA
Fyno has implemented appropriate technical and organisational measures in accordance with applicable laws. The technical and organisational measures as implemented by Fyno can be accessed through the trust centre at https://trust.fyno.io.
SCHEDULE C
LIST OF SUB-PROCESSORS
Not Used
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