Frends Authorized Subcontractors

Frends Technology (“Frends”) uses certain subcontractors to assist it in providing the Frends Platform and related Professional Services as described in the Agreement concluded between Frends and customer identified in the Agreement (“Customer”).

In the event that Frends processes Customer’s Personal Data in connection with the provision of the Frends Platform and related Professional Services, and in the event that the subcontractors engaged by Frends have or potentially will have access to such Personal Data, these subcontractors shall act as sub-processors of the Personal Data of Customer, as stipulated in the GDPR.

The purpose of this document is to list the authorized subcontractors of Frends who may take part in the provision of the Frends Platform and related Professional Services under the Agreement, and to outline the principles, procedures and conditions pursuant to which these subcontractors may act as sub-processors of Frends in relation to the Personal Data of Customer. Frends reserves the right to update this document and the information provided herein from time to time at its sole discretion. Frends shall inform Customer of any such updates without undue delay.

1. Subcontractors acting as Sub-Processors

When acting as a data processor (as defined in the GDPR) of Customer’s Personal Data in connection with the provision of the Frends Platform and related Professional Services, Frends may delegate some aspects of the processing to another processor, a “sub-processor”, who shall be either an Affiliate of Frends or an unaffiliated third party.

Frends engages different types of subcontractors to perform various functions as explained in the table below in Section 3. Third parties used to provide the services specified in the Agreement who do not have access to or process Personal Data of Customer shall not be considered sub-processors of Frends as stipulated hereinabove.

2. Due Diligence

Frends undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed subcontractors that will or may have access to or process Customer’s Personal Data. Frends has also executed a data processing agreement with each of its subcontractors acting as sub-processors of Frends, by which said subcontractors are committed to the processing of Personal Data in accordance with the GDPR and other applicable privacy laws and regulations.

3. List of Authorized Subcontractors

Frends Affiliates (including Frends Sweden AB, as well as other Affiliates appointed by Frends from time to time) may act as subcontractors of Frends under the Agreement and as sub-processors for Customer’s Personal Data processed in connection with the provision and use of the Frends Platform.

In addition, Frends uses as its subcontractors certain unaffiliated third parties to perform specific processing functions related to its services. These unaffiliated third-party providers are the subcontractors set forth below:

Notwithstanding anything to the contrary in the Agreement or any other document executed between the Parties or provided by Frends, the processing of Customer’s Personal Data conducted by an unaffiliated third-party subcontractor of Frends shall always occur solely and exclusively subject to the data processing terms and conditions issued by the third-party provider in question.