FreeAgent Subprocessors

Version 1.0: This list of subprocessors was produced on 9th May 2018. It may be updated in the future and we'll post the updated version here on our website.

To support delivery of our Service, FreeAgent Central Ltd. (“FreeAgent”) may engage and use data processors with access to certain Service data (each, a “Subprocessor”). This page provides important information about the identity, location and role of each Subprocessor. Terms used on this page but not defined have the meaning set forth in our Terms of Service and/or Standard Framework Agreement (the “Agreement”). Defined terms used herein shall have the same meaning as defined in the Agreement.

What is a subprocessor

A Subprocessor is a third party data processor engaged by FreeAgent who has or potentially will have access to or process Service data (which may contain Personal Data). FreeAgent engages different types of Subprocessors to perform various functions as explained in the tables below.

Due diligence

FreeAgent undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed Subprocessors that will or may have access to, or process, Service data.

Contractual Safeguards

FreeAgent requires its Subprocessors to satisfy equivalent obligations as those required from FreeAgent (as a Data Processor) as set forth in either FreeAgent’s, or the corresponding Subprocessor’s equivalent, Data Processing Addendum (“DPA”), incorporating Standard Contractual Clauses ("SCC") where appropriate, including but not limited to the requirements to:

  • process Personal Data in accordance with FreeAgent’s instructions;
  • 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;
  • implement and maintain appropriate technical and organisational measures (including measures consistent with those to which FreeAgent is contractually committed to adhere insofar as they are equally relevant to the Subprocessor’s processing of Personal Data on FreeAgent’s behalf);
  • promptly inform FreeAgent about any actual or potential security breach; and
  • cooperate with FreeAgent in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.

This policy does not give users of the Service any additional rights or remedies and should not be construed as a binding agreement. The information here is provided for transparency purposes to illustrate FreeAgent’s engagement process for Subprocessors as well as to provide the actual list of third party Subprocessors used by FreeAgent (as of the date of this policy) which FreeAgent may use in the delivery and support of its Service.

Process to engage new subprocessors

As our business grows and evolves, the Subprocessors we engage may also change. We will provide users of the Service with notice of any new Subprocessors to the extent required under the Agreement by posting such updates here.

FreeAgent will provide notice via this policy of updates to the list of Subprocessors that are utilised or which FreeAgent proposes to utilise to deliver its Service. FreeAgent undertakes to keep this list updated regularly to enable users of the Service to stay informed of the scope of subprocessing associated with the Service.

Please check back frequently for updates.

The following is an up-to-date list (as of the date of this policy) of the names and locations of FreeAgent Subprocessors.

Infrastructure Subprocessors – Service Data Storage

FreeAgent owns and controls access to the physical infrastructure that FreeAgent uses to host Service data submitted to the Service, other than as set forth below. FreeAgent production systems for the Service are located in co-location facilities in the United Kingdom. FreeAgent may use the following Subprocessors to host Service data or provide other infrastructure that helps with the delivery of the Service.

Entity Name Subprocessing Activities Country(ies) Adequacy
The Bunker Data centre colocation (no access to Service data) UK ISO 27001
OVH Data centre colocation (no access to Service data) France ISO 27001
Amazon Web Services, Inc. Cloud service provider United States;
United Kingdom;
Ireland
GDPR Link
ISO 27001
Privacy Shield
DPA with SCC
Google, Inc. Cloud service provider United States GDPR Link
ISO 27001
Privacy Shield
DPA with SCC
Datto, Inc. Cloud storage provider United States GDPR Link
SOC II
Privacy Shield
DPA with SCC

Other Subprocessors

FreeAgent works with certain third parties to provide specific functionality around and within the Service. These providers are the Subprocessors detailed below. In order to provide the relevant functionality, we may transfer Service data to these Subprocessors. Their use is limited to the indicated activities.

Entity Name Subprocessing Activities Country(ies) Adequacy
Salesforce Customer management services United Kingdom ISO 27001
DPA
Drip Automated email and marketing services United States DPA with SCC
ZenDesk Customer support services United States GDPR Link
ISO 27001
DPA with SCC
Typeform Online surveys United States;
Germany
GDPR Link
Privacy Shield
DPA with SCC
FormAssembly Web form and survery generation United States GDPR Link
Privacy Shield
DPA with SCC
Teleware Call recording for QA of incoming support calls United Kingdom ISO 27001
Moneypenny Automated answering service for inbound support calls United Kingdom DPA

FreeAgent does not store payment card information. Payment processing is handled directly by the following third parties according to their respective Privacy Policies and Terms of Service.

Entity Name Subprocessing Activities Country(ies) Policy
Stripe Outsourced payment management United States; Europe Privacy Policy
Paypal Outsourced payment management United States;
Europe
Privacy Policy
GoCardless Outsourced payment management Europe Privacy Policy

Company Contact

FreeAgent
One Edinburgh Quay
133 Fountainbridge
Edinburgh
Scotland United Kingdom
EH3 9QG