What is a Sub-Processor?
A sub-processor is a third party engaged by a data processor to perform specific processing activities on behalf of a data controller. In the context of data protection and privacy regulations, such as the General Data Protection Regulation (GDPR), the following roles are defined:
- Data Controller: The entity that determines the purposes and means of processing personal data.
- Data Processor: The entity that processes personal data on behalf of the data controller.
- Sub-Processor: Any third party that the data processor uses to assist in processing the personal data.
In our case, in connection with ZeroBounce’s services such as email validation and list cleaning, a ZeroBounce customer (who acts as a data controller) outsources its data processing to a service provider (data processor - ZeroBounce). The service provider then hires another company (sub-processor) to perform some specialized task, like data storage. That third company becomes a sub-processor.
Under laws like the GDPR, data processors are required to obtain the controller's authorization before engaging sub-processors. Also, they must ensure that sub-processors adhere to the same data protection obligations as the original processor.
Due Diligence
ZeroBounce is committed to conducting thorough due diligence when engaging with third parties, ensuring that they are assessed prior to onboarding and as part of our annual risk management program.
We hold our service providers to strict contractual obligations, requiring them to process personal data solely for the purpose of delivering services to ZeroBounce. These contracts ensure that service providers comply with our commitments to ZeroBounce customers and adhere to applicable data protection laws.
List of Sub-processors
Sub-processors involved in processing customer registration data
| Name | Exchanged data | Purpose |
|---|---|---|
| LinkedIn Ads | email address and cookie tracking data | ad placement |
| Google Ads | email address and cookie tracking data | ad placement |
| Microsoft | email address and cookie tracking data | ad placement |
| Meta | email address and cookie tracking data | ad placement |
| Copper CRM | email address | marketing aggregator |
| Zapier | email address | marketing aggregator |
| LemList | email address | marketing aggregator |
email address | Central repository and ZeroBounce’s communication platform; also used in the limited instance where a customer attaches an email list in conjunction with a request for support. | |
| Zendesk | email address | Customer service ticketing and communication; also used in the limited instance where a customer submits a request for support using our chat function/form |
Sub-processors involved in the email validation process
| Name | Exchanged data | Purpose |
|---|---|---|
| Cloudflare | email address | Perimeter security, Web application firewall (WAF). Customer email addresses will be logged only in the case of API validation calls if the customer exceeds the technical recommendation of product usage (e.g., sending request limits, IP violations, etc.) |
Cloudflare - email address, purpose: perimeter security, web application firewall. Customer email address will be logged only in case of API calls validation if the client exceeds technical recommendation of product usage (e.g., sending request limits, IP violations etc.).
List of Service Providers
ZeroBounce works with the service providers listed below for email validation service delivery.
| Name | Purpose of processing | Exchanged data | Entity country |
|---|---|---|---|
| Okta | identity management provider | email address | US |
| Stripe | payment gateway | cardholder data | US |
| PayPal | payment gateway | cardholder data | US |
| M247 | infrastructure hosting provider | none | EU |
Updates to this page
Given the global scope of our business and the large number of customers we serve, our business needs and service providers may change periodically.
For instance, we may discontinue a service provider to streamline and reduce the number of providers we use or add a new service provider if it improves our ability to deliver our email validation service.
We will regularly update this page to reflect any changes, including the addition or removal of service providers or sub-processors.