Sub-Processors

Information about sub-processors utilized by Wingify

Wingify Software Pvt Ltd. (“Wingify”, “We”) makes use of selected sub-processors to assist in providing the Services as defined in our Terms & Condition (“Terms”) while ensuring privacy and security as described in our Privacy Policy. Terms used on this page but not defined have the meaning set forth in our Terms.

A sub-processor is a third-party data processor retained by Wingify, who has or potentially will have access to Service data i.e. visitor of Wingify’s Customer’s website or application (which may contain Personal Information) while providing Services on our behalf. We engage different types of sub-processors to perform various functions as explained in the tables below.

We also collects some data from our Customers as outlined in our Privacy Policy as an independent Data Controller.

We uses a commercially reasonable selection process to evaluate the security, privacy and confidentiality practices of such sub-processors.

We act as an independent Data Controller for Customer Account Information, which includes the personal data of VWO application users and customer representatives. However, we act as a Data Processor for all Visitor Data (as defined below) that is processed and stored through the VWO application. 

The list of sub-processors provided below applies to cases where Wingify acts as a Data Processor and the Customer acts as the Data Controller. Accordingly, the third parties mentioned herein serve as sub-processors engaged by Wingify in connection with the processing activities performed on behalf of its customers.

Sub-processors involved in processing of Visitor Data

“Visitor Data” means Personal Data related to the end-user of Customer’s Properties or platform, more specifically as detailed in Annexure 1 to the Wingify DPA.

Due Diligence

Wingify undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of such sub-processors.

Contractual Safeguards

Wingify generally requires such sub-processors to satisfy equivalent obligations required from Wingify as set forth in applicable Data Protection Addendum and Data Protection laws.

Process to Engage New Sub-processors

For all Customers who have executed Wingify’s standard DPA, Wingify will provide notice of updates to the list of sub-processors that are utilized or which Wingify proposes to utilize to deliver its Services. Wingify undertakes to keep this list updated regularly to enable its customers to stay informed of the scope of sub-processing associated with the VWO Services.

Pursuant to the DPA, We shall provide Customers with a minimum of fifteen (15) days’ prior written notice before engaging any new sub-processor. During this notice period, the Customer shall have the right to object to the appointment of such sub-processor on reasonable and legitimate grounds relating to data protection. If the Customer does not raise any objection within the specified notice period, the proposed sub-processor shall be deemed accepted by the Customer.

Updates

Wingify will keep this list updated by adding the names of new or replacement sub-processors.

If you have any questions or concerns regarding our Sub-processor(s), you may write to privacy@vwo.com, and we will try to resolve your concerns.