Third-Party Subprocessors
Untitled may engage trusted third-party service providers (“Subprocessors”) to support the delivery, security, and performance of the Platform Services.
This article outlines how subprocessors are used, the safeguards in place, and where clients can review governing contractual protections.
What Is a Subprocessor?
A subprocessor is a third-party service provider engaged by Untitled to process data in connection with providing the Platform Services.
Subprocessors may assist with functions such as:
Cloud hosting and infrastructure
Data storage and security
Analytics and monitoring
Customer support tooling
Communication services
Subprocessors do not receive data for independent use. They process data solely on behalf of Untitled and strictly for the purpose of delivering the Platform Services.
Contractual Safeguards
Untitled’s use of subprocessors is governed by Section 8.4.6 of the Platform Services Agreement.
Under that section:
Untitled may engage third-party subprocessors to assist in providing the Platform Services, provided that: 1. Untitled provides Client with reasonable advance notice of any new subprocessors; 2. All subprocessors are bound by data protection obligations no less protective than those set forth in the Agreement; 3. Untitled remains fully liable for the acts and omissions of its subprocessors.
This ensures that:
Clients are notified of material subprocessor additions
Subprocessors are contractually required to meet equivalent data protection standards
Untitled retains responsibility for subprocessor compliance
Untitled does not transfer liability to subprocessors.
Data Protection Standards
All subprocessors engaged by Untitled are required to:
Process data only under documented instructions
Maintain appropriate technical and organizational security measures
Comply with applicable data protection laws
Enter into written agreements reflecting data protection obligations consistent with the Platform Services Agreement
Where applicable, subprocessors must also support:
Confidentiality obligations
Data minimization
Secure deletion or return of data upon termination
Subprocessor Transparency
Untitled maintains an internal list of active subprocessors supporting the Platform Services.
At the time of writing this article, that manifest includes the following parties:
Prospect Desk
Cookie Enrichment Services Supporting Identity Resolution System (see Cookies & Storage Overview for more details)
United States
Beeswax (Freewheel)
Digital Advertising Ecosystem for the Untitled DSP
United States
Metabase
Internal Data Visualization Reports (may access aggregated platform data)
United States
Posthog
Application Observability & Product Analytics (for platform performance monitoring)
United States
Clients may request the current list of subprocessors by contacting:
Where required by agreement, Untitled will provide reasonable advance notice before engaging new subprocessors that materially impact data processing.
Liability & Accountability
Untitled remains fully liable for:
The acts of its subprocessors
Compliance with contractual data protection commitments
Any breach of obligations arising from subprocessor activity
Engaging a subprocessor does not reduce Untitled’s responsibility to its clients.
Questions
If you have questions regarding subprocessors, data protection safeguards, or contractual provisions, please contact: [email protected]
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