xcPEP Sub-Processor List and Policy
1. Purpose and Scope
This Sub-Processor List and Policy aims to provide transparency regarding the third-party service providers (Advanced Structures India Private Limited refers to these as "Sub-Processors") who may process customer data on behalf of Advanced Structures India Private Limited in connection with the provision of the xcPEP SaaS platform.
2. Definition of Sub-Processor
A Sub-Processor is any third party engaged by Advanced Structures India Private Limited to process customer data on behalf of Advanced Structures India Private Limited in its role as a data processor for the xcPEP service. This includes entities that store, access, or otherwise process customer data to provide their services to Advanced Structures India Private Limited.
3. Our Commitment to Due Diligence
Advanced Structures India Private Limited exercises rigorous due diligence when selecting and engaging Sub-Processors. Our process includes:
- Security Assessments: Evaluating the Sub-Processor's security measures, certifications (e.g., ISO 27001, SOC 2), and adherence to industry best practices.
- Contractual Agreements: Ensuring that legally binding agreements (e.g., Data Processing Addenda) are in place with all Sub-Processors, obligating them to protect customer data in accordance with our own data protection standards and applicable laws.
- Compliance Checks: Verifying the Sub-Processor's compliance with relevant data protection regulations (e.g., GDPR, local data protection laws).
4. List of Current Sub-Processors
Below is a list of our current Sub-Processors for the xcPEP service. This list may be updated periodically.
Category of ServiceSub-Processor Name(s)Purpose of ProcessingData Location(s) (Primary Region)Cloud HostingAmazon Web Services (AWS)Core infrastructure for hosting xcPEP, data storage, compute, networking.Multiple AWS Regions (e.g., US East, EU (Frankfurt), Asia Pacific (Mumbai)) - Specific region based on customer choice.Internal Productivity ToolsMicrosoftInternal communication and collaboration, may incidentally process some customer contact data.GlobalInternal Productivity ToolsMicrosoft VendorsInternal communication and collaboration, may incidentally process some customer contact data.India5. Notification of New Sub-Processors
Advanced Structures India Private Limited will notify customers of any new Sub-Processors engaged to process customer data by:
- Updating this xcPEP Sub-Processor List and Policy on our Trust Center page.
- Providing direct email notification to designated customer contacts 30 days prior to engaging a new Sub-Processor, allowing time for objection where applicable based on Data Processing Addendum.
6. Contractual Obligations
All Sub-Processors are required to enter into written agreements with Advanced Structures India Private Limited that include data protection clauses, ensuring they provide a level of data protection and security equivalent to that provided by Advanced Structures India Private Limited itself, in accordance with applicable laws.
7. Policy Review and Updates
This xcPEP Sub-Processor List and Policy is regularly reviewed and updated to reflect any changes in our use of third-party service providers.