A subprocessor is a third-party vendor that provides services for Lyyti, who has or potentially will have access to or process personal data. Lyyti engages different types of vendors to perform various duties.
Lyyti uses commercially available measures to evaluate potential and current subprocessors. All subprocessors need to have sufficient security, privacy, and confidentiality measures in place to act as subprocessors.
Subprocessor
Upcloud Oy
Google Cloud Platform From the beginning of July 2022
Mailjet S.A.S
LINK Mobility Oy
Aiven Oy
Fiarone Oy
Virnex Oy
Type
Cloud Service Provider
Cloud Service Provider
Email Gateway Provider
SMS Gateway Provider
Database Services
Security monitoring, and security information and event management (SIEM)
Bank Connectivity Service (only for the Finnish customers)
Location of processing
EU/EEA, Finland
EU/EEA, Finland
EU/EEA, France, Germany, Belgium
EU/EEA, Finland
EU/EEA, Finland
EU/EEA, Finland
EU/EEA, Finland
Lyyti will keep the personal data processing in the EU/EEA area. Processing locations will be Finland (Google, Upcloud, LINK Mobility, Fiarone, Aiven, and Virnex), Germany (Mailjet), and Belgium (Mailjet).
We wanted to modernize our operating infrastructure and utilise the public cloud for hosting. Google Cloud Platform offers capabilities that would be time-consuming, even impossible, to build and operate by ourselves. Scalability, security, and maintainability are requirements that Google Cloud Platform fulfills well. Amazon’s AWS and Microsoft Azure were options as well and the decision to choose Google Cloud Platform was influenced by the fact that Google operates one of their data center facilities in Finland.
We utilize Google Cloud Platform’s technical capabilities to ensure that the data is kept inside EU/EAA at all times. Google Cloud Platform is offered in geographically delimited regions that control where the services are run and data stored physically. We will utilize the option to enforce data residency to the EU/EAA region for the services run. The main processing and data storage location will be Google Cloud Platform facilities in Finland.
Lyyti is always responsible for the work of the subprocessors as it is for its own work. Lyyti has written agreements with every subprocessor.
Subprocessors are responsible to keep all the data they process confidential, even after the agreement has ended.
