List of Ethico Sub-Processors

Name: LionBridge Technologies, LLC
Address: 1050 Winter Street, Suite 2300, Waltham, MA 02451, United States of America
Subject matter: To provide assistance, if requested or needed, on translation from native language into English.
Nature of Processing: Providing translation services in real time
Duration of Processing: Only for this time period required for the call

Name: Propio LS, LLC
Address: 10801 Mastin St # 550, Overland Park, KS 66210, United States of America
Subject matter: To provide assistance, if requested or needed, on translation from native language into English.
Nature of Processing: Providing translation services in real time
Duration of Processing: Only for this time period required for the call

Name: Microsoft Corporation (dba Azure)
Address: Microsoft Corporation One Microsoft Way Redmond, WA 98052-6399, United States
Note that Microsoft Ireland Operations Limited is Microsoft’s data protection representative for the European Economic Area and Switzerland. The privacy representative of Microsoft Ireland Operations Limited can be reached at the following address: Microsoft Ireland Operations, Ltd., Attn: Data Protection, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland.
Subject matter: To provide a backup of Ethico’s data.
Nature of Processing: To ensure business continuity
Duration of Processing: Information is repeatedly replaced until a client off-boards
Additional Information on Azure: Microsoft Azure data centres host the infrastructure used in the processing of data. Microsoft Azure personnel have no access to unencrypted data – only the computing resources used by the Data Processor.

Name: Five9, Inc.
Address: 3001 Bishop Drive, Suite 350, San Ramon, CA 94583, United States of America
Additional Information on Ada: Five9 is a cloud-based software company that provides a platform for managing contact centers, essentially allowing businesses to handle customer interactions through phone calls, chat, email, and other channels, all within a single, scalable system.
Subject matter: Phone numbers and other similar information
Nature of Processing: To allow the call center to handle a large number of calls and other similar input
Duration of Processing: While a client is with Ethico

Name: Trailant Operating, LLC
Address: 1600 Rosecrans Avenue, Manhattan Beach Studios, 4th Flr. Media Center, Manhattan Beach, CA 90266, United States
Additional Information: This sub-processor provides a Learning Management System (LMS) offered on behalf of Ethico, including Online Training Programs and Training Administration Tools, on its own platform. Information collected and processed includes names, email addresses, and information about the training completed by each employee (e.g., type of training and date of completion).
Subject matter: Information related to the client’s required training
Nature of Processing: What training was taken, for how long, responses, etc.
Duration of Processing: Ethico does not have control over how long Traliant keeps its training. We recommend visiting Traliant and viewing its privacy policy for more information. Ethico retains no information from Traliant’s training program, even initially.

Name: Ada Support Inc.
Address: 314-371 Front St W, suite 314 Toronto, Ontario M5V 3S8, Canada
Additional Information: This sub-processor is only used if a client elects to set up a chatbot as an additional reporting method. Information collected would be similar to what individuals would report during a hotline call or via MyCM. Clients who wish to utilize the chatbot feature can visit Ada’s Privacy Policy to learn more about their data protection practices.
Subject matter: Whatever someone places in the chatbot
Nature of Processing: Information provided in the chatbot
Duration of Processing: Ethico does not have control over how long Ada keeps its chatbot conversations. We recommend visiting Ada and viewing its privacy policy for more information. Ethico retains information as long as the client continues to be a client of Ethico’s.