Why we use sub-processors
Showbie will never sell your Personal Data/PII to third parties and does not engage in any personal predictive profiling.
To support the delivery of our services, to provide customer support, and for the delivery of notifications, Showbie engages with carefully selected sub-processors. These sub-processors have access to certain customer Personal Data in order to perform their tasks.
Prior to engaging any third party, Showbie performs due diligence to assess their privacy, security, and confidentiality practices.When a sub-processor’s services involve transferring Personal Data from customers located in the European Economic Area (EEA) to countries outside the EU/EEA (third countries), Showbie ensures appropriate safeguards - transfer mechanisms – are in place, in accordance with Chapter V of the General Data Protection Regulation (GDPR). These data transfers are made either on the basis of the EU Standard Contractual Clauses (EU SCCs) or under an Adequacy Decision issued by the European Commission, such as the EU-U.S. Data Privacy Framework (DPF).Please review our Transfer Impact Assessment for more information on the transfers of Personal Data to sub-processors relying on EU SCCs.
In addition, we share teacher Personal Data with other teachers through a teacher’s profile and/or newsfeed, depending on the newsfeed privacy settings. We share teacher’s name and school with students and parents.
We share student Personal Data only with that student’s teacher(s) and parent(s) and as expressly described in our Privacy Policy and our COPPA Privacy Policy.
Our sub-processor list
Showbie's current sub-processors, their locations of Personal Data processing and the services they provide are as follows:
Name | Description of the Processing | Location(s) of the Processing | Teacher Personal Data/PII Processed | Student Personal Data/PII Processed | Transfer Mechanism (if relevant) |
Amazon Web Services , Inc.(AWS) | Database hosting - all data and content contained in Showbie is stored in AWS. | The U.S. and Sweden | User Login, User Profile, Class Info, IP Address, School Info, Subscription Info¹ | User Login, User Profile, IP Address, School Info | EU-U.S. Data Privacy Framework (DPF)/ Standard Contractual Clauses (EU SCCs) |
Amazon Web Services,Inc.CloudFront | Content delivery network for application performance improvement. | The U.S. | IP Address, User Profile, Class Info, Filenames² | IP Address, Filenames² | EU-U.S. Data Privacy Framework (DPF)/ Standard Contractual Clauses (EU SCCs) |
ConvertAPI,UAB | File conversion service used for converting files to PDF for use with annotation tools. | The Netherlands | Converted files | Converted files | N/A |
Peaberry Software, Inc.(Customer.io) | Notification service for sending product notifications and business-critical communications. | The U.S. | User Profile, Class Info, School Info | User Profile, School Info, Notification content³ | EU-U.S. Data Privacy Framework (DPF)/ Standard Contractual Clauses (EU SCCs) |
Intercom, Inc. | Product notifications, marketing outreach, and technical support delivery. | The U.S. | User Login, User Profile, IP Address/,School Info, Subscription Info¹ | None⁴ | EU-U.S. Data Privacy Framework (DPF)/ Standard Contractual Clauses (EU SCCs) |
Google LLC(Looker) | Business intelligence tool for surfacing and analyzing user data, and for providing Admin Analytics. | The U.S. and Ireland | User Login, User Profile, Class Info, IP Address/, School Info | User Login, User Profile, Class Info, IP Address/, School Info | EU-U.S. Data Privacy Framework (DPF)/ Standard Contractual Clauses (EU SCCs) |
OpenAI API,Inc | Large language model to analyze text, generate insights, and create content for our AI Feedback feature. | The U.S. | Class Info, Assignment Info, Provided Grade, Provided Feedback⁵ | None | Standard Contractual Clauses (EU SCCs) |
Twilio Inc.(Segment.io) | Collection and transmission of relevant metadata to enable application functionality. | The U.S. | User Login, User Profile, Class Info, IP Address, School Info, Subscription Info¹ | User Login, User Profile, IP Address, School Info | EU-U.S. Data Privacy Framework (DPF)/ Standard Contractual Clauses (EU SCCs) |
Functional Software,Inc.(Sentry) | Application error monitoring to identify application problems and troubleshoot issues. | The U.S. | IP Address, User Profile | IP Address | EU-U.S. Data Privacy Framework (DPF)/ Standard Contractual Clauses (EU SCCs) |
Whereby AS | Video streaming tool. | Ireland | User Profile (display name only) | User Profile (display name only) | N/A |
PubNub, Inc. | Collection and transmission of event data from the application client to the server. | The U.S. | User Login, User Profile, Class Info, IP Address, School Info, Subscription Info¹ | User Login, User Profile Class Info | Standard Contractual Clauses (EU SCCs) |
¹ Subscription Info is only included for teacher users who have a purchase history for individual Pro subscriptions.
² Amazon Web Services, Inc. processes file URLs which may contain Personal Data/PII included in the file name of uploaded content.
³ Peaberry Software Inc. can access Student Personal Data/PII entered in posts that will be shown in email notifications to teachers.
⁴ Intercom, Inc. may access Student Personal Data/PII if students contact customer support directly from our support page (support.showbie.com).
⁵ Provided grade and feedback does NOT include any Student Personal Data/PII, only teacher-generated content.
Definitions
Personal Data: Personal Data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly as defined in the EU/UK General Data Protection Regulation (GDPR)
PII: Personally Identifiable Information as defined in Canada Personal Information Protection and Electronic Documents Act (PIPEDA).
User Profile: First name, last name, email address, profile picture, login credentials
School Info: School name and location
Class Info: Class name, settings, subject and year group
Assignment Info: Assignment name and description
Subscription Info: Subscription plan and term dates
Metadata: Contextual information such as your device type, operating system, activity timestamps
If you have questions about the sub-processors who have access to your Personal Data, please contact us at privacy@showbie.com.