Version 1.0 · as at [DATE]
Below is a list of other data processors that TREJKA Sp. z o.o. uses when providing services to clients who have entrusted us with the processing of their personal data on the basis of entrustment agreements.
Each sub-processor processes data solely in relation to the service concerned and on the basis of a contract ensuring a level of data protection at least equivalent to that required under our data processing agreement. A sub-processor processes a particular customer’s data only when that customer is using the relevant service.
Coprocessors
| Entity | Service / purpose | Applies to services | Data location | Basis for transfers outside the EEA |
|---|---|---|---|---|
| [NAME OF CLOUD PROVIDER e2, registered office] | off-site storage of backups (on-premises storage) | backups, WordPress maintenance, IT support | European Union [region] | not applicable – data within the EEA |
| G DATA CyberDefense AG, Bochum, Germany | centralised management of workstation antivirus protection | IT support | European Union (Germany) | not applicable – data within the EEA |
| [NAME OF HOSTING/SERVER PROVIDER: TREJKA, registered office] | servers on which the client panel, monitoring and reporting systems run | all services | [country] | [Not applicable / SCC / DPF] |
| [Microsoft 365 / Google Workspace Copy Tool, Head Office] | copying email inboxes, calendars and contacts | backup of company email | [country] | [Not applicable / SCC / DPF] |
| [REMOTE SUPPORT TOOL, head office] | remote access to workstations in order to provide assistance | IT support, remote assistance | [country] | [Not applicable / SCC / DPF] |
| [TREJKA E-MAIL SERVICE PROVIDER, registered office] | correspondence with customers, handling enquiries | all services | [country] | [Not applicable / SCC / DPF] |
| Cloudflare, Inc., San Francisco, USA [please confirm whether this applies to clients’ websites] | content delivery network (CDN), protection against attacks and an application firewall for clients’ websites | WordPress maintenance (if enabled) | worldwide, including the US | EU-US Data Privacy Framework, standard contractual clauses |
| CleanTalk [please confirm the organisation and whether this applies to client websites] | protecting forms and comments from spam | WordPress maintenance (if enabled) | [country] | [SCC / DPF] |
TREJKA’s own infrastructure
We provide some of our services using our own infrastructure, which does not constitute a further outsourcing arrangement:
- TREJKA Backup Centre in Białystok – backups stored on servers owned by TREJKA in Poland.
- TREJKA’s proprietary plugins (WP Admin Helper, WP Backup, WP Monitor, WP Report, WP Shield) – these operate on clients’ websites and transmit data to TREJKA’s systems, without the involvement of third parties.
- QNAP servers at the client’s premises – the customer’s devices that we configure and manage.
Services for which the customer has a direct contract
Suppliers with whom the customer has entered into a contract independently – e.g. the hosting provider for the customer’s website, Microsoft 365 or Google Workspace on the customer’s account, or the payment processor for the online shop – are not our sub-processors. These are the customer’s own suppliers, and their data protection policies are governed by the customer’s contract with the relevant supplier.
Changes to the list
We shall notify customers by email of our intention to add or replace a sub-processor at least 14 days before the change takes effect. During this period, the client may raise a justified objection in accordance with the terms set out in § 4 of the data processing agreement. Previous versions of this list are available in the document archive.
Enquiries regarding sub-processors: Bartosz Stępniewski, well****@****ka.com, +48 695 423 811.
