The following document provides an overview of the subprocessors of the Fenergo Platform, and other non-Fenergo Limited parties that support the Fenergo Platform and related services.
Definitions
The capitalised terms used in this document are as defined in the subscription agreement. To the extent these terms are not defined in the relevant customer agreement, the following terms and definitions shall apply to this document.
- Customer Personal Data is Personal Data received by Fenergo, acting as a data processor, from or on behalf of the customer in connection with the Fenergo Platform.
- Fenergo Platform means the Fenergo Client Lifecycle Management product(s) described in the order form and subscribed to by the customer in accordance with the subscription agreement.
- Relationship Data is Personal Data processed in support of the administration of the Fenergo Platform provided under the Agreement, including client engagement and customer support.
- Subprocessor is a third-party data processor engaged by Fenergo, including entities from the Fenergo Group, that processes Customer Personal Data on behalf of our customers as data controller or data processor in relation to its obligations under the subscription agreement.
Notification Service
Fenergo maintains and regularly updates this list of approved third parties used in connection with the Fenergo Platform. By signing up via our webform, you will receive email notifications whenever changes are made to the list.
Fenergo Limited Affiliates
Services provided by Fenergo may include professional services, engineering support and / or customer support provided by one or more of the following affiliates of Fenergo Limited.
| Entity | Location(s) | Purpose | Applicable Service(s) | Types of Personal Data Processed |
|---|---|---|---|---|
| Fenergo Greece | Greece | Engineering support function | Fenergo SaaS | Relationship Data (i.e., name, email, contact number), Customer Personal Data*(*Explicit customer approval required) |
| Fenergo Netherlands B.V. / Fenergo Sentinels B.V. | Netherlands | Engineering support | Fenergo SaaS | Relationship Data (i.e., name, email, contact number), Customer Personal Data*(*Transaction Monitoring only / Explicit customer approval required) |
| Fenergo Spain, S.L | Spain | Engineering support function | Fenergo SaaS | Relationship Data (i.e., name, email, contact number) |
| Fenergo Inc | United States | Customer support & professional services | Fenergo SaaS | Relationship Data (i.e., name, email, contact number) |
| Fenergo Canada Limited | Canada | Customer support & professional services | Fenergo SaaS | Relationship Data (i.e., name, email, contact number) |
| Fenergo UK Limited | United Kingdom | Customer support & professional services | Fenergo SaaS | Relationship Data (i.e., name, email, contact number) |
| Fenergo PTY Limited | Australia | Professional services, customer support and engineering support | Fenergo SaaS | Relationship Data (i.e., name, email, contact number) |
Hosting, Infrastructure and Other Service Providers
Delivery and support of the Fenergo Platform may involve the following third parties.
| Entity | Data Location(s) | Purpose | Applicable Service(s) | Types of Personal Data Processed |
|---|---|---|---|---|
| Amazon Web Services EMEA SARL | Customers select their AWS region: US, Canada, EU, Singapore, UAE, or Australia. | Critical cloud hosting and platform services | Fenergo SaaS | Customer Personal Data |
| Elasticsearch BV | EU or US, based on selected AWS region | Search engine | Fenergo SaaS*(*Applicable only when Transaction Monitoring is purchased) | Customer Personal Data |
| Okta Inc. | EU, US or Australia based on selected AWS region | Identity provider as a service | Fenergo SaaS*(*Applicable only when the Fenergo portal is purchased) | Customer Personal Data*(*User authentication profile only) |
| Sinch AB | EU or US, based on selected AWS region | Platform specific email notifications (Mailgun) | Fenergo SaaS*(*Applicable where email notifications are in use) | Customer Personal Data*(*Business contact information & content of the email notification) |
| Atlassian (Jira) | Data hosted in multiple locations*(*US, Canada, EEA, UK, AU, Brazil, Singapore, South Korea, India, Japan) | Customer support ticketing platform | Fenergo SaaS | Relationship Data (i.e., name, email, contact number) |
| Gainsight | EU | Product experience platform (analytics and adoption) | Fenergo SaaS | Usage data (i.e. Unique IDs) |
| Trustwave Holdings | EU*(*Trustwave employees operate out of Canada, US and EU but the data is stored in the EU) | Security monitoring and advanced threat detection | Fenergo SaaS | Service logs (including IP addresses) |
| Microsoft | EU | Security monitoring tools (*On roadmap, not yet live) | Fenergo SaaS | Service logs (including IP addresses) |
| Intercom | EU | Customer facing conversational AI assistant*(*On roadmap, not yet available) | Fenergo SaaS | Relationship Data*(i.e., name, email, contact number) (*No Customer Personal Data should be included in prompts) |
| OpenAI | US | Platform specific feature (Early warning) (*On roadmap, not yet available) | Fenergo SaaS*(*Opt-in & applicable only where the early warning feature is used) | Customer Personal Data*(*Legal entity details – data will not be stored) |
Staff Augmentation
Fenergo personnel may include individuals supplied by the following third parties to augment customer support, engineering support, and/or professional staff. These individuals work under Fenergo’s direct control and supervision. Relationship Data, where accessed or processed by such individuals, is handled solely under the control of Fenergo and in accordance with its security & privacy policies. No services are subcontracted to these third parties unless expressly agreed in writing in advance with the customer.
| Entity | Location(s) | Purpose |
|---|---|---|
| Luxoft Global Operations GmbH | India | Staff augmentation (Customer support & professional services) |
| CSHARK Sp. z o.o. | Poland; Portugal | Staff augmentation (Customer support, engineering support & professional services) |
| Kaha Management Pty Limited | South Africa; Canada; US | Staff augmentation (Customer support & professional services) |
| Mirai Services Pty Ltd | Australia; India | Staff augmentation (Customer support & professional services) |
| Nuby Technology Private Limited | India | Staff augmentation (Software development) for the Salesforce Application only |
| Deloitte | Ireland | Staff augmentation (Professional services) |
| IT Ironworks | Poland | Staff augmentation (Professional services) |
| NS IT Solutions | India | Staff augmentation (Professional services) |
| Remote.com | Portugal | Staff augmentation (Software development) |
Compliance Obligations
Fenergo ensures that all third parties supporting the Fenergo Platform and related services adhere to obligations that align with applicable regulatory requirements. As part of its due diligence and oversight processes, Fenergo requires these third parties to:
- Process Customer Personal Data strictly in accordance with the documented instructions of the data controller (i.e., Fenergo's clients), and in compliance with applicable data protection laws.
- Engage only personnel who are reliable and are subject to contractually binding obligations regarding data privacy and information security, to the extent required by applicable law.
- Provide ongoing training in information security and data protection to all relevant personnel.
- Implement and maintain appropriate technical and organizational measures to ensure the security, confidentiality, and integrity of personal data at a standard no less protective than the measures to which Fenergo is contractually committed.
- Promptly notify Fenergo of any actual or suspected personal data breach or security incident.
- Cooperate fully with Fenergo in responding to any inquiries or requests from data controllers, data subjects, or competent supervisory authorities, as applicable.
Fenergo remains fully responsible for the acts and omissions of any subcontractors and subprocessors it uses connection with its services.
Submitting an Objection
Unless otherwise agreed in writing, a customer may object to changes within thirty (30) days following updates to this list. You may submit an objection by emailing:
Use the subject line “Third-party objection”, along with your name, your company’s name, name of the third-party and grounds for objection.