Third-Party Subprocessors of Personal Data & Location of Processing of Personal Data

Third-Party Subprocessors of Personal Data

Bureau van Dijk, Regulatory DataCorp and PassFort, part of the Moody’s group, use the following third-party service providers, which, depending on the jurisdiction, may qualify as clients’ subprocessors of personal data.

• Amazon Web Services, Inc. (AWS), 410 Terry Avenue North, Seattle, WA 98109-5210 - cloud hosting

• Amazon Web Services, Inc. (AWS), 410 Terry Avenue North, Seattle, WA 98109-5210 - cloud hosting
• WNS Global Services Private Limited, V-Tech IT Park South Block 1st Floor Survey No.113/2, Wadala Road Near Indira Nagar Jogging Track, Nashik, Maharashtra, 422006, India; Gate no 2, Plant 5 Godrej & Boyce Complex, Pirojshanagar, LBS Marg Vikhroli (West), Mumbai, Maharashtra, 422006, India; WestGate Park, H1 Building, 3rd Floor, Preciziei Blvd., no. 24, Sector 6, Bucharest – 062204, Romania – remote customer support (all Review products), and analyst review (for Analyst Review only)
• ServicEngine, Ltd., 111 Bir Uttam CR Dutta Road, Dhaka-1205, Bangladesh - analyst review (for Analyst Review only)

Bureau van Dijk and Regulatory DataCorp, as part of the Moody’s group of companies, have executed data processing terms with the above vendors.

PassFort Products

The applicable subprocessors per client depend on which particular produc(s) and service(s) client takes:

• Microsoft Ireland Operations, Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland - Cloud hosting
• Google Cloud Platform, Gordon House, Barrow Street, Dublin 4, Ireland – cloud hosting
• CreditSafe Business Solutions Limited, Unit 1 H, Block 71, The Plaza, Parkwest Facilities Complex, Nangor Road, Dublin, Ireland - credit reference checks
• Experian, Sir John Peace Building Experian Way NG2 Business Park, Nottingham NG80 1ZZ, UK - identity and address verification
• GB Group PLC (GBG), The Foundation, Herons Way, Chester Business Park, Chester CH4 9GB, UK - identity and address verification
• ComplyAdvantage, LABS House, 15-19 Bloomsbury Way, London WC1A 2TH, UK - PEP & adverse media screening
• Global Data Consortium, Inc. (GDC), 1101 Haynes St Suite 109, Raleigh, NC 27604, United States - international identity and address verification
• Functional Software, Inc. d/b/a Sentry, 45 Fremont Street, 8th Floor, San Francisco, CA 94105 - error tracking within the platform
• Elastic NV, 800 West El Camino Real, Suite 350, Mountain View, California, 94040 - search & filtering capabilities within the platform 

Location of Processing of Personal Data

Data hosting location:

• AWS EU-Central-1 (Frankfurt, Germany)
• AWS EU-West-1 (Dublin, Ireland) (when integrated with Regulatory DataCorp Screening Services)

• Country of client’s location, United Kingdom, United States of America, India, EU Member States, China, Japan, and Singapore.

Data hosting location:

• Americas region: AWS US East 1 (Virginia) as primary, with AWS US West 2 (Oregon) as failover

• EMEA region: AWS EU West 1 (Ireland) as primary, with AWS EU Central 1 (Frankfurt) as failover

• India: AWS AP-South 1 (Mumbai).

Remote access within the Moody’s group for technical assistance and client services:

• Country of client’s location, United Kingdom, United States of America, and Singapore.

Third-party subprocessor locations as above.

PassFort Products

Data hosting location:

• Default: Google Cloud (Belgium data center primary; multi EU disaster recovery)
• On specific client request: Microsoft Azure (UAE)

Remote access within the Moody’s group for technical assistance and client services:

Third-party subprocessor locations as above. 

Bureau van Dijk, Regulatory DataCorp and PassFort, as part of the Moody’s group of companies, have executed EU standard contractual clauses intragroup and with the above vendors.