Last Modified: September 16, 2024
PLEASE READ THESE TERMS CAREFULLY
Our Eco Toreda Regional Data Hosting Policy ("Policy") explains where Customer Data will be hosted by Eco Toreda. This Policy sets out our commitment to hosting Customer Data in a specific location and the exceptions to that commitment.
If your Order Form does not indicate a data hosting location, your Customer Data will be stored in the United States of America (“USA” or "United States").
Any terms not defined in this Policy will have the same meaning as set out in the Eco Toreda Customer Terms of Service. In the event of a conflict between this Policy and the Agreement, this Policy will control. We may periodically update this Policy. We will post any changes on this page and, if the changes are material, we will provide an update through the notification app in your Eco Toreda account.
1.1 Definitions
"Location" means the region or geographic area where your Customer Data is primarily stored within our cloud infrastructure (e.g., North America, Europe, etc.). The location will be indicated on your Order Form and in your Eco Toreda account. If no Location is specified in your Order Form your Customer Data is hosted in the USA.
"Exclusions" means the services and processing not covered by Regional Data Hosting Policy and which will continue outside of the Location, as described in the ‘Exclusions’ section below.
1.2 If you are located in Europe (including Switzerland and the United Kingdom), Russia, the Middle East and Africa (based on your IP address on sign up) we will store Customer Data within the Location for the duration of your Subscription Term in accordance with the terms of this Policy. You agree that for the purposes of the DPA, this Policy constitutes your Instructions in relation to the storage of Customer Data. The Location will be indicated on your Order Form. If no Location is specified in your Order Form your Customer Data will be hosted in the USA. Your Location will also be indicated in your Eco Toreda account. Your Customer Data will be replicated for disaster recovery and back-up purposes to other data centers within the Location.
1.3 You understand and agree that while Customer Data will be primarily stored and processed in the Location: (i) Eco Toreda International, Inc. is located in the USA and certain storage and processing may continue outside of the Location, including in the USA and other regions where we, our Affiliates and Sub-processors operate; (ii) we may change Sub-processors in order to provide the Subscription Service, in accordance with the DPA; (iii) Customer Data may be accessed outside of the Location if Users accessing the Marketplace Service are located outside of Europe; (iv) except as otherwise agreed only Customer Data that was submitted or collected after Regional Data Hosting was included as part of your subscription will be stored in the Location; and (v) we make no warranty that Regional Data Hosting will meet your data residency requirements. Regional Data Hosting does not apply to the Exclusions, see the ‘Exclusions’ section below for further information.
2.1 Eco Toreda International, Inc. is located in the USA and certain storage and processing may continue outside the Location, including in the USA and other regions where Eco Toreda, its Affiliates and Sub-Processors operate. Customer Data may be transferred and/or accessed outside the Location for the following Exclusions:
(i) Customer and Product Development Support: In order to provide customer support and product development support, Eco Toreda employees from other office locations and Sub-Processors may access your Eco Toreda account and Customer Data. For example, we may access your Eco Toreda account if you call Eco Toreda Support and have a question about how to use a certain feature or to fix a bug.
(ii) Security and Abuse Prevention: Eco Toreda employees from other office locations may access your Eco Toreda account and Customer Data to investigate or remediate security incidents and/or product abuse.
(iii) Integrations: If you choose to use integrations that process Customer Data, those integrations may process and/or store Customer Data in locations other than the Location. Before installing integrations, you should investigate how data is being passed to these integrations and where the data will be stored and/or processed. You are responsible for any integrations you use in conjunction with your Eco Toreda account.
(iv) User Access: Your Users may log in to your Eco Toreda account from areas outside of the Location. This means that data may be accessed and transferred from the User’s location. User access is your responsibility.
(v) Usage Data: As described in the ‘Customer Data’ section of the Customer Terms of Service, we may collect data about how you use and interact with the Marketplace Service. This usage data will be transferred from the Location to the USA.
(vi) Sub-Processors: Eco Toreda uses Sub-Processors to provide the Subscription Service and Consulting Services. These Sub-Processors may process Customer Data (which may contain Personal Data). As a Eco Toreda Customer, your Customer Data will be stored and processed by these Sub-Processors within the Location, except for those listed in the table below.
You can review the list of Sub-Processors in Annex 3 of the DPA. You may choose to not use certain features or integrations supported by the Sub-Processors included in the table below. If you wish to use the features or integrations supported by these Sub-Processors, you acknowledge your Customer Data will be processed and/or stored outside of the Location.
Service: OpenAI, LLC
Purpose: Eco Toreda AI Products
Description: Used for Eco Toreda AI Products. If you do not choose to use AI Products, no Customer Data will be accessed by this Sub-Processor.
Hosting Region: United States
Service: Twilio, Inc.
Purpose: SMS Functionality
Description: You can choose to not subscribe toSMS notifications to avoid this Sub-Processor having access to Customer Data.
Hosting Region: United States