Here are our terms in plain English:

This update to our terms and conditions is effective from 24 May 2018.

When we briefed our legal team in early April 2018, about an update to our terms and conditions, this is what we wanted to say.

  1. We need to update our terms and conditions in line with the new GDPR regulations
  2. We need to make sure that our customers understand that we (Websand) are providing them with a data processing platform, they act as the data controller so they are responsible for the gathering of consent (processing and marketing) of the audience data they upload into their Websand platform.
  3. We also need them to understand that we use some other suppliers as part of our offering (they are called sub-processors), namely, AWS, Braintree, GoCardless, SendGrid and Stripe.
  4. Of course in the case of running our business, we (Websand) act as both the data controller and processor of the data we collect about them (our customers), that’s their personal, business and the financial history of our dealings).
  5. Unless we have a direct and separate contract with you, our agreement is a rolling 30 day agreement.  Payment will be taken based on the size of your audience (the number of email addresses held in Websand).
  6. Any emails that unsubscribes or bounce will be suppressed, and no longer included in any of your future marketing
  7. We don’t own your data.  Should you ever wish to leave, your data will be returned or destroyed (your decision on that one)
  8. We will monitor your data to ensure system performance, and make sure you are following email best practice (no spamming)
  9. We expect you to adopt and use email best practice at all times.  That means be respectful with your email marketing, and always get people to opt in at the point of signup.  We follow the DMA code of conduct and we are registered with the ICO.
  10. Our users are responsible for their own GDPR compliance, if they need help, we will help them all we can.
  11. Finally, we are a business, so if you don’t pay, we will take it away. In that event, we will destroy your data.

 

They noted this down, took a deep breath and a few weeks later responded with the following…

Here’s the full legal version

These general terms of business (the “General Terms of Business”) apply to the delivery of services by Websand to a client pursuant to the agreement for the supply of services (“the Supply Terms”) to which these General Terms of Business are annexed.

  1. Definitions
    1. The meanings of the following words and phrases which are widely used in these General Terms of Business shall be as set out below: “Agreement” means the Supply Terms and these General Terms of Business together with any documents or other terms applicable to the Services (“Additional Terms”) to which specific contractual reference is made in the Supply Terms;“Websand” or “we” “us” or “our” means Websand Limited (incorporated in England and Wales as a limited liability company under the Companies Act 2006 with registered number 07313735);“Customer” and “you” (and derivatives) means the Customer (or Customers) identified in the Supply Terms and, in respect of any Customer that shall be a company, it shall be deemed to include any new holding company of the company;“Other Beneficiaries” means any and each person or organisation identified in the Supply Terms (other than you) as a beneficiary of the Services and any product thereof;“Renewal Date” means the business day, 30 days following the date of this Agreement and thereafter the anniversary of such date in each year of this Agreement;“Renewal Term” a month period (or lesser period in the event of termination under the provisions of clause 6) commencing on a Renewal Date and expiring on the business day prior to the next Renewal Date and each subsequent month thereafter; “Services” means the on-line database tool service to be licensed to the Customer further specified in the Part I of the Agreement and provided through the Websand ‘instance’ together with such other services as we shall agree to provide during the term of this Agreement.“Instance” means the software operated by the Websand.Data Protection Legislation” [until 25 May 2018, the national laws implementing the Data Protection Direction 95/46/EC and then, on and from 25 May 2018:]  (i) unless and until GDPR is no longer directly applicable in the UK, GDPR and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998;GDPR” the General Data Protection Regulation (EU) 2016/679;“Standard Contractual Clauses” the standard contractual clauses for the transfer of personal data to processors established in third countries which do not ensure an adequate level of protection, as set out in Commission Decision C(2010) 593, as updated, amended or superseded from time to time;
    2. Words and expressions defined in the Supply Terms shall, except where otherwise provided or expressly defined above, have the same meaning in these General Terms of Business and those provisions of the Agreement dealing with construction or interpretation shall, except where otherwise provided, apply as if expressly set out herein.
    3. The Supply Terms shall set out the Services to be delivered by us and associated matters. These General Terms of Business shall be subject to variation if required in the Supply Terms.
    4. The commencement of the Services is from the date you first instructed us to provide services to you. These General Terms of Business override any prior agreement or any terms and conditions or similar provisions contained or referred to in any correspondence between us or any course of dealing between us.  All future dealings between us shall be on these General Terms of Business unless otherwise expressly agreed by us in writing.
    5. Each term (or part of a term) in these General Terms of Business shall be construed separately.  If any part of these General Terms of Business is unenforceable or invalid, that shall not affect the validity or enforceability of any of the other General Terms of Business.
    6. Unless otherwise agreed in writing you alone will be our client and your subsidiaries, shareholders and directors will not be considered to be our client.
    7. We will only provide the Services to the directors of the Customer in their capacity as directors and not in their capacity as shareholders in the Customer.  We will not represent any other party in the matter unless we specifically agree to do so in writing.
    8. Unless otherwise agreed in writing by us, these General Terms of Business shall apply to the exclusion of any terms and conditions stipulated or referred to by the Customer or any inconsistent terms and conditions implied by law or trade custom or course of dealing.
    9. These General Terms of Business may not be varied, amended or extended except by each of us in writing.
  2. Our Charges
    1. We shall render invoices in respect of the Services comprising fees, expenses, disbursements, outlays and VAT thereon (where appropriate) (“our Charges”). Details of our Charges and any special payment terms are set out in the Supply Terms. Our Charges may differ from estimates or quotations, which shall be provisional only.
    2. In return for the delivery of the Services by us, you shall pay our Charges on presentation of our invoice or at such other time as may be specified in the Supply Terms.
    3. We reserve the right to charge interest at the rate of 12% per annum on outstanding balances (this rate applying after as well as before any court award or judgment in our favour in respect of outstanding balances).
    4. In the event you dispute our Charges, you shall promptly notify us as to the amount of such Charges you consider to be in dispute and pay the balance of any undisputed amount within such 30 day period.
    5. If any request for payment of our Charges is not met on time, or is not under dispute, we reserve the right to suspend or withdraw the Services from you or any person associated with you.  In such circumstances we accept no liability for the effects of any delays.
    6. The existence of any agreement between us and another person that our Charges will be paid by that other person will not absolve you from discharging all your obligations to us including payment of all our Charges.
  3. Operation of the Instance
    1. You shall:
      1. report to us any suspected faults in or infiltration of the Instance of which it becomes aware as soon as such suspected faults or infiltration comes to your attention.
      2. keep confidential and take all necessary steps to ensure the continued confidentiality of your account identification details, password, security encryption devices and other confidential information relating to the Instance or Websand and notify us forthwith in the event of any party other than those individuals specifically authorised by you (and notified in advance to us) obtaining your password or using your account identification details;
      3. keep confidential and take all necessary steps to ensure the continued confidentiality of the dealings conducted by it via the Instance (including, but not limited to, the identity of any of your employees or other users); and
      4. provide us with such information as we may request concerning your use of the Instance.
    2. We shall:
      1. in connection with its operation of the Instance, comply with the provisions of the Data Protection Act 1998.
      2. use all reasonable endeavours to ensure that the Instance shall remain secure and that information not generally available to a third party accessing the Instance shall remain confidential; and
      3. provide you with identification details, passwords and security encryption devices necessary to permit you to access the Instance for the purposes of the Service.
    3. We shall provide the Instance ‘as is’ and ‘as available’.  It is agreed that it is technically impossible to guarantee that the Instance will be uninterrupted, free from errors or that the Instance will be free from unauthorised users or ‘hackers’. For the avoidance of doubt, we provide no warranty that the services will be uninterrupted.
    4. Where downtime is anticipated, downtime will be agreed with you in advance.  In emergency situations, we reserve the right to take the following operational decisions affecting the Instance.  You will be informed of any such decisions taken without your prior agreement.
      1. Take the Instance off line without notice for essential maintenance, technical reasons or upgrades.
      2. Vary the technical specifications of the Instance (or any part of it) for operational reasons
      3. Remove any or all of the information which we reasonably believe is impairing the operation of the Instance
      4. Remove or amend any of all of the information which we reasonably believe is unlawful or has been placed on the Instance in breach of agreement.
    5. SERVICE LEVELS
      1. Call response times.  Any issues reported will be acknowledged within 2 working hours of reporting (working hours are Monday to Friday 8am to 6pm)
      2. Unless otherwise agreed, the Instance will be available for you a minimum of 99% per month.
  4. Limitation of liability
    1. We shall not be liable to you or to any person whether in contract, tort or otherwise for:
      1. any direct loss or damage suffered or incurred by you in relation to the Services provided by us unless, at the time that you used them, that loss was a reasonably foreseeable result of our negligence or failure to comply with these terms;
      2. indirect or consequential loss or damage (including but not limited to loss of profit, business, revenue, goodwill or anticipated savings);
      3. any liability arising as a result of any term implied by common law or statute, order, regulation or any other enactment.
    2. Nothing in these General Terms of Business shall exclude:-
      1. Our liability for death or personal injury arising from our negligence or that of our servants, agents or employees;
      2. any other liability which we are prohibited from excluding by law
    3. In the particular circumstances of the Services set out in the Supply Terms the aggregate liability to you and to Other Beneficiaries of each and all Websand persons, in contact tort or otherwise, for any loss or damage suffered by you (or by any such other party) arising from or in connection with the Services, however the loss or damage is caused, including our negligence but not our fraud or other deliberate breach of duty shall be limited to the amount specified in the Supply Terms, or if no amount is specified there, to £250,000.
    4. We will not be liable (whether in contract, tort or otherwise) in respect of all and any claims brought by you against us to the extent that the matter giving rise to such claim is remediable and such matters shall have been remedied to your reasonable satisfaction within the period of 60 days following the date of service of notice by you on us of such claim.
    5. Notwithstanding our duties and responsibilities in relation to the Services, we expressly exclude, and, you shall retain, responsibility and accountability for:
      1. the management, conduct and operation of your business and your affairs;
      2. Making any decision affecting the Services, any product of the Services, your interests or your affairs
      3. the delivery, achievement or realization of any benefits directly or indirectly related to the Services.
      4. the production and input of all input data (including without client and marketing data) unless the production of such input data is specifically undertaken by us as part of the Services.
    6. And you agree to indemnify and hold us and (as applicable) our affiliates, officers, directors, agents, and employees, harmless from any losses arising as a result of the responsibilities outlined in this paragraph.
    7. Any advice, option, statement of expectation, forecast or recommendation supplied by us as part of the Services shall not amount to any form of guarantee that we have determined or predicted future events or circumstances.
    8. Except as expressly set out in this Agreement, we make no warranties or representations either express or implied in relation to the whole or part of the Instance, including (but not limited to) implied terms, warranties or conditions of title, usability, condition, non-infringement of intellectual property rights, completeness, accuracy, satisfactory quality or fitness for a particular purpose thereof or that the Instance will be uninterrupted or error free, that it will meet any particular criteria of performance or quality. All such warranties, terms and undertakings (whether express or implied, statutory or otherwise) in respect of the availability and operation of the Instance are hereby expressly excluded.
    9. We do not accept any liability in connection with the operation of any external website or resource which you many access when using the Instance. Your rights and obligations in relation to the operation of the relevant resource or website shall be governed by the terms and conditions of the relevant data provider.
    10. You agree to indemnify and hold Websand and (as applicable) its, affiliates, officers, directors, agents, and employees, harmless from any claim or demand, including reasonable legal fees, made by any third party due to or arising out of your breach of this Agreement (including any documents incorporated by reference), or your violation of any law or the rights of a third party.
  5. Circumstances beyond our control
    1. Neither party shall be in breach of their contractual obligations nor shall either party incur any liability if and to the extent that we may become unable to carry out all or any of our obligations under the Agreement as a result of any event or matter beyond our reasonable control.  By way of illustration and not of limitation, the following are considered as events beyond our reasonable control: strike, lock-out or other industrial dispute, public disorder, riot, revolution, mobilisation, hostilities, war (whether or not formally declared), epidemic, fire, earthquake, storm, flood and other acts of God, official regulations, orders, requirements or acts of government, governmental or administrative authority, transport difficulties, working difficulties, machine breakdowns, failure of supplies or other causes whether similar or not.
    2. In the event of any such occurrence affecting one of us, then that one shall be obliged to notify as soon as is reasonably practicable the other, who shall have the option of suspending or terminating the operation of the Agreement.
  6. Term and Termination
    1. The Services shall be provided by us to you from the date of this Agreement, and shall (subject to clauses 6.2 and 6.3) continue to be supplied for an initial period of 30 days and as a rolling monthly renewal term thereafter unless and until this Agreement is terminated by one of the parties giving to the other not less than 30 days prior notice in writing to the other at any time.
    2. We reserve the right to terminate the Agreement immediately on written notice if:
      1. You commit any serious breach of the Agreement or fail to remedy to our satisfaction, within 7 days of receiving a written request to do so, any other breach of this Agreement:
      2. You commit any breach of any license granted by us or any third party in connection with the Services.
      3. You fail promptly to pay our invoices or any requested monies on account or if you fail to give us instructions as reasonably requested.
      4. in the event that you, or any of your senior employees or staff, acting in an official capacity do anything or act which might reasonably be deemed to bring us or our products or business into disrepute or to damage in any way our he public standing, goodwill, name or reputation.
      5. in the event that you, or any of your senior employees or staff, acting in an official capacity do anything or act which is unlawful or unethical.
    3. This agreement shall terminate immediately without notice if:
      1. You suspend or cease trading or indicate that you intend to cease trading or become unable to pay your debts as they fall due; or
      2. You have a receiver or liquidator appointed, or pass an effective resolution for winding up (except for the purpose of amalgamation, reconstruction or reorganization) or a court makes an order to that effect or a similar event occurs; or
      3. distress or execution is levied against your property
    4. Upon termination of the Agreement:
      1. the Customer shall (for the avoidance of doubt) cease to have further access to the Instance; and
      2. we shall be entitled to retain any advance payments made by the you in respect of Charges.
      3. Customer data provided to Websand shall be returned to you in unprocessed form.  All communication history and business rules applied by the system shall be retained by Websand.
    5. Termination or suspension under clauses 6.1, 6.2 and 6.3 shall be without prejudice to any rights that may have accrued to either of us before termination or suspension and all sums  due to us shall become payable in full when termination or suspension takes effect.
    6. The following terms of these General Terms of Business shall survive expiry or termination of the Agreement 4.1, 4.2, 4.3, 4.3, 4.5, 4.6, 3.3, 4.7, 4.8, 4.9, 7.1, 7.2, 7.3, 7.4, 7.5, 7.6, 8.1, 8.2, 8.3, 8.4, 10, 11, 13, 14, 15 and 16
  7. Confidentiality
    1. We may acquire sensitive information regarding your business and your affairs in the course of delivering the Services (“Confidential Information”).
    2. In relation to confidential information we shall adhere to the confidentiality restrictions imposed on us by any authority in the United Kingdom with whose requirements we are bound to comply, as well as any obligations imposed on us by English law.
    3. We shall be entitled to comply with any requirement of English law or with any authority in the United Kingdom with whose requirements we are bound to comply to disclose Confidential Information.
    4. This clause shall not apply when Confidential Information properly enters the public domain.
    5. This clause shall not prohibit our disclosure of Confidential Information where we wish to disclose it to our insurers or advisers, in which event we may do so in confidence only.
    6. All reports prepared by us are strictly confidential and are issued on the understanding that they are for the use of the addressees only and are not to be discussed with, or shown to, any other party without our prior written consent.
  8. Ownership and Use
    1. We shall retain ownership of the copyright and all other intellectual property rights (including, but not limited to, any patent, trade mark, service mark, domain name, trade name or copyright and any application for registration or protection of any of the same anywhere in the world) in the product of the Services the Instance and the software upon which it is based (“the Software”). Without prejudice to the generality of the forgoing, you shall not:
      1. use, copy or transfer the Software (or any part of it) except as permitted by this Agreement; or
      2. alter, adapt, merge, modify or translate the Software (or any part of it) in any way for any purpose; or
      3. reverse-engineer, disassemble or decompile the Software (or any part of it).
    2. Without prejudice to the generality of clause 8.1, we shall own the copyright in the design and layout of the Instance. All goodwill arising in connection with the Instance shall belong to us.
    3. For the purposes of delivering services to you or other clients, we shall be entitled to use, develop and share knowledge, experience and skills of general application gained through performing the Services.
    4. Any product of the Services released to you in any form or medium shall be supplied by us on the basis that it is for your benefit and information only, and that, save as may be required by law or by a competent regulatory body (in which case you shall inform us in advance), it shall not be copied, referred to our disclosed, in whole (save for your own internal purposes) or in part without our prior written consent. The Services shall be delivered on the basis that you shall not quote our name or reproduce our logo in any form or medium without our prior written consent. You may disclose in whole any product of the Services to your legal and other professional advisers for the purposes of your seeking advice in relation to the Services, provided that when doing so you inform them that to the fullest extent permitted by law, we accept no liability or responsibility to them in connection with the Services.

9               Fax and email communication

You should be aware that fax and email communications may not be secure and may not be received by their addressees or with readable attachments.  We cannot guarantee the security or confidentiality of information so transmitted. However the majority of our clients expect us to correspond by email.  We will therefore correspond with you by email where appropriate. Please let us know in writing if you do not wish to use email.  

10            Data Protection

10.1         Notwithstanding any other provision of this Agreement, in exercising its rights and performing its obligations under this Agreement, Websand shall, to the extent necessary, comply with the Data Protection Legislation. For the purpose of this clause 8, “controller”, “processor”, “personal data”, “process” and “processing” have the meanings given to them by the Data Protection Legislation.

10.2         The parties will comply with all applicable requirements of the Data Protection Legislation. This clause 10.2 is in addition to, and does not relieve, remove or replace, a party’s obligations under the Data Protection Legislation

10.3         The parties each acknowledge that for the purposes of the Data Protection Legislation, you are the controller and Websand is the processor of any personal data from the point when any such data is transferred by you to Websand.

10.4         If, notwithstanding the intentions of the parties set out at clause 10.3, Websand processes personal data as a controller, it shall comply with the provisions of the Data Protection Legislation imposed on a controller.

10.5         You warrant that you have the legal right and have in place all necessary appropriate consents and notices required to disclose all personal data that you do in fact disclose to Websand under or in connection with this Agreement, and that the processing of that personal data by Websand for the purposes of performing its obligations under this Agreement will not breach any Data Protection Legislation.

10.6         Without prejudice to the generality of clause 10.2, where, in the performance of its obligations under this Agreement, Websand process personal data on your behalf then in relation to such personal data it shall:

(a) act only on and at all times comply with your lawful, reasonable and documented instructions, unless Websand is required by the laws of any member of the European Union or by the laws of the European Union applicable to Websand to process personal data in which case Websand shall, to the extent permitted by such law, inform you of that legal requirement before processing that personal data;

(b) having regard to the state of technological development and to the cost of implementing any measures, take appropriate technical and organisational measures against  unauthorised or unlawful processing of such personal data, unauthorised access to, or disclosure of, such personal data and against accidental loss or destruction of, or damage to, such personal data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected. At a minimum, Websand’s safeguards for the protection of personal data shall include (i) limiting access of personal data to authorised employees/authorised persons who are obliged to keep the personal data confidential; (ii) securing business facilities, data centres, paper files, servers, back-up; (iii) implementing network, device application, database and platform security; (iv) securing information transmission, storage and disposal; (v) implementing authentication and access controls within applications,  operating systems and equipment; (vi) not sharing, disclosing or subcontracting the processing of such personal data with any third parties, unless required to by an instrument of law, without your express written consent; and (vii) where appropriate, may also include the pseudonyimisation or encryption of personal data;

(c) not transfer personal data provided by you to Websand outside of the European Economic Area (EEA) unless such transfer is undertaken in accordance with applicable Data Protection Legislation.

10.7         You shall indemnify and hold harmless Websand against all losses costs and expenses incurred by it as a result of: (1) breach of clause 10.; and/or (2) processing personal data on your behalf in accordance with the provisions of clause 10.5.

10.8         Websand may at its sole discretion and at any time on not less than 30 days’ written notice, revise this clause 8 by replacing it with any applicable controller to processor standard clauses or similar terms forming part of an applicable certification scheme.

10.9         Where Websand engages another processor for carrying out specific processing activities on your behalf (a “Sub-processor”), in relation to each Sub-processor:

(a)        [you acknowledge and hereby authorise Websand to engage in connection with exercising its rights and performing its obligations under this Agreement those Sub-processors set out in Annex 1 (“Approved Sub-processors”) to this Agreement, which includes the identities of those Sub-processors and their country of location;]

(b)        Websand may amend and update the Approved Sub-processors list by providing written notice to you of any proposed new Sub-processor. You may notify Websand promptly in writing within ten (10) Business Days after receipt of Websand’s notice if you have a reasonable basis for objecting to a new Sub-processor.   Websand shall not appoint (or disclose any personal data to) that proposed Sub-processor until reasonable steps have been taken to address the objections raised by you and you have been provided with a reasonable written explanation of the steps taken;

(c)         prior to giving any Sub-processor access to personal data, Websand shall ensure that such Sub-processor has entered into a written agreement with Websand including terms in the contract between Websand and the proposed Sub-processor which are substantially the same as those set out in this clause 8 and the requirements of article 28(3) of the GDPR; and Websand shall remain fully liable to the Customer for any failure by a Sub-processor to fulfil its obligations in relation to the Processing of any Personal Data under the Agreement; and

(d)        In the EEA, or in circumstances or in a country that is the subject of a valid adequacy decision by the European Commission (“Restricted Country”), Websand may only authorise a third party to process the personal data in a Restricted Country if the Standard Contractual Clauses are at all relevant times incorporated into the agreement between, on the one hand, Websand and on the other hand the Sub-processor, or, if requested by you and required by Data Protection Legislation, you have entered into (or have procured that any relevant third party has entered into) a controller to processor data transfer agreement, incorporating  the Standard Contractual Clauses for the transfer of personal data to processors established in third countries which do not ensure an adequate level of protection, as set out in Commission Decision C(2010) 593, as updated, amended or superseded from time to time to the extent that such sub-processing does not occur. .                                                                                                                                           

11            Files and Documents

Documents may at our discretion be retained in storage on behalf of you for a reasonable period and thereafter may without notice to you be destroyed.  If you wish to ensure retention of papers, you should make specific arrangements with us. We may charge for such a service.

12            Waiver and Assignment

12.1         Our failure to exercise or enforce any rights available to us shall not be a waiver of any rights and does not prevent us enforcing the rights at a later date.

12.2         You may not assign or otherwise transfer any rights or obligations under these conditions without our prior written consent

13            Notices

13.1         Any notice to be given under the Agreement shall be in writing and shall be delivered by pre-paid first class post (or pre-paid overseas equivalent) to our respective addresses as set out in the Engagement Letter (or such other address as may be notified in writing from time to time) Notices delivered shall  be deemed to have arrived:.

(a)         When posted from and to addresses in the UK, on the second day after posting;

(b)         When posted from and to addresses overseas, on the tenth day after posting

(c)          When sent by fax, the notice shall be deemed received immediately (provided the sender can produce a valid transmission report)

13.2         The sender must prove that the notice was correctly sent.  Unless there is evidence to the and            

14            Entire Agreement

The Agreement sets out the entire understanding between the parties in connection with the services and supersedes any prior arrangements, understandings, agreements, statements or representations (unless made fraudulently) relating to the Services. In the event of any inconsistency between the Engagement Letter and any other elements of the Agreement, the Engagement Letter shall prevail. In the event of any inconsistency with these General Terms of Business and Additional Terms that may apply, the Additional Terms shall apply.

15            Third Party Rights

The Agreement shall not create or give rise to, nor shall it be intended to create or give rise to, any third party rights. No third party shall have any right to enforce or rely on any provision of the Agreement which does or may confer any right or benefit on any third party, directly or indirectly, expressly or impliedly. The application of any legislation giving or conferring on third parties contractual or other rights in connection with the Agreement shall be excluded.

16            Law & Jurisdiction

The Agreement shall be subject to and shall be governed by English law and all disputes arising out of or in connection with the Agreement or any related matters shall be subject to the exclusive jurisdiction of the English courts.   

 

Annex 1

Approved Sub-processors

We hold our data with Amazon Web Services (AWS) who are contracted by us for the provision of technical services. We remain responsible at all times for the security of your information, but if you want to know more about how we interact with AWS you can view their Privacy Notice, amongst their other policies here.

 

We use Braintree, GoCardless or Stripe to handle our subscription processing.  You can view more information about Braintree and their policies here.

You can view more information about GoCardless and their policies here.  You can view more information about Stripe and their policies here.

 

We use SendGrid to deliver our email messages as part of our service.  You can view more information about SendGrid and their policies here.
We store some client data electronically using Google Drive.  If you want to learn more about Google’s service and how they handle your data you can visit their website here.