At Unily, ensuring the privacy, integrity and security of our customers’ data is of the utmost importance. We strive to offer our customers the tools they need to adhere to legal requirements and to that end, Unily is issuing an SCC Addendum to its customers, to accommodate international data transfers where applicable.
Why is Unily issuing an SCC Addendum?
We have issued an SCC Addendum primarily to account for and incorporate the new Standard Contractual Clauses (SCCs) that the European Commission published on June 4, 2021 (“EU SCCs”) to enable transfers of personal data from the European Economic Area (EEA) to non-adequate countries, where applicable. We’ve also incorporated the UK’s International Data Transfer Addendum to the EU SCCs (“UK SCCs”), which allows customers to also use the new EU SCCs for transfers of personal data from the UK to non-adequate countries, where applicable.
Does the SCC Addendum include any other changes?
In an effort to be as transparent as possible to our customers, we’ve also taken this opportunity to revise and reformat our sub-processor list, to make it more accessible to our customers and easier to keep up to date with any sub-processor changes. You can now find our sub-processor list and subscribe to notifications of changes on our website here. These changes are also referenced in the SCC Addendum.
Do the SCCs apply to all customers?
The SCCs are only applicable to customers that contract with a Unily entity outside of the UK/EU (e.g. Unily Inc) and that use Unily to process personal data which is subject to the UK GDPR and/or EU GDPR. In this instance, the use of Unily Services will involve the transfer of personal data to, and processing of personal data in, locations outside of the UK and/or EEA in performance of the Unily Services.
To the extent Unily’s processing relates to an international transfer which is subject to the UK GDPR (except if in an applicable adequate country), the UK SCCs will apply and Unily is the 'data importer' and customer is the 'data exporter’.
To the extent Unily’s processing relates to an international transfer which is subject to the EU GDPR (except if in an applicable adequate country), the EU SCCs will apply and Unily is the 'data importer' and customer is the 'data exporter’.
To the extent that the contracting Unily entity transfers any Personal Data to a sub-processor (including any Unily Affiliates) that processes personal data outside the UK or EEA (except if in an adequate country), such transfers are outside of the scope of the SCC Addendum. For these purposes, Unily will be deemed the ‘data exporter’ and has therefore entered into applicable standard contractual clauses with any relevant sub-processors.
What about the main agreement between the parties?
The Unily SCC Addendum is an addendum to the main agreement between Unily and our customer and forms part of that agreement. In the event of any conflict between the terms of this SCC Addendum and the terms of the main agreement, the terms (including definitions) of this SCC Addendum shall prevail so far as the subject matter concerns the processing of personal data.
How can I access and execute the Unily GDPR Addendum?
The SCC Addendum has been pre-signed by Unily and can be downloaded here. It can be executed by the customer signing and returning it to privacy@unily.com.
What if I have additional questions?
If you have additional questions or concerns, please contact your Customer Success Manager or alternatively, you may reach out to our Data Privacy team directly at privacy@unily.com.
