RUSSIA IDENTITY CHECK (Item check 0359) | ID NUMBER 200160
• Supplier hosts the Supplier Data
• Supplier is a Sub-processor of Client Information
• Client Information includes Personal Data
• The Sub-processor is located in Cyprus
• The Sub-processor is based within the EEA
• The Sub-processor uses further Sub-processors based in Russia
• The further Sub-processors are based outside of the EEA
• Where GDPR applies to the End User, the End User must rely on a derogation to transfer Client Information to the Sub-processor based outside of the EEA in accordance with Article 49 GDPR
The Supplier Data that GBG uses to provide Russia Identity Check is supplied by GBG’s Data Supplier. GBG is obliged under the terms of its agreement with its Data Supplier to ensure that all End Users agree to comply with the following provisions:
1. DATA PROTECTION AND COMPLIANCE WITH RELEVANT LAWS
1.1. The Supplier Data used to provide this element of the Service is hosted by the Data Supplier. In order to perform the Services, the Data Supplier shall act as Sub-processor of Client Information (including any Personal Data supplied) for the sole purpose of delivering this element of the Service. The End User authorises GBG to appoint the Data Supplier as Sub-Processor for the purposes specified in this clause 2.
1.2. The Data Supplier is based in Cyprus which is located within the EEA. The Data Supplier uses Sub-processors based in Russia which is located outside of the EEA. Where GDPR applies to the End User, the End User acknowledges that prior to submitting Client Information to GBG for processing it shall determine, and is solely liable for ensuring that it can rely on a derogation to transfer Client Information to the Sub-processor based outside of the EEA in accordance with Article 49 GDPR.