Version 2, 29 October 2026
What this list covers
This list covers the data you entrust to us when you use our platform: the data in your sales invoices, purchase invoices, cash books, daily receipts books, centralisation books, till receipts, in the Peppol messages you send and receive, and in your user accounts. For this data, you are the controller and Scrada acts as processor. The parties we engage for this purpose are sub-processors. You have the right to object to a change; how this works is explained below.
Data for which Scrada itself is the controller, such as your contact details as a customer or prospect, what you ask us via our website and the measurement of visits to that website, is not covered by this list. Our privacy statement informs you about that data.
Sub-processors we engage
| Processor | Service | Place of processing | Type of data |
|---|---|---|---|
| TransIP B.V. | Hosting of the Scrada platform | EU | All data you process in Scrada: invoices, purchase invoices, books, Peppol messages, account and login data |
| Acronis (via TransIP) | Backup of the production systems | EU | The same data as above, as present at the time of the backup |
| Hetzner Online GmbH | SFTP and FTPS servers for file-based integrations, and storage of backups | EU | Invoice and accounting files exchanged through a file-based integration, and the data in the backups stored there |
| SuperPDP | Mandatory route for sending and receiving invoices between French customers | EU | Invoice data of French customers and their counterparties, with the related exchange data |
| Freshworks (Freshdesk) | Ticketing system for customer support | EU | Name, e-mail address and the content of your support requests, including anything you attach to a ticket yourself |
| Postmark, operated by AC PM LLC, part of ActiveCampaign | Sending and receiving e-mail from the platform, such as invoice and notification e-mails | United States, under an adequacy decision with standard contractual clauses as a fallback | Name, e-mail address, content and metadata of the messages sent |
| Microsoft Ireland Operations Ltd | Microsoft 365: e-mail, Teams and document storage used by Scrada in its communication with you | EU | Correspondence and documents containing your data |
| TeamViewer SE | Guided remote support, only when you start the session yourself and give your consent | EU | What is visible on your screen during the session |
Processing outside the European Economic Area
For almost all parties on this list, processing takes place within the European Economic Area. There is one exception, for which a safeguard under Chapter V of the General Data Protection Regulation applies.
The e-mails sent or received by the platform pass through Postmark, which processes them in the United States. The processing entity is AC PM LLC, part of ActiveCampaign. ActiveCampaign, LLC is on the official EU-US Data Privacy Framework list of the US Department of Commerce, so the transfer relies first and foremost on an adequacy decision of the European Commission. Postmark’s data processing terms also invoke the standard contractual clauses of the European Commission as a fallback.
You can ask us which safeguard applies to a particular party, and obtain a copy of it, at the address below.
Changes to this list
When we add or replace a sub-processor, we announce it at least fourteen calendar days in advance on this list, with the date on which the change takes effect, and at the same time we inform you by e-mail or through a notification in our application. You can object to a new sub-processor within that period; to do so, contact us at the address below. We will then discuss together what solution is possible. How this works is set out in article 5 of Annex 1 to our General Terms and Conditions.
The version number and date at the top show which version of this list applies and from when it takes effect. We keep previous versions of this list and make them available on request.
Questions
You can send questions about this list or about the processing of your data to dpo@scrada.be. We will answer them as soon as possible.