Fresh Relevance Third Party Sub-Processor

Who does Fresh Relevance transfer data to and why?

As Fresh Relevance is a Dotdigital Company, many of Fresh Relevance Ltd’s global entities are associated with the Dotdigital Group, which include:

  • Dotdigital EMEA Limited
  • Dotdigital Inc
  • Dotdigital APAC Pty Limited
  • Dotdigital B.V
  • dotmailer SA Pty Ltd
  • Dotdigital SG Pte, Ltd
  • Dotdigital Poland Sp. Z.O.O.
  • Dynmark International Ltd
  • Fresh Relevance Inc

We currently engage with an external subprocessor for the purposes of platform hosting, network management, internet and network services, data back-ups and storage. This is:

  • Amazon Web Services, Inc.


Will data be transferred outside of the EEA?

Yes, but only in limited circumstances and all such transfers are protected by safeguards in place. In particular, such transfers relate to Internal Global Entities of Fresh Relevance, a Dotdigital company. As a standard, UK and EU client data will be stored in the EU. There may however be a transfer outside of the EEA in the event employee’s from Dotdigital’s global entities access customer accounts in connection with providing the service. This would typically be for support and account management purposes.

What measures does Fresh Relevance have in place to protect data transferred outside of the EEA?

Currently we have established Intra-group Data Processing Addendums and Standard Contractual Clauses to cover the different transfers made outside of the EEA to Fresh Relevance global entities.

Does Fresh Relevance inform clients where a new third-party sub-processor is being engaged and can we object?

Yes, we would always notify clients at least 30 days in advance when we are planning on engaging a new external sub-processor. This is usually by way of an email to the email address provided by you on the Service Agreement. As a client, you will always be given 10 days to object to Fresh Relevance engaging a new sub-processor where you have any data protection concerns.