Standard Contractual Clauses (SCCs)
Excalidraw uses the European Commission’s Standard Contractual Clauses (“SCCs”) to ensure appropriate safeguards for international transfers of Personal Data in accordance with applicable Data Protection Laws.
These SCCs form part of the Excalidraw Data Processing Agreement (“DPA”) and apply to transfers of Customer Personal Data from the European Economic Area (“EEA”) to countries that do not provide an adequate level of data protection.
Applicable SCCs
Excalidraw relies on the Standard Contractual Clauses adopted by the European Commission under Implementing Decision (EU) 2021/914, Module 2 (Controller to Processor).
The official SCC text is available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj
(Commission Implementing Decision (EU) 2021/914)
Parties
- Data Exporter (Controller): The customer, as defined in the Agreement and the DPA.
- Data Importer (Processor): Excalidraw s.r.o., Pražákova 1008/69, Štýřice, 639 00 Brno, Czech Republic
International Transfers
Customer Personal Data may be transferred to and processed in countries outside the EEA, including the United States, where Excalidraw or its subprocessors operate.
Such transfers are safeguarded through the SCCs and the technical and organizational measures described above.
UK and Swiss Transfers
For transfers subject to United Kingdom or Swiss Data Protection Laws, the SCCs apply together with the applicable international transfer addendum, as described at: https://plus.excalidraw.com/legal/international-transfer-addendum
Order of Precedence
In the event of any conflict between the SCCs and the DPA, the SCCs shall prevail to the extent required by applicable Data Protection Laws.
Contact
If you have questions about international data transfers or these SCCs, you may contact Excalidraw at: security@excalidraw.com
Annexes
The following annexes form an integral part of the SCCs and are incorporated by reference:
- Annex I – Description of Processing: A description of the processing activities, categories of Personal Data, categories of Data Subjects, and purposes of processing is available at https://plus.excalidraw.com/legal/description-of-processing
- Annex II – Technical and Organizational Measures (TOMs): A high-level description of the technical and organizational measures implemented by Excalidraw is available at https://plus.excalidraw.com/legal/technical-and-organizational-measures-toms
- Annex III – Subprocessors: A current list of authorized subprocessors is available at https://trust.excalidraw.com/subprocessors