Summerbase

Third-Party Management Policy

Last updated: October 22, 2026

Vendors that touch company or customer data are reviewed before use and yearly after, bound by a contract and DPA, and listed publicly when they are sub-processors.

Scope

All vendors, SaaS tools, contractors and sub-processors that store, process or access company or customer data, or that the production service depends on.

Vendor tiers

Tier Definition Examples Review
Critical Hosts or processes customer data, or production depends on it Google Cloud, email delivery, error tracking Before use and yearly: SOC 2 / ISO 27001 report, DPA, transfer mechanism
High Holds confidential company data Identity provider, source control, password manager, HR system Before use and yearly: security questionnaire or report
Low No sensitive data Design tools without customer data Before use: owner approval

Policy

  1. Before use. New vendors are recorded in the vendor list and approved by the Security Officer after a review proportionate to tier.
  2. Contracts. Critical and High vendors have contracts covering confidentiality, security obligations and breach notification. Vendors processing personal data sign a DPA meeting GDPR Art. 28.
  3. Transfers. For vendors outside the EU/EEA, the transfer mechanism (EU–US Data Privacy Framework certification, SCCs or other) is documented and a transfer impact assessment is done where required.
  4. Region alignment. Sub-processors handling EU customer data must process it in the EU/EEA, or have an approved transfer mechanism that is disclosed to customers.
  5. Sub-processor list. A public list of sub-processors, their purpose and location is kept at summerbase.com/policies/subprocessors, split into sub-processors for Customer Data and other service providers that receive only Summerbase’s own customer data. Customers are notified at least 10 days before a new sub-processor is added, as the DPA requires.
  6. Annual review. The Security Officer reviews Critical and High vendors yearly, including their SOC 2 report exceptions and complementary user entity controls (CUECs) that Summerbase must operate.
  7. Offboarding. When a vendor is retired, data is returned or deleted with confirmation, and access is removed.