Adobe Sub-Processors

Last Updated: 5 December 2024

To help deliver products and services, Adobe Inc. and Adobe Systems Software Ireland Limited (“Adobe”) may use sub-processors. These are the third party entities that support delivery of functions that Adobe has outsourced, as well as other Adobe companies that assist with providing our customers with products and services. This page lists Adobe’s current sub-processors where Adobe is acting as a data processor for a customer acting as a data controller. Capitalised terms not defined on this page have the meanings set out in Adobe’s General Terms and Data Processing Addendum. Adobe will update this page to reflect any changes in the use of sub-processors as set out in our Data Processing Addendum. To subscribe to updates, click here. “Adobe Cloud Services” as used below refers to Cloud Services as defined in the General Terms and includes Adobe Experience Cloud, Document Cloud and Creative Cloud.

For each sub-processor, we provide the following information:

  • Name of sub-processor.
  • Associated Adobe products. We list Adobe products that utilise this sub-processor. If applicable, we indicate the product by its high-level business cloud (e.g., Adobe Creative Cloud). If a sub-processor only supports a particular product within that high-level cloud, then we indicate the particular product(s) as applicable.  
  • Description. We describe how Adobe uses the sub-processor.
  • Primary Processing Location. We indicate the primary processing locations from which the sub-processor provides or delivers its applicable services. Primary locations are: (1) country/region where the sub-processor is headquartered and (2) any countries/regions where a sub-processor has a key processing hub outside of its headquarter country (with other potential processing locations available via the sub-processor’s own documentation).

This page is organised as follows:

Third Party Sub-processors for Cloud Services

Third Party Sub-processors providing Storage and Infrastructure for Cloud Services

Name

Adobe Products

Description

Location

Microsoft Corporation

Adobe Cloud Services, including:

  • Adobe Creative Cloud
  • Adobe Document Cloud
  • Real-Time Customer Data Platform
  • Adobe Journey Optimizer
  • Adobe Journey Optimizer B2B Edition
  • Customer Journey Analytics
  • Adobe Analytics
  • Adobe Experience Manager
  • Marketo
  • Workfront
  • Campaign
  • GenStudio for Performance Marketing
  • Adobe Commerce

Microsoft Azure (Azure) provides cloud hosting services for Adobe Cloud Services (Experience Cloud, Creative Cloud and Document Cloud). Adobe also offers the use of the Azure OpenAI service to provide features within Adobe Apps/Services where customers decide to use such features (e.g., AI Assistant in Adobe Acrobat).

Azure is a full-service cloud platform. Data resides in Microsoft data centres but is managed day-to-day by Adobe (including strict access control protocols). For the limited categories where Microsoft Azure can access Adobe customer data, there are strict controls applied and all processing is subject to a range of technical and organisational measures.

For certain Adobe products, customer may have the ability to choose their primary hosting location subject to data centre availability. For more information on available hosting locations for each product, please refer to the Security Whitepapers available on the Adobe Trust Centre.

  • USA
  • EU
  • UK
  • Canada
  • India
  • Australia

Amazon Web Services, Inc

Adobe Cloud Services, including:

  • Adobe Creative Cloud
  • Adobe Document Cloud
  • Real-Time Customer Data Platform
  • Adobe Journey Optimizer
  • Adobe Journey Optimizer B2B Edition
  • Customer Journey Analytics
  • Adobe Analytics
  • Workfront
  • Target
  • Audience Manager

Amazon Web Services (“AWS”) provides cloud hosting services for Adobe to host applications (including Experience Cloud, Creative Cloud and Document Cloud). AWS provides a broad suite of web service architecture to enable Adobe to manage its cloud-based products and services.

For certain Adobe products, customer may have the ability to choose their primary hosting location subject to data centre availability. For more information on available hosting locations for each product, please refer to the Security Whitepapers available on the Adobe Trust Centre.

  • USA
  • EU
  • Australia
  • Singapore
  • Japan

Snowflake Computing Inc.

  • Real-Time Customer Data Platform
  • Campaign Managed Cloud Services
  • Marketo Engage
  • Audience Manager
  • Advertising Cloud
  • Workfront

Adobe uses Snowflake for data warehousing and database storage services across a subset of Experience Cloud products. This includes business intelligence on campaign performance, various KPI tracking tools and sales report features.

  • USA
  • EU

Akamai Technologies Inc.

  • Adobe Dynamic Media Classic
  • Adobe Experience Manager Dynamic Media 
  • Marketo Measure

Akamai provides Adobe with content delivery network services.

  • USA
  • UK
  • India
  • Switzerland

 

Cloudflare, Inc.

  • Marketo Engage
  • Adobe Developer App Builder

Marketo leverages Cloudflare’s global content delivery network to assist providing high availability and performance by distributing the service spatially relative to end-users.

For Adobe Developer App Builder, Cloudflare allows Adobe customers to query and modify their data across multiple APIs using a unified schema through a single endpoint. This endpoint is served by Cloudflare and uses Cloudflare’s security products such as Firewalls, DDos mitigation tools and rate limiting.

IP addresses and limited log in credential data are required for Internet communications and so Cloudflare server logs may contain the IP address of incoming requests, but there would be no other identifying data tied to such requests (as Adobe does not route user information through Cloudflare).

  • USA

Box, Inc.

  • Adobe Learning Manager

Box assists with the secure exchange of uploading and downloading files from user accounts for Adobe Learning Manager by providing a file transfer protocol service (known as FTP). To do so it processes the following data categories: name, username, email address, transactional information (e.g., information about data storage preferences), employment details and technical usage information.

  • USA
  • EU
  • UK

Fastly, Inc.

  • Adobe Experience Manager
  • Advertising Cloud
  • Adobe Commerce

Fastly assists in providing a subset of Adobe Experience Cloud products content delivery network services to help provide high availability and performance to Adobe customers by distributing the service spatially relative to end-user locations. Fastly hasn't got access to Adobe customer personal data outright, outside of the limited scope of its content delivery network services (and therefore is limited to email address, IP address, username and technical and system data such as browser or device information).

  • USA
  • EU
  • UK

MongoDB, Inc.

  • Real-Time Customer Data Platform
  • Customer Journey Analytics
  • Adobe Analytics
  • Adobe Journey Optimizer
  • Adobe Journey Optimizer B2B Edition
  • Adobe Workfront
  • Adobe Commerce
  • Adobe Experience Manager
  • Marketo Engage

Adobe leverages MongoDB’s “Atlas” cloud service. This service is used (1) to store the structured content in customer’s content repository (e.g., for Workfront and Commerce customers) and (2) for the processing of metadata required to support data processing and reporting (e.g., for Adobe Analytics and Customer Journey Analytics).

  • USA
  • EU

New Relic Inc.

  • Adobe Cloud Services
  • Adobe Commerce
  • Adobe Experience Manager

New Relic provides Adobe tools to help monitor overall software infrastructure and provide alerts as to telemetry data to help Adobe identify critical issues. New Relic primarily only processes technical telemetry data for Adobe (namely metrics, events, logs and traces). New Relic processes minimal personal data of customer users (e.g., IP addresses in CDN logs are used in New Relic to detect BOT traffic and bad actors in order to update firewall rules and maintain site performance).

  • USA
  • EU

Databricks

  • Real-Time Customer Data Platform
  • Adobe Journey Optimizer
  • Customer Journey Analytics

Adobe uses Databricks as an orchestration and compute layer for big data processing on AWS.  

  • USA

Redis Cloud

  • Real-Time Customer Data Platform
  • Adobe Journey Optimizer
  • Adobe Journey Optimizer B2B Edition
  • Customer Journey Analytics

Redis Cloud shops and processes probabilistic data structures to provide enhanced computing capabilities. Redis Cloud also provides caching services for customer reports.

  • USA

Red Hat, Inc.

  • Real-Time Customer Data Platform
  • Adobe Journey Optimizer
  • Adobe Journey Optimizer B2B Edition
  • Customer Journey Analytics

Adobe leverages OpenShift on top of its cloud infrastructure to orchestrate, scale and manage its services. OpenShift is an implementation of Kubernetes, which enables container orchestration, scaling and service management.

  • USA

Platform.sh

  • Adobe Commerce

Platform.sh provide “platform-as-a-service” hosting services for Adobe Commerce. This means they allow customers to develop commerce solutions via Adobe Commerce by providing fully automated cloud infrastructure. This is done on a single instance approach, meaning customer data is not comingled.

  • USA
  • EU

Brightcove

  • Adobe Workfront

As part of the Workfront Proof feature, Customers can upload videos to adjust viewer settings and add time-stamped comments. To facilitate this uploading, Brightcove provides Adobe transcoding services via their Zencoder product. This is used to return the video in a format suitable for preview display within Workfront. Brightcove has limited access to customer audio or video recordings when the service is requested.

  • USA
  • UK

Files.com

  • Adobe Captivate

Files.com assist Adobe by providing an FTP service for data migration and bulk import for the Adobe Captivate Prime product. This allows customers to download or upload material and plan migrations of project files.

  • USA

Vantage Gateway

  • Adobe Dynamic Media Classic
  • Adobe Experience Manager Dynamic Media 

Vantage Gateway provides storage for customer video assets and processing using application programming interfaces. They assist with transcoding video, storage and certain API’s (that customer themselves remain in control of setting up).

  • USA

Aiven Ltd

  • Adobe Workfront

Workfront leverages Aiven’s PostgreSQL cloud service as a database to store structured content for all Workfront customers that have selected to run Workfront on Azure. Aiven PostgreSQL is the primary data store of Workfront for customer data.

  • USA
  • EU

Third Party Sub-processors providing Security for Cloud Services

Name

Adobe Products

Description

Location

Okta, Inc.

  • Adobe Cloud Services

Adobe uses Okta to authenticate secure access to Adobe Cloud Services. It is integrated with Adobe’s cloud functions and provides provisioning, single sign-on, active directory and lightweight directory access protocol integration, centralised deprovisioning of users, multifactor authentication and mobile identity management. Okta may process contact information (such as name, email address and phone number), additional multi-factor authentication factor set-up details, content a customer upload (such as identification or other documentation) and information regarding the websites and applications that a specific user visits when using the Okta authentication service. Okta may also receive ancillary data such as device data, usage data and metadata. Okta’s endpoint threat detection occurs on the Adobe solution stack (meaning their access to raw customer personal data is prevented).

  • USA
  • EU
  • UK

Splunk, Inc.

  • Adobe Cloud Services

Splunk assists with security event logging and monitoring via the collection of system data. Logs are generated through Adobe’s software applications and are analysed and inspected for bugs or system failures in an Adobe-managed Splunk environment. Splunk may process data about Adobe’s operating environment and configuration. This in turn can include user interactions and sessions related to Adobe’s use of Splunk in which information and related metadata about Adobe’s network and systems architecture configurations is accessible. From a customer data perspective, Splunk may process the number and types of searches, errors and number of active and licensed users. Additionally, Splunk offers support services to Adobe for troubleshooting which may involve access to user/customer identifiable information. Finally, there is also a possibility of certain customer data (such as IP addresses, names, contact information,) being processed as part of a security investigation, threat detection or incident monitoring.

  • USA
  • EU
  • UK

Crowdstrike Holdings, Inc.

  • Adobe Cloud Services

Crowdstrike provides endpoint threat detection as part of the Adobe Operational Security Stack (OSS). This is a monitoring solution that examines relevant devices to detect and respond to cyber threats (like ransomware and malware). It works by recording limited data points (binaries, devices, files, systems, software inventory statuses and other data) to monitor particular sequences of events that may indicate a malicious action. Some of the information collected could potentially identify a unique user. However, this is only a remote possibility - it is extremely unlikely that customer personal data will be processed by Crowdstrike as part of this monitoring solution.

  • USA

LexisNexis Risk Solutions Group 

  • Adobe Sign (part of Document Cloud)

LexisNexis Risk Solutions assists Adobe by providing ID verification and authentication services related to our Adobe Acrobat Sign product for our customers based in the USA. The solution works by using rule-based and machine-learning algorithms to differentiate between fraudulent actors and legitimate users. It does this by generating an identity score using personal data such as name, email, IP address, phone number, delivering address, billing address or date of birth.

  • USA

Mitek Systems Inc.

  • Adobe Sign 

Mitek powers the Government ID Verification service in Adobe Sign. It provides the ability to authenticate signers by retrieving their identity information from a physical ID document and checking the likeness of the person by matching the photo ID with a live photo. Mitek may process names, national ID information (including taxpayer IDs and passport information) and images.

  • USA
  • EU

Mitto AG

  • Adobe Cloud Services

Adobe may send SMS messages to its customers for authentication, authorisation and commerce flows. Mitto helps Adobe by providing SMS delivery services. To do this Mitto would have access to names, addresses and phone numbers.

  • USA
  • EU
  • UK
  • Serbia

Telesign Corporation

  • Adobe Sign
  • Behance

Telesign provides mobile communication services to Adobe by relaying SMS messages with links to Adobe customers and placing automated phone voice calls that read aloud predefined messages (complementing the SMS messages service). These services are run to support functions in the Adobe Sign and Behance products. In providing these services Telesign may access first name, surname, address, email address, telephone number, location data, contact information and device information.

  • USA
  • EU
  • UK
  • Serbia

Twilio, Inc.

  • Adobe Frame

Twilio provides multi-factor authentication services allowing users to receive SMS messages and phone calls to verify their log in information. Twilio’s Segment product is used to collect and transform customer data across the Adobe Frame platform. To do this, Twilio may process name, contact details (email and work number), work details (e.g., title) along with technical information such as device data, referring URL and web browsing information associated with the authentication being verified.

  • USA

Third Party Sub-processors providing Product Functionality and User Experience for Cloud Services

Name

Adobe Products

Description

Location

Appcues Inc.

  • Adobe Frame

Appcues provides in-app messaging (tooltips, user guidance and tutorials) to help customers understand how to use Adobe Frame. Data is passed to Appcues to assist with user activation and provide a more personalised onboarding experience. Users are provided with pop-ups, checklists and options for how to explore product features. Appcues potentially processes marketing sales data (meaning details of pricing subscription data and transaction data) alongside limited personal data (such as name, email and location, user ID and, if users choose to, details of feedback).

  • USA

Datadog Inc 

  • Adobe Workfront 

Adobe uses Datadog for real-time user monitoring and logging. Datadog assists Adobe in providing insight into the front-end performance of applications from the perspective of users so that the product can quickly detect poor user experience and resolve issues with context from across the stack. Through Datadog, Adobe can view visualisations of metrics that can indicate issues like slow load times. The information collected is primarily collated metrics, rather than breakdowns of individual’s experiences.

  • USA

Sisence Ltd.

  • Adobe Marketo Engage

Sisence provides a data analytics query and visualisation software tool with particular plug-ins for Marketo that allow customers to generate specific data visualisation analysis. Customers decide on the parameters of the visualisation and in doing so can choose to input user level information such as name, contact details (email, phone number) and engagement data (such as web browsing information such as clicks and open rate).

  • USA
  • France

SendGrid, Inc.

  • Adobe Marketo Engage
  • Adobe Commerce

SendGrid is used to send transactional emails from Adobe Commerce (such as receipts to customers, log in emails and other administration information) if a customer chooses to use this option. When enabled, SendGrid will process certain details (including email address, IP address and subject line of emails).

  • USA
  • EU

Speechmatics

  • Adobe Premier Pro
  • Adobe Experience Manager

Speechmatics provides automatic speech recognition software to allow for speech to text within Adobe products. To do this, Speechmatics has limited ability to process personal data contained in voice details, names and personal data.

  • USA
  • UK

Stream

  • Behance
  • Adobe Live

Adobe uses Stream's enterprise chat offering for facilitating livestreaming chat functions with Behance. Currently, chat functionality is only available while streamers are live and is an optional service customers may choose to deploy. If deployed, Stream will have access to the personal data submitted to the chat and video in question along with names, email addresses and user account information.

  • USA
  • EU

Third Party Sub-processors providing Customer Support for Cloud Services

Name

Description

Location

Amazon Inc. (Connect) 

Amazon Connect assists with phone and chat support by providing a set of digital, cloud-based tools to routeing customer issues. This can include call recordings, screen recordings and chat transcripts along with phone numbers.

  • USA

BellSystem 24 Inc.

BellSystem 24 assists Adobe by providing customer care support services for the Adobe Creative Cloud and Document Cloud products in Japanese. They assist with providing self-service resources that allow Adobe’s customer care staff to manage customer requests quickly. Like our other customer care support services, they may process some limited personal data (such as name, age and date of birth) and details relating to business activities (e.g., the context of the support issue they are helping to route).

  • Japan

Concentrix Corporation

Concentrix assists Adobe by providing customer care and technical support services for Adobe across all Adobe SMBC products, including translation services in Korean and Japanese (through Concentrix’s Korean entity, Concentrix Service Korea Limited). They assist with providing self-service resources that allow Adobe’s customer care staff to manage customer requests quickly. Like our other customer care support services, they may process some limited personal data (such as name, age and date of birth) and details relating to business activities (e.g., the context of the support issue they are helping to route). However, Adobe remains in control of all customer data processed by Concentrix and they are bound to act only within our specific instructions.

  • USA
  • EU
  • Korea
  • India

Genesys Cloud Services, Inc.

Genesys works with Adobe to underpin the technical solutions for the Adobe Customer Care support platform in the USA and EU. They provide the resources to allow our customer care staff to see complete information on all customer requests in real time (via analytics). Adobe have engaged the “EEA-only” support option which means that cases marked as “EEA” cannot be handled by staff located in the USA (unless there is a specific ticket or issue that requires expertise - in which case an escalation for customer consent-based access control is deployed, meaning the customer can make this decision). This also means that only EEA region Genesys personnel are able to access support and operations issues, if there is a requirement for them to access. Additionally, measures have been put in place to exclude personal data (such as phone numbers or names) in the logs that Genesys processes from the Adobe Customer Care support platform (meaning that only customer user IP Addresses or unique user ID’s have the potential to be processed by Genesys).

  • USA
  • EU

Hoodoo Digital LLC

Hoodoo Digital assists Adobe by establishing platform connection services between Adobe Workfront and Adobe Experience Manager for our customers. Hoodoo Digital is essentially a consultancy that specialises in Adobe solutions, offering services with A/B testing and personalisation, analytics and asset workflow management. As a sub-processor, they potentially may process some limited Adobe customer data (such as customer user details including name, location or email address along with technical information such as IP address and unique user identifier codes) in the course setting up a connection to the Workfront and Adobe Experience Manager products.

  • USA

Intercom Inc.

Intercom helps Adobe provide a platform for community-based support, where users can keep in touch to ask questions or address issues by supplying in-app messaging software to allow for the handling of complaints and issues raised by customers related to Frame.io and Adobe Express products. Intercom may access personal data contained in customer-initiated support messages as well as email addresses, IP addresses and other technical information.

  • USA
  • EU
  • UK
  • Australia

Khoros LLC

Khoros helps Adobe provide a platform for community-based support, where users can keep in touch to ask questions or address issues. Khoros provides customer engagement software to support messaging, chat, online communities and social media management (e.g., handling complaints and issues raised through these channels). Adobe remains in control of all customer data processed by Khoros and they are bound to act only within our specific instructions. The personal data that is in scope is details of users (such as name, email address, job title and location) and their internal communications (e.g., what individual users submit as part of community-based support).

  • USA
  • UK

Merkle, Inc.

Merkle is an Adobe solution partner that provides customer care expertise. Specifically, they help customers get more tailored services from the Adobe Experience Cloud product by providing an integration with their Merkury Identity Solution product (that allows customers to get their own insights, optimised segmentation and breakdowns of profiles in accordance with what they want the Adobe Experience Cloud to deliver). Like our other customer care support services, they may process some limited personal data (such as name, age and date of birth) and details relating to business activities (e.g., the context of the support issue they are helping to route).

  • USA
  • India

Microsoft Corporation (Dynamics)

Microsoft Dynamics 365 Customer Service is a solution that Adobe deploys to assist with customer engagement management. Dynamics allows Adobe to track the progress of tickets in an organised fashion designed to ensure that service level agreements with our customers are met. Customers often have different preferences for tracking the progress of issues (particularly when it comes to assessing whether Adobe is delivering on support obligations it has been contracted for). For this reason, Dynamics is deployed to provide insights into support operations by generating reports and analytics on key metrics (like ticket volume, response times and customer satisfaction). As a result, they may process some limited personal data (such as name, age and date of birth) and details relating to business activities (e.g., the context of the support issue they are helping to route). However, Adobe remains in control of all customer data processed by Microsoft Dynamics and they are bound to act only within our specific instructions.

  • USA
  • EU

Slack Technologies

Slack assists Adobe with resolving service requests (e.g., customer calls or partner requests on bugs, fixes and other issues). It allows Adobe to track tickets by assigning case numbers to every service enquiry we receive and track the issue to the resolution. It can distribute tickets according to priority and subject matter while giving top-level dashboards and reports on things like overall resolution time and productivity spikes. Adobe customers tend to seek support in a variety of ways (e.g., by phone, email, text, social media messaging or via community platforms). Slack also helps Adobe with omni-channel routeing which allows Adobe to filter requests that come in through the different channels and get them to the right customer care support function. To provide these services, Slack may process some limited personal data (such as name, age and date of birth) and details relating to business activities (e.g., the context of the support issue they are helping to route).

  • USA
  • EU

SCSK Serviceware Corporation

SCSK Serviceware provides Adobe Experience Cloud’s customer support services, including call centre functions, as the Tier1 service desk and customer care for professional services for Marketo in Japanese. To provide these services, they may process some limited personal data (such as name, phone number and email address) and details relating to business activities (e.g., the context of the support issue they are engaging with Adobe on).

  • Japan

Teleperformance

Teleperformance supports Adobe’s customer care support services by providing technical support functions (including call centre functions) and professional services for the Japan, Hong Kong and Taiwan markets (through Teleperformance Japan Co. Ltd and Beijing Interactive CRM Technology Limited). To provide these services, they may process some limited personal data (such as name, age and date of birth) and details relating to business activities (e.g., the context of the support issue they are engaging with Adobe on). Adobe remains in control of all customer data processed by Teleperformance and they are bound to act only within our specific instructions.

  • USA
  • EU
  • Japan
  • China
  • India

Zendesk Inc.

Zendesk supports Adobe’s customer care support services by providing scalable customer service solutions (including messaging, help centre co-ordination, agent workspaces, ticketing integration, issue routeing, integrations and analytics and reporting). To provide these services, they may process some limited personal data (such as name, age and date of birth) and details relating to business activities (e.g., the context of the support issue they are engaging with Adobe on).

  • USA
  • EU

Adobe Affiliates

The following Adobe affiliates support Adobe’s provision of Cloud Services by providing technical and support services.

 

Name and Location

Purpose

Adobe Inc., USA
Adobe Systems Canada Inc., Canada
Adobe Systems India Pvt. Ltd., India
Adobe Systems Belgium BV, Belgium
Adobe Systems s.r.o., Czech Republic
Adobe Systems Danmark ApS, Denmark
Adobe Systems France SAS, France
Adobe Systems Engineering GmbH, Germany
Adobe Systems GmbH, Germany
Adobe Systems Italia Srl., Italy
Adobe Systems Benelux BV, Netherlands
Adobe Systems Norge AS, Norway
Adobe Systems Romania SRL, Romania
Adobe Systems Iberica, S.L., Spain
Adobe Systems Nordic AB, Sweden
Adobe Research Schweiz AG, Switzerland
Adobe Systems Schweiz GmbH, Switzerland
Adobe Systems Europe Limited, United Kingdom
Adobe Development ARM, LLC, Armenia
Adobe Systems Pty Ltd., Australia
Adobe KK, Japan
Frame.io, USA
Marketo, Inc., USA
Marketo EMEA Ltd., United Kingdom
Workfront Inc., USA
Workfront Ltd., United Kingdom

All provide technical and customer support services depending on region of customer.

Sub-Processor Frequently Asked Questions

How often is this list updated?

 

This list is updated whenever a new sub-processor is added or taken away (generally at least once per quarter). As set out in our Data Processing Addendum, Adobe will inform customers who have signed up to our sub-processor updates in advance of any new sub-processor being added.

 

What security measures are applied to these sub-processors?

 

Adobe applies a high standard of technical and organisation measures to our sub-processors, as set out here. Adobe takes contractual responsibility for all sub-processors, requiring that substantially equivalent terms to those in our customer contracts are passed down to bind our sub-processors. Additionally, Adobe’s vendor risk assessment programme has a set of requirements for third-party vendors that collect, store, process, transmit or dispose of data on behalf of Adobe from outside Adobe-controlled physical offices or data centre locations. This risk assessment programme evaluates each vendor’s compliance with our information security standards, providing a risk-based review of the vendor’s security practices. More details on this standard can be found here.

 

Is there an option to exclude a specific sub-processor?

 

Generally no, as Adobe services have been calibrated in a way that does not easily allow for the substitution or removal of a particular sub-processor. That said, as set out above, different sub-processors cover different functions in numerous Adobe products. If you are not using a particular product, then your data is not in scope for processing by the associated sub-processors. Similarly, some processors only assist in particular regions (e.g., translation services in APAC). Please refer to the details in the above list to confirm whether a particular sub-processor is in scope for the products and services you are licensing. As set out below, existing Customers do have the ability to object to new sub-processors as set out in the Data Processing Addendum.

 

Do all sub-processors listed here have access to my personal data?

 

No. The sub-processors above only have access to the limited categories of data necessary for the particular function they are assisting Adobe with. Adobe is dedicated to providing safe, secure environments for your data and has been certified to comply with several global industry standards.

 

Given the broad terms of the definition of “processing” (which includes imprecise concepts such as ‘access’ and ‘restructuring’) and “personal data” (which refers to “any information relating to an identifiable… individual”) in Article 4 of the EU General Data Protection Regulation (“GDPR”) and other similar privacy laws, we have drafted this sub-processors list in the interest of being fully transparent about who we work with to provide our services. In many cases (especially where data is encrypted), the sub-processors may only have access to elements of the surrounding infrastructure containing the personal data, rather than directly to the personal data itself. In other cases, such as with content delivery network systems, the only categories of personal data potentially in scope would be technical information like IP addresses and limited log in credential data (which are required for Internet communications) which may be included in server logs of incoming requests with no other identifying data tied to it. We have set out the applicable categories in the list above.

 

Is the processing limited only to the locations listed above?

 

We have set out the primary office locations where our sub-processors are based. They may in turn have further support offices and their own sub-processors, however these are all bound to the same security and technical measures as set out in our contracts as well as the specific limited parameters of access we grant sub-processors (e.g., they only can process the personal data required for the specific function they are assisting with).

 

Do Adobe customers have the right to refuse a sub-processor entirely?

 

Yes. As set out in our Data Processing Addendum, there are options for customers to review and reject particular sub-processors however this may have consequences for the delivery of the service if the service is dependant on the sub-processor and an alternative is not available.

 

What international transfer protections are applied and are there any privacy frameworks used?

 

Adobe applies numerous international transfer protections to customer data. These include the European Commission approved Standard Contractual Clauses, security certifications and frameworks and specific country agreements such as the Data Privacy Framework. For more details on international transfers, please visit our cross-border data transfers page and for information on our security certifications and frameworks please visit our Trust Centre.

 

Are there specific pages listing service providers for customers based in China or South Korea?

 

Yes. Pages listing our service-providers for Korea and China can be found here and here. The entities listed on this page are Adobe’s sub-processors (meaning they help Adobe, acting as a data processor, provide the products and services for Customers as data controllers). For the entities listed on the Korea and China pages, there are broader categories and include entities that assist Adobe with its own processing activities as a data controller (e.g., marketing, customer outreach, internal administration and legal assistance). Any entities in China and Korea that act as a sub-processor for customer data are listed on the service-providers pages as well.

Update History

Date

Summary

2024 December

Redrafted and rebuilt list to add further product description information and more detailed breakdowns of associated Adobe products in scope for their respective third party sub-processors. Addition of new sub-processors supporting infrastructure and removal and consolidation of other sub-processors no longer relevant.

2024 April

Added updates on entity names (e.g. when company changes name) and processing locations along with further information added to descriptions of services provided.

2023 December

Added further details and updates on entity names (e.g. when company changes name) and processing locations along with further information on the processing in scope and services provided.

2023 September

Added further details to specific processing locations along with further refinement of information in descriptions of services provided.

2023 March

Added further details on entity names (e.g. when company changes name) and further information in descriptions of services provided.

2022 December

Addition of new infrastructure and customer support sub-processors along with new sub-processors supporting Workfront and Marketo. Removal of sub-processor that assisted with depreciated Marketo and Frame features. Added more details on entity names and locations.

2022 June

Addition of new security and customer support sub-processors along with new sub-processors supporting Creative cloud, AEM, Magento and Frame. Removal of hosting provider and email distributor as no longer in scope. Added more details on entity names and locations.

2021 September

Launch of public list on Adobe.com (previously made available to customers through contracts and Trust Centre).