Data Processors
In accordance with Section 19 (Privacy and Data Processing) of the Disciple Terms of Service, Lobaso Limited provides a digital community platform to brands and organisations ("Customers" or "Community Owners").
Under applicable data protection legislation (including EU/UK GDPR):
- Community Member Data (End User Data):the Customer acts as the Data Controller for personal data of their community end users ("Members"). Disciple acts as a Data Processor, and third parties handling Member data on Disciple's behalf act as Subprocessors.
- B2B Customer Data (Account & Billing Data): Disciple acts as a Data Controller for the contact, billing, and account information of the Customer (Community Owner) needed to maintain the commercial agreement.
Before engaging any third-party subprocessor, Lobaso Limited conducts a vendor risk assessment to evaluate their security posture, data protection practices, and compliance with applicable privacy legislation. Each subprocessor handling End User personal data is bound by a written data processing agreement containing data protection obligations substantially similar to those set out in Section 19 of our Terms of Service, including Standard Contractual Clauses (SCCs) or the UK International Data Transfer Agreement (IDTA) where cross-border data transfers occur.
Subprocessors for Community Member Data
The following third parties process personal data belonging to your Community Members (End Users) on behalf of Disciple, acting as a Processor for the Customer.
| Subprocessor | Service Category | Location of Processing |
|---|---|---|
| Amazon Web Services (AWS) | Cloud Infrastructure | EU / USA |
| Mux | Video Infrastructure | USA / Global |
| Stripe | Payment Gateway | USA |
| Agora | Real-time Streaming | USA / Global |
| Cloudinary | Media Management | EU / USA |
| Pubnub | Real-time Messaging | USA / Global |
| Twilio (incl. SendGrid) | Communications API | EU / USA |
| Timescale | Database Infrastructure | EU / USA |
Amazon Web Services (AWS)
Cloud Infrastructure
Data processed in EU / USA
Mux
Video Infrastructure
Data processed in USA / Global
Stripe
Payment Gateway
Data processed in USA
Agora
Real-time Streaming
Data processed in USA / Global
Cloudinary
Media Management
Data processed in EU / USA
Pubnub
Real-time Messaging
Data processed in USA / Global
Twilio (incl. SendGrid)
Communications API
Data processed in EU / USA
Timescale
Database Infrastructure
Data processed in EU / USA
Processors for B2B Customer Data
The following third parties handle business, billing, or account management details of Disciple's direct B2B Customers (Community Owners), where Disciple acts as the Data Controller.
| Processor | Service Category | Location of Processing |
|---|---|---|
| GoCardless | Direct Debit Processing | UK / EU |
| Recurly | Subscription Management | USA |
| Xero | Corporate Accounting | USA |
| Custify | Customer Success | EU |
| Stripe | Payment Gateway | USA |
| Attio | CRM | UK / EU |
| Ruler Analytics | Marketing Attribution | UK / EU |
GoCardless
Direct Debit Processing
Data processed in UK / EU
Recurly
Subscription Management
Data processed in USA
Xero
Corporate Accounting
Data processed in USA
Custify
Customer Success
Data processed in EU
Stripe
Payment Gateway
Data processed in USA
Attio
CRM
Data processed in UK / EU
Ruler Analytics
Marketing Attribution
Data processed in UK / EU
Updates & Modifications
Lobaso Limited maintains an up-to-date list of subprocessors. Pursuant to Section 19.1 of our Terms of Service, Customers will be informed of any addition or replacement of subprocessors by updating this document or via direct notification, and Customers may object to any new subprocessor on reasonable data protection grounds within 30 days of notification by contacting help@disciplemedia.com.
Contact Information
For any questions regarding this Subprocessor List or our data privacy practices, please contact Lobaso Limited's Data Protection & Legal Team at Office One, 1 Coldbath Square, Farringdon, London, EC1R 5HL, United Kingdom, or by email at help@disciplemedia.com.