Information on new (sub-)processors
Your data has always been in safe hands with us. In order to fulfill our obligation under Art. 28 para. 2 and para. 4 GDPR, we inform you today that we intend to expand the circle of our (sub)processors and to use additional AI-supported services in the future. For this purpose, we will utilize the services of the following providers:
| Provider | Service | Existing (Sub-)Processor | New (Sub-)Processor | Purpose | Country | Data Protection Legal Safeguards / Guarantees |
|---|---|---|---|---|---|---|
| Anthropic Ireland Limited | Claude Team | x | Support for research, drafting texts, summarization, and productivity tasks | Ireland |
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| DeepL SE | DeepL Pro Standard | x | Translations and linguistic optimization of texts | Germany | Data Processing Agreement (DPA) pursuant to Art. 28 GDPR | |
| Microsoft Ireland Operations, Ltd. | MS Copilot and Microsoft 365 Copilot | x | Support for research, drafting texts, summarization, and productivity tasks | Ireland |
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| OpenAI Ireland Limited | ChatGPT Team | x | Support for research, drafting texts, summarization, and productivity tasks | Ireland |
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| ServiceNow Inc. | Now Assist Suite | x | Support for service, support, and workflow processes through AI-powered functionalities | United States |
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Personal data will only be processed by these (sub-)processors where necessary in the individual case and exclusively:
- in connection with the performance of contractual services; and
- on the basis of our legitimate interest in providing secure, efficient, and state-of-the-art services.
Where transfers of personal data to third countries cannot be excluded, such transfers will be carried out on the basis of appropriate safeguards in accordance with Article 46 GDPR, in particular through the execution of EU Standard Contractual Clauses (SCCs) and the implementation of supplementary protective measures. In addition, Microsoft, OpenAI, and ServiceNow are certified participants in the EU-U.S. Data Privacy Framework.
Pursuant to Article 28(2) GDPR, you have the right to object to the engagement of the above-mentioned (sub-)processors on grounds relating to your particular situation. Any objection must be submitted in writing within 14 days of receipt of this notice to: datenschutz@bacher.eu
If an objection is submitted within the specified period, we will review it and work with you to agree on a GDPR-compliant solution. If no objection is received within the stated period, your consent to the engagement of the above-mentioned (sub-)processors shall be deemed granted.
An up-to-date overview of our (sub-)processors is available on our website.