Third country transfers

In the light of the CJEU ruling on the case referred to as “Schrems II”, most businesses must now assess their transfers of personal data to third countries, including the US. Pagero is a global provider of cloud-based solutions used by businesses to reach other businesses worldwide, and is therefore naturally affected by the implications of the ruling. Pagero’s business is built upon providing secure and compliant solutions for our customers, and we are continuously monitoring the legal landscape to be up to date. Here we have gathered some key information that may be useful when assessing your use of Pagero’s services in the light of the Schrems II case:

• The platform (Pagero Online) is hosted in Sweden but;
• If you have selected any additional service (such as for example print, scanning or data capture) the additional service may be provided by a provider based outside of the EU in accordance with the specific agreement. You can find the list of all such providers here. Please reach out to your sales rep if you are unsure of which services and providers apply to you.
• Depending on where your recipients of documents are located, the service itself may allow you to transfer information to any recipient in the world.

Pagero is a global company with offices all over the world, which enables us to provide timely and efficient support to our customers as well as local project management. If you are an EU-based company, we will only allow access to Pagero employees that are based within the EU for development and support of your services. If your company is based outside of the EU, Pagero employees from other offices may have access. A full list of all Pagero entities with access can be found here. Transfers of personal data within the group is governed by an intra group processing agreement and we have implemented technical and organizational measures to ensure the security of the data. Please read more about how we protect data here.

• We have re-build Pagero Online so that any organisation based within the EU will have EU-only processing as a default.
• We have reviewed all of our data flows and assessed all transfers of customer data
• We have updated our notices and data processing agreements to reflect the current situation and ensured to include appropriate transfer mechanisms to replace any transfers relying on Privacy Shield

If you have any questions or would like to discuss more, please do not hesitate to contact your sales rep or Pagero’s data protection officer at dpo@pagero.com