Regional Data Hosting Policy

Zendesk’s Regional Data Hosting Policy (“Data Hosting Policy”) explains where Zendesk Service Data can be Hosted, and where other processing activities occur. “Hosting/Hosted” means the storing, hosting or replicating of Service Data including for archival, backup and log purposes. All other capitalized terms not otherwise defined herein such as “Service Data”, shall have the meaning set forth in Zendesk’s Master Subscription Agreement available here. Definitions for the categories of Service Data covered in this Data Hosting Policy can be found following the table below.

This Data Hosting Policy does not apply to (a) data that resides in any Zendesk product or services not detailed in this Data Hosting Policy; (b) data that resides in Third Party Services managed and hosted by third parties and the Service Data that is or may be shared with such Third Party Services (as defined in our Master Services Agreement); or (c) data that resides in a Zendesk product or service that is in a Beta, Testing or Early Access Program (except as noted within this Data Hosting Policy).

Where Zendesk Service Data Can Be Hosted

Zendesk Subscribers who purchase the Data Center Location Deployed Associated Service (“Add-on”) have the ability to select the region in which data centers that Host certain of their Service Data are located from the data center regions made available by Zendesk (“Data Locality”). The table below summarizes the geographical region(s) where certain types of Service Data can be Hosted when the Add-On is purchased and Data Locality is enabled. For the avoidance of doubt, all Service Data which is available for Data Locality as detailed in this Data Hosting Policy can only be Hosted in a single Data Locality:

Zendesk Support

Unstructured Service Data Description	Hosting Options
Ticket Data	Available to be Hosted in the European Economic Area (EEA) or the United States (US)
User Data	Available to be Hosted in the EEA or the US (except for Insights data which is Hosted in the US only)
Attachments	Available to be Hosted in the EEA or the US
Insights (Analytics within Zendesk Support)	Available to be Hosted in the US only
Net Promoter Score (NPS) email distribution lists	Available to be Hosted in the US only
Archived Screencasts (No longer available)	Available to be Hosted in the US only
Messaging Channel Data	Hosted in the same region where the Subscriber's Zendesk Support account is Hosted or in the US at Zendesk's discretion.

Zendesk Guide

Service Data Type	Hosting Options
Guide Content	Available to be Hosted in the EEA or the US
Attachments and Images	Available to be Hosted in the US only
Spam Filter	Available to be Hosted in the US only

Zendesk Chat

Service Data Type	Hosting Options
Chat Content	Available to be Hosted in the EEA only
Messaging Conversations	Hosted in EEA or in the US at Zendesk's discretion.

Zendesk Talk

Service Data Type	Hosting Options
Call Recordings	Available to be Hosted by Zendesk’s third party service provider, Twilio, in the US only
Transcriptions	Available to be Hosted by Zendesk’s third party service provider, Twilio, in the US only; also stored in tickets where Subscriber’s Zendesk Support account is Hosted
SMS Messages	Available to be Hosted by Zendesk’s third party service provider, Twilio, in the US only; also stored in tickets where Subscriber’s Zendesk Support account is Hosted

Zendesk Explore

Service Data Type	Hosting Options
Application Data	Hosted in the same region where Subscriber’s connected Zendesk Support account is Hosted
Connector Data	Hosted in the same region where Subscriber’s connected Zendesk Support account is Hosted
Email Campaign Data	Available to be Hosted by Zendesk’s third party service provider, Sendgrid, in the US only

Zendesk Connect

Service Data Type	Hosting Options
Connect Service Data	Available to be hosted in the US only

Zendesk Sunshine

Service Data Type	Hosting Options
Custom Objects Data	Typically Hosted in the same region where the Subscriber’s Zendesk Support account is Hosted, but might be Hosted in different regions at Zendesk's discretion. Data Locality is not available for Sunshine Custom Objects Data.
Events API Data	Typically Hosted in the same region where the Subscriber's Zendesk Support account is Hosted, but might be Hosted in different regions at Zendesk's discretion. Data Locality is not available for Sunshine Events API Data.
Profiles Data	Typically Hosted in the same region where the Subscriber's Zendesk Support account is Hosted, but might be Hosted in different regions at Zendesk's discretion. Data Locality is not available for Sunshine Profiles Data.

Definitions

• Ticket Data: includes ticket comments, tags, custom fields and audit events.
• User Data: includes identities, hashed passwords and names for both Agents and End-Users.
• Attachments: includes files attached to tickets or articles.
• Messaging Channel Data: includes all content entered into the third party messaging channels that can be enabled within Zendesk Support. 
• Guide Content: includes data posted on a Subscriber’s Guide Account such as articles and any comments thereto.
• Images: includes image files attached to articles in Guide.
• Chat Content: includes content inserted into a chat session by an End-User or Subscriber.
• Messaging Conversations: includes content entered into the third party messaging channels that can be enabled within Zendesk Chat.
• Call Recordings: includes live call recordings and voicemails.
• Transcriptions: includes written transcriptions of call recordings and voicemails. Transcriptions are also stored in Zendesk Support tickets.
• SMS Messages: includes content exchanged through Zendesk Text by Agents and End-Users. This data is also stored in Zendesk Support tickets.
• Application Data: includes data that is stored as part of the Zendesk Explore Service, such as accounts, users, and metric/query/dashboard metadata.
• Connector Data: includes data that is ingested into Explore from other Zendesk Services as part of the Zendesk integration (such as Support, Talk, Chat, Guide).
• Email Campaign Data: includes email addresses of recipients receiving dashboard emails within Zendesk Explore and content of the emails themselves.
• Connect Service Data: includes all content inserted into Connect by Customers excluding Account Information.
• Custom Objects Data: includes all content inserted into the Custom Objects functionality (including through Zendesk Sunshine features integrated into Zendesk Support).
• Events API Data: includes all content inserted into the Events API (including through Zendesk Sunshine features integrated into Zendesk Support).
• Profiles Data: includes all content inserted into the Profiles functionality (including through Zendesk Sunshine features integrated into Zendesk Support).

Disabling Features or Functionality Within a Zendesk Service to Limit Hosting of Service Data Outside of a Selected Region

Many of the features or functionality that require Hosting of Service Data in a particular region are, by default, disabled or may be disabled by Agents authorized as administrators within a Zendesk Service. These include the following:

Service	Options
Insights (Analytics within Zendesk Support)	Insights is optional and disabled by default. Custom ticket fields enabled for export into Insights may be disabled upon request. Default ticket fields exported to Insights (including End-User organization) cannot be disabled.
Net Promoter Score (NPS) email distribution lists	NPS is optional and is disabled by default
Spam Filter	Spam filter is optional and is disabled by default
Zendesk Sunshine	Zendesk Sunshine features are optional and must be activated by Subscribers.

Hosting and Processing of Backups and Logs

Backups and audit logs of Service Data for which Data Locality is available (“Backups and Logs”) are also Hosted in the selected region. Backups and Logs may be otherwise Processed outside of the EEA and the US in accordance with the policies below.

Processing of Service Data

Notwithstanding the Data Locality options above, Service Data, including Service Data for which Data Locality is available, may be Processed (as that term is defined in our Master Subscription Agreement and Privacy Policy (as amended from time to time)) by any member of the Zendesk Group or their authorized third party service providers in other regions, countries and territories. Processing of Service Data is performed as necessary to provide the applicable Service and all members of the Zendesk Group and third party service providers are subject to strict technical and organizational measures to protect the Service Data that is Hosted or Processed by them. Service Data may also be transferred, Processed or disclosed as required by law or in response to subpoena or other legal process as described in our Master Subscription Agreement and Privacy Policy. Processing of Service Data by a member of the Zendesk Group or their authorized third party service providers may include storage (that is incidental to the purpose of such Processing) in other regions, countries and territories for a limited period of time.

Protections for Personal Data

Service Data may include Personal Data (“Personal Data”). Applicable Data Protection Laws (as the term is defined herein) sets out a number of data protection requirements which apply when Personal Data is being Processed. Applicable Data Protection Law means the following data protection law(s)): (i) where Data Controller is established in an EEA member state or where Data Controller’s Agents or End-Users access the Services from an EEA member state: the EU Regulation 2016/679 (“GDPR”) (and any applicable national laws made under it).

Service Data is Processed by the Zendesk Group and its third party service providers in compliance with GDPR. This includes compliance with requirements that Personal Data transferred from the EEA to other countries where the Zendesk Group or its third party service providers operate is adequately protected. Zendesk regularly enters into Data Processing Agreements with its Subscribers which incorporate the EU Standard Contractual Clauses ("Model Clauses") and detail our obligations with respect to the Processing of Personal Data. If you would like to review and enter into such an agreement, please contact [e-mail].

Zendesk maintains an up-to-date list of the names and locations of all subprocessors (including members of the Zendesk Group and third parties) used for Hosting or other Processing of Service Data, including Personal Data, which can be found here or may be obtained by contacting [e-mail].

Zendesk computing environments are routinely audited with standards, certifications and accreditations including ISO 27001:2013, ISO 27018:2014, and SOC 2 Type II; Zendesk servers are hosted at Tier IV or Tier III+, SSAE-16, PCI DSS, or ISO 27001 compliant facilities. Learn more about Security at Zendesk here. By operating in an accredited environment, Zendesk Subscribers reduce the scope and cost of audits they need to perform. Zendesk continuously undergoes assessments of its underlying infrastructure, including the physical and environmental security of its hardware and data centers, so its Subscribers can take advantage of those certifications and simply inherit those controls.

Migration

For existing Zendesk Subscribers who enable Data Locality, migration of Service Data to a data center in the requested region may be required. In such circumstances, a copy of Subscriber’s Service Data will be created during the migration process for the purposes of ensuring that all Service Data required to be migrated has been fully migrated to the data center in the specified region. This assurance process conducted by Zendesk may take up to thirty (30) days from the date of commencement of such migration. After the migration process has been completed and confirmed, deletion of the copy of the Subscriber’s Service Data in the former data center will commence under Zendesk’s Data Deletion Policy available here. Subscribers should expect that migrations will likely require a scheduled downtime.

Zendesk Apps and Third Party Services

Service Data may be shared with Third Party Services (as that term is defined in our Master Subscription Agreement, as amended from time to time), including third party applications that integrate with Zendesk Services through apps and other integrations. These include Zendesk Apps made available on the Zendesk Marketplace or through the Agent interface in the Zendesk Service. Service Data that is Hosted or Processed through such Third Party Services is outside the scope of this Data Hosting Policy. Please contact the providers of these Third Party Services directly if you have questions about Hosting or Processing of Service Data through these Third Party Services.

Other Data Collected

As detailed in our Privacy Policy available here, we collect data and other information in connection with the operation and management of Zendesk, Inc., the Zendesk Group and the marketing, sales, support and administration of their respective businesses and services, including Zendesk’s Services. This information may include Personal Data, such as (but not limited to) payment information and the names and email addresses of individuals authorized to use Zendesk’s Service as Agents (as that term is defined in our Master Subscription Agreement). Our collection, use and sharing of this information is outside the scope of this Data Hosting Policy and is governed by our Privacy Policy; however, you can rest assured that we comply with GDPR with respect to all Personal Data included in such information.