Salesforce Data Processing Addendum
Salesforce Data Processing Addendum
This Data Processing Addendum, including its Schedules, (“DPA”) forms part of the Main Services Agreement or other written or
electronic agreement between SFDC and Customer for the purchase of online services (including associated SFDC offline or mobile
components) from SFDC (identified either as “Services” or otherwise in the applicable agreement, and hereinafter defined as
“Services”) (the “Agreement”) to reflect the Parties’ agreement with regard to the Processing of Personal Data.
In the course of providing the Services to Customer pursuant to the Agreement, SFDC may Process Personal Data on behalf of
Customer and the Parties agree to comply with the following provisions with respect to any Personal Data, each acting reasonably
and in good faith.
Except as otherwise expressly provided in the Agreement, this DPA will become legally binding upon receipt by SFDC of the
validly completed DPA at this email address.
For the avoidance of doubt, signature of the DPA on page 8 shall be deemed to constitute signature and acceptance of the Standard
Contractual Clauses, including Schedule 2. Where Customer wishes to separately execute the Standard Contractual Clauses and its
Appendix, Customer should also complete the information as the data exporter and sign on page 14 (Schedule 2).
1. DEFINITIONS
“Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with the subject
entity. “Control,” for purposes of this definition, means direct or indirect ownership or control of more than 50% of the
voting interests of the subject entity.
“Authorized Affiliate” means any of Customer’s Affiliate(s) which (a) is subject to the data protection laws and regulations
of the European Union, the European Economic Area and/or their member states, Switzerland and/or the United Kingdom,
and (b) is permitted to use the Services pursuant to the Agreement between Customer and SFDC, but has not signed its own
Order Form with SFDC.
“CCPA” means the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended by the California
Privacy Rights Act, and its implementing regulations.
“Controller” means the entity which determines the purposes and means of the Processing of Personal Data.
“Customer” means the entity that executed the Agreement together with its Affiliates (for so long as they remain Affiliates)
which have signed Order Forms. For the purposes of this DPA only, and except where indicated otherwise, the term
“Customer” shall include Customer and its Authorized Affiliates.
“Customer Data” means what is defined in the Agreement as “Customer Data” or “Your Data”, provided that such data is
electronic data and information submitted by or for Customer to the Services. This DPA does not apply to Content or Non-
SFDC Applications as defined in the Agreement or, if not defined in the Agreement, as defined in the Main Services
Agreement at https://www.salesforce.com/company/legal/agreements/.
“Data Protection Laws and Regulations” means all laws and regulations applicable to the Processing of Personal Data
under the Agreement, including those of the European Union, the European Economic Area and their member states,
Switzerland, the United Kingdom and the United States and its states.
“Data Subject” means the identified or identifiable person to whom Personal Data relates.
"Europe" means the European Union, the European Economic Area, Switzerland and the United Kingdom.
“GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection
of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing
Directive 95/46/EC (General Data Protection Regulation), including as implemented or adopted under the laws of the United
Kingdom.
“Personal Data” means any information relating to (i) an identified or identifiable natural person and, (ii) an identified or
identifiable legal entity (where such information is protected similarly as Personal Data or personally identifiable information
under applicable Data Protection Laws and Regulations), where for each (i) or (ii), such data is Customer Data.
“Processing” or “Process” means any operation or set of operations which is performed upon Personal Data, whether or
not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination,
restriction, erasure or destruction.
“Processor” means the entity which Processes Personal Data on behalf of the Controller, including as applicable any
“service provider” as that term is defined by the CCPA.
“Public Authority” means a government agency or law enforcement authority, including judicial authorities.
“Salesforce Processor BCR” means Salesforce’s processor binding corporate rules for the Processing of Personal Data, the
most current versions of which are available on SFDC’s website, currently located at
https://www.salesforce.com/company/privacy.
“Security, Privacy and Architecture Documentation” means the Security, Privacy and Architecture Documentation
applicable to the specific Services purchased by Customer, as updated from time to time, and accessible via SFDC’s Trust
and Compliance webpage at https://www.salesforce.com/company/legal/trust-and-compliance-documentation/ (also
accessible via http://www.salesforce.com/company/legal/agreements/ under the “Trust and Compliance Documentation”
link), or as otherwise made reasonably available by SFDC.
“SFDC” means the SFDC entity which is a party to this DPA, as specified in the section “HOW THIS DPA APPLIES”
above, being Salesforce, Inc. (f/k/a salesforce.com, inc.), a company incorporated in Delaware, US; Salesforce.com Canada
Corporation, a company incorporated in Canada; salesforce.com France, a French S.A.S company with a share capital of
37,000 €, registered with the Paris Trade Registry under number 483 993 226 RCS Paris, Registered office: 3 Avenue Octave
Gréard, 75007 Paris, France; salesforce.com Germany GmbH, a limited liability company, incorporated in Germany;
Salesforce.com Italy S.r.l., an Italian limited liability company having its registered address at Piazza Filippo Meda 5, 20121
Milan (MI), VAT / Fiscal code n. 04959160963; Salesforce Systems Spain, S.L., a limited liability company incorporated
in Spain; Salesforce UK Limited (f/k/a salesforce.com EMEA Limited), a company registered in England and Wales; SFDC
Ireland Limited, a limited liability company incorporated in Ireland; Salesforce Japan Co., LTD (f/k/a Kabushiki Kaisha
salesforce.com), a company incorporated in Japan ; Salesforce.com Singapore Pte. Ltd., a company incorporated in
Singapore; SFDC Australia Pty, Ltd., a company incorporated in New South Wales; Salesforce.com India Private Limited,
an Indian private limited company; Salesforce.org, LLC, a company registered in California, US; Salesforce.org EMEA
Limited, a private company, limited by shares, registered in England and Wales; Salesforce Tecnologia Ltda., a limited
liability company incorporated in Brazil,, US; Demandware, LLC, a company registered in Delaware, US;, Heroku, Inc., a
company incorporated in Delaware, US; Krux Digital, LLC, a company registered in Delaware, US; MuleSoft, LLC, a
company registered in Delaware, US; Tableau Software, LLC, a company registered in Delaware, US; Tableau International,
Unlimited Company, a company incorporated in Ireland; Vlocity, LLC, a company registered in Delaware, US; Slack
Technologies, LLC, a limited liability company formed in Delaware, US; Slack Technologies Limited, a private company
limited by shares incorporated under the laws of Ireland; or as applicable.
“SFDC Group” means SFDC and its Affiliates engaged in the Processing of Personal Data.
“Standard Contractual Clauses” means Standard Contractual Clauses for the transfer of Personal Data to third countries
pursuant to Regulation (EU) 2016/679 of the European Parliament and the Council approved by European Commission
Implementing Decision (EU) 2021/914 of 4 June 2021, as currently set out at https://eur-
lex.europa.eu/eli/dec_impl/2021/914/oj.
“Sub-processor” means any Processor engaged by SFDC or a member of the SFDC Group.
3.1. Data Subject Request. SFDC shall, to the extent legally permitted, promptly notify Customer of any complaint, dispute or
request it has received from a Data Subject such as a Data Subject’s right of access, right to rectification, restriction of
Processing, erasure (“right to be forgotten”), data portability, object to the Processing, or its right not to be subject to an
automated individual decision making, each such request being a “Data Subject Request”. SFDC shall not respond to a Data
Subject Request itself, except that Customer authorizes SFDC to redirect the Data Subject Request as necessary to allow
Customer to respond directly.
3.2. Required Assistance. Taking into account the nature of the Processing, SFDC shall assist Customer by appropriate technical
and organizational measures, insofar as this is possible, for the fulfillment of Customer’s obligation to respond to a Data
Subject Request under Data Protection Laws and Regulations.
3.3. Additional Assistance. To the extent Customer, in its use of the Services, does not have the ability to address a Data Subject
Request, SFDC shall upon Customer’s request provide commercially reasonable efforts to assist Customer in responding to
such Data Subject Request, to the extent SFDC is legally permitted to do so and the response to such Data Subject Request
is required under Data Protection Laws and Regulations. To the extent legally permitted, Customer shall be responsible for
any costs arising from SFDC’s provision of such assistance.
4.1. Confidentiality, Reliability and Limitation of Access. SFDC shall ensure that its personnel engaged in the Processing of
Personal Data are informed of the confidential nature of the Personal Data, have received appropriate training on their
responsibilities and have executed written confidentiality agreements. SFDC shall
(i) ensure that such confidentiality obligations survive the termination of the personnel engagement;
(ii) take commercially reasonable steps to ensure the reliability of any SFDC personnel engaged in the Processing of
Personal Data; and
(iii) ensure that SFDC’s access to Personal Data is limited to those personnel performing Services in accordance with
the Agreement, any applicable Order Form(s) and Documentation.
4.2. Data Protection Officer. Members of the SFDC Group have appointed a data protection officer. The appointed person may
be reached at [email protected].
5. SUB-PROCESSORS
5.1. Appointment of Sub-processors. Customer acknowledges and agrees that (a) SFDC’s Affiliates may be retained as Sub-
processors; and (b) SFDC and SFDC’s Affiliates respectively may engage third-party Sub-processors to provide the Services.
SFDC or an SFDC Affiliate has entered into a written agreement with each Sub-processor containing, in substance, data
protection obligations no less protective than those in the Agreement with respect to the protection of Personal Data to the
extent applicable to the nature of the Services provided by such Sub-processor.
5.2. Current List of Sub-processors and Notification of New Sub-processors. The current list of Sub-processors engaged in
Processing Personal Data for the performance of each applicable Service, including a description of their processing
activities and countries of location, is listed under the Infrastructure and Sub-processor Documentation which can be found
on SFDC’s Trust and Compliance webpage at https://www.salesforce.com/company/legal/trust-and-compliance-
documentation/ (“Infrastructure and Sub-processor Documentation”, also accessible via
http://www.salesforce.com/company/legal/agreements/ under the “Trust and Compliance Documentation” link). Customer
hereby consents to these Sub-processors, their locations and processing activities as it pertains to their Personal Data. The
Infrastructure and Sub-processor Documentation contains a mechanism to subscribe to notifications of new Sub-processors
for each applicable Service, and if Customer subscribes, SFDC shall provide notification of a new Sub-processor(s) before
authorizing any new Sub-processor(s) to Process Personal Data to provide the applicable Services.
5.3. Objection Right for New Sub-processors. Customer may object to SFDC’s use of a new Sub-processor by notifying SFDC
promptly in writing within thirty (30) days of receipt of SFDC’s notice in accordance with the mechanism set out in section
5.2. If Customer objects to a new Sub-processor as permitted in the preceding sentence, SFDC will use reasonable efforts to
make available to Customer a change in the Services or recommend a commercially reasonable change to Customer’s
configuration or use of the Services to avoid Processing of Personal Data by the objected-to new Sub-processor without
unreasonably burdening Customer. If SFDC is unable to make available such change within a reasonable period of time,
which shall not exceed sixty (60) days, Customer may terminate the applicable Order Form(s) with respect only to those
Services which cannot be provided by SFDC without the use of the objected-to new Sub-processor by providing written
notice to SFDC. SFDC will refund Customer any prepaid fees covering the remainder of the term of such Order Form(s)
following the effective date of termination with respect to such terminated Services, without imposing a penalty for such
termination on Customer.
5.4. Liability. SFDC shall be liable for the acts and omissions of its Sub-processors to the same extent SFDC would be liable if
performing the services of each Sub-processor directly under the terms of this DPA, unless otherwise set forth in the
Agreement.
6.3. Audit Program. SFDC shall maintain an audit program to help ensure compliance with the obligations set out in this DPA
and shall make available to Customer information to demonstrate compliance with the obligations set out in this DPA,
including those obligations required by applicable Data Protection Laws and Regulations, as set forth in this section 6.2.
6.3.1. Access to Third-Party Certifications and Audits Information. Upon Customer’s written request at reasonable
intervals, and subject to the confidentiality obligations set forth in the Agreement, SFDC shall:
(i) the make available to Customer (or Customer’s Third-Party Auditor - as defined below in section 6.2.4) information
regarding SFDC’s compliance with the obligations set forth in this DPA in the form of a copy of SFDC’s then most
recent third-party audits or certifications set forth in the Security, Privacy and Architecture Documentation. Such
third-party audits or certifications may also be shared with Customer’s competent supervisory authority on its request;
(ii) provide Customer with a report and/or confirmation of SFDC's audits of third-party Sub-processors’ compliance with
the data protection controls set forth in this DPA and/or a report of third-party auditors’ audits of third party Sub-
processors that have been provided by those third-party Sub-processors to SFDC, to the extent such reports or
evidence may be shared with Customer (“Third-party Sub-processor Audit Reports”). Customer acknowledges that
(i) Third-party Sub-processor Audit Reports shall be considered Confidential Information as well as confidential
information of the third-party Sub-processor and (ii) certain third-party Sub-processors to SFDC may require
Customer to execute a non-disclosure agreement with them in order to view a Third-party Sub-processor Audit
Report.
6.3.2. On-Site Audit. Customer can request an on-site audit of SFDC’s Processing activities covered by this DPA (“On-
Site Audit”). An On-Site Audit may be conducted by Customer either itself or through a Third-Party Auditor (as defined
below in section 6.3.4) selected by Customer when:
(i) the information available pursuant to section “Third-Party Certifications and Audits” is not sufficient to demonstrate
compliance with the obligations set out in this DPA and its Schedules;
(ii) Customer has received a notice from SFDC of a Customer Data Incident; or
(iii) such an audit is required by Data Protection Laws and Regulations or by Customer’s competent supervisory authority.
Any On-Site Audits will be limited to Customer Data Processing and storage facilities operated by SFDC or any of SFDC’s
Affiliates.
6.3.3. Reasonable Exercise of Rights. An On-Site Audit shall be conducted by Customer or its Third-Party Auditor:
(i) acting reasonably, in good faith, and in a proportional manner, taking into account the nature and complexity of the
Services used by Customer;
(ii) up to one time per year with at least three weeks’ advance written notice. If an emergency justifies a shorter notice
period, SFDC will use good faith efforts to accommodate the On-Site Audit request; and
(iii) during SFDC’s normal business hours, under reasonable duration and shall not unreasonably interfere with SFDC’s
day-to-day operations.
Customer acknowledges that SFDC operates a multi-tenant cloud environment. Before any On-Site Audit commences,
Customer and SFDC shall mutually agree upon the scope, timing, and duration of the audit and the reimbursement rate for
which Customer shall be responsible. All reimbursement rates shall be reasonable, taking into account the resources
expended by or on behalf of SFDC. SFDC shall have the right to reasonably adapt the scope of any On-Site Audit to avoid
or mitigate risks with respect to, and including, service levels, availability, and confidentiality of other SFDC customers’
information.
6.3.4. Third-Party Auditor. A Third-Party Auditor means a third-party independent contractor that is not a competitor of
SFDC. An On-Site Audit can be conducted through a Third Party Auditor if:
(i) prior to the On-Site Audit, the Third-Party Auditor enters into a non-disclosure agreement containing confidentiality
provisions no less protective than those set forth in the Agreement to protect SFDC’s proprietary information; and
(ii) the costs of the Third-Party Auditor are at Customer’s expense.
6.3.5. Findings. Customer must promptly provide SFDC with information regarding any non-compliance discovered during
the course of an On-Site Audit.
6.4. Data Protection Impact Assessment. Upon Customer’s request, SFDC shall provide Customer with reasonable cooperation
and assistance needed to fulfill Customer’s obligation under Data Protection Laws and Regulations to carry out a data
protection impact assessment related to Customer’s use of the Services, to the extent Customer does not otherwise have
access to the relevant information, and to the extent such information is available to SFDC.
destruction, loss, alteration, unauthorized disclosure of, or access to Customer Data, including Personal Data, transmitted,
stored or otherwise Processed by SFDC or its Sub-processors of which SFDC becomes aware (a “Customer Data Incident”).
SFDC shall make reasonable efforts to identify the cause of such Customer Data Incident and take such steps as SFDC
deems necessary and reasonable to remediate the cause of such a Customer Data Incident to the extent the remediation is
within SFDC’s reasonable control. The obligations herein shall not apply to incidents that are caused by Customer or
Customer’s Users.
8.2 Sub-processors requirements. SFDC shall ensure that Sub-processors involved in the Processing of Personal Data are
subject to the relevant commitments regarding Government Access Requests in the Standard Contractual Clauses and
Salesforce Processor BCR.
Affiliate, and (ii) the Customer that is the contracting party to the Agreement shall exercise any such rights under this
DPA, not separately for each Authorized Affiliate individually, but in a combined manner for itself and all of its Authorized
Affiliates together (as set forth, for example, in section 10.3.2, below).
10.3.2 The parties agree that the Customer that is the contracting party to the Agreement shall, when carrying out an On-
Site Audit of the procedures relevant to the protection of Personal Data, take all reasonable measures to limit any impact
on SFDC and its Sub-Processors by combining, to the extent reasonably possible, several audit requests carried out on
behalf of itself and all of its Authorized Affiliates in one single audit.
12.4. Impact of local laws. As of the Effective Date, SFDC has no reason to believe that the laws and practices in any third
country of destination applicable to its Processing of the Personal Data as set forth in the Infrastructure and Sub-processors
Documentation, including any requirements to disclose Personal Data or measures authorizing access by a Public Authority,
prevent SFDC from fulfilling its obligations under this DPA. If SFDC reasonably believes that any existing or future enacted
or enforceable laws and practices in the third country of destination applicable to its Processing of the Personal Data ("Local
Laws") prevent it from fulfilling its obligations under this DPA, it shall promptly notify Customer. In such a case, SFDC
shall use reasonable efforts to make available to the affected Customer a change in the Services or recommend a
commercially reasonable change to Customer’s configuration or use of the Services to facilitate compliance with the Local
Laws without unreasonably burdening Customer. If SFDC is unable to make available such change promptly, Customer may
terminate the applicable Order Form(s) and suspend the transfer of Personal Data in respect only to those Services which
cannot be provided by SFDC in accordance with the Local Laws by providing written notice in accordance with the “Notices”
section of the Agreement. Customer shall receive a refund of any prepaid fees for the period following the effective date of
termination for such terminated Services.
List of Schedules
Schedule 1: Transfer Mechanisms for European Data Transfers
Schedule 2: Description of Processing/Transfer
Print Name: Joachim Wettermark ______________ Print Name: Joachim Wettermark ______________
Title: Director, President, and Secretary________ Title: Director, President, and Secretary________
VLOCITY, LLC
Signature: _______________________________
Date: 11/20/2023__________________________
2.9. Complaints - Redress. For the purposes of clause 11, and subject to section 3 of this DPA, SFDC shall inform data subjects
on its website of a contact point authorized to handle complaints. SFDC shall inform Customer if it receives a complaint
by, or a dispute from, a Data Subject with respect to Personal Data and shall without undue delay communicate the
complaint or dispute to Customer. SFDC shall not otherwise have any obligation to handle the request (unless otherwise
agreed with Customer). The option under clause 11 shall not apply.
until such laws are amended to no longer apply to a legal entity. In such circumstances, general and specific references in
the Standard Contractual Clauses to GDPR or EU or Member State Law shall have the same meaning as the equivalent
reference in Swiss Data Protection Laws.
2.17. Conflict. The Standard Contractual Clauses are subject to this DPA and the additional safeguards set out hereunder. The
rights and obligations afforded by the Standard Contractual Clauses will be exercised in accordance with this DPA, unless
stated otherwise. In the event of any conflict or inconsistency between the body of this DPA and the Standard Contractual
Clauses, the Standard Contractual Clauses shall prevail.
3.1. Instructions and notifications. For the purposes of clause 8.1(a), Customer hereby informs SFDC that it acts as Processor
under the instructions of the relevant Controller in respect of Personal Data. Customer warrants that its Processing
instructions as set out in the Agreement and this DPA, including its authorizations to SFDC for the appointment of Sub-
processors in accordance with this DPA, have been authorized by the relevant Controller. Customer shall be solely
responsible for forwarding any notifications received from SFDC to the relevant Controller where appropriate.
3.2. Security of Processing. For the purposes of clause 8.6(c) and (d), SFDC shall provide notification of a personal data
breach concerning Personal Data Processed by SFDC to Customer.
3.3. Documentation and Compliance. For the purposes of clause 8.9, all enquiries from the relevant Controller shall be
provided to SFDC by Customer. If SFDC receives an enquiry directly from a Controller, it shall forward the enquiry to
Customer and Customer shall be solely responsible for responding to any such enquiry from the relevant Controller where
appropriate.
3.4. Data Subject Rights. For the purposes of clause 10 and subject to section 3 of this DPA, SFDC shall notify Customer
about any request it has received directly from a Data Subject without obligation to handle it (unless otherwise agreed),
but shall not notify the relevant Controller. Customer shall be solely responsible for cooperating with the relevant
Controller in fulfilling the relevant obligations to respond to any such request.
1. LIST OF PARTIES
Data exporter(s): Identity and contact details of the data exporter(s) and, where applicable, of its/their data protection officer and/or
representative in the European Union
Address:
Activities relevant to the data transferred under these clauses: Performance of the Services pursuant to the Agreement and as further
described in the Documentation.
Role: For the purposes of SCC Module 2 Customer and/or its Authorized Affiliate is a Controller. For the purposes of SCC Module
3 Customer and/or its Authorized Affiliate is a Processor.
Data importer(s): Identity and contact details of the data importer(s), including any contact person with responsibility for data
protection
Address: Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, USA
Contact person’s name, position and contact details: Lindsey Finch, DPO, [email protected]
Activities relevant to the data transferred under these clauses: Performance of the Services pursuant to the Agreement and as further
described in the Documentation.
Role: Processor
Customer may submit special categories of data to the Services, the extent of which is determined and controlled by Customer in
its sole discretion, and which is for the sake of clarity Personal Data with information revealing racial or ethnic origin, political
opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the
purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual
orientation.
The applicable security measures are described under the Security, Privacy and Architecture Documentation applicable to the
specific Services purchased by Customer, as updated from time to time, and accessible via SFDC’s Trust and Compliance webpage
at https://www.salesforce.com/company/legal/trust-and-compliance-documentation/ (also accessible via
http://www.salesforce.com/company/legal/agreements/ under the “Trust and Compliance Documentation” link), or as otherwise
made reasonably available by SFDC.
8. DURATION OF PROCESSING
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period:
Subject to section 9 of the DPA, SFDC will Process Personal Data for the duration of the Agreement, unless otherwise agreed upon
in writing.
9. SUB-PROCESSOR TRANSFERS
For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing:
As per 7 above, the Sub-processor will Process Personal Data as necessary to perform the Services pursuant to the Agreement.
Subject to section 9 of this DPA, the Sub-processor will Process Personal Data for the duration of the Agreement, unless otherwise
agreed in writing.
Identities of the Sub-processors used for the provision of the Services and their country of location are listed under the Infrastructure
and Sub-processor Documentation which can be found on SFDC’s Trust and Compliance webpage (also accessible via
http://www.salesforce.com/company/legal/agreements/ under the “Trust and Compliance Documentation” link).