SUB-PROCESSOR SCHEDULE
SUB-PROCESSOR SCHEDULE
Food Handler Solutions, LLC
Effective Date: September 1, 2026 | Last Updated: September 1, 2026
1. Purpose
This Sub-Processor Schedule ("Schedule") identifies the third-party sub-processors that Food Handler Solutions, LLC ("Food Handler Solutions," "we," "us," or "our") engages to process personal information on behalf of our customers in connection with the services, courses, training, certifications, and content we provide (the "Services").
This Schedule supplements the Food Handler Solutions Privacy Policy and any separate written agreement between Food Handler Solutions and a customer. If a customer's written agreement with Food Handler Solutions contains sub-processor terms that are more specific or more protective than this Schedule, that agreement controls with respect to the personal information governed by it.
2. Definitions
"Sub-Processor" means any third party engaged by Food Handler Solutions to process personal information on our behalf in connection with the Services.
"Customer Data" means personal information that Food Handler Solutions processes on behalf of a customer in connection with the Services, including information the customer provides to us and information generated through use of the Services by the customer's learners or authorized users.
3. Current Sub-Processors
The table below lists each active sub-processor engaged by Food Handler Solutions, together with:
- (a) Entity name;
- (b) Function performed on our behalf;
- (c) Categories of Customer Data accessed;
- (d) Processing and storage location (country level); and
- (e) Confirmation that a written agreement is in place obligating the sub-processor to protect Customer Data on terms no less stringent than those Food Handler Solutions owes to its customers.
| (a) Entity | (b) Function Performed | (c) Categories of Customer Data Accessed | (d) Processing / Storage Location | (e) Written Agreement in Place |
| Pagely, Inc. | Managed WordPress hosting; storage of website databases, files, and nightly backups on Amazon Web Services (AWS) infrastructure under Pagely's AWS account. | All Customer Data present on the hosted site or database, which may include: learner name; email address; employer / school / facility; course and completion records; IP and device identifiers; and transactional payment metadata (no full payment card numbers — card data is handled by PCI-compliant payment processors and is not stored on the hosted database). | United States (default AWS region: US East — Virginia). Food Handler Solutions uses US regions only. | Yes. Data Processing Agreement / Master Services Agreement in place with Pagely obligating confidentiality, security, and breach-notification terms no less stringent than the customer commitments described above. |
| Google LLC (Google Analytics) | Website analytics — measurement of Site traffic, page views, sessions, and aggregated usage patterns used to improve the Services. IP-anonymization / IP truncation is enabled. | Only IP / device identifiers and pseudonymous online identifiers (cookies). Learner name, email, employer, course and completion records, and payment metadata are NOT sent to Google Analytics by Food Handler Solutions. | United States (primary), with Google global infrastructure. Data may transit Google data centers in the United States and other countries operated by Google LLC. | Yes. Google Analytics Terms of Service and Google Ads Data Processing Terms (incorporated by reference) are in effect, obligating Google to security, confidentiality, and processor-level protections no less stringent than the customer commitments described above. |
| Mailgun Technologies, Inc. (a Sinch company) | Transactional and notification email delivery — sending account, course-completion, receipt, password-reset, and marketing emails on behalf of Food Handler Solutions. Message bodies are held temporarily by Mailgun for delivery and retry (approximately 3–7 days). | Learner name and email address, and — where included in the message body — course and completion information (e.g., certificate holder name, course title, completion date). Employer identifiers, IP / device identifiers, and payment metadata are not routinely sent to Mailgun. | United States (Mailgun US region — AWS US infrastructure). Food Handler Solutions uses the Mailgun US region only. | Yes. Mailgun's Data Processing Addendum ("DPA") is in effect, obligating Mailgun to confidentiality, security, sub-processor management, and breach-notification terms no less stringent than the customer commitments described above. |
4. Notice of Changes to Sub-Processors
Food Handler Solutions will provide affected customers with prior written notice before engaging any new sub-processor that will process their Customer Data, or before making a material change to an existing sub-processor arrangement.
Where a customer's written agreement with Food Handler Solutions specifies a notice period or objection window, that agreement controls. Where no notice period is specified, we will provide at least fifteen (15) days' prior written notice before the new sub-processor begins processing Customer Data.
If a customer reasonably objects to a new sub-processor on the basis that the sub-processor cannot meet the data-protection obligations we owe that customer, Food Handler Solutions will either (a) not engage the sub-processor, or (b) work in good faith with the customer to identify an alternative acceptable to the customer.
5. Written Agreements With Sub-Processors
Food Handler Solutions enters into a written agreement with every sub-processor that will process Customer Data. Each such agreement obligates the sub-processor to protect the data on terms no less stringent than the terms Food Handler Solutions owes to its customers, including obligations of confidentiality, security, purpose limitation, and breach notification. Food Handler Solutions remains fully responsible and liable for the acts and omissions of its sub-processors.
6. Restrictions on Sub-Processor Use of Customer Data
Food Handler Solutions does not authorize any sub-processor to:
- Sell Customer Data;
- Use Customer Data to inform, influence, or enable targeted advertising;
- Share or integrate Customer Data with social media platforms or third-party advertising networks;
- Employ behavioral tracking, cross-platform tracking, or device fingerprinting to track users across websites or services;
- Develop a profile of a learner or a family member/guardian; or
- Train, develop, or improve artificial intelligence or machine learning models on Customer Data, except with the customer's prior written authorization.
7. Requesting the Current Sub-Processor List
The most current version of this Schedule is available at foodhandlersolutions.com/subprocessors. A customer may also request an up-to-date copy at any time by emailing privacy@foodhandlersolutions.com.
8. Contact
For questions about this Sub-Processor Schedule, to request notice of sub-processor changes, or to raise an objection to a proposed sub-processor, please contact:
Food Handler Solutions, LLC
Attn: Privacy Officer
2931 Ridge Rd Ste 101 #537
Rockwall, TX 75032
United States
Privacy inquiries: privacy@foodhandlersolutions.com
Legal inquiries: legal@foodhandlersolutions.com
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