In the delivery of our Services, D2L and its affiliates may engage and use data processors to assist in providing D2L Services who may have access to and/or process Client Data (“Subprocessors”). This page provides information regarding each of these Subprocessors including a description of the Subprocessor services, the type of data made available for processing, and the location of data processing. Terms used on this page but not defined have the meaning set forth in the applicable written agreement between your organization and D2L (the "Agreement").
To read about D2L's third-party suppliers in greater detail, refer to the Integrations documentation in Community.
Note that typical types of User Data include:
- First name
- Last name
- Grade information
- Location data
- Student unique identifier
- Email address
Cloud Providers
Subprocessor: AWS
Purpose: Infrastructure as a Service provider.
Location of Processing: USA, Canada, Australia, Republic of Ireland, Singapore, India, depending on the location of the customer
Degree of Personal Data Processing: User Data
Third-Party Apps in Brightspace Core (Client Facing)
Subprocessor: Bongo (optionally used if enabled in Brightspace)
Purpose:
Virtual Classroom: Schedule live discussions, office hours, video-based training, and more. Video sessions can be automatically recorded and seamlessly embedded directly into a course alongside other learning materials
Video Assignments: Deliver structured, video-based assessments that evaluate learners on speeches, presentations, and more. Instructors can easily grade video assessments and add time-stamped feedback, showing learners exactly where they need to improve.
Location of Processing: The USA, Republic of Ireland, Canada (except video transcoding), Australia (except video transcoding), South America (except video transcoding, depending on the location of the customer
Degree of Personal Data Processing: User Data – names and grades
Optional Third-Party Apps (Client Facing)
Subprocessor: Atomic Jolt
Purpose: Provide users with effective learning and teaching tools through Atomic Search and Atomic Assessments
Location of Processing: US-East, Australia, Ireland
Degree of Personal Data Processing: User Data
Subprocessor: Brightspace Extended Administration by Genius
Purpose: Enables corporate users to use decentralized workflows to leverage shared resources and create new assets
Location of Processing: AWS (ca-central-1 [CA05-Canada] ), us-east-1 (US04-US), Azure (Canada Central, US-East)
Degree of Personal Data Processing: Basic user information (First and Last Name, Email Address), course information, course registration, course history (Course Name, Completion Date, Completion Status)
Subprocessor: Class Technologies
Purpose: Class is a synchronous online learning platform and virtual classroom that adds training and learning tools to Zoom and Microsoft Teams
Location of Processing: United States, Canada, United Kingdom, Singapore, Australia, and New Zealand
Degree of Personal Data Processing: Personal data is collected for purposes related to the contract between Class and the user, and shall be retained until the contract is fulfilled
Subprocessor: Copyleaks
Purpose: Provides AI-powered text analysis to identify potential plagiarism and uncover AI-generated content
Location of Processing: US-East, Europe
Degree of Personal Data Processing: Two copies of User Data are stored on separate Google Cloud data centers to ensure data safety
Subprocessor: Credly
Purpose: A digital credential solution that includes issuing, verifying, and managing digital credentials with Brightspace
Location of Processing: United States, Europe
Degree of Personal Data Processing: User personal data
Subprocessor: Domo
Purpose: Formatting of reports requested from the system by clients
Location of Processing: The USA, Republic of Ireland, depending on the location of the customer
Degree of Personal Data Processing: User personal data within the system
Subprocessor: FeedbackFruits
Purpose: Implements diverse pedagogy tools like Comprehension, Interactive Presentation, and a suite of peer feedback tools
Location of Processing: United States, Canada, Australia, Europe
Degree of Personal Data Processing: Student work only during processing
Subprocessor: Integrity Advocate
Purpose: A software company that provides identity verification, participation monitoring, and examination proctoring for online training events.
Location of Processing: Canada
Degree of Personal Data Processing: User Data - Student ID for validation (which is deleted after a short period of time from its servers)
Subprocessor: OpenSesame
Purpose: Provides a catalog of eLearning courses from the world's top publishers
Location of Processing: United States, Europe
Degree of Personal Data Processing: User Data shared externally only for the purpose of obtaining a certification or credential after permission is granted by the user
Subprocessor: ShuffleLabs (MS Teams Connector)
Purpose: ShuffleExchange is an integration platform that runs the Brightspace Course Connector for Microsoft Teams, which connects Brightspace to Microsoft Teams.
Location of Processing: USA, Canada, Australia, Republic of Ireland, Singapore, depending on the location of the client.
Degree of Personal Data Processing: First Name, Last Name, Email Address, User’s role in Brightspace
Subprocessor: Urkund
Purpose: An automatic text-recognition system made for detecting, preventing, and handling plagiarism.
Location of Processing: USA or Europe depending on the location of the customer
Degree of Personal Data Processing: Email address, Linguistic style, IP address, Shibboleth identity, Name, Document (which may contain personal data in the text of the document), Email messages (which may contain personal data in the body of the message), Submission comments (which may contain personal data in the text)
Subprocessor: Workato
Purpose: D2L Link, powered by Workato, integrates Brightspace with other systems users use each day to automate manual tasks and improve data accuracy
Location of Processing: US-East, Australia, Europe
Degree of Personal Data Processing: User and organizational data across connected systems
Subprocessor: YuJa
Purpose: Offers cloud platforms and applications like YuJa Panorama and YuJa Verity
Location of Processing: United States, Europe
Degree of Personal Data Processing: Personal information is used to understand and meet users' product needs and preferences, develop new services and product offerings, enhance existing service and product offerings, manage YuJa's day-to-day business and internal operations, and meet legal and regulatory requirements in the jurisdictions in which YuJa operates
Platform Apps (Internal)
Subprocessor: Honeycomb
Purpose: Honeycomb is a platform that enhances observability in software systems, helping teams monitor and troubleshoot complex applications. The platform collects and displays OpenTelemetry events, providing realtime insights into application performance. Additionally, Honeycomb allows users to visualize system behavior to identify issues quickly.
Location of Processing: USA
Degree of Personal Data Processing: User ID
Support
Subprocessor: D2L Subsidiaries (D2L Corporation (Canada), D2L Australia Pty. Ltd. (Australia))
Purpose: Providing implementation services and support
Location of Processing: Canada and Australia
Degree of Personal Data Processing: User personal data within the system
Subprocessor: Medallia
Purpose: Platform for client satisfaction surveys
Location of Processing: Canada
Degree of Personal Data Processing: First name, Last Name, and email address
Subprocessor: ServiceCloud
Purpose: D2L’s ticketing systems
Location of Processing: ServiceCloud - Canada
Degree of Personal Data Processing: Users’ first and last names along with email address, phone number, and email communication.
Subprocessor: The Results Companies/Support Ninja (used if Controller purchases End User Support)
Purpose: End-user support
Location of Processing: Mexico; other locations depending on the location of the client
Degree of Personal Data Processing: User personal data within the system