GDPR Articles 44-49 | Schrems II

Transfer Impact Assessment

Assessment of international data transfers to third countries

Executive Summary

MultiComply transfers personal data to third countries (primarily the United States) through our subprocessors. Following the Schrems II judgment (CJEU C-311/18), we have conducted this Transfer Impact Assessment to evaluate the lawfulness and security of these transfers.

3
Transfers Assessed
3
With SCCs in Place
3
With Supplementary Measures

Overall Conclusion

Based on our assessment, the international data transfers conducted by MultiComply are lawful under GDPR Chapter V when considering:

  • Standard Contractual Clauses are in place with all recipients
  • Technical supplementary measures (encryption) prevent access to data in clear
  • All recipients maintain robust security certifications
  • Data minimization principles are applied
  • Recipients have committed to challenging unlawful government requests

Individual Transfer Assessments

Supabase Inc.

United States

MEDIUM RISK

Purpose of Transfer

Encrypted database backups for disaster recovery

Data Categories

  • User account data (name, email)
  • Generated documents
  • Activity logs
  • Form responses

Legal Basis for Transfer

Standard Contractual Clauses (EU Commission 2021/914, Module 2)

SCCs in Place
Supplementary Measures

Third Country Laws Assessment (US)

FISA 702:Potentially applicable (Supabase is a US company)
CLOUD Act:Potentially applicable
Supplementary Measures Applied:
  • All data encrypted at rest with AES-256 (keys stored in EU)
  • Encryption in transit with TLS 1.3
  • Supabase cannot decrypt data without EU-held keys
  • Access controls limiting US personnel access to encrypted data only
  • Supabase has committed to challenging unlawful government requests
ISO 27001
SOC 2 Type II
Last assessed: 2025-11-25 | Next review: 2026-05-25

Stripe, Inc.

United States

LOW RISK

Purpose of Transfer

Payment processing and subscription management

Data Categories

  • Name and email
  • Billing address
  • Payment card details (tokenized)
  • Transaction history

Legal Basis for Transfer

Standard Contractual Clauses (EU Commission 2021/914, Module 2)

SCCs in Place
Supplementary Measures

Third Country Laws Assessment (US)

FISA 702:Potentially applicable
CLOUD Act:Potentially applicable
Supplementary Measures Applied:
  • Card data tokenized - raw card numbers never stored or transmitted
  • PCI-DSS Level 1 compliance (highest security standard)
  • Strong Customer Authentication (SCA) for EU payments
  • Data minimization - only necessary payment data processed
  • Stripe has robust legal challenge procedures
PCI-DSS Level 1
SOC 2 Type II
ISO 27001
Last assessed: 2025-11-25 | Next review: 2026-05-25

Cloudflare, Inc.

United States (Global Edge Network)

LOW RISK

Purpose of Transfer

Security services, CAPTCHA, DDoS protection

Data Categories

  • IP addresses
  • Browser fingerprints
  • Request metadata
  • User agent strings

Legal Basis for Transfer

Standard Contractual Clauses + Binding Corporate Rules

SCCs in Place
Supplementary Measures

Third Country Laws Assessment (US)

FISA 702:Limited applicability (metadata only, no content)
CLOUD Act:Potentially applicable
Supplementary Measures Applied:
  • Only metadata processed (no document content)
  • Turnstile CAPTCHA is privacy-first (no tracking cookies)
  • Data automatically deleted after short retention period
  • Cloudflare has BCRs approved by EU DPAs
  • EU traffic primarily processed in EU data centers
ISO 27001
SOC 2 Type II
EU BCRs
Last assessed: 2025-11-25 | Next review: 2026-05-25

Assessment Methodology

This Transfer Impact Assessment follows the methodology recommended by the European Data Protection Board (EDPB) in Recommendations 01/2020 on measures that supplement transfer tools.

Step 1: Know Your Transfers

Mapped all transfers to third countries via subprocessors

Step 2: Identify Transfer Tools

Verified SCCs and BCRs are in place with all recipients

Step 3: Assess Third Country Laws

Analyzed US surveillance laws (FISA 702, CLOUD Act) applicability

Step 4: Supplementary Measures

Implemented technical measures (encryption) to prevent access in clear

Questions About Data Transfers

If you have questions about our international data transfers or wish to request copies of our Data Processing Agreements with subprocessors, please contact us:

Contact Privacy Team

This Transfer Impact Assessment is reviewed semi-annually or when significant changes occur to our data transfer arrangements.

Last updated: November 25, 2025