This provision states that enabling NLP functionality for Einstein Bots causes Customer Data to be routed to a specific region determined by the location of the customer's Salesforce Services org: Germany for EMEA, Japan, India, or the United States for APAC, and the United States for all other regions.
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This provision establishes that NLP-processed data from Einstein Bots is stored in a location determined by the customer's primary org region rather than by a separate regional election, and that APAC customers may have their data stored in the United States as a possible outcome, which may not align with data residency expectations for customers in APAC jurisdictions with localization requirements.
Under this clause, enabling Einstein Bots NLP functionality routes Customer Data to a region that is determined by the location of the primary Salesforce Services org. The document states that APAC customers may have NLP-related data stored in Japan, India, or the United States, meaning the specific destination within that set is not contractually fixed at the point of feature enablement.
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"If a Customer enables NLP functionality for Bots and has Salesforce Services data stored in the EMEA region, then some related Customer Data will be stored in Germany. If a Customer enables NLP functionality for Bots and has Salesforce Services data stored in the APAC region, then some related Customer Data will be stored in Japan, India or the United States. If a Customer enables NLP functionality for Bots and has Salesforce Services data stored outside of EMEA or APAC, then some related Customer Data will be stored in the United States.— Excerpt from Slack's Slack Sub-Processors (Salesforce)
(1) REGULATORY LANDSCAPE: This provision engages data protection frameworks in EMEA and APAC jurisdictions, including GDPR for EU and EEA customers routed to Germany, and applicable laws in Australia, Japan, South Korea, and Singapore for APAC customers whose data may be routed to the United States. Transfers to the United States from APAC jurisdictions require evaluation under applicable transfer mechanisms or adequacy frameworks. (2) GOVERNANCE EXPOSURE: Medium. The indeterminate nature of the APAC routing (Japan, India, or the United States) means that the specific processing location for NLP data cannot be precisely specified in records of processing activities at the time of feature enablement, which may complicate transfer impact assessments for APAC customers. (3) JURISDICTION FLAGS: APAC customers in jurisdictions including Australia, South Korea, and Singapore face heightened exposure where Customer Data may be routed to the United States, requiring evaluation of transfer mechanisms. EU and EEA customers benefit from Germany-based routing, which is within the EU, reducing cross-border transfer concerns for that population. (4) CONTRACT AND VENDOR IMPLICATIONS: Organizations enabling Einstein Bots NLP should confirm that their DPA and applicable transfer mechanisms cover all three possible APAC routing destinations (Japan, India, United States) to ensure compliance regardless of which location is ultimately used. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should document the NLP routing rule for their org's region in records of processing activities, confirm that transfer mechanisms cover all applicable routing destinations, and evaluate whether customers or data subjects in their APAC environment require notification of potential US routing.
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This provision establishes that NLP-processed data from Einstein Bots is stored in a location determined by the customer's primary org region rather than by a separate regional election, and that APAC customers may have their data stored in the United States as a possible outcome, which may not align with data residency expectations for customers in APAC jurisdictions with localization …
Under this clause, enabling Einstein Bots NLP functionality routes Customer Data to a region that is determined by the location of the primary Salesforce Services org. The document states that APAC customers may have NLP-related data stored in Japan, India, or the United States, meaning the specific destination within that set is not contractually fixed at the point of feature …
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