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Cloud recordings, in-meeting chat transcripts, and file attachments submitted to Zoom support agents are conditionally shared with four subprocessors: MaestroQA for quality assurance, SendSafely for encrypted file transfer, ServiceNow for customer service platform functions, and TaskUS for support operations, with processing locations spanning Ireland, the United States, Germany, and the Philippines.
This analysis describes what Zoom's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that Customer Content including recordings and chat transcripts submitted through support interactions may be shared with vendors in the Philippines and multiple EU and US jurisdictions; TaskUS is located in the Philippines and Croatia, jurisdictions lacking EU adequacy status, with SCCs as the stated transfer mechanism.
Under this provision, customers who submit cloud recordings or chat transcripts as attachments to Zoom support tickets authorize those materials to be processed by up to four third-party vendors across the United States, Ireland, Germany, and the Philippines. The agreement conditions this sharing on the customer's affirmative act of providing the content to a support agent.
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"Communications Content such as cloud recordings or in-meeting chat transcripts may be shared with MaestroQA but only if Customer chooses to provide it directly to a Zoom support agent through a support interaction, i.e., as an attachment to a support ticket... Communications Content such as attachments may be shared with SendSafely but only if Customer chooses to provide it directly to a Zoom support agent through a support interaction (i.e., as an attachment to a support ticket)... Communications Content such as cloud recordings or in-meeting chat transcripts may be shared with ServiceNow but only if Customer chooses to provide it directly to a Zoom support agent through a support interaction... Communications Content such as cloud recordings or in-meeting chat transcripts may be shared with TaskUS but only if Customer chooses to provide it directly to a Zoom support agent through a support interaction.Excerpt from Zoom's Sub-Processors
1) REGULATORY LANDSCAPE: This provision engages GDPR for transfers of potentially sensitive Customer Content to TaskUS in the Philippines and Croatia, both lacking EU adequacy status, under SCCs. The Philippines engages its own Data Privacy Act of 2012 enforced by the National Privacy Commission. Transfers of recordings and chat transcripts may involve special categories of personal data depending on content, which would engage GDPR Article 9 heightened protection requirements if health, biometric, or other sensitive data is present in meeting recordings. 2) GOVERNANCE EXPOSURE: Medium. The conditionality of sharing on customer action (submitting content to support) provides a meaningful operational constraint, but organizations that routinely share recordings or transcripts via support tickets should assess whether their data subject notices and Records of Processing Activities reflect these four subprocessors. TaskUS in the Philippines represents a non-adequacy jurisdiction with active operations, warranting specific transfer impact assessment. 3) JURISDICTION FLAGS: EU and EEA organizations should assess whether SCC-based transfers to the Philippines are supported by adequate supplementary measures, particularly given the Philippines' data protection regulatory environment. Organizations processing recordings containing sensitive personal data of EU residents should assess whether GDPR Article 9 compliance is maintained through the support interaction pathway. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should note that the support interaction pathway may not be prominently disclosed in Zoom's primary DPA; teams should confirm that their DPA covers all four support subprocessors. The conditionality of sharing on customer action means that organizations can operationally limit exposure by instructing personnel not to submit recordings or transcripts via support tickets unless necessary. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether internal data handling policies for Zoom support interactions account for the four named subprocessors. Organizations with data residency requirements should evaluate whether submitting recordings or transcripts to Zoom support is consistent with those requirements given the Philippines and Croatia processing locations. Privacy notices should reflect the possibility of support-related data sharing with these vendors.
This provision establishes that Customer Content including recordings and chat transcripts submitted through support interactions may be shared with vendors in the Philippines and multiple EU and US jurisdictions; TaskUS is located in the Philippines and Croatia, jurisdictions lacking EU adequacy status, with SCCs as the stated transfer mechanism.
Under this provision, customers who submit cloud recordings or chat transcripts as attachments to Zoom support tickets authorize those materials to be processed by up to four third-party vendors across the United States, Ireland, Germany, and the Philippines. The agreement conditions this sharing on the customer's affirmative act of providing the content to a support agent.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Zoom.