Standard Contractual Clauses (SCCs)

Layer 9 Solutions Ltd │ Effective: 01 May 2025

Layer 9 Solutions Ltd uses Standard Contractual Clauses (SCCs) to safeguard international transfers of personal data in accordance with the UK GDPR and EU GDPR requirements.

1. What Are SCCs?

Standard Contractual Clauses (SCCs) are pre-approved legal contracts issued by the European Commission and UK Information Commissioner's Office (ICO). They ensure that when personal data is transferred outside the UK or EEA, it remains protected to GDPR standards.

2. Why We Use SCCs

We occasionally use infrastructure and sub-processors based outside the UK and EEA — for example, cloud servers in the United States to deliver services such as VPN access or US-based website hosting. When such transfers of personal data occur, we rely on SCCs to ensure compliance with legal obligations and to uphold your rights.

3. Which SCCs Apply

EU SCCs: Commission Implementing Decision (EU) 2021/914 of 4 June 2021
UK International Data Transfer Addendum to the EU SCCs (March 2022 version)

4. Who We Use SCCs With

We have signed or incorporated SCCs with infrastructure providers and sub-processors outside the UK/EEA, including:

OVH US — for cloud servers and virtual machines
Vultr (Choopa LLC, US) — for VPN and US-region hosting
Other partners where required, as listed in our DPA and sub-processor annex

Where SCCs are not embedded in a provider’s standard data processing agreement, we proactively seek to execute signed SCCs to ensure full compliance with UK GDPR. If you have questions about a specific provider or data transfer arrangement, please contact us.

5. Requesting a Copy

If you are a Layer 9 Solutions customer and require a signed copy of the SCCs used with a particular sub-processor, you may request this by emailing:

[email protected]

6. Do Customers Need to Sign SCCs?

No. As a customer of Layer 9 Solutions, you are not required to sign SCCs separately. We act as your data processor or sub-processor, and we ensure that all international transfers are legally covered by SCCs or other safeguards.