Part 2: Charting Our Course in Response to the ECJ’s Safe Harbor Ruling

By Suk Kim

In immediate response to the European Court of Justice’s decision regarding the EU-U.S. Safe Harbor Framework on October 6, 2015, Urban Airship provided a statement regarding our privacy and security practices and processes. We also stated that once the European Commission provides further guidance, we’d follow-up with a response that takes into consideration such guidance.

On October 16, 2015, the Article 29 Working Party (composed of representatives from the national data protection authorities of the EU Member States, the European Data Protection Supervisor and the European Commission) issued a statement (PDF) offering guidance on the practical consequences of ECJ’s Safe Harbor decision. In light of the ECJ decision and the Article 29 Working Party’s guidance, Urban Airship is offering our customers Urban Airship’s new data processing addendum (PDF), which incorporates the European Commission’s standard contractual clauses for data processors, commonly referred to as the “model clauses.”

Urban Airship customers, who are using our service to transfer personal data from Europe to the U.S. under EU data protection laws, now have the option to enter into Urban Airship’s data processing addendum. To execute the data processing addendum, complete, sign and return it to privacy@urbanairship.com. Please note that the model clauses will apply only to the extent there is not another legal basis in place to validate the transfer of personal data from the EU to the U.S.