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Legal · Sub-processors

Sub-processors

Version1.0 (draft)
Last updated2026-05-16
Change notice30 days before any addition
Annex ofDPA · Annex III
This is a working draft, pending external legal review. The list below is the current set of sub-processors we engage to operate the Adfinia platform. The categorisation and notice language are pending counter-signature by external counsel and may change before commercial publication. To subscribe to change announcements, write to support@adfinia.com with subject "Sub-processor notifications".

What this list is

Sub-processors are third parties Adfinia engages to perform parts of the processing on the Customer's behalf. This page is the source of truth — Annex III of the DPA incorporates it by reference.

For each entry we publish: the vendor, the category of service, the jurisdiction of processing, the categories of Personal Data they may touch, and the lawful transfer mechanism in use. Material changes — including the addition of a new sub-processor or a move of an existing sub-processor to a new region — are announced at least 30 days in advance, via this page and an email to the operational contact on each affected tenant.

Customers who reasonably object to a new sub-processor on data-protection grounds may terminate the affected service component within 30 days of notice, with a pro-rated refund of pre-paid unused fees.

Current sub-processors

Vendor Category Jurisdiction Purpose & data touched Status
Amazon Web Services EMEA SARL aws.amazon.com Infrastructure hosting EU (eu-north-1 Stockholm; eu-west-1 Ireland backup) EC2 compute, EBS storage, RDS Postgres, S3 object storage, ELB networking, IAM. Touches all Personal Data resident in the platform. Live
Stripe Payments Europe Ltd. stripe.com Payment processing EU (Ireland) · USA Billing identifiers, payment-method tokens, invoice data. Does not touch customer-uploaded contacts or campaign content. EU SCCs in place for USA transfer of billing data. Live
Amazon SES (AWS EMEA SARL) aws.amazon.com/ses Transactional & campaign email delivery EU (eu-north-1) Email envelope (recipient address, subject, content), per-message delivery telemetry. Same legal entity and DPA as core AWS hosting. Live
Twilio Ireland Ltd. twilio.com SMS & WhatsApp Business delivery EU (Ireland) · USA Recipient phone number, message body, per-message status. EU SCCs for USA transfer; in-region API endpoints used by default. Engaged when SMS or WhatsApp dispatch is enabled on a tenant. Planned · GA Q3 2026
Functional Software Inc. (Sentry) sentry.io Error monitoring USA (with EU data-residency option on enablement) Stack traces, request metadata, anonymised user IDs. PII redacted by our SDK middleware before transmission. EU SCCs in place; Sentry's EU-region tenancy will be enabled at GA so no Personal Data leaves the EEA. Planned · GA Q3 2026

Status legend — Live currently processing Personal Data for at least one production tenant. Planned contractually engaged but not yet wired into a production dispatch path; will move to Live ≥ 30 days after the first production tenant is connected.

What is not on this list

We do not engage:

  • Any advertising-network or ad-exchange sub-processor on the public Adfinia surfaces.
  • Cross-site tracking or device-fingerprinting vendors.
  • Any LLM provider as a sub-processor for tenants in Sovereign AI mode — inference runs on infrastructure under the tenant's control.

For tenants in default (cloud) AI mode, the AI provider routing is documented inside your tenant's Order Form and the AI matrix at /settings/ai; it does not appear on this Annex III list until at least one tenant is on cloud-AI with that provider as primary route.

How we notify you of changes

  1. The change is announced on this page with a date stamp.
  2. An email is sent to the operational contact on every tenant whose region or service is affected.
  3. The change does not take effect until 30 days after the later of (1) and (2).
  4. For changes required by law, regulator instruction, or an active security incident, notice may be shorter — we tell you why on this page.

Recent changes

  • 2026-05-16 Initial publication. AWS EMEA SARL added as primary infrastructure host. Stripe Payments Europe Ltd. added for billing.
  • 2026-05-16 AWS SES added as the transactional and campaign email vendor.
  • 2026-05-16 Twilio Ireland Ltd. recorded as planned SMS / WhatsApp vendor; not yet in a production dispatch path.
  • 2026-05-16 Functional Software Inc. (Sentry) recorded as planned error-monitoring vendor; not yet in a production dispatch path.

Contact

Questions or objections to a sub-processor on this list — write to support@adfinia.com with subject "Sub-processor — <vendor name>". We respond within 5 business days. Procurement teams may also request the executed sub-processor DPA chain on request.