Sub-processors

The third parties Fidify engages to help deliver the service, with the purpose, data categories, and processing location for each.

About this list

A sub-processor is any third party Fidify engages to help deliver the service on behalf of our customers under GDPR Article 28. Every sub-processor is bound by a written agreement that imposes equivalent data-protection obligations to those in our Data Processing Agreement.

Current sub-processors

Google Ireland Limited (Google Cloud Platform)

Purpose
Hosting infrastructure, including compute, storage, database, messaging, encryption-key management, and logging. Also provides AI inference for the AI providers selected by customer policy.
Data categories
Customer document content, identifiers, authentication tokens, session data, logs, encryption keys, AI prompts and completions.
Location
European Union
Transfer mechanism
Intra-EU. No transfer mechanism required.

Google LLC

Purpose
Push notification delivery to Android and web users.
Data categories
Device registration tokens, user identifiers, notification title and body, event metadata.
Location
United States
Transfer mechanism
EU Standard Contractual Clauses, plus supplementary safeguards.

Apple Distribution International Ltd

Purpose
Push notification delivery to iOS users.
Data categories
Device tokens, notification title and body, event metadata.
Location
Ireland and United States
Transfer mechanism
Intra-EU for the Apple contracting entity. EU Standard Contractual Clauses cover any onward transfer to the United States.

Twilio SendGrid Inc.

Purpose
Transactional email delivery, including invitations, document share links, recovery emails, and one-time passcodes.
Data categories
Recipient email addresses and names, invitation tokens, portal and organisation names, email body content.
Location
United States
Transfer mechanism
EU Standard Contractual Clauses, plus supplementary safeguards.

Stripe Payments Europe Ltd

Purpose
Payment processing and billing.
Data categories
Customer email, billing name, payment-method metadata (last four digits, card brand, expiry; full card number never reaches Fidify), transaction amounts, subscription identifiers.
Location
Ireland, with onward processing in the United States for payment-network routing.
Transfer mechanism
Intra-EU primary. EU Standard Contractual Clauses for onward transfer to the United States.

Functional Software, Inc. (Sentry)

Purpose
Error monitoring across the web portal, services, and mobile applications.
Data categories
Stack traces, user identifiers, IP addresses, browser and device fingerprints, application event trails. Personal data is scrubbed before submission.
Location
European Union
Transfer mechanism
Intra-EU. No transfer mechanism required.

OpenAI Ireland Ltd

Purpose
AI inference for risk assessment, compliance narrative generation, and document analysis when a customer's AI policy selects OpenAI as the provider.
Data categories
Document text excerpts, policy prompts, extracted compliance fields. Content is not used to train OpenAI models.
Location
United States
Transfer mechanism
EU Standard Contractual Clauses, plus the OpenAI data-processing agreement.

Anthropic Ireland, Limited

Purpose
AI inference when a customer's AI policy selects Anthropic as the provider.
Data categories
Document text excerpts, policy prompts, extracted compliance fields. Content is not used to train Anthropic models.
Location
United States
Transfer mechanism
EU Standard Contractual Clauses, plus the Anthropic data-processing agreement.

Tavily AI Inc.

Purpose
Web search context retrieval for AI workflows, including compliance research and entity enrichment.
Data categories
Search queries, which may include entity or company names.
Location
United States
Transfer mechanism
EU Standard Contractual Clauses.

Notification of changes

Before engaging a new sub-processor or replacing an existing one, Fidify notifies customers in line with section 5.2 of our Data Processing Agreement. Customers have fourteen days from notice to object in writing.

Questions

For questions about this list or to request the signed records of processing activities, email dpo@fidify.se.

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