> Third-party services that process personal data on behalf of EthicsPortal. Published per GDPR Article 28. Source: https://ethicsportal.eu/subprocessors/ Updated: 2026-09-23 --- # Subprocessors Subprocessors are third parties that process personal data on behalf of EthicsPortal when EthicsPortal acts as processor for operator-organizations (controllers). This list is published per Article 28(2) GDPR and the Data Processing Agreement. Last updated: 2026-09-13. --- ## Current subprocessors | Subprocessor | Jurisdiction | Purpose | Data categories | |---|---|---|---| | Hetzner Online GmbH | ๐Ÿ‡ฉ๐Ÿ‡ช Germany (EU) | Server, database hosting, and file attachment storage | All application data: reports, handler identity, messages, audit logs; uploaded attachments (metadata stripped before upload) | | Mailjet SAS | ๐Ÿ‡ซ๐Ÿ‡ท France (EU) | Transactional email delivery | Handler addresses and notifications; reporter email, report access code and link when the reporter elects email notices; billing emails | | AppSignal B.V. | ๐Ÿ‡ณ๐Ÿ‡ฑ Netherlands (EU) | Error and application-performance monitoring | Stack traces and request metadata; reporter portal requests are configured to be excluded from transaction monitoring | **Whistleblower reporter privacy.** No third-party script, cookie, or identifier reaches the whistleblower reporting channel --- the surface where reporters submit and follow up on their reports. In-app support chat for handlers is built into EthicsPortal and self-hosted; it involves no external chat vendor. **No AI or LLM sub-processor.** No large language model, generative AI service, or AI-based classifier is a sub-processor of EthicsPortal. Report content, reporter identity, handler messages, and audit logs are not transmitted to OpenAI, Anthropic, Google, Mistral, or any other AI inference provider. This is a product commitment, not a configuration default --- see [ยง5 of the Directive coverage map](/directive-coverage/#5-confidentiality-of-identity-art-16) for the legal framing. The direct reporting-service subprocessors are EU-based. Their downstream support, email and telemetry chains may involve providers outside the EEA; EU incorporation alone is not an EU-only processing guarantee. See the [DPA transfer section](/dpa/#9-international-data-transfers). Account, billing, and public-site providers outside this DPA chain are disclosed in the [Privacy Notice](/privacy/). --- ## What counts as a subprocessor A subprocessor is any third-party service that processes personal data on behalf of EthicsPortal under a written processing agreement. Services appear here only if they receive, store, or transmit personal data. Internal libraries, package registries, and build-time dependencies are not subprocessors. --- ## Notification of changes Operators are notified of additions or changes to this list at least 30 days before a new subprocessor begins processing personal data. Objections to a proposed subprocessor may be raised under the Data Processing Agreement. --- ## Questions For questions about subprocessor data-handling, contact [privacy@ethicsportal.eu](mailto:privacy@ethicsportal.eu).