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: 2026-11-10.
Current subprocessors #
| Subprocessor | Jurisdiction | Purpose | Data categories |
|---|---|---|---|
 Hetzner Online GmbH | 🇩🇪 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 | 🇫🇷 France (EU) | Transactional email delivery | Handler addresses and notifications; reporter email, Case ID and link when the reporter elects email notices; one-time password in the receipt for a report sent by email; billing emails |
 AppSignal B.V. | 🇳🇱 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 whistleblowing 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. EthicsPortal does not transmit report content, reporter identity, handler messages, or audit logs to OpenAI, Anthropic, Google, Mistral, or any other AI inference provider. An AI assistant or other service that a customer connects to the API is engaged by the customer, not by EthicsPortal (DPA §6.10). This is a product commitment, not a configuration default — see §5 of the Directive coverage map 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. Account, billing, and public-site providers outside this DPA chain are disclosed in the Privacy Notice.
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 by email at least 30 days before a new subprocessor begins processing personal data, and may object within 14 days on data-protection grounds. Where a subprocessor must be replaced sooner to protect personal data or keep EthicsPortal running, operators are notified without undue delay. Objections are handled under the Data Processing Agreement.
Questions #
For questions about subprocessor data-handling, contact privacy@ethicsportal.eu.
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