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 | 🇩🇪 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, report access code and link when the reporter elects email notices; 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 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 §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 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 .
Last updated: