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Subprocessors

Version 3 · in force since 5 Oct 2026

Annex III — Subprocessors (as of 5 October 2026)

Hosted documents and the consent banner are not offered to new customers. References to generated documents, hosting, embeds and consent records describe existing customer use only.

Subprocessor
DigitalOcean, LLC
Service
Hosting of application and database
Data
All Customer Personal Data
Location
USA (New York, NYC3)
Transfer safeguard
Onward-transfer contract (SCCs Clause 8.8); DPF where certified
Status
Active
Subprocessor
Cloudflare, Inc.
Service
DNS, network and security; hosted-page and banner traffic for existing customers only
Data
Technical request data (IP address, user agent), content in transit
Location
Global network; company in USA
Transfer safeguard
Onward-transfer contract (SCCs Clause 8.8); DPF where certified
Status
Active
Subprocessor
Postmark (ActiveCampaign, LLC)
Service
Transactional email to Customer's users (not to visitors)
Data
Email addresses and message content of Customer's users
Location
USA
Transfer safeguard
Onward-transfer contract (SCCs Clause 8.8); DPF where certified
Status
Active
Subprocessor
Functional Software, Inc. (Sentry)
Service
Error monitoring, without request bodies, cookies or personal data except a user ID
Data
User ID, technical data
Location
USA
Transfer safeguard
Onward-transfer contract (SCCs Clause 8.8); DPF where certified
Status
Not active on 5 October 2026; 30 days' notice before activation
Subprocessor
OpenRouter, Inc.
Service
Vendor classifier: suggests a "Likely" vendor when a scan finds a vendor that our catalogue does not know. OpenRouter passes the request to the OpenAI model in the next row.
Data
Only vendor domains, cookie names and script hosts found in scans. No personal data is intended. Never page content, cookie values, form values, IP addresses or account data.
Location
USA
Transfer safeguard
Onward-transfer contract (SCCs Clause 8.8); DPF where certified
Status
Not active. No activation date is set; notice under section 7.2 is required before activation
Subprocessor
OpenAI, L.L.C.
Service
Vendor classifier: the AI model that OpenRouter calls (same purpose as the row above)
Data
Only vendor domains, cookie names and script hosts found in scans. No personal data is intended. Never page content, cookie values, form values, IP addresses or account data.
Location
USA
Transfer safeguard
Onward-transfer contract (SCCs Clause 8.8); DPF where certified
Status
Not active. No activation date is set; notice under section 7.2 is required before activation
Subprocessor
Cloudflare, Inc. (Workers AI)
Service
Vendor classifier, second model, used when the first one fails (same purpose as the rows above)
Data
Only vendor domains, cookie names and script hosts found in scans. No personal data is intended. Never page content, cookie values, form values, IP addresses or account data.
Location
Global network; company in USA
Transfer safeguard
Onward-transfer contract (SCCs Clause 8.8); DPF where certified
Status
Not active. No activation date is set; notice under section 7.2 is required before activation

The list of providers that do not process Customer Personal Data is new; Cloudflare Turnstile moves to that list.

Providers that do not process Customer Personal Data (listed for transparency; they are not Subprocessors under this DPA):

Provider
GitHub, Inc.
Service
Repository hosting that Customer chooses. When Customer connects a repository through the tosgenerator GitHub App, Sprout reads the repositories that Customer selects and, if Customer turns them on, posts checks or issues to them.
Data
Data in Customer's own GitHub account. Customer's agreement with GitHub governs it.
Location
USA
Status
Active when Customer connects a repository
Provider
Stripe
Service
Payments for Customer's own account, as a separate service
Data
Payment data of Customer's own account
Location
USA and other locations
Status
Active
Provider
Cloudflare, Inc. (Turnstile)
Service
Bot check on Sprout's own public scan form and policy check form
Data
IP address and browser and device signals of the person who uses the form, and the check result. Sprout is the controller of this data (Privacy Policy, /legal/privacy).
Location
Global network; company in USA
Status
Active

Sprout does not send Customer Personal Data to AI providers. The planned vendor classifier would send only the data in the OpenRouter, OpenAI and Cloudflare Workers AI rows, and Sprout turns it on only after the notice period in section 7.2.

Status on 5 October 2026: OpenRouter, OpenAI and Cloudflare Workers AI remain not active. No activation date is set. Any activation requires the notice in section 7.2, and Customer can object under section 7.3 by writing to facundomartin@sproutco.io.