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Sub-processors

This environment
staging
Activation status reviewed
14 September 2026
Register compiled
16 July 2026 · evidence refreshed 14 September 2026
Sub-processor policy
Version 1.2 · adopted 14 September 2026

The platform is operated as a data processor for each academy (the data controller of its students' and staff's personal data). To deliver the service, the operator engages the sub-processors below under written data-protection terms consistent with Article 28 GDPR. Where a sub-processor is outside the EU/EEA, transfers rely on the European Commission's Standard Contractual Clauses (SCCs) and/or the vendor's EU–US Data Privacy Framework (DPF) certification, as listed per vendor. Each DPA link points to the vendor's own official document; the line beneath it states what that document currently is — an executed agreement, terms incorporated by reference whose verification is still pending, or an execution step still to be completed.

The status column is read from the configuration of the deployment serving this page (staging) at the time you open it — it is not a manually maintained list. A vendor is shown as active whenever the integration that sends it personal data is enabled here.

This list is maintained under the operator's Vendor & Sub-processor Management Policy, version 1.2 (adopted 14 September 2026): every vendor is risk-assessed and bound by written data-protection terms before it receives personal data, reviewed at least annually and on any material change. Academies receive advance notice of material changes to this list so they may object; every change is recorded in the change log. See also the Privacy Policy.

Active sub-processors in this environment (staging)

These vendors currently process personal data on the academies' behalf as part of delivering the service in this deployment.

Sub-processors active in staging
VendorPurposePersonal dataLocation / regionTransfer mechanismStatus (staging)DPA
ElevenLabsSpeech-to-text and the synthesised voice of the speaking interlocutor / AI tutor (text-to-speech + conversational AI)Candidate raw spoken audio (realtime speech-to-text during Speaking) and exam text to be voicedUnited States (EU residency available on the Enterprise tier only)SCCs (Modules 2 + 3) + EU–US Data Privacy Framework (certified)
Active

Speech synthesis, transcription and the live Speaking interlocutor are enabled.

ElevenLabs DPA

DPA: Incorporated by reference — verification pending

SimliPhoto-real avatar rendering (lip-sync) for the speaking interlocutor / AI tutorThe avatar's own synthesised speech audio and the avatar video it renders, plus session metadata and the learner's IP address. The learner's microphone and camera are never sent to SimliNorway (EEA) — Simli AS, Oslo; processing in the EEA by defaultProcessed in the EEA by default (intra-EEA, Norwegian entity). Per-session exceptions only, never by default, including during an EU capacity outage: (a) the live media stream may be carried over LiveKit Cloud's global network while avatar rendering, logs and storage stay in the EEA; and (b) where EU capacity is unavailable for a session, or while Simli has reported an EU capacity outage within the preceding minutes, that session may be processed in Simli's other regions, with transfers under the SCCs in Simli's DPA
Active

The photoreal Speaking avatar is enabled.

LiveKitRealtime WebRTC media transport for the live speaking session (engaged via Simli's avatar service)The avatar's audio and video stream between Simli and the learner, transported in real time (transient — routed, not recorded or stored), plus connection/session metadata and the learner's IP addressUnited States (LiveKit Cloud). Used through Simli's EEA-pinned service by default; for individual sessions (e.g. learners outside the EU) the stream may be routed over LiveKit Cloud's global networkSCCs (Modules 1, 2 + 3); DPF self-certification under verification
Active

Engaged through the avatar vendor's real-time media transport (no direct credential).

LiveKit DPA (2025-11-18)

DPA: Incorporated by reference — verification pending

AnthropicAI-assisted grading, tutoring and coaching of exam responses (Claude)Candidate written responses, speaking transcripts and tutor/coach contextUnited States / global (no EU residency for the API)SCCs (Modules 2 + 3) + UK and Swiss addenda (no DPF reliance)
Active

AI grading, feedback and tutoring are enabled.

Anthropic DPA (2025-02-24)

DPA: Incorporated by reference — verification pending

AWS (Amazon Web Services)Production infrastructure — compute (Fargate), database (Aurora PostgreSQL), object storage (S3) and secrets managementAll authoritative platform data: candidate account data, exam attempts, answers and scores, rosters, credentials (hashed) and the audit logEU — Frankfurt (eu-central-1); data at rest stays in the selected regionProcessing pinned in-region (EU); 2021 SCCs auto-apply to any ancillary transfer; EU–US Data Privacy Framework (certified)
Active

Hosts the platform: database, compute and storage.

AWS GDPR DPA (Service Terms §1.14)

DPA: Incorporated by reference — verification pending

AWS SESTransactional email — invitations and notifications (per-academy sending domains)Recipient name and email address, and message contentEU sending region (per tenant) — an AWS serviceCovered by the AWS GDPR DPA (row above); in-region EU sending
Active

Transactional email is sent through AWS SES.

Covered by the AWS DPA

DPA: Covered by the AWS DPA

CloudflareContent delivery, object storage for exam media (R2), WAF and edge routingExam content (audio/images — not per-candidate records) and edge traffic metadata (IP address, host headers) of users transiting the networkGlobal edge network (EU localisation via a separate Data Localization Suite product)SCCs (Modules 2 + 3) + EU–US Data Privacy Framework (certified)
Active

Serves exam media and edge traffic (object storage, CDN, custom domains).

Cloudflare Customer DPA (v6.4, 2026-04-03)

DPA: Incorporated by reference — verification pending

StripePayment processing and payouts (Stripe Connect). Dual role: processor for merchant payment processing, and independent controller for fraud detection, loss mitigation and AML/KYCBilling identifiers, payer name and email, connected-account onboarding data (card data goes to Stripe directly — the platform never stores card numbers)United States / global (no customer-selectable EU residency)SCCs (Modules 1 + 2) + UK IDTA + EU–US Data Privacy Framework (certified)
Active

Payments and payouts are enabled.

Stripe DPA (2025-11-18)

DPA: Incorporated by reference — verification pending

SlackQA reviewer feedback channels (exam-review workflow)Reviewer identity and report message content (may include exam screenshots); candidate personal data is kept out by policyUnited States (EU residency on Business+/Enterprise tiers only)SCCs (2021, deemed-executed) + DPF via parent Salesforce, Inc.
Active

Reviewer feedback and operational alerts are posted to Slack.

Salesforce DPA (Apr 2026, via Slack)

DPA: Executed 2026-08-06

GitHubSource control, CI/CD and the QA feedback dispatch pipelineSource code and CI logs (no production candidate data by design); QA dispatch payloads carry reviewer report textUnited States / globalSCCs (Modules 2 + 3) + EU–US Data Privacy Framework (certified)
Active

Hosts the source code and CI; QA reports can trigger fix runs.

GitHub Data Protection Agreement (Oct 2025)

DPA: Incorporated by reference — verification pending

SentryApplication error reporting (observability)Error events and stack traces (may embed user identifiers); no default PII is sentEU region available (Frankfurt), chosen at organisation creationSCCs (Modules 2 + 3) + UK Addendum
Active

Application error reporting is enabled.

Sentry DPA (v5.1.0, 2024-05-29)

DPA: Executed 2026-08-06

OpenAIAlternate AI model path (tutor / feedback when an OpenAI model is selected)The same class of data as Anthropic (written responses, speaking transcripts, tutor context) when its model path is usedUnited States (EU residency at project level, gated)SCCs (Modules 2 + 3) + UK Addendum (not DPF-listed)
Active

An alternate AI model path is enabled (used when an OpenAI model is selected).

OpenAI DPA (v.010126)

DPA: Executed 2026-09-14

Approved, not active in this environment (staging)

These vendors are approved and integrated but the integration is not enabled in this deployment, so they do not currently receive personal data from it. They are listed for transparency.

Approved vendors not active in staging
VendorPurposePersonal dataLocation / regionTransfer mechanismStatus (staging)DPA
WorkOSStaff identity — SSO / AuthKit / directory sync (SCIM) for enterprise academiesStaff and admin identity (name, email, organisation, authentication events) when single sign-on is usedUnited States (no EU hosting commitment)SCCs (Modules 2 + 3) — SCC-only (no DPF listing found)
Not active

Single sign-on is switched off in this deployment; no identity data is sent.

WorkOS DPA (2023-06-27)

DPA: Incorporated by reference — verification pending

ResendTransactional email — alternate provider to AWS SESRecipient email and message content, when selected as the email providerUnited States (no EU residency)SCCs (Modules 1, 2 + 3) + UK/Swiss addenda; DPF claimed (under verification)
Not active

No Resend credential is configured; nothing is sent through Resend.

Resend DPA

DPA: Incorporated by reference — verification pending

TypeSafe AIDecision primitives on TOEIC Speaking / Writing verification (text only) — a shadow check beside the served result, never changing itThe text of a TOEIC Writing Q1–5 sentence or a Speaking Q8–10 transcript, with the item's own prompt — no name, e-mail, account or audioUnited States (TypeSafe AI, Inc.; hosted in the US per its privacy policy — EU residency to confirm in the DPA)To confirm in the DPA (SCCs Modules 2 + 3 expected; no EU–US Data Privacy Framework listing verified)
Not active

The verification checks are switched off in this deployment; nothing is sent.

Where the operator is the controller

For the vendors below, the platform operator acts as the data controller in its own right (for example, marketing enquiries from prospective academies). This is a separate legal seat from the candidate-data chain above: no candidate or exam data is involved.

Processors engaged where the operator is the controller
VendorPurposePersonal dataLocation / regionTransfer mechanismStatus (staging)DPA
HubSpotB2B sales pipeline (CRM) for the public website's self-serve demo funnel — ProficientHub is the data controller for this processing; one-way platform → HubSpot sync, gated on the consent recorded at the lead formProspective-customer contact data (name, work email, academy/company, role, country, phone, demo usage counts) — never candidate or exam dataEuropean Union (EU-hosted portal, account 148302337; HubSpot EU data centre, Frankfurt)SCCs (Modules 2 + 3) + EU–US Data Privacy Framework (certified)
Active

Marketing-lead sync to the CRM is enabled.

HubSpot DPA (2026-04-14)

DPA: Incorporated by reference — verification pending

Stripe additionally acts as an independent controller for its own fraud-detection, loss-mitigation and AML/KYC processing (see its DPA). Sign in with Google is not a sub-processor: when you choose to sign in with a Google Account, Google acts as an independent controller of that account under its own terms. See the Privacy Policy for details.