Sub-processors
Every third party that touches your data, where it runs, and what it sees. This page is the live version of Annex A in the Data Processing Agreement.
Version 2.0, published 8 September 2026
30 days notice, in writing, before anything changes.
When we intend to add or replace a sub-processor, we update this page and email the data protection contact and platform administrators at every customer institution at least 30 days before the change takes effect. You can object on data protection grounds within 14 days of the notice, as set out in section 5.4 of the DPA.
To add a colleague to the notification list, or to ask about any entry, write to privacy@studentpulse.io.
Sub-processors that process personal data
All student and platform data is stored in the EU. One processor sits outside the EU, Anthropic, and is used only by StudentPulse staff on aggregated and redacted data. Each provider below has signed a data processing agreement with us.
| Sub-processor | Purpose | Data location | Data it handles |
|---|---|---|---|
| Amazon Web Services (AWS) | Application servers, file storage and cache for the StudentPulse platform and Engage module | Frankfurt, Germany (EU) | Platform user data, student feedback, student support requests (Engage) in transit |
| DigitalOcean | Managed MySQL database and database backups | Frankfurt, Germany (EU) | All platform data stored in the database: platform user data, student feedback, organisation configuration |
| Mailersend | Transactional email. Optional: forwarding student support requests by email (Engage) | EU | Email addresses of platform users. Optionally: student name, email, phone and support message |
| Microsoft Teams (optional) | Forwarding student support requests to institutional Teams channels by webhook (Engage) | Ireland (EU) | Student name, email, phone and support message. Covered by your own agreement with Microsoft |
| Microsoft Azure OpenAI Service | AI model provider: topic classification, summarisation, translation and report generation on feedback text | Stockholm, Sweden (EU) | Free-text feedback after automated redaction of personal identifiers. No student identity fields. Not used for model training. Prompts and outputs retained up to 30 days for abuse monitoring, then deleted |
| PostHog | Product analytics on the platform interface | Frankfurt, Germany (EU) | Platform user ID, IP address, browser data and session recordings of the platform interface. No student-facing pages are recorded |
| Intercom | In-app support chat for platform users | Dublin, Ireland (EU) | Platform user name, email, chat content and platform navigation data |
| Fly.io | Hosting of the internal reporting tool StudentPulse staff use to query the platform database | Stockholm, Sweden (EU) | Feedback and platform user data in transit only; nothing is stored |
| Anthropic | AI-assisted analysis and report preparation by StudentPulse staff for your institution. Access is per employee via Google Workspace sign-in, and every query is logged with the employee’s email | USA. EU-US Data Privacy Framework (certified), Standard Contractual Clauses as fallback | Aggregated feedback results, free-text feedback after automated redaction of personal identifiers, and platform user names and emails. No student identity data. Not used for model training |
Services that do not process personal data
Used for platform operations and technically configured so that no personal data enters their data flows.
| Service | Purpose | Location | Technical safeguard |
|---|---|---|---|
| Ably | Real-time WebSocket connections for platform notifications | United Kingdom (adequacy decision) | Carries only event triggers and channel identifiers. No personal data passes through Ably |
| Honeybadger | Scheduled-job health monitoring | USA | Receives a timestamped heartbeat ping only. No payload, no user or feedback data |
Used by StudentPulse to run the customer relationship, covered by the Privacy Policy for Platform Users rather than the DPA: Google Workspace (email, calendar, documents), HubSpot (CRM), Podio and RightSignature (contracts, customer service), Loom (video messages), e-conomic (invoicing).
The full agreement, including Annex B on security measures, is in the document room.