Data Protection

Sub-processors

The third parties Sarucci engages to process personal data, and where each of them processes it.Version 1.0

Authorised Sub-processors

As of the Effective Date, Provider engages the sub-processors listed in the table below. Where a sub-processor is identified below by category rather than by name, Provider will identify the engaged entity and its location on the sub-processor page before that sub-processor begins processing Personal Data. An up-to-date list, including entity names and locations, is maintained at sarucci.com/sub-processors and is incorporated by reference into this Annex.

Sub-processor / CategoryPurpose of ProcessingLocation of Processing
Google Cloud EMEA Limited / Google LLC (Google Cloud Platform)Hosting and execution of the Platform, managed database services, object storage, asynchronous task queues, container registry and scheduled jobsEuropean Union (Belgium) and United Kingdom (London)
Google LLC / Google Cloud EMEA Limited (Firebase — Hosting, Authentication, Cloud Firestore)Delivery of the Platform web application, user authentication and storage of user-configured application stateEuropean Union and United States
Amazon Web Services EMEA SARL / Amazon Web Services, Inc.Supplementary hosting, compute and storage for Platform servicesEuropean Union (Ireland and Frankfurt) and United States
Zoho Corporation Private LimitedDelivery of transactional and system email (account, security, rate-publishing and report notifications) and operation of the support mailboxIndia and European Union
Anthropic PBCLarge language model processing for the Platform’s AI analyst, AI consultant and agentic advisor featuresUnited States
OpenAI Ireland Limited / OpenAI, L.L.C.Large language model processing, embeddings and document retrieval for the Platform’s AI featuresEuropean Union and United States
Google LLC (Gemini API)Large language model processing for the Platform’s AI featuresEuropean Union and United States
RunPod, Inc.GPU compute for the Platform’s real-time voice consultant (speech recognition, speech synthesis and avatar rendering) and for machine learning model trainingEuropean Union and United States
Google Maps Platform (Google LLC)Map rendering and geocoding on the Platform’s market and competitor intelligence screensEuropean Union and United States
Analytics providerAnonymised and aggregated Platform usage analyticsEuropean Union and United States
Stripe Payments Europe, Limited / Stripe, Inc.Subscription billing, invoicing and payment processing. No payment card data is stored by ProviderIreland and United States

Provider will give Client at least thirty (30) days’ advance written notice of any new or replacement sub-processor, in accordance with Section 4 of this DPA.

For the avoidance of doubt, property management systems and other third-party systems that Client connects to the Platform — including Oracle OPERA Cloud (OHIP) and Cloudbeds — are not sub-processors of Provider. Where Client authorises such a connection, Provider exchanges Client Data with that system on Client’s instruction, and Client’s relationship with that system’s provider is governed by Client’s own agreement with it.

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