Draft: Have it checked by a lawyer before publishing. Marked details[[…]] are still missing.

Sub-processors

Annex 1 to the data processing agreement. We use these providers to run Farola. Version 1.1 · As of: 29 September 2026.

Current list

This list is Annex 1 to the data processing agreement (DPA) and part of it.

ProviderPurposeDataLocationTransfer basisDPA status
SupabaseDatabase, sign-in, file storage, realtimeAll master, visit and health data (Art. 9), sign-in dataEU (Frankfurt)SCCs (Implementing Decision 2021/914)to be concluded
VercelHosting and delivery of the dashboardProcesses requests including health data transiently; no health data in logsEU region; static content via a global CDNSCCs (Vercel Inc., USA)in place
Google Cloud, Vertex AIAI: transcription and text analysis, assistantTranscripts, context, real names (Art. 9)EU multi-regionSCCs (Google Cloud DPA)in place, to be confirmed
Google PlacesGeocoding of addressesOnly the typed address snippet and a session token, no names or identifiersEUSCCs (Google Cloud DPA)in place, to be confirmed
ResendSending e-mailsE-mail address and message contentEU (Ireland)SCCs (US parent)to be concluded
HeiGIT gGmbH, openrouteserviceRouting and travel timeOnly rounded coordinates, no names, addresses or identifiersGermany (Heidelberg)EU, no third countryto be concluded (before the first real client)
Telnyx (planned)Telephony and VoIPPhone numbers, call audio, connection dataEU region, to be confirmedSCCs (US parent)planned, active only after confirmation
LiveKit (planned)Real-time voice connection for the phone AICall audio, connection dataEU (Frankfurt, eu-central)SCCs (US parent)planned, active only after confirmation
Sentry (planned)Error monitoringTechnical error data; personal data is removed before sendingEU (Frankfurt)SCCs (US parent)planned, active only after confirmation
Nominatim, OpenStreetMapGeocoding of the care service's own address onlyOnly the care service's business address, no client or staff dataEU and United Kingdom (OSMF)Adequacy decision (United Kingdom)no DPA required

What the DPA status means

in place
A data processing agreement with the provider is in place.
to be concluded
The provider is in use or intended for use; the data processing agreement is still to be concluded. Until then, no real client data is given to it, where this has not already happened.
to be confirmed
A contract or location is in place but still to be finally checked (such as the exact region or the DPF certification).
planned, active only after confirmation
The provider is prepared but not yet in use. It becomes active only after you have consented to it.
no DPA required
The provider processes no personal data of clients or staff, only the care service's business address.

Changes and consent

This list is Annex 1 to the DPA in version 1.1. Before we use a new sub-processor or replace an existing one, we inform the administration by e-mail (on the day of the announcement and with a reminder after 14 days) and show a notice in the dashboard. The new provider stays technically locked until the administration accepts the new DPA version in the product: until then no personal data flows to it, only the already authorised providers remain in use, and the rest of Farola remains usable (DPA Sections 10, 13).

The maps provider that the caregiver app opens for navigation is not a sub-processor: when the caregiver taps, the app hands over only the destination (coordinate or address text), and the maps provider is then its own controller (DPA Annex A).