# Sub-processors

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

Source: https://farolacare.com/en/unterauftragsverarbeiter · As of: 2026-10-26

_This translation is for convenience. Farola is offered under German law; the German version prevails._ [Read the German original](https://farolacare.com/unterauftragsverarbeiter)

_Draft: details marked `[[…]]` are still missing._

## Current list

This list is Annex 1 to the [data processing agreement (DPA)](https://farolacare.com/en/avv) and part of it.

| Provider | Purpose | Data | Location | Transfer basis | DPA status |
| --- | --- | --- | --- | --- | --- |
| Supabase | Database, sign-in, file storage, realtime | All master, visit and health data (Art. 9), sign-in data | EU (Frankfurt) | SCCs (Implementing Decision 2021/914) | to be concluded |
| Vercel | Hosting and delivery of the dashboard | Processes requests including health data transiently; no health data in logs | EU region; static content via a global CDN | SCCs (Vercel Inc., USA) | in place |
| Google Cloud, Vertex AI | AI: transcription and text analysis, assistant | Transcripts, context, real names (Art. 9) | EU multi-region | SCCs (Google Cloud DPA) | in place, to be confirmed |
| Google Places | Geocoding of addresses | Only the typed address snippet and a session token, no names or identifiers | EU | SCCs (Google Cloud DPA) | in place, to be confirmed |
| Resend | Sending e-mails | E-mail address and message content | EU (Ireland) | SCCs (US parent) | to be concluded |
| HeiGIT gGmbH, openrouteservice | Routing and travel time | Only rounded coordinates, no names, addresses or identifiers | Germany (Heidelberg) | EU, no third country | to be concluded (before the first real client) |
| Telnyx (planned) | Telephony and VoIP | Phone numbers, call audio, connection data | EU region, to be confirmed | SCCs (US parent) | planned, active only after confirmation |
| LiveKit (planned) | Real-time voice connection for the phone AI | Call audio, connection data | EU (Frankfurt, eu-central) | SCCs (US parent) | planned, active only after confirmation |
| Sentry (planned) | Error monitoring | Technical error data; personal data is removed before sending | EU (Frankfurt) | SCCs (US parent) | planned, active only after confirmation |
| Nominatim, OpenStreetMap | Geocoding of the care service's own address only | Only the care service's business address, no client or staff data | EU 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).