[ LEAVEPILOT · LEGAL ]
Sub-processors
- Last updated
- 21 August 2026
This list is read from Annex C of the data processing agreement: it is the same source the customer accepts, not a separate copy. Any addition or replacement is notified at least thirty days in advance and may be objected to under article 6 of the agreement.
| Name | Function | Place of processing | Basis for the transfer |
|---|---|---|---|
Databricks, Inc., through Neon, LLC | database hosting and management: all data entered into the platform, including that of the Controller's employees | European Union, | Standard contractual clauses of the European Union, incorporated into the supplier's agreement, which at article 8.1 states them as the basis of every restricted transfer. The supplier participates in the EU-U.S. Data Privacy Framework, but its certification covers non-HR data only: it is therefore not a usable basis for the data covered by this Agreement. Sources: the supplier's data processing agreement and its public profile on the programme list, consulted on 18 August 2026 |
Netlify, Inc. | hosting of the application and of the functions that process requests; delivery of static content; storage of the sick leave certificates uploaded by the Controller's employees, kept encrypted with the AES 256-bit algorithm | United States, the supplier's default region for function execution; content delivery network with a global presence | Standard contractual clauses of the European Union (modules 2 and 3), applicable by express provision of article 14.3 of the supplier's agreement where the transfer is not covered by the Framework. The supplier's certification covers non-HR data only and therefore does not cover this transfer. Sources: the supplier's data processing agreement of 9 June 2026 and its public profile on the programme list, consulted on 18 August 2026 |
Plus Five Five, Inc., trading as Resend | sending service communications to the Controller's employees: the recipient's name and email address and the content of the communication. Not used where the Controller configures its own email provider | United States | Standard contractual clauses of the European Union, which the supplier's agreement states as the basis for transfers outside the European Economic Area and which are deemed entered into upon acceptance of the terms. The supplier's certification under the Framework covers non-HR data only and therefore does not cover this transfer. Sources: the supplier's data processing agreement of 31 December 2025 and its public profile on the programme list, consulted on 18 August 2026 |
Anthropic PBC | production of the report commentary text, on aggregated data free of identifying elements | United States, called directly with no intermediaries | Standard contractual clauses of the European Union (modules 2 and 3), automatically incorporated into the supplier's commercial terms. The supplier does not participate in the Framework: the clauses are the sole basis, and there is no coverage check to perform. Source: the supplier's data processing agreement in force since 24 February 2025, consulted on 18 August 2026 |
For the full set of obligations imposed on sub-processors see article 6 of the data processing agreement.
Processing chain
Each provider in turn publishes the list of its own sub-processors:
PostHog is not one of the sub-processors listed above. It receives the platform's diagnostic events, which LeavePilot processes as an independent controller under Annex D of the data processing agreement: the legal basis is legitimate interest, not article 6 of Annex C, and data subjects are informed through the privacy notice. The thirty-day notice described further below applies only to the four providers listed above. PostHog too publishes its own list of sub-processors, for the same transparency: PostHog.
Links verified on 21 August 2026.
Changes to the list
Any addition or replacement is notified to customer organisations at least thirty days in advance, with a right to object, as provided for in article 6 of the data processing agreement.