List of Sub-Processors
This Sub-Processor List forms part of the DLEGATE Terms of Service and the Data Processing Agreement (“DPA”). It identifies third parties engaged by DLEGATE Solutions GmbH (“DLEGATE”) to process Personal Data on behalf of Customers in connection with the provision of the DLEGATE SaaS platform.
Processing activities relating to Customer-initiated data access, export, portability, or sharing are additionally governed by the Data Access & Sharing Addendum, which prevails in the event of any conflict with this Sub-Processor List.
DLEGATE enters into appropriate contractual arrangements with all sub-processors to ensure compliance with Article 28 GDPR and equivalent data protection obligations.
All sub-processors listed below act as processors within the meaning of Article 28 GDPR.
1. Infrastructure and Hosting Sub-Processors
| Sub-processor | Legal entity | Registered address | Country |
|---|---|---|---|
| Amazon Web Services (AWS) | AWS Europe (Ireland) DAC | One Burlington Plaza, Burlington Road, Dublin 4 | Ireland |
Service provided: Cloud infrastructure, hosting, storage, networking
Processing Location: EU (primarily Frankfurt); potential third-country access subject to appropriate safeguards, including Standard Contractual Clauses
Notes:
AWS acts as a processor under Art. 28 GDPR. Data processing is governed by the AWS Data Processing Addendum, available at aws.amazon.com/legal/dpa/.
2. Website Hosting (Public Website Only)
| Sub-processor | Legal entity | Registered address | Country |
|---|---|---|---|
| Squarespace | Squarespace Ireland Ltd. | 5 Harcourt Road, Dublin 2 | Ireland |
Service provided: Hosting and delivery of the publicly available website
Processing Location: EU; potential third-country access subject to safeguards
Scope Clarification:
Squarespace is used only for the public website (e.g. informational
pages, contact forms).
It does not process Customer Data generated within the DLEGATE Service. Processing
is governed by the Squarespace Data Processing Addendum
(https://www.squarespace.com/dpa).
3. Mapping and Geolocation Services (If Enabled)
| Sub-processor | Legal entity | Registered address | Country |
|---|---|---|---|
| Google Maps Plaform | Google Ireland Limited | Gordon House, Barrow Street, Dublin 4 | Ireland |
Service provided: Map display, address resolution, geolocation services
Processing Location: EU; potential third-country access subject to SCCs
Scope Clarification:
Google Maps services are used to support address and location visualization
where geolocation data is collected via a mobile device.
Google acts as a processor for this purpose. Processing is
governed by the Google Data Processing Addendum (https://cloud.google.com/terms/data-processing-addendum).
4. Customer-Initiated Data Access, Export, and Sharing
Where the Customer uses functionality provided under the Data Access & Sharing Addendum to access, export, port, or share Customer Data with third parties or external systems, such transfers:
- occur solely on the Customer’s documented instructions,
- are not disclosures by DLEGATE acting as Controller, and
- do not constitute engagement of sub-processors by DLEGATE.
Recipients selected by the Customer in this context are not listed as sub-processors and are governed by the Customer’s own legal and contractual arrangements.
5. Explicit Exclusions
The following entities are not sub-processors under the DPA and are therefore not included in this list:
- Payment service providers used for subscription billing, which act as independent controllers under applicable data protection laws.
- Third parties receiving Customer Data as a result of Customer-initiated export, sharing, or integration actions.
6. Updates and Changes
DLEGATE may update this Sub-Processor List from time to time.
Material changes will be communicated in accordance with the Terms of Service.