> For the complete documentation index, see [llms.txt](https://docs.ilert.com/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.ilert.com/trust-center/legal/subprocessors.md). # Sub-processor List {% hint style="info" %} **Version 1.3 ยท published 10 November 2026**\ Applies to agreements concluded from 10 November 2026. For existing agreements, it applies from the date given in our notice of the change, unless the customer objects; until then, the previously agreed version applies. [Versions and changes](/trust-center/legal/versions/subprocessors.md) {% endhint %} This is the canonical list of sub-processors engaged by ilert for the delivery of its SaaS services. Customers receive 30 days' prior written notice of any new or replacement sub-processor, with the right to object. ## At a glance * ilert hosts its platform at Amazon Web Services in the EU: in Frankfurt and Stockholm. * The other sub-processors for all customers have their data locations in the EU, with two exceptions that process data in the United States for every customer who uses them: the AI Voice Agent (xAI, under a zero data retention agreement), and SMS to North American (+1) numbers, which Twilio sends from its US region. * For customers in the EU/EEA, Switzerland and the United Kingdom, AI features other than the AI Voice Agent use only AWS models in EU regions. OpenAI and Anthropic process none of their data. * For customers outside the EU/EEA, Switzerland and the United Kingdom, Twilio processes SMS, voice calls and Call Routing in its US region instead of Ireland. * Sub-processors, their affiliates and their own sub-processors can also access or process data from outside the EU/EEA, for example for support. The page [Access from Outside the EU/EEA](/trust-center/legal/subprocessors/access-from-outside-the-eu-eea.md) is part of this list and gives the countries. ## Current Sub-processors ### Sub-processors for all customers | Sub-processor | Address | Service | Data Location | Transfer Mechanism | | --------------------------------------- | -------------------------------------------------------------- | ---------------------------------------- | ---------------------------------------------------------- | ----------------------------- | | **Amazon Web Services EMEA SARL** | 38 avenue John F. Kennedy, L-1855 Luxembourg | Cloud Hosting, AI Features | Frankfurt, Stockholm; AI features: EU regions | Privacy Framework, SCCs | | **Bird B.V.** (MessageBird) | Keizersgracht 268, 1016 EV Amsterdam, Netherlands | Telecommunication | EU (Bird's region eu1) | Privacy Framework, SCCs | | **Vonage B.V.** | Radarweg 29 A 12, Office 10.42, 1043 NX Amsterdam, Netherlands | Telecommunication | Dublin, Frankfurt | Privacy Framework | | **Twilio Inc.** | 101 Spear Street, Suite 500, San Francisco, CA 94105, USA | Telecommunication, Call Routing | Ireland; SMS to North American (+1) numbers: United States | SCCs, BCRs, Privacy Framework | | **HubSpot Germany GmbH** | Am Postbahnhof 17, 10243 Berlin, Germany | CRM, Customer Service and Account Emails | Germany | Privacy Framework, SCCs | | **PostHog Inc.** | 2261 Market St., #4008, San Francisco, CA 94114, USA | Product Analytics, Customer Service | Frankfurt (EU Cloud) | Privacy Framework, SCCs | | **Fly.io, Inc.** | 2261 Market St #4990, San Francisco, CA 94114, USA | Sandbox Environment for AI Products | Frankfurt | Privacy Framework, SCCs | | **SpaceX Super Intelligence LLC** (xAI) | 800 W Cesar Chavez St., Austin, TX, USA | AI Voice Agent, with zero data retention | United States | SCCs | ### Additional sub-processors and data locations for customers outside the EU/EEA, Switzerland and the United Kingdom | Sub-processor | Address | Service | Data Location | Transfer Mechanism | | -------------------- | ---------------------------------------------------------- | ------------------------------- | --------------------------------- | ----------------------------- | | **OpenAI OpCo, LLC** | 1455 3rd Street, San Francisco, CA 94158, USA | AI Features | United States | SCCs | | **Anthropic, PBC** | 548 Market Street, PMB 90375, San Francisco, CA 94104, USA | AI Features | United States | SCCs | | **Twilio Inc.** | 101 Spear Street, Suite 500, San Francisco, CA 94105, USA | Telecommunication, Call Routing | United States, instead of Ireland | SCCs, BCRs, Privacy Framework | SCCs = Standard Contractual Clauses. BCRs = Binding Corporate Rules. ilert sends alert notifications by SMS and voice call through Bird, Vonage or Twilio, depending on the destination and on availability: if one provider fails, another one takes over. Call Routing (incoming calls to phone numbers that ilert provides) runs only on Twilio. Twilio processes the data of customers in the EU/EEA, Switzerland and the United Kingdom in its Ireland region, and the data of other customers in its US region. SMS to North American (+1) numbers always go through Twilio's US region. If Twilio's Ireland region fails, ilert can move the Call Routing of customers in the EU/EEA, Switzerland and the United Kingdom, and the SMS and voice notifications that Twilio sends for them, to Twilio's US region until the Ireland region is available again. The move is not automatic: ilert decides on it. Channels and integrations that the customer or its users choose and activate, such as WhatsApp and Telegram, and transmission services such as the push services of Apple and Google, are not sub-processors. ilert transmits data to them on the customer's instructions; their providers process the data under their own terms and responsibility, also outside the EU/EEA. ilert sends WhatsApp messages through Twilio's US region. Customers can deactivate these channels. Amazon Web Services EMEA SARL, Bird B.V., Vonage B.V. and HubSpot Germany GmbH are EU companies. The transfer mechanisms listed for them cover the transfers to their affiliates and sub-processors outside the EU/EEA, such as Amazon Web Services, Inc., Bird.com Inc., Vonage's US companies and HubSpot, Inc. in the United States. AI features are on by default for new accounts and can be turned off. For accounts with AI features turned off, OpenAI, Anthropic, xAI and Fly.io process no data, and Amazon Web Services processes no data for AI features. Except for the AI Voice Agent, AI features for accounts in the EU/EEA, Switzerland and the United Kingdom use only the AI models of Amazon Web Services in EU regions. OpenAI and Anthropic process data only for accounts in other countries. SpaceX Super Intelligence LLC (xAI) processes data for the AI Voice Agent in its US region, including data of customers in the EU. ilert has agreed zero data retention with xAI and sends data to xAI only through its zero data retention API, as xAI's Enterprise Terms and Data Processing Addendum require for personal data. xAI deletes requests and responses once the response is delivered, at the latest one hour after the request is processed, and keeps no logs, backups or other copies of them. ## Changes ilert notifies customers in writing at least 30 days before adding or replacing a sub-processor. Customers may object on reasonable grounds within that period. For questions about sub-processors, contact . --- # Agent Instructions This documentation is published with GitBook. GitBook is the documentation platform designed so that both humans and AI agents can read, navigate, and reason over technical content effectively. Learn more at gitbook.com. ## Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation by asking a question. Perform an HTTP GET request on the following URL with the `ask` and `goal` query parameters: ``` GET https://docs.ilert.com/trust-center/legal/subprocessors.md?ask=&goal= ``` `ask` is the immediate question: it should be specific, self-contained, and written in natural language. `goal` is what the user is ultimately trying to achieve, the reason they need the answer. Sharing it helps GitBook give you a better, more relevant answer. 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