GDPR - Sub-processors

Sub-processors

Nalpeiron Labs, Inc. (“Nalpeiron”) uses certain sub-processors and content delivery networks to assist with the interoperability of the Nalpeiron Growth Platform. Capitalized terms used and not otherwise defined below will have the meanings given to such terms in our Terms of Service.

What Is a Sub-processor?

A sub-processor is a third-party data processor engaged by Nalpeiron, who has or potentially will have access to or process Customer Data (which may contain personal data). Nalpeiron engages different types of sub-processors to perform various functions as explained in the tables below. Nalpeiron refers to third parties that do not have access to or process Customer Data, but who are otherwise used to provide the Services, as “subcontractors” and not sub-processors.

Due Diligence

Nalpeiron applies a commercially reasonable selection process to evaluate the security, privacy, and confidentiality practices of proposed subprocessors that will or may have access to or process Customer Data.

Contractual Safeguards

Nalpeiron requires its sub-processors to satisfy equivalent obligations as those required from Nalpeiron as outlined in Nalpeiron’s Terms of Service, including but not limited to the requirements to:

• process personal data by the data controller’s (i.e. Customer’s) documented instructions (as communicated in writing to the relevant sub-processor by Nalpeiron);

• in connection with their sub-processing activities, use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, under applicable data protection laws;

• provide regular training in security and data protection to personnel to whom they grant access to personal data;

• implement and maintain appropriate technical and organizational measures (including measures consistent with those to which Nalpeiron is contractually committed to adhere insofar as they are equally relevant to the sub-processor’s processing of personal data)

This notice does not give Nalpeiron Customers any additional rights or remedies and should not be construed as a binding agreement.

The information herein is to provide a list of third-party sub-processors and content delivery networks used by Nalpeiron as of the date of this notice (which Nalpeiron may use to deliver and support its Services).

Infrastructure Sub-processors – Customer Data Storage

Nalpeiron controls access to the infrastructure that Nalpeiron uses to host Customer Data submitted to the Services, other than as set forth below. Currently, the Nalpeiron production systems for the Nalpeiron Platform are located in facilities in the United States. Customers may be shifted among regional data centers to promote the Services' performance and availability. The following table describes the countries and legal entities engaged in Nalpeiron's storage of customer data.

Name	Address	Purpose of use/Services provided by Subprocessor
Microsoft	One Microsoft Way, Redmond, WA 98052-6399, USA	Hosting and Infrastructure
Amazon Web Services Inc	410 Terry Avenue North, Seattle, WA, USA	Hosting and Infrastructure
MongoDB	1633 Broadway 38th Floor New York, NY 10019 USA	Data Storage
Zapier, Inc.	548 Market St. #62411, San Francisco, CA 94104-5401, USA.	Processing of Controller Personal Data as specifically directed by Controller through use of Processor Services

Service Specific Sub-processors

Nalpeiron works with certain third parties to provide specific functionality within its services - as we offer a B2B service, we do not work with end-user data using these sub-processors, but that of our business clients. To provide the relevant functionality, these subprocessors may access Customer Data, but most do not. Their use is limited to the indicated Services. This list is provided as a courtesy only, has no legal meaning, is not part of our terms of service, and changes regularly. It is not exhaustive and is only updated periodically.

Entity Name	Purpose	Applicable Services	Entity Country
Pendo	Delivers messaging and analytics for the service.	Nalpeiron Service	United States
Salesintel	Provides data service for the Nalpeiron platform	Nalpeiron Service	United States
Maxio	Billing, analytics for Nalpeiron subscriptions	Nalpeiron Service	United States
Calendly	Call scheduling with Nalpeiron customers	Nalpeiron Customer Success and, Support	United States
Cloudflare Inc.	DNS, SSL Termination and Web Application Firewall	Nalpeiron Platform	United States
Google	Communication, collaboration, analytics and insights	Nalpeiron Marketing, Sales, Platform Partnerships, Support and, Customer Success	United States
Krisp	Sales conversations intelligence platform	Nalpeiron Sales, and, Customer Success	United States
Hubspot	Provides lead qualification, personalized experience, and emails and support for Nalpeiron customers	Nalpeiron Marketing. Nalpeiron Support	United States
Anthropic	Service provider for AI powered features.	Nalpeiron Service, Nalpeiron Support	United States
OpenAI, L.L.C.	Service provider for AI powered features.	Nalpeiron Service, Nalpeiron Support	United States
Perplexity	Service provider for AI powered features.	Nalpeiron Service, Nalpeiron Support	United States
Salesforce	Stores customer contact information, subscription status, and other customer related information	Nalpeiron Service, Sales, and, Customer Success	United States
Slack	Real time chat communication with Nalpeiron Partners	Nalpeiron Partnerships	United States
Stripe	Payment processing, Security Information and Event Management	Nalpeiron Service, Nalpeiron Security	United States
TypeForm	Request product feedback from Nalpeiron customers	Nalpeiron Product Management and, Customer Success	Spain
Wistia	Video hosting platform for the Nalpeiron platform	Nalpeiron Service	United States
Zapier	Workflow Automation tool	Nalpeiron Marketing	United States
Zendesk	Used by technical support and the customer success team to manage tickets concerning product support, billing, and other related issues	Nalpeiron Support	United States
Zoom	Video conferencing	Nalpeiron Sales, Marketing and, Support	United States

Content Delivery Networks

As explained above, Nalpeiron’s Services may use content delivery networks (“CDNs”) to provide the Services, for security purposes, and to optimize content delivery. CDNs do not have access to Customer Data, but are commonly used systems of distributed services that deliver content based on the geographic location of the individual accessing the content and the origin of the content provider. Website content served to website visitors and domain name information may be stored with a CDN to expedite transmission, and information transmitted across a CDN may be accessed by that CDN to enable its functions. The following describes the use of CDNs by Nalpeiron’s Services.

CDN Provider	Services Using CDN	CDN Location	Description of CDN Services
Amazon Web Services, Inc.	Nalpeiron Service	Global	Public website content served to website visitors may be stored with Amazon Web Services, Inc., and transmitted by Amazon Web Services, Inc., to website visitors, to expedite transmission.
Cloudflare, Inc.	Nalpeiron Service	Global	Public website content served to website visitors may be stored with Cloudflare, Inc., and transmitted by Cloudflare, Inc., to website visitors, to expedite transmission.